Gaggle safety and tracking software combines machine learning technology with safety representatives who review student content. Gaggle reviews student generated content through Google Apps or Office 365 by applying machine-learning content analysis and review of email, documents, and uploads for suspicious content. Gaggle's terms state it collects school-wide aggregate information, Personally Identifiable Information, and other non-personal information in its content analysis and review of email, documents, and uploads for suspicious content. Gaggle's terms state that they follow comprehensive security standards to protect a user’s information, and have implemented measures designed to secure personal information from accidental loss and unauthorized access, use, alteration and disclosure. Lastly, Gaggle's terms state they help schools and districts comply with all U.S. privacy and safety laws, particularly those involving children that include the Children’s Online Privacy Protection Act (COPPA), Children’s Internet Protection Act (CIPA), and the Family Educational Rights and Privacy Act (FERPA).

Gaggle can be accessed through its website. The Privacy Policy and Terms and Conditions accessed for this evaluation can be found on Gaggle’s website. Additionally, other policies used for this evaluation include: Student & Staff Data Privacy Notice.This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Gaggle reviews student generated content through Google Apps or Office 365 by applying machine-learning content analysis and review of email, documents, and uploads for suspicious content. However, because Gaggle has unrestricted and unlimited access to all students' private or sensitive information within a classroom or all students within an entire school, there exist inherent safety and privacy concerns. Administrator accounts for this service should be managed with extreme caution, and students should be aware of the types of content that could appear "suspicious". In addition, the terms state that in order to protect schools or districts against the risks involved in handling child pornography, Gaggle registers incidents containing pornographic videos and images with the appropriate law enforcement authorities.

Privacy

Gaggle's terms state it collects school-wide aggregate information, Personally Identifiable Information, and other non-personal information in its content analysis and review of email, documents, and uploads for suspicious content. In addition, Gaggle's terms state that it will not sell student or school staff information, and will not share or reuse Personally Identifiable Information from education records for any purpose, unless instructed to do so by the School or District. Gaggle's terms state they do not behaviorally target advertising or show advertising to any user, and does not use student information to target students or their families for advertising or marketing efforts.

Lastly, Gaggle's terms state they may use de-identified information to improve its products and services, and use reasonable de-identification approaches to ensure they are not compromising the privacy or security of the personal information a user entrusts to Gaggle. In addition, Gaggle's terms state they will not attempt to re-identify de-identified data and will not transfer de-identified data to any third party unless they agree not to attempt re-identification.

Security

Gaggle's terms state that they follow comprehensive security standards to protect a user’s information, and have implemented measures designed to secure personal information from accidental loss and unauthorized access, use, alteration and disclosure. Gaggle's terms state they ensure personal information is encrypted in transit to and from Gaggle using SSL technology, and all personal information is stored in multiple databases with extensive redundancy and fail over while maintained at data centers located in two geographically dispersed states.

In addition, the terms specify that Gaggle implements strict restrictions on how data may be accessed, and by whom, and that audit logs are kept to be able to track data modification. Additional security measures are in place to prevent and identify data tampering. In the case of a data breach, Gaggle's terms state they will immediately notify all customers affected using the primary email address specified in their accounts. Lastly, Gaggle's terms state it is the responsibility of all schools to contact parents or legal guardians in the event of a data breach.

Compliance

Gaggle's terms state they help schools and districts comply with all U.S. privacy and safety laws, particularly those involving children that include the Children’s Online Privacy Protection Act (COPPA), Children’s Internet Protection Act (CIPA), and the Family Educational Rights and Privacy Act (FERPA). Individual children are not allowed to sign up for any Gaggle product and the only way a child may obtain access to a Gaggle product is through their school. In addition, the terms state each school is responsible for creating student accounts for any Gaggle product and they may choose to provide a student's full name, grade level, and ID number.

Gaggle's terms specify it considers all school and district data to be confidential and does not use student data for any purpose other than to provide services. Gaggle's terms reiterate that Student data are the property of the school or district and remain in the school or district’s control throughout the duration of any agreement or contract, and access to student information remains the legal responsibility of the applicable school.

The terms state that before a teacher or school enters, uploads, or access any data concerning a minor student, they must confirm that they have obtained appropriate consent from the parent or guardian of that student, or determined that one of the limited exceptions to the consent requirement applies. Gaggle's terms state they will not distribute to third parties any staff or student data without the consent of either a parent/guardian or a qualified educational institution.

• Personal information is not sold or rented to third parties.
• Personal information is not shared for third-party marketing.
• Personalised advertising is not displayed.
• Data are not collected by third-parties for their own purposes.
• User's information is not used to track and target advertisements on other third-party websites or services.
• Data profiles are not created and used for personalised advertisements.