Learn to navigate the privacy challenges of popular technology.

The Common Sense Privacy Program recently published privacy evaluations of the top 10 edtech products used in schools and districts. This updated list adds five more products to the list. The list is curated by the Privacy Program, which is a coordinated effort to evaluate edtech tools, protect student privacy, and increase awareness of privacy and security concerns. The program helps clarify privacy policies so teachers can make smart choices about the learning tools they use with students and so schools and districts can participate in evaluating the technology used in K–12 classrooms. With the involvement of over 150 schools and districts, we are working in collaboration with software developers to bring greater transparency to privacy policies.

As part of this work, our privacy evaluations help break down complex privacy policies and help educators make better informed choices to protect student information online. Our privacy evaluations make recommendations that go beyond the requirements of the Children's Online Privacy Protection Act (COPPA), the Family Educational Rights and Privacy Act (FERPA), and other federal and state privacy regulations. We consider a broad range of legal requirements and industry best practices to pinpoint exactly what educators need to know about edtech policies on safety, privacy, security, and compliance. All schools and districts use technology differently, depending on their specific needs and contexts, so our new Common Sense standard privacy reports were developed to help educators better understand and compare privacy concerns among the products that are the most important for their uses and needs. Standard privacy reports display the most important privacy practices from a product's policies in a single, easy-to-read outline.

Key findings

Following are our key findings from our product evaluations of those five additional edtech products. These products are deployed school- or district-wide and facilitate activities, for teachers and students, such as communication, collaboration, learning management, content delivery, and student assessment. The following table illustrates better, worse, and unclear practices around the selected transparency questions. Blue means the policies disclose better practices, red means they disclose worse practices, and orange means they are unclear as to whether or not the vendor engages in the respective practice.

Product Tier Score (100) Effective Date Data Sold Third-Party Marketing Behavioral Ads Third-Party Tracking Track Users Ad Profile
Summit Learning Use Responsibly 72              
Microsoft Office 365 Education Use Responsibly 64              
Adobe Spark Education Use Responsibly 60              
Canvas Use with Caution 36              
Moodle Use with Caution 31              

Our findings show that Summit Learning, Microsoft Office 365 Education, and Adobe Spark Education products should be used responsibly, given that all three products have the highest relative overall scores as a result of transparent policies and disclosure of better privacy practices (shown in blue) in their policies when compared to the other school- or district-wide products in this evaluation. Summit Learning, Microsoft Office 365 Education, and Adobe Spark Education received our blue "Use Responsibly" tier designation because their policies disclosed that they do not sell student data and do not use student data for third-party marketing, advertising, tracking, or ad-profiling purposes. However, in addition to this information about a product's tier, each product's overall score is helpful in making an informed decision about whether to use the product school- or district-wide. For example, even though Adobe Spark Education is designated "Use Responsibly," the product's overall score is 4 percentage points different from Microsoft Office 365 Education, because their terms were not as transparent and did not disclose (comparatively) the same percentage of better practices in its policies.

Moreover, one of the school- or district-wide products we evaluated disclosed worse privacy practices (shown in red) in their policies in regard to the use of student data for third-party tracking and advertising purposes. Canvas was also unclear in their policies about whether they engaged in better or worse privacy practices (shown in orange) and therefore provided no promise of expectations for teachers, schools, and districts on how that product would collect or use student information.

For the purposes of our evaluation process, Canvas and Moodle are a bit different from the other three products used in this comparison, because they both allow for the software to be self-hosted by third parties, which could result in different privacy practices depending on the installation. Therefore, the privacy evaluations for Canvas and Moodle are based only on the terms of the installation hosted by their respective companies at https://moodle.org and https://www.canvaslms.com. Our privacy evaluations do not apply to third-party installations of Canvas and Moodle.

Full evaluations

The following full privacy evaluations, as we've said, represent some of the most popular products that are deployed school- or district-wide. Our evaluation process considers only policies that have been made publicly available prior to an individual using the application or service. 

1. Summit Learning

  • The Summit Learning Program is a personalized approach to teaching and learning inspired by the vision of equipping every student to lead a fulfilled life. The services are designed to facilitate strong relationships between teachers and students through real-­time data about progress toward goals, access to ongoing feedback, and access to a wide range of learning resources that enable students to build on what they learn from the teacher by self­-directing some of their learning.

2. Adobe Spark Education

  • Adobe Spark is an integrated web and mobile solution that enables everyone, especially teachers and students of all ages, to easily create and share affecting visual stories. Adobe Spark provides a free, premium, and education version of its product with two different account types: an Adobe ID, or an enterprise or federated ID.

3. Microsoft Office 365 Education

  • Microsoft Office 365 Education is a collection of online services that allows students to collaborate and share their schoolwork. Students and educators are eligible to use Office 365 Education for free, and it includes Outlook, Word, Excel, PowerPoint, OneNote, Publisher, and Access.

4. Canvas

  • Canvas by Instructure provides a cloud-based learning management system (LMS) that connects digital tools and resources for teachers. This evaluation covers the cloud-based service offered by the vendor, not the open-source codebase available on GitHub. 

5. Moodle

  • Moodle allows educators of any kind to create a private space online. It is filled with tools that let educators easily create courses and activities, all optimized for collaborative learning. The Moodle software is free and open source, and this evaluation is based only on the terms for the installation hosted at https://moodle.org; it does not apply to third-party installations of Moodle.

Methodology

Our evaluation process for edtech products attempts to address some of the common barriers to effectively evaluating privacy practices. Privacy concerns and needs vary widely based on the type of application or service and the context in which it is used. For example, it makes sense for a student-assessment system to collect a home address or other personal information. However, it would not make sense for an online calculator to collect a student's home address or other types of personal information. Therefore, our evaluation process pairs a transparency evaluation with a qualitative evaluation. This provides the ability to track the information a policy discloses as well as the strengths and weaknesses of how a policy discloses that information with a privacy evaluation tier and overall score. Lastly, our evaluation process includes reviewer-written summary evaluations that highlight the implications of the product's privacy practices alongside the goals and contexts within which the service may be used.

Evaluation tier

In schools and districts, people make decisions about privacy based on their specific needs -- and these needs can vary between districts and schools. The privacy evaluation process is designed to support and augment local expertise, not replace it. The evaluation process incorporates these specific needs and the decision-making processes of schools and districts into the following three tiers:

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Use Responsibly indicates that the product meets our minimum criteria but more research should be completed prior to use.

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Use with Caution indicates that the product does not clearly define the safeguards to protect child or student information.

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Not Recommended indicates that the product does not support encryption or lacks a detailed privacy policy.

For more information about our evaluation tiers, click here.

Overall score

The numerical roll-up score should be used only as part of a decision-making process that includes the rest of the evaluation. The number's best use is as an indicator of how much additional work a person will need to do to make an informed decision about a product. This use is directly related to the core mission driving the evaluations: to help people make informed decisions about a product with less effort. The higher the number, the less effort required to make an informed and appropriate decision. For more information about our overall score, click here.

Transparency questions

The following transparency questions are part of the tier criteria used in our full evaluation process; they are also shown in the table above as the most important privacy concerns educators have when they want to compare products and make an informed decision. 

Effective date: Do the policies clearly indicate the version or effective date of the policies?

Tip: When the policy has a date on it, people can see when it's updated or changed.

Data sold: Do the policies clearly indicate whether or not a user's personal information is sold or rented to third parties?

Tip: This lets people know whether or not someone else can see and use your personal information. Any third parties that get your information will usually have different privacy policies that affect how they can use and share your personal information.

Third-party marketing: Do the policies clearly indicate whether or not personal information is shared with third parties for advertising or marketing purposes?

Tip: If yes, this means that outsiders can use your personal information to sell you goods and services.

Behavioral ads: Do the policies clearly indicate whether or not behavioral advertising based on a user's personal information is displayed?

Tip: If yes, the product may watch what you do while you're using it and then use that information to sell you goods and services. This information could be combined with information about you from other websites and services and used to send you advertising.

Third-party tracking: Do the policies clearly indicate whether or not third-party advertising services or tracking technologies collect any information from a user of the product?

Tip: If yes, this product allows outside companies to get information about you while you're using the product.

Track users: Do the policies clearly indicate whether or not a user's information is used to track users and display target advertisements on other third-party websites or services?

Tip: If yes, the product may watch what you do on other websites and combine that information about you with other information it has gathered to sell you goods and services on other websites or apps across the internet.

Ad profile: Do the policies clearly indicate whether or not the vendor allows third parties to use a student's data to create an automated profile, engage in data enhancement, conduct social advertising, or target advertising to students, parents, teachers, or the school?

Tip: If yes, this product may let the vendor or third parties use student information to create student profiles for advertising purposes to students and their families and can even combine that profile information or expose it to other advertisers.

For more information about our privacy evaluations, visit the Common Sense Privacy Program.

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Girard K.

Girard Kelly is an attorney focused on Internet, privacy, cybersecurity, and Intellectual Property law who thrives on cutting-edge legal issues and has a strong background in public policy, information technology, entrepreneurship, and emerging technologies.