The Common Sense Privacy Initiative is a coordinated effort to evaluate edtech tools, protect student privacy, and increase awareness of privacy and security concerns. The initiative helps clarify privacy policies so that teachers can make smart choices about the learning tools they use with students, and 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 across the board.
As part of this work, our Privacy Evaluations help to break down complex privacy policies and help educators make better informed choices to protect student information online. Our privacy evaluations go beyond the requirements of the Children's Online Privacy Protection Act (COPPA), 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 own specific needs and context, so our new Common Sense standard privacy reports were developed to help educators better understand and compare privacy concerns between 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.
Speaking with Educators
To further enhance this work, we have spoken with numerous educators to learn what are the most popular edtech school- or district-wide products used in classrooms today, and what privacy issues matter most to educators in protecting student information. The purpose of this work, as in all of our endeavors, is to increase transparency, extend educators' knowledge base on privacy, and improve communication between vendors and schools to better serve and protect students.
Many educators are already aware that school- or district-wide products typically require additional Student Data Privacy Agreements between the company and the school in connection with the student registration process. These additional agreements are typically private agreements negotiated between the company and the school and therefore cannot be used in our evaluation process. The additional agreements are often the only way to close gaps left open by a vendor's publicly available policies, which may not address all the necessary privacy protections for the collection and use of student data.
When speaking with schools and districts, we commonly hear that the process of negotiating separate agreements is difficult and time consuming. School and district staff need to contact numerous edtech companies to learn whether additional privacy protections are available in a separate agreement that go beyond what is disclosed in their publicly available terms. If a company agrees to provide additional protections, schools and districts still need to understand what those specific additional protections should be, and then begin a lengthy negotiation process. Schools and districts have indicated that it's a time-consuming discovery process to learn exactly what are the privacy practices of each vendor for the products they wish to deploy in their school or district. In addition to the arduous task of discovering a vendor's baseline privacy protections, schools and districts have to also negotiate to cover any gaps in privacy protections needed in their particular educational context. This process presents numerous technical, as well as legal, hurdles -- in addition to an already time-intensive process -- to fully research and understand the data collection practices and compliance requirements, and whether privacy protections are appropriate given the product's intended use.
These challenges disproportionately affect smaller and rural districts, which typically do not have the resources available to engage privacy consultants, legal counsel, and specialists, or hire staff with the expertise required to effectively navigate the additional steps required to adequately protect students and their information. Our evaluation process attempts to level the playing field by providing schools and districts of all sizes more information about the privacy practices of the most popular edtech products they are interested in adopting across their school or district. First, our evaluation process provides a Common Sense standard privacy report for each product so that educators can better understand what privacy issues are the most important for them, given their specific needs. Second, our privacy evaluations use a company's publicly available terms so that schools and districts can better understand what a company's policies actually disclose, and what additional protections would need to be included in a separate Student Data Privacy Agreement if the school or district were to deploy that edtech product school or district wide. This evaluation process highlights the most important deficiency gaps in edtech products' publicly available terms, and also encourages edtech vendors to increase the transparency and quality of their privacy policies in order to enable schools and districts to make an easier and more informed decision about whether to adopt school- or district-wide technology.
The following key findings of the top 10 most popular edtech product evaluations represent products that are deployed school-wide or district-wide and provide features for teachers and students such as communication, collaboration, learning management, content delivery, and student assessment.
|Product||Tier||Score||Effective Date||Data Sold||Third-Party Marketing||Behavioral Ads||Third-Party Tracking||Track Users||Ad Profile|
|Apple School Manager||72|
Table 1: This table illustrates better, worse, and unclear practices for the selected transparency questions. The color blue means the policies disclose better practices, red means the policies disclose worse practices, and orange means the policies are unclear as to whether or not the vendor engages in the respective practice.
Our key findings illustrate that Apple and Google education products should be used responsibly, given that both companies 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 used in this evaluation. Apple, Google, and Kiddom all 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 also helpful in making an informed decision about whether to use a school- or district-wide product. For example, even though Kiddom is designated "Use Responsibly" in Table 1, the product received a lower overall score than Apple School Manager and Google Classroom because Kiddom's terms were not as transparent, and did not disclose comparatively the same percentage of better practices in its policies.
Moreover, many of the school- or district-wide products we evaluated disclosed worse privacy practices (shown in red) in their policies in regards to the use of student data for third-party marketing, tracking, or advertising purposes. Several products were also unclear in their policies about whether they engaged in better or worse privacy practices (shown in orange), and therefore provided no promise of future expectations for teachers, schools, and districts on how that product would collect or use student information.
The following top 10 full privacy evaluations represent the most popular products that are deployed school-wide or district-wide. Our evaluation process only considers policies that have been made publicly available prior to an individual using the application or service.
- Apple School Manager is a free web-based service that has everything technology managers need to deploy iPad and Mac devices in schools. Apple School Manager lets you buy content, configure automatic device enrollment in your mobile device management (MDM) solution, create accounts for your students and staff, set up class rosters for the Schoolwork and Classroom apps, enable progress recording in Schoolwork, and manage apps and books for teaching and learning.
- Google Classroom is a free web service developed by Google and part of the G Suite for Education to help schools streamline the process of sharing files between teachers and students. Students using Google Classroom can view assignments, submit homework, and receive grades from teachers to help them stay on track and organized.
- Kiddom is described as an all-in-one school operating system that enables educators to collaborate and personalize student instruction and assessment.
- Blackboard Learn provides instructors with the ability to provide students with course documents, online assignments and assessments, individual grades, and other learning materials in a single environment.
- The MasteryConnect Services are a classroom tool and resource that teachers can use as part of their classroom activities to identify levels of student understanding around their instruction on a real-time basis.
- Edmodo provides a learning network for students, teachers, parents, schools, and districts.
- D2L Brightspace is learning management system (LMS) software for online learning and teaching that helps give each student a more personalized learning experience on any mobile device, for each grade level.
- Engrade by McGraw-Hill Education is a learning management system (LMS) and assessment engine that empowers educators and unlocks student achievement.
Schoology is a learning management system (LMS) that allows parents, teachers, students, and school officials to track coursework.
- Neo is a learning management system (LMS) for managing all classroom activities. The service focuses on delivering learning experiences while incorporating all the essential tools schools need to support efficient teaching and learning.
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.
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.
Use Responsibly indicates that the product meets our minimum criteria but more research should be completed prior to use.
Use with Caution indicates that the product does not clearly define the safeguards to protect child or student information.
For more information about our evaluation tiers, click here.
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 work 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.
The following transparency questions are part of the tier criteria used in our full evaluation process; they are also shown in Table 1 as the most important privacy concerns educators want to know in order 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 if 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 in order to 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 or expose that profile information to other advertisers.
For more information about our privacy evaluations, visit the Common Sense Privacy Evaluation Initiative.