COPPA & Change… #EdublogsClub

***Update*** I am re-posting this as part of the #EdublogsClub week 8 prompt.

This post is part of the #EdublogsClub – a group of educators and educational technology enthusiasts that blog around a common theme each week. Simply write a post and share it (via social media w/ #edublogsclub or posting a link as a comment to that topic’s posting on the Edublogger site) to join in, or sign up to receive email reminders of each new prompt. 

Prompt: Write a post about student privacy.
Some helpful notes:

  • Should student work be public on the web? Why or why not?
  • How do you evaluate the tools that you use in your classroom when it comes to student privacy?
  • Do you have a favorite resource or video that discusses this topic
  • Do you have tips or rules that you use with your students relating to identifiable information?
  • Do you have any other ideas, rants, or questions about student privacy you wish to discuss?
Originally posted: Dec. 1, 2015
***Disclaimer – I, in no uncertain terms, claim to be an expert on Federal Law and Regulations***

COPPA which stands for Children’s Online Privacy Protection Act is meant to protect students online from knowingly or unknowingly giving out personal information (full, formal name; address; etc.). It went into law in 2000 and is designed for websites to either not allow users under the age of 13 or parent permission must be given for their services to be used. Some great webtools have been removed from students’ use or teachers have had to create accounts with no identifiable student information (i.e. google +1 email hack)

One tool which I find useful but fell into the category of users under 13 were forbidden was Screencastify.  Working in a 1:1 middle school with chromebooks, the Screencastify Extension would be easy to use tool for students to create multimedia presentations. Their Privacy Policy stated:

Our Services are not intended for and may not be used by children under the age of 13. We do not knowingly collect information from children under the age of 13 and we do not target our Services to children under the age of 13.

But, it did have this key line after it: “If you have questions about our Service, please contact us at info@screencastify.com So I thought, why not? I reached out to them and found Manuel, or Manu as he signed his emails, very responsive and wanted to make sure their tool worked for schools. We communicated back and forth for about 2½ weeks till they had an updated policy which included the above statement, plus:

Educators that have the authority to act on parent’s behalf, may allow students under 13 to use our Services, if such use is for educational purposes, and if this use ensures that students will not provide any personal information and will not share or otherwise distribute recordings containing personal information of a student.

Thank you, Manu & Screencastify for being willing to allow your tool to be used for educational purposes while remaining COPPA compliant.

So my big takeaway from this experience, reach out! I sent an email and asked a question which had two potential outcomes: no, we won’t change our policy or yes, let’s explore this!  If Screencastify said no, I would have been in the same position I was before sending the email.  Yet, they said yes and I now have two grade levels in my building which can utilize a tool for creation purposes.

Do you have a tool which you can’t use with your students? Have you ever tried reaching out to them? I would love to hear about your experiences in the comment section. 

“What Is COPPA (Children’s Online Privacy Protection Act )? – Definition from WhatIs.com.” SearchCRM. 1 May 2010. Web. 24 Nov. 2015. <http://searchcrm.techtarget.com/definition/COPPA>.

  10 comments for “COPPA & Change… #EdublogsClub

  1. Bill Fitzgerald
    March 22, 2017 at 12:50 pm

    But. But. But.

    Screencastify’s terms explicitly state that they are NOT compliant with COPPA – this is a direct quotation from their privacy policy at https://www.screencastify.com/privacy

    “Although this is a secure Service, we do not claim to be COPPA compliant.”

    Given that they state outright that they are not COPPA compliant, we have an obligation to take them at their word.

    • Mr. G.
      March 22, 2017 at 2:52 pm

      Thank you Bill, for pointing this out. Back when this post was written, Dec. 1, 2015, they had the phrasing that is written in this post as their Privacy Policy. As their website states, their Policy was updated in Oct. 2016. I have reached out for clarification as to what changed but as of posting this comment, I haven’t heard back from them.

      • Bill Fitzgerald
        March 22, 2017 at 3:12 pm

        The language I quoted is from their current policy, which has the updates from October 2016. I read the language today, March 22, 2017.

        This is pretty common in edtech apps – terms drift from a vendor’s intent, and aren’t updated.

        The “educational purpose” guidance for schools is described here: https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions#Schools

        The bottom line on this app: given the language in their terms that explicitly states the vendor’s position on COPPA, I would strongly recommend against using this app with under 13s.

        Related note for extra fun :/ – there are many vendors that state in their terms that they do comply with COPPA, and still other vendors who require parental consent with under 13s to get “permission” for tracking that isn’t explicitly permitted under COPPA. Personally, when a vendor states in their terms that they comply with COPPA and have an explicit requirement for parental consent, that’s a flag to look deeper at how the app works, as parental consent opens the door for any things that wouldn’t otherwise be okay under COPPA.

        • Mr. G.
          March 23, 2017 at 1:22 pm

          Bill, again thank you. I heard back from Screencastify and they apologized for the confusion. They have reinstated the language from when I spoke with them in 2015.

          Privacy for Student’s and Children’s Under 13 Years Old. The entire Screencastify team takes the privacy of students and children extremely seriously. We do not intentionally target our services to students or children of any kind. Educators that have the authority to act on parent’s behalf may allow students under 13 to use our services, if such use is for educational purposes, and if this use ensures that students will not provide any personal information and will not share, or otherwise, distribute recordings containing personal information of a student. We are able to sign FERPA requests when necessary as well

  2. Avra Robinson
    March 22, 2017 at 12:01 pm

    Thank you so much for this wonderful post! Can you tell me…what did you do in your building to start using it with students? Did you discuss the parameters stated in the policy with teachers first? How do they “act on the parents’ behalf?” Does that mean a parent letter? Please know…I’m not questioning you in a negative way at all…I’m EAGER to use this tool with kids under 13, and I am just not sure I’m clear how to do it exactly. Does that make sense? Thanks, in advance, for any help! ~Avra

    • Mr. G.
      March 22, 2017 at 3:01 pm

      Avra, I know your questioning is not negative, I’m in the same boat. After I reached out with Screencastify and worked on the wording, we introduced this to the teachers stating that this was for school purposes only. We had the teachers set it up that the default setting was to save videos directly to Google Drive. Students were told that they were to only use this tool for school assignments and that anything in their Google Drive is subject to district searching. As for “act on the parents’ behalf”, this is the essence of ‘In loco parentis‘ which our district has stated, I believe, in our Acceptable Use Policy where we have specified web tools that we have identified as appropriate for student use and teachers may approve the use with their students. Now, Bill (another commenter to the blog) has pointed out a change which I’m in the process of trying to have explained. I think this post will be something I will be revisiting again in the future.

  3. Ms. Knapp
    March 21, 2017 at 12:20 pm

    Thank you! I just posted a link to your post in a G+ discussion on this topic!

    • Mr. G.
      March 22, 2017 at 7:42 am

      Ms. Knapp, I saw you shared (small world) I was the comment right above yours in the same G+ discussion. This question surprised me since I worked with Screencastify to change the wording of their Privacy Policy to allow students to be able to use the tool. I am reaching back out to them to see what happened and why the phrasing we worked on crafting is no longer there.

  4. Lisa Suhr
    February 22, 2017 at 4:05 pm

    Great lesson! Thanks for sharing the thought and your success story!

    LS

    • Mr. G.
      February 23, 2017 at 7:28 am

      Lisa, I was surprised with the response. I figured when I reached out they would respond with something like, we can’t our lawyers will not approve or we’ll take that under advisement; but they were more than willing to work on how they could be accommodating to the education sphere.

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