Effective on August 4, 2017
Blackboard is currently undergoing an assessment by iKeepSafe regarding the collection, use and disclosure of personally identifiable information in order to obtain the iKeepSafe COPPA Safe Harbor Program Seal. This program will only cover data that is collected through the Solution. The use of data collected through the Solution shall be limited to the purpose of providing the Solution for which the Client has engaged Blackboard.
Information we collect when hosting a School’s Solution
You may visit certain Solutions as a guest without registering. Registration, however, will give you access to certain features as well as the ability to personalize certain features. An individual who seeks access to a Solution, or who seeks to correct, amend, or delete inaccurate data, should direct any query to the School. If the School requests Blackboard to remove the data, we will respond to the request within 30 days. Before a child under 13 may access features that require registration, the School must first obtain any necessary parental consent. After all necessary consent is received by the School, the School is responsible for providing parent access to the child's profile so the parent may, at any time, review, request modifications to, or request deletion of the child's personal information. A parent also has the right to refuse to further collection of the child's information, subject to the School’s policies and procedures in this regard. If you have questions regarding registration, please contact the School.
Blackboard collects and subsequently processes personal information in two ways:
- Self-Registration. If you choose to become a registered user, on behalf of the School, we will ask for personal information from you through the Solution. After we collect this information from you, it may be verified by the School. So that the registration process is compliant with federal law under the Children's Online Privacy Protection Act (COPPA), you are first asked for your birth date. Birth date information is collected only to validate your age and is not stored. Children under 13 years of age are not allowed to register themselves with the Solution. Since we are collecting personal information from students for the use and benefit of the School, all information collected by Blackboard is verified for compliance with applicable laws (such as COPPA) by the School directly and not by Blackboard. If you feel your child under 13 years of age has registered on this Solution without your permission, please contact the School directly.
- Pre-Registration. You may be pre-registered by the School in one of two ways. Either way, the School may not share personal information for children under 13 years of age with Blackboard without first receiving the necessary parental consent as described above. The two means of pre-registration are:
- Your School may share registration information with Blackboard, either manually or via an authorized third-party system feed. Blackboard would conduct an import of this registration information.
- A school-designated individual may input registration information for you.
Regardless of the way you are registered, various types of information are collected during registration. Some information is required, such as First and Last Name, Email Address, User Name and Password. These fields are labeled to indicate that they are required. Other information is optional such as Title, Address, City, State, ZIP Code, and Phone. Your School may elect to provide certain optional information on your behalf in order to use certain features and functions of the Solution. By way of example, the School may provide Blackboard with your mobile phone number in order to be able to send certain text and/or voice messages to you.
After registration, the Site Administrator for the school may decide to assign to you a role(s) or group(s). Based upon your designated role(s) or group(s), you may have access to additional information or services. If you have questions concerning your role(s) or group(s), please contact the School.
Additional information which you provide to us on behalf of Schools
Additional information may be provided to us in other situations, for example, in connection with a customer support request or a content submission request. The goal of collecting this additional information is to serve you more effectively and efficiently.
In addition, students, members of the School, and other users of the Solution may choose to post, download or upload various pieces of content and/or information on or through the use of the Solution, and may use certain“social media”, collaboration, interaction and other capabilities of the Solution to exchange various categories of data, materials and information. While we cannot know in advance all types of such information, one example is that teachers or administrators may post blogs, announcements and other information and content directly onto the Solution. Another example is that students may chat with each other, or send instant messages or e-mail, via technology which may now or in the future be made available over the Solution and may share information, photographs, images or recordings with each other or with the community. Information such as an individual’s name and e-mail address can also be exchanged or made available in messages, chats and other social media and collaborative communications facilitated over the Solution. Blackboard has no practical ability to restrict the information, conduct, communications, or content which might be posted on or exchanged through the use of its technology, nor can Blackboard ensure prompt removal of any such communications, information or content after transmission or posting. If you or your child provide personal information when using any social interaction, collaboration or messaging capabilities or features of the Solution (such as chat rooms, blogs, message boards, profile pages, etc.), that personal information may be copied, publicly posted and otherwise disclosed without limitation as to its use by third parties. There may be monitoring or filtering tools utilized by the Solution which track or log content or information downloaded or posted to the Solution. If you are concerned about any information or content that may be posted, transmitted or accessed on the Solution, please contact the School. In connection with the use of PassKey Manager™ or similar solution, you or the School may provide us with your or your child’s login credentials for certain software applications and web services in order to facilitate single sign-on access to these applications and services. These login credentials may include the username, password and any other required information which you selected or were supplied in order to access certain applications and web services.
On behalf of the School, we may also (now or in the future) maintain and/or present academic and other similar information regarding students via technology or software provided by Blackboard or by third parties who have authorized Blackboard to distribute and/or present this information. We do not at any time collect any personal information through these technologies or software.
As noted below, we may also ask you to provide us with voluntary survey information to help us improve our products and services.
Information from the School
The School administers and oversees the Solution which presents and archives information supplied by content contributors designated by the School. Blackboard does not supply the school-specific content appearing on the Solution. Once content is posted to the Solution by content contributors at the school, it is public information available on the Internet. If content is posted by content contributors to groups or pages with restricted viewing permissions, that content is only displayed to users authorized to see that content.
In addition to supplying the content for its Solution, the School can control which individuals can be registered to use certain Solution features and which individuals or groups are granted privileges to access, view or use personal information collected, exchanged or maintained on the Solution. The Site Administrator can also access your personal information, and grant rights of access to others, as it deems appropriate. The School may also provide Blackboard with the registration information and login credentials described above, as well as with other information about you which it deems appropriate. Please contact the School regarding its policies and/or practices in this regard.
Information collected through technology
As noted below, we may also collect cookies, device information and web beacons in the course of your use of our technology.
Privacy of children; Privacy of students
As a parent or legal guardian for children under 13, you may review your child's personal information. After your child's parental consent is submitted, an individual at the School will supply you with your child's Sign-In and Password so that you may access and review the types of personal information collected from your child. If you would like to refuse to allow any further collection or use of your child's information (or only wish to consent to the collection and use of your child’s personal information without consenting to the disclosure of that information to third parties), please contact the School or Blackboard. If the request is made to Blackboard, we will look to the School to validate the request and respond accordingly.
Blackboard is dedicated to maintaining the privacy of all students, whether under 13 or older, in accordance with applicable laws. In this regard, we will maintain any and all personal information in education records which come into the possession of Blackboard in accordance with the requirements of the Family Educational Rights and Privacy Act (“FERPA”), and will not disclose such information to third parties except with the consent of a parent, the School or an eligible student (as applicable), unless otherwise permitted under FERPA and its associated regulations. One instance in which personal information in education records may be disclosed to third parties under FERPA is if the information is classified as “directory information” by your educational institution. Please check with the School if you have any questions as to which information they have classified in this manner.
How we use information collected when hosting the School’s Solution
Blackboard does not associate information that we collect through log files or third parties with your user account. The information is provided voluntarily by you or the School during registration. A user account is stored information that gives you access to certain features as well as the ability to personalize certain features. Your user account can only be accessed and used by you (including, where applicable, your parent or guardian), the Site Administrator and restricted personnel of Blackboard and its contractors.
Cookies and Web beacons; “do not track” signals
A cookie is a piece of data stored on your computer tied to information about you. The only personal information a cookie can contain is information you supply. Blackboard uses session or dynamic cookies, e-tags, and scripts to let us know when a user is signed in. Once you close your browser, the cookie simply terminates. We may use web beacons (single-pixel gifs) to count visitors.
When you are signed in and depending on your assigned role(s), additional services become available through our menu system. Again, depending on your assigned role(s), cookies may offer the following benefits after Sign-In:
- A personalized salutation greeting
- Content tailored to your role(s)
- Use of services that require Sign-In
- Session time-out, a security feature
You can disable cookies in your browser's preferences. If you disable cookies in your browser, you may still use the Solution but certain services and/or features may not function properly. For example, services that require Sign-In will not work if cookies are disabled.
As true of most Web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.
Registered users may collaborate and communicate through interactive means facilitated on the Solution. As an example, if you are a student who is a registered user, you may utilize instant message chat features, e-mail features, posting on message boards and other features. In using these digital and social media features, you may disclose personal information of your choosing to other registered users. If you post content to the Solution, we may maintain such content and publish your screen name and other similar information provided to us by you or your school in order to facilitate the intended operation and interaction of the digital and social media features.
Communications from the site
From time to time, it may be necessary for Blackboard to send out a service-related announcement. For instance, if our service is temporarily suspended for maintenance, we might send you a notification email. Users cannot opt-out of these communications though they can delete their account. (For more information, see the Modifications to Personal Information section.) These communications are not promotional in nature.
When you or the Site Administrator deletes your account, the information contained in your user account is no longer available except to the extent it is backed-up as described below. We do not retain your data on behalf the School except as necessary to provide the service requested, comply with our legal obligations, resolve disputes and enforce our agreements, all in compliance with applicable laws. We also back-up information in accordance with industry standard practices and as directed by the School.
The E-Alert feature is a Solution feature available on certain platforms. There are two types of E-Alerts:
- Broadcast E-Alerts are used by Site Administrators to send messages to a specific group or multiple groups of users (i.e., users assigned the same groups). As an example, the School may send voice and/or text messages to groups of users as determined by Site Administrators.
- Content E-Alerts are messages to users when certain changes are made to one or more homepages or sections to which they subscribe. Content editors decide whether to send an E-Alert to subscribers and the content within the message. Users can opt out of E-Alerts through options in their Account Settings.
The Solution will notify Site Administrators by email or by electronic means when new users request access to the Solution through self-registration. In addition, the Solution will notify users by email or by electronic means when other users comment on their blog, when account changes are made to their account, and when other such activities occur on the Solution.
As necessary, Blackboard may communicate with you through email, phone or online to provide requested services and in regards to account-related issues on behalf of the School.
Sharing of information collected when hosting a School’s Solution
When required by law
Though we make every effort to preserve your privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on the Solution.
Users who have been assigned administrative privileges by the School have access to all registered user information strictly and solely on their Solution. Contact the School for more information regarding who has been assigned these privileges and how this assigning process works.
From time to time, Blackboard may retain trusted businesses and contractors to provide certain services which support our provision and hosting of the Solution or otherwise support the operation of the associated online services. We may also contract with trusted third parties to provide complimentary products or services which may be integrated with, linked to (either via a website link or otherwise) or accessible from (such as through single sign on functionality), the Solution.
Compliance with laws
If you have any inquiries regarding our partner’s privacy practices or how they use your child’s personal information, please contact us directly at PRIVACY@SCHOOLWIRES.COM (see contact section below).
Terms which apply to all personal information collected and processed by Blackboard
Modifications to personal information
There are three ways personal information can be modified:
- If your personal information changes, or if you no longer want a user account on the Solution, you or (depending on the platform you are using) your Site Administrator may update or delete your personal information in your account.
- Site Administrators can modify personal information. These Administrators only have access to their Solution’s user information. For children under 13 years of age, the School is responsible for first validating receipt of verifiable parental consent.
- If you have any other requests related to the modifications or deletion of your personal information, please contact the Site Administrator or Blackboard. If the request is made to Blackboard, we will look to the School to validate the request and respond accordingly.
Surveys and feedback forms
Blackboard servers that store personal information are maintained in a physical environment that utilizes industry-standard security measures. Personal information is stored in password-controlled servers with limited access. When you enter sensitive information (such as login credentials) we encrypt the transmission of that information using secure socket layer technology (SSL).
Be aware though that, despite our diligent efforts and implementation of reasonable security measures, no security measures are perfect or impenetrable and no data transmissions over the Internet can be guaranteed to be 100% secure. If you have any questions about the security of the Solution, please email us at SECURITY@SCHOOLWIRES.COM
If the School hosts your Solution or hosts with a third-party, the School or the third-party is responsible for ensuring security. In addition, as noted above, the School has the ability to control the collection, use and dissemination of personal information maintained or processed through the Solution. Contact the School for information regarding security provisions.
Usage implies consent