This Privacy Notice applies to Teaching Strategies, LLC Software as a Service products, located on the Web site www.teachingstrategies.com (the “Site”). The Site is owned and operated by Teaching Strategies, LLC (“Teaching Strategies”). Teaching Strategies makes the following available on the Site: online management, reporting, and assessment systems (the “Services”). Teaching Strategies is committed to ensuring the privacy and accuracy of the information collected on the Site. This Privacy Notice identifies the information that Teaching Strategies collects from users and visitors of the Site and describes how we will use, share, and otherwise process the information we have collected.
This document is organized as follows:
A. Information We Collect
B. How We Protect and Secure Our User’s Information
C. How We Use The Information We Collect
D. When and How We Share Information
E. International Visitors
G. We Do Not Collect Information from Children
H. How Users Can Correct Their Information
I. Data Release and Deletion Request
J. Links to Third Party Sites and Listservs
K. Data Tracking
M. Disclaimer of Liability
A. WHAT INFORMATION WE COLLECT
Teaching Strategies collects Member Data, Student Data, and Portfolio Data. The Data includes Personally Identifiable Information (PII), which means information that may identify an individual Student or Member. Teaching Strategies complies with applicable laws, regulations, industry standards, and contracts and agreements pertaining to the safeguarding of PII. The Data are provided by the authorized representative of an organization who has purchased a subscription to use the Services (an “Authorized User”).
Member Data is limited information that can be used to personally identify an Authorized User. This information is required before the Authorized User can access the Services (whether on a trial basis or through a paid subscription). There are several kinds of Member Data:
- Subscribers: Organizations and Individual Subscribers are members that have purchased a subscription from Teaching Strategies to use the Services. Subscribers provide their full name, the name of their organization, their mailing and e-mail addresses, telephone number, and information regarding their method of payment (e.g., purchase order number).
- Group Members: Program and Site Administrators and Teachers are members who register through a school, school district, childcare center, Head Start program, or other organization that has purchased a subscription from Teaching Strategies to use the Services. They provide us with their full names and e-mail addresses.
- Invited Guests: Invited Guests are Parents and Others who register to use the Services in response to an invitation from another registered member. They provide their full names and e-mail addresses.
- Student Data is information that personally identifies a student and his or her Portfolio. The personally identifiable information includes first name, last name, date of birth, gender, language spoken, ethnicity, and, where applicable, State Student Identification Number. Student Data is stored in online Portfolios. Each Portfolio includes Documentation and Checkpoint information.
- Documentation: Teachers observe children in the classroom and gather documentation of their learning and development over the course of the year. Documentation can be notes, photos, videos, samples of children’s artwork, and observations from families about their child’s development.
- Checkpoint: A few times a year, teachers analyze the Portfolio Data collected during the checkpoint period and make ratings based on their observations and the documentation they have gathered. These ratings are based on a list of research-based and developmentally appropriate indicators that reflect widely held expectations for children of similar ages, classes, or grades. Completing these checkpoints allows teachers to evaluate children’s progress and show growth in the children’s learning and development over the course of the year. The Student Data is only provided by authorized Subscribers during the initial setup or in the development of an individual student Portfolio. The provision of information is sometimes required by law and at other times is a result of a contractual requirement. You may be required to provide information, for example in a case where we sign a contract with your organization, and the non-provision of information could, in certain circumstances, prevent a transaction from concluding.
B. HOW WE PROTECT AND SECURE OUR USER’S INFORMATION
We utilize technical, administrative, and physical procedures to ensure Data is protected from unauthorized access, disclosure, or alteration.
You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law.
We have implemented reasonable safeguards designed to prevent loss, misuse and unauthorized access, disclosure, or modification of Personal Data provided or collected through the Teaching Strategies Services. With respect to Personal Data collected through the Teaching Strategies Services, we use Secure Socket Layer Technology or SSL to encrypt or scramble that information during transmission, and data is encrypted at rest.
- Data Storage and Security: Secure data centers, located within the continental United States, house all Member Data, Student Data, and Portfolio Data. These data centers are continuously monitored and are audited annually.
- Disclosures: The uses and disclosures of Student Data are in compliance with state and federal laws designed to protect such information. Only authorized individuals, including Teaching Strategies employees and subcontractors, have access to children’s portfolio items, and their authorization is constantly reviewed and verified by a cross functional working group, which includes the Information Security Officer and senior Legal and HR staffs. Individuals authorized to have access to Student Data are limited to only those who need access to that data in order to perform the work necessary under our contractual arrangements with our Subscribers.
- Accountability: All Teaching Strategies employees and subcontractors are accountable for the Security and Privacy of the Member Data, Student Data, and Portfolio Data we maintain on our Subscribers’ behalf. This policy applies to all computing systems, networks, business processes, and the verbal transmission of information.
C. HOW WE USE THE INFORMATION WE COLLECT
- Only for Authorized Purposes: We only use information we collect for the educational purposes for which we were authorized by our Subscribers.
- Member Data: We will use the Member Data provided to register the membership, set up and maintain the account, determine the number of Portfolios an Authorized User is authorized to create (if any), and determine which Portfolios the Authorized User is authorized to access, update, view, and/or modify. We will also use Member Data to notify Authorized Users of updates to the Site and our Services, and for contact purposes if we need more information. If an Authorized User has purchased a subscription to use the Services, we will use the financial information provided to invoice the Authorized User. If an Authorized User has registered to use the Services through a school, school district, childcare center, Head Start program, or other organization that has purchased a subscription from Teaching Strategies, the Member Data provided will be accessible by the organization that purchased the subscription, as outlined in the contract with the organization.
- Student Data: Student Data is used to set up and maintain Portfolios and to grant other Authorized Users the right to access, update, view, and/or modify such Portfolios. Portfolio Data can be used to identify and recommend appropriate activities and customize student plans. Aggregated, non-personalized outcome group progress reports for Subscribers are also generated using Student Data. Only the Student Data provided by a Subscriber’s Authorized Users will be used to create reports for such Subscriber. We also may aggregate the Portfolio Data, with all personally identifying information about individual students, Authorized Users, organizations, and programs removed, to conduct research to enhance the services, analyze usage trends, conduct aggregated statistical analysis, and to provide technical support. Third parties who provide support for these activities and have access to de-identified and aggregated data are listed here. From time to time, we may publish the results of the aggregated, de-identified Portfolio Data. In no event will any such results permit the personal identification of students and their parents, or identify in any way the site, program, or organization.
- Invited Guests: If an Authorized User has invited the parent or legal guardian of a child to view his or her child’s Portfolio, we will make the Student Data and Portfolio Data in the child’s Portfolio available to such invited guest for review. All invited guests must register with Teaching Strategies before being granted access to a Portfolio, and the invited guest’s access will be limited to the Portfolio such guest has been invited to view. An invited guest will not be able to modify or add to a Portfolio. Additionally, if the Authorized User has registered to use the Services through a school, school district, childcare center, Head Start program, or other organization that has purchased a subscription from Teaching Strategies, any Student and Portfolio Data that the Authorized User provides will be accessible by the organizations that purchased the subscription services, as outlined in the contract with the organization. We do not use automatic decision-making or engage in profiling. In the event that circumstances require us to process your personal data for a purpose other than the purpose for which it was collected, we will provide you with information regarding the purpose for the processing, as well as other relevant information, prior to processing your personal data for the new purpose. Please see Section D. below for applicable circumstances.
D. WHEN AND HOW WE SHARE INFORMATION
We share information only for the educational purpose of the work. We do not share Member Data, Student Data, or Portfolio Data for advertising or any other use outside of the educational purpose of the collection of such information. We vigilantly review our policies and practices to ensure compliance with the Federal Educational Rights and Privacy Act (FERPA) and the European Union’s General Data Protection Regulation (GDPR), applicable state law and regulations, and Subscriber policies. We will not disclose any of the Member Data, Student Data, or Portfolio Data we collect to any third parties except as described in C(1)(b) above and in the following limited circumstances:
- Disclosures that are necessary to carry out the scope of work. We may use subcontractors and/or sub-processors (current list available here) to carry out functions within the scope of work when it is in compliance with GDPR, federal, and state law and with applicable Subscriber agreements. In such circumstances, the subcontractor is acting as a Teaching Strategies employee and is required to comply with the privacy and security requirements and safeguards that apply to Teaching Strategies and all of its employees. This includes all applicable federal laws, state laws and regulations, contractual agreements, and applicable Subscriber policies.
- Legally compelled disclosures. We will disclose the data we collect if required to do so by law or in the good-faith belief that disclosure is necessary (a) to obey the law or comply with legal process served on us or our affiliates; (b) to protect and defend our rights or property or the rights or property of other users of our Web site; or (c) to act in an emergency to protect the personal safety of users of our website or the public.
- Analytics. We may work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes. For example, Teaching Strategies uses Google Analytics to improve the performance of the Site and for other analytics purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit https://www.google.com/policies/privacy/partners/ , and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/ .
- We do not sell or rent your data: Teaching Strategies, LLC does not sell or rent any data that has been collected through the Services.
E. INTERNATIONAL VISITORS
This section applies to those who visit our Site from the European Economic Area or Switzerland.
- Lawful Basis for Processing
On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide services to you that you have requested. We may also process your personal data to respond to your inquiries concerning our products and services. On other occasions, we process your personal data where required by law. We may also process your personal data to protect your interests or the interests of a third party. Additionally, we process your personal data when it becomes necessary for us to provide important notifications to Subscribers concerning the Services. We will also use your personal data to communicate with you if you choose to opt into our marketing communications so that you can learn more about our Services and products. However, this interest in providing you with information does not override your data protection rights. Where we process your personal data for this purpose, our legitimate interest is to improve our Services and secure our Site. If the processing of personal data is necessary and there is no statutory basis for such processing, we will ask for your consent to process your personal data. You have the right to withdraw your consent to processing of personal data at any time. If you wish to exercise the right to withdraw consent, contact us via the “Contact” section below for contact information.
- Transfers of Personal Data
Please be aware that the personal data we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store personal data in the United States.
- Complaints Resolution
If you are affected by the GDPR, please consult the following link for the Teaching Strategies, LLC GDPR Addendum, which states your rights under the GDPR: Teaching Strategies, LLC GDPR Addendum
We will process and store your information only for the period necessary to achieve the purpose of the storage, or as permitted by law.
G. WE DO NOT COLLECT INFORMATION FROM CHILDREN
Our services are not intended to be accessed by anyone under 18 years of age. We respect the sensitive nature of children’s privacy online. The Services are intended for use by schools, school districts, program administrators, teachers, parents, and legal guardians. They are not intended for use by persons under the age of 18. We do not expect and are not aware of children under the age of 18 accessing our site, and we are in full compliance with the legal requirements outlined in COPPA regarding children under the age of 13. If we learn that a user is under 18 years of age, we will promptly delete any personally identifiable information provided by that user.
H. HOW USERS CAN CORRECT THEIR INFORMATION
Members can manage the data they entered: Our Authorized Users are able to manage and modify the information that they provide to us. They may correct or change any of their Member Data by logging onto the site and updating or correcting their Member Data. Authorized Users may change any of the Student Data that they provide by logging onto the Services and modifying the applicable student Portfolio. Only the Authorized User who created the Portfolio and such member’s program administrator have the ability to modify the Student Data for a Portfolio. If you need assistance modifying Student Data, you may contact Teaching Strategies’ support services line at 1-866-736-5913.
I. DATA RELEASE AND DELETION REQUESTS
Teaching Strategies does not own the member, student, or invited guest data stored and processed by our software-as-a-service suite of products. The childcare provider or school in which your child is or was previously enrolled has contracted with Teaching Strategies to provide the services associated with collecting that data. As such, all data that we collect for that provider or school is owned by that organization.
We may not delete or release data without express written permission from that organization except in limited cases such as a court order. All data deletion and data release requests must be made directly to your childcare provider or school.
- External links: The Site may contain links to other Web sites or refer our users to other resources. We are not responsible for the privacy practices or the content of such Web sites or resources, and our users should refer to such Web sites and resources for information about how such sites and resources protect the information they collect.
- Discussion groups: The Site also makes available to Authorized Users a discussion group through which Authorized Users may communicate with other Authorized Users and exchange ideas. Any information disclosed in these areas becomes public information.
K. DATA TRACKING
Tracking Information: We use the anonymous information we collect to administer our Site, improve our services, determine how the Site is being used, identify popular areas of the Site, and analyze trends and usage patterns. We may use the IP address of our Authorized Users to help diagnose problems with our server. This anonymous information cannot be used to personally identify users or students.
M. DISCLAIMER OF LIABILITY
If you have any questions or concerns about Teaching Strategies’ information collection and use practices, please contact our Legal Affairs team at: [email protected].
If you have questions regarding our role as a data controller, please contact us at: [email protected]