This document is organized as follows:
- Information We Collect
- How We Protect and Secure Our User’s Information
- How We Use The Information We Collect
- When and How We Share Information
- We Do Not Collect Information from Children
- How Users Can Correct Their Information
- Links to Third Party Sites and Listservs
- Data Tracking
- 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 always 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 three 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 address, telephone number, and information regarding their method of payment (e.g., purchase order number).
- Group Members: Program and Site Administrators and Teachers are members that 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 name and e-mail address.
- Invited Guests: Parents and Others are members that register to use the Services in response to an invitation from another registered member. They provide their full name and e-mail address.
- Student Data is information that personally identifies a student and his or her Portfolio. The personally identifiable information includes first name, last name and date of birth. 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.
B. HOW WE PROTECT AND SECURE OUR USER’S INFORMATION
The security and privacy of the data held in GOLD® is one of our highest priorities. Teaching Strategies is committed to protecting the Member Data, Student Data, and Portfolio Data that we maintain on behalf of our Subscribers and their Authorized Users. We utilize and continually review appropriate technical, administrative, and physical procedures to ensure Data is protected from unauthorized access, disclosure, or alteration.
- Data Storage and Security: Secure data centers house all Member Data, Student Data, and Portfolio Data. These data centers are constantly monitored and tested for maximum security. Access to the data center infrastructure is strictly controlled and we adhere to industry standard administrative, technical, and physical safeguards.
- 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 staff.
- 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. Every employee or subcontractor who has access to Member Data, Student Data, or Portfolio Data has the responsibility to keep the information safe and to only use it for authorized educational purposes as described below. 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 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 bill the Authorized User.
- 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 generate reports and conduct research. 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.
If an Authorized User has registered to use the Services through a school, school district, child care 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.
If an Authorized User has invited the parent or legal guardian of a child to view their child’s Portfolio, we will make the Student Data and Portfolio Data in the child’s Portfolio available to such invited guests for their 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 is not authorized to modify or add to a Portfolio.
Additionally, if the Authorized User has registered to use the Services through a school, school district, child care 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, as outlined in the contract with the organization.
D. WHEN AND HOW 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), applicable state law and regulations, and Subscriber polices. 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 to carry out functions within the scope of work when it is in compliance with 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.
- We do not sell or rent your data: Teaching Strategies, LLC does not sell or rent any data that has been collected through GOLD®.
E. 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.
F. 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 provided 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 has 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.
G. LINKS TO THIRD PARTY SITES AND LISTSERVS
- 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 an e-mail discussion group through which Authorized Users may communicate with other Authorized Users and exchange ideas. Any information disclosed in these areas becomes public information.
H. 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.
J. DISCLAIMER OF LIABILITY
If you have any questions or concerns about Teaching Strategies’ information collection and use practices, please e-mail firstname.lastname@example.org.