Student Privacy and Digital Learning Platforms


Looking over the Privacy Policies, Terms of Service or Legal sections of Digital Media is something majority of us want to skip. Reading through pages of “legalese” (a term used by one of my law professors) is the plot of many nightmares and horror movies. Within those lines of legal terms and policies is the online the safety of our students, teachers and parents need to take a moment to read and understand the service and terms. When our students click “log in” what are we consenting to happen?
On a daily basis my students routinely log-in to three digital platforms, Belouga, PenPalSchools and Doulingo.  I was curious what the Privacy Policies included for each and how it applied specifically to the age groups I teach.  For the purposes of this post I review the Duolingo for Schools Privacy Policy, PenPalSchools Privacy Policy and Belouga Privacy Policy, all three were downloaded on August 18, 2018.
One of the interesting parts of the data was that the policies of Belouga and PenPalSchools had two section: one for educators (schools, districts and teachers) and one for students.  Due to federal and state laws, the information is handled differently and the policies are divided to make that clear to the reader. For the purposes of the review we will focus on the students sections of the policies.  
The Privacy Policy of Belouga outlines COPPA (Children Online Privacy Protection Act) although PenPalSchool’s does not mention COPPA by name their policy does align with the Act.  The platforms are also designed for students under the age of 18 and under the of 13 to use and to interact with each other. Each policy states that teacher/school gives consent for the student to use the platform with the parent and/or guardian having the final consent.  Besides the students’ basic login information no other personal data is being collected or shared including third parties. The platforms “may offer third-party products or services on the websites that directly relate to educational content.” (Belouga, Third-Party Links) The third-parties have their own independent privacy policies that will take effect when the student clicks on the link.  Hyperlinks and Third Party are not regularly used on the site (Personally I have used both of these site for three years and never had a student interact with a hyperlink). Belouga and PenPalSchools are both designed for students to interact with students within a global community. As students interact with each other, they can volunteer more identifying information that is necessary to log-in into the site.  This communication is monitored by the teachers and the community within the platform for the safety of the students. Teachers and educators need to review answers and the communication to make sure the student privacy is being protected. Students should not give out username, passwords, home addresses and telephone number or any other identifying information. This is a great opportunity to create a lesson on digital citizenship and protecting personal information.
Duolingo’s Privacy Policy is different from Belouga and PenPalSchools,  there is no section for students, it is the general Duolingo user. When setting up an account the students go to the Duolingo website and login with their school Google Account information.  Then I provide the students with a web address and a class code to join our Duolingo for Schools Account. Searching the Duolingo for Schools site I did not locate a privacy policy that was specific for Schools platform, I was only able to locate the policy for general use Duolingo. Majority of the information policy did not apply to the Schools platform.  As the student enters the classroom through Duolingo for Schools, the teacher is able to take control of the privacy settings of the students’ account. The teacher has the options to turn-off the students ability to create a social profile, join the forums, join/create a clubs and enter the events page. When these features are enable a student can interact with others on through Duolingo without the teacher monitoring the interaction.  Example: a student can create a club, share the code with others to join, other users from the Duolingo site can also join the club.
Changes or Actions:  I will continue to use all three platforms in my class on a regular basis. With the consent for Belouga and PenPalSchools, the opt-out form will remain  the process for gathering parent consent for student usage. All parents will be informed that the students are using the platforms and given the opportunity to view the privacy policies as I have.  If a parent does not want to a student to participate in the activity, the opt-out form can be signed and alternative assignments will be given. I will also to continue to monitor the student response to make sure they are not giving out more personal information than necessary. I am confident that my students privacy and safety are a high priority for Belouga and PenPalSchools.  
For Duolingo For School,  I need to take a more proactive approach to the accounts since there is no monitoring format like PenPalSchools and Belouga.  First all students will only use the school Google Accounts to create accounts on Duolingo. Second, when creating my classrooms in the platform I need to make sure that I do not enable clubs, forums, events and social profiles.  This will stop my students from interacting with anyone through Duolingo without my direct supervision.

Final Review:  Belouga and PenPalSchool have a through and complete privacy policy that protects that students, Duolingo has one that protects the general user, not the “student.”  With the introduction of Duolingo for Schools the privacy policy should be updated to include sections that specific for students, schools and educators. A better recommendation is for Duolingo to have a separate privacy policy for Duolingo for Schools.

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