Student Data Privacy Statement | CWPubOnline

STUDENT DATA PRIVACY STATEMENT

CWPubOnline complies with all applicable student data privacy laws. Only the necessary information relating to the student’s progression through our simulations is collected.

 

District and organization Student Data Privacy Agreements that need to be completed by our staff can be emailed to customerservice@cwpub.com, faxed to 815-441-4308 or mailed to PO Box 744, Sterling, IL 61081. Completed agreements will be returned within 10 business days.

CW Publications Privacy Policy

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. The following outlines our privacy policy:

  • Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
  • We will collect and use personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
  • We will only retain personal information as long as necessary for the fulfillment of those purposes.
  • We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
  • Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
  • We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
  • We will make readily available to customers information about our policies and practices relating to the management of personal information.
  • We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

Storage of Electronic Data

Student data is stored in hashed format in an encrypted database. The only collected and stored data are student name, username, password (grade and email are optional). The information is only accessible to school personnel with a username and password to the admin portal. Only senior level employees have access to the system storing the data and we use a continuous monitoring system to detect unusual file activity, suspicious accounts, and computer behavior. CW Publications shall use industry standard best practices to protect and safeguard data. Controls employed against various systems include but are not limited to:

User Access Control

  • Identity management (authentication/authorization)
  • Role based access
  • Strong passwords and controls
  • Local access management
  • Access logging/monitoring (device & location)
  • Intrusion penetration/vulnerability testing
  • Laptop/mobile device password locks
  • Annual mandatory user security awareness training

At-Rest and In-Transit Data Encryption

  • Multi-level database encryption
  • Secure File Transfer Protocol (SFTP)
  • HTTPS and TLS security

Physical security

  • Controlled building and data center access
  • Video surveillance

Once any data is removed from the database it is irretrievable after 24 hours as the database is cleaned and compressed nightly. If requested, CW Publications will send a certification on company letterhead explicitly stating that the data has been destroyed.

 

CW Publications is in complete compliance with the Supplemental Information to the Parents Bill of Rights. No PII will be released or sold for any commercial purpose and all applicable state and federal laws will be strictly adhered to.

Storage of Non-Electronic Data

We do not collect or store non-electronic student data.

Personnel/Workforce Security Measures

All personnel’s identities are verified along with his/her right to work in the U.S.  Confirmations are made regarding employment history and qualifications. All personnel are trained in the proper use of the company’s electronic systems and only senior staff have access to systems that contain any student data.

 

Training is done internally and focuses on reasonably foreseeable internal and external risks to the security, confidentiality, and/or integrity of any electronic, paper, or other records containing personal information. Our training is ongoing and is given for not only permanent employees but also temporary and contract employees. All employees are trained before being allowed access to any PII and training is revisited annually.

Physical Security Measures

All systems are run on servers located in a building that houses a secure date center. There is a biometric entry security for access into the building and separate biometric entry into the data center.

Account Management and Access Control

CW Publications creates a single admin account for the school. That information is shared with the technical contact designated by the school. The school then creates accounts that adhere to the school’s policy.

Our Student Data Collection and Usage

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Application Technology Meta Data

  • Addresses, use of cookies, etc.
  • Other application technology meta data

Application Use Statistics

  • Meta data on user interaction with application

Assessment

  • Standardized test scores
  • Observation data
  • Other assessment data

Attendance

  • Student school (daily) attendance data
  • Student class attendance data

Communications

  • Online communications that are captured (emails, blog entries)

Conduct

  • Conduct or behavior data

Demographics

  • Date of birth, place of birth, gender, ethnicity or race, language information, other

Enrollment

  • Student school enrollment, student grade level, homeroom, guidance counselor
  • Specific curriculum programs, year of graduation, other

Parent/Guardian Contact Information

  • First and/or last name
  • Address, email, phone
  • ID number (created to link parents to students)

Schedule

  • Student scheduled courses and teacher names

Special Indicator

  • English language learner information
  • Low income status
  • Student disability information, medical alerts
  • Specialized education services
  • Living situations (homeless/foster care)

Student Contact Information

  • Local (school district) ID number
  • State ID number
  • Vendor/App assignment ID
  • Student app username
  • Student app passwords

Student Name

  • First and/or last

Student In-App Performance

  • Program/application performance

Student Program Membership

  • Academic or extracurricular activities a student may belong to or participate in

Student Survey Responses

  • Student responses to surveys or questionnaires

Student Work

  • Student generated content, writing, pictures, etc

Transcript

  • Student course grades
  • Student course date
  • Student course grades/performance scores

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