Effective starting: January 01, 2021
Educator Impact (EI Pty. Ltd.), collects some information about teachers\educators which falls under the definition of “personal information” including under
- the Privacy Amendment (Private Sector) Act, 2000 in Australia.
- Children’s Online Privacy Protection Rule (COPPA) and Family Educational Rights and Privacy Act (FERPA) in the U.S.A; and
- General Data Protection Regulation (GDPR) in the European Union.
We hold the privacy and security of this information with the utmost importance. This policy outlines how we keep this information secure, and how we use it, conforming with
- the Australian Privacy Principles, under the Privacy Act, 1988.
- COPPA and FERPA regulations
- the GDPR
For details regarding the Australian Privacy Principles, please consult https://www.oaic.gov.au/privacy/privacy-act/australian-privacy-principles.
Our approach to the privacy of your personal information is very simple – we only use a system to process your personal information if we would also use that system to process Educator Impact’s company-confidential information.
1. The personal information that Educator Impact holds
For all of our products
During the roll-out of an EI delivery at an organisation/school, we will often be in email or phone contact with participants, observers, and school staff whom we assist in that roll-out. During the course of that contact, we may receive names and contact details of people at the school who require our assistance.
For users of our Pulse products we collect your name, email and class from your institution. We use that data to make Pulse easier to use, for example by sending you reminders and allowing you to reach out when you need help.
We also collect information about your wellbeing directly from you. For example, we ask you “How are you feeling today?” and questions about your experiences at school. We use this data to help your school provide you with the support that you need. Most of the data we collect is provided to the school aggregated and anonymised. When you answer a question we tell you how the answer will be shared with the school.
EI Pulse allows you to say “Thank you” to individuals at your school who might have made your day or week a little better.
EI for Teachers/Leaders/Support Staff
For educators who participate in the Educator Impact 360-degree Feedback Process (participants), we obtain personal and demographic information (e.g. first name, last name, email address and the year-groups taught) from those participants’ schools. This data is used for the purpose of providing personalised 360-degree feedback, professional development resources, and professional development plans.
We also collect and store students’ and other teachers’ observations about participants’ teaching practice, and calculate aggregate statistics to ensure that the feedback we provide to participants is based on sound data.
We ask educators who provide observations about participants’ practice (observers) for their name, which is used to identify their observations.
For students who provide feedback on participants’ teaching practice, we do not require or collect any identifying or other personal information. We do not provide students with the opportunity to identify themselves – they are asked only multiple-choice questions.
From time to time, schools will ask for customisations to our products. For example, they might ask EI to collect additional information specific to that school. In this case, they may collect personal information not listed above.
2. What Educator Impact does with personal information
Educator Impact may use personal information for the following purposes:
- to maintain a record of your wellbeing check-ins,
- to provide your institution (e.g. your classroom teacher, your line manager) with your answers to ‘How are you feeling today?’
- to provide your institution with the other answers you provide during your check-in, after those answers have been de-identified,
- to allow you to reach out for help in the event that you need it,
- to allow you to to say “Thank You” to other users of EI Pulse
- to send emails to participants or observers, where these emails contain administrative details about the EI process (e.g. links to surveys, reminders of upcoming milestones)
- to provide a school with summary information about the progress of participants through the EI process (e.g. a list of which observers have made observations about which participants, or which students have checked in).
- to provide technical or other logistical support to participants, teachers, or school coordinators (e.g. to re-send survey links, or to organise an extension to a milestone).
- to send emails and reports to participants and schools, where those documents might contain: quantitative and qualitative feedback based on surveys and observations by students and observers; professional development goals selected by participants; professional development resources related to those goals; and certificates of completion/participation.
- to send schools reports that contain aggregated quantitative and qualitative feedback
- to perform quality assurance on the system (for example to ensure participant data is migrated correctly during major system upgrades)
Educator Impact may also use de-identified information to conduct and publish research related to Education and wellbeing. Such research may be conducted in collaboration with research partners, (e.g. universities or state governments). Educator Impact may use survey data to investigate factors influencing excellence in teaching and wellbeing. Where a teacher is identified as a potential candidate for such research, the school and teacher are contacted to seek permission to include them in any research undertaken.
3. Where Educator Impact stores and processes personal information
Educator Impact treats the confidentiality of data extremely seriously – the technical architecture of the system is designed with the anonymity of participants and students in mind. All data is protected with security safeguards that are commensurate with the sensitivity of the data. All data is password protected, redundantly stored, and encrypted where appropriate.
All personal information is archived on regularly backed-up, secure data centres located in Australia. This is the final destination of all personal data collected by Educator Impact.
4. Divulging personal information
Except where stated above, or as required by legislation, court order or subpoena, Educator Impact does not share personal information with third parties. Educator Impact can share anonymised survey responses or aggregated statistics for the purposes of research or improvement of the EI process. Except where stated above it is very unlikely that EI would disclose any personal information with overseas entities. All systems which hold personal information are operated in Australia.
5. Data access requests
A data access request asks Educator Impact to provide, correct or delete personal information. All data access requests are lodged via an email to [email protected]. Depending on the nature of the request we may require the requestor provide information to verify their identity, and/or be an authorised agent of their school.
Any party wishing for Educator Impact to provide or correct their personal information can make a request either via their school or directly to Educator Impact and we will provide or correct the information as instructed.
We collect data on behalf of our schools. Any party wishing for Educator Impact to delete their personal information can make a request via their school, and we will delete the data as requested.
6. Opting out
Users, or parents/guardians of users, can request that Educator Impact ceases collecting that users data. We collect data on behalf of our schools – Educator Impact will act on a request coming from an authorised representative of the school. At that point, the user will be removed from participation in the relevant Educator Impact product(s).
7. Data breaches
Educator Impact makes its best efforts to satisfy and exceed our obligations under the Privacy Act. Complaints about a breach can be raised via email to [email protected], and we will work with affected parties to reach a satisfactory outcome.
If Educator Impact becomes aware of a systems security breach by an unauthorized party or that any user data was used for an unauthorized purpose, we will comply with relevant state and other data breach laws. We will notify users via their school of any breach resulting in unauthorized release of data electronically, at minimum, and without unreasonable delay so that you can take appropriate steps. The notification will include: date of the breach, the types of information that were subject to the breach, general description of what occurred, and steps Educator Impact is taking to address the breach.
8. Questions or Complaints
You are welcome to contact us about any aspects of how we process and protect your data, including any questions about how third parties process your data, by sending an email to [email protected]. For any issues that are not resolved by this process, you may contact the Educator Impact CTO, Dr Joe Thurbon, at [email protected] or mail to our offices at 3rd Floor, Customs House, 31 Alfred Street, Sydney, Australia.
Protecting Children’s and student’s privacy is especially important to Us. We participate in the iKeepSafe Safe Harbor program. We have been granted the iKeepSafe COPPA Safe Harbor seal signifying that the Educator Impact Service, as well as our Web Site, has been reviewed and approved for having policies and practices surrounding the collection, use, maintenance, and disclosure of personal information from children consistent with the iKeepSafe COPPA Safe Harbor program guidelines. COPPA protects the online privacy of children under the age of 13; The email for the iKeepSafe Safe Harbor program is [email protected]
In the event of a material change to this policy (i.e. any change that would reduce your rights or increase your risks) we will make the school aware of that change by email to the school’s contact person at least 30 days before the change comes into effect.
10. Our website
Appendix A – Third party data processors
To deliver our products, Educator Impact uses a number of cloud services. Some of these services process personal information. They are:
|Provider||What do they do for us?||What do we give them?|
|Amazon Web Services (AWS)||AWS hosts all of our databases, web servers, login services, emails sent from our application, and more. It’s where “EI Lives” on the internet.||All information we collect from you or your school is stored and processed on AWS, in Australia. This includes wellbeing check in data.|
|GSuite (Google)||We use GSuite (Google Drive, Google Docs, etc) to store information that is given to us by your institution so that we can get the school started with EI and keep it running.||Names, Email addresses and Class lists for all participants.|
|GMail (Google)||We use GMail for email communication by our team.||If a school provides us personal information via email, it is processed by Gmail. This information includes names, Email addresses, class lists and details of issues for which a user has asked for assistance.|
|Firebase (Google)||We use Firebase to send notification to users of our Apps (iOS, Android)||Firebase receives a device ID (which they already have) and the contents of the notification. We do not send personal information in any of our notifications.|
|Apple||Firebase will use Apple’s notification service to send notifications to iOS devices.||As above.|
|Slack||We use Slack for communication in our team, especially finding and fixing issues that are raised by users. Slack is also used to notify us if email addresses are invalid valid||A user ID, an email address or name may be shared during trouble-shooting or bug-finding.|
|Microsoft Teams||We use Microsoft Teams for communication in our team, especially finding and fixing issues that are raised by users.||A user ID, an email address or name may be shared during trouble-shooting or bug-finding.|
|Pivotal Tracker||When a problem is too complicated for fixing immediately, we move from Slack to Pivotal Tracker to manage an issue to its resolution.||As above.|
|Salesforce Service Cloud||When a user contacts our customer success team, for support or onboarding, we keep track of the activities required to resolve the issue in Salesforce Service Cloud’s ticketing system.||Whatever the user has provided us to resolve the issue, but typically: a user name, email address and the nature of the problem.|
|Zoom||We use Zoom to stay in contact with our schools, including making or receiving support calls.||We store names, phone numbers, and email addresses.|
|PandaDoc||We use PandaDoc as part of our onboarding and renewal processes.||It holds their name and email for sending the document and reminders.
We store their e-signature for the purpose of the renewal.
We store their goals, delivery plans and key milestones.
For marketing, sales and administrative purposes, Educator Impact uses a number of cloud services to process personal information. Note: these systems are not involved with the delivery of our products, and do not have access to the personal information of users (e.g. teachers, students), unless they have another relationship with EI (e.g. purchaser, administrator, etc).
|Provider||What do they do for us?||What do we give them?|
|Salesforce Marketing Cloud||Customer relationship management platform used to manage communication and maintain an up to date customer record.||Name, email address, job title, phone numbers, school/employer name and address.|
|Pardot||We use Pardot to create digital marketing marketing campaigns to website visitors and subscribers to our marketing list. This includes managing website forms to capture contact details and communication preferences.||Recipient names, email addresses, job description (where applicable), and location (where applicable)|
|Panda Doc||We use Pandadoc to issue proposals to customers and capture e-signatures on the proposals.||In the course of preparing proposals for customers, we provide the recipient name & email address and the system captures an e-signature|
|Hubspot||We use Hubspot to create digital marketing marketing campaigns to website visitors and subscribers to our marketing list. This includes managing website forms to capture contact details and communication preferences.||Recipient names, email addresses, job description (where applicable), and location (where applicable)|
|Calendly||We use Calendly to make it easier for customers and prospects to schedule appointments with our staff.||Names, email addresses, contact numbers|
Appendix B – Change of control
In the unlikely event that Educator Impact goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third-party.
Appendix C – Data retention policy
We keep personal information until it is deleted, or until we no longer need it to provide you with the Service. We will not retain student personal information for any longer than is necessary for educational purposes and legal obligations, or to provide the Service for which we receive or collect the student personal information. In addition, student personal information is de-identified after a student’s account is deactivated (e.g. the school ceases to be a customer of EI), unless we are required by law or the student’s school to retain it, or need it to protect the safety of our users. Note that some content may be kept after an account is deleted for school legal compliance reasons (e.g. maintenance of “education records” under FERPA or “student records” under various state student privacy laws).
Appendix D – Security practices
Educator Impact protects your personal information using a number of cornerstone security practices. This section outlines them:
- When data is in transit, it is protected using HTTPS.
- When data is at rest (i.e. stored within our database) it is protected using encryption provided by the AWS RDS service
- we make use of Amazon Web Services (AWS) for all application services, hosted in Sydney, Australia.
- we make use of other cloud-based services (e.g. Microsoft Teams, Slack, Google) that are secure but may be hosted in regions other than Australia.
- Educator Impact staff may access personal information only if they require access to the data for the execution of their duties. Such access is limited to the smallest number of employees possible, and access is revoked if duties change.
- Educator Impact conducts background checks on all employees who have access to student data.
- Educator Impact conducts regular, independent, security audits
Appendix E – COPPA Supplement
- Consent for students’ participation in Pulse will be gathered from the school, on behalf of parents.
- Pulse does not encourage or allow students to make their personal information publicly available.
- Information about what information is disclosed to third parties is provided in Appendix A of the policy.