Character Lab Research Network – Student Privacy Policy


Character Lab takes student privacy very seriously.  This means that we think very carefully about how we handle personally identifiable information.  We have published this privacy policy to make clear to schools and parents how personally identifiable information is collected, used, and disclosed through our Character Lab Research Network (“Research Network”) platform.  If you have any questions about our privacy practices, please visit our Frequently Asked Questions, reach out to your school, or contact us directly at privacy@characterlab.org.

Character Lab is a non-profit organization whose mission is to advance the science and practice of character development, not to profit from the use of personally identifiable information. We understand the sensitive nature of personally identifiable information, and therefore make a number of commitments about how we protect the privacy of that information.  In particular:

  • We will never collect, use, share, or retain personally identifiable information for any purpose other than as authorized by the school.
  • We will never share personally identifiable information with a researcher unless authorized by the school, and then only subject to strict protections.
  • We will never partner with any for-profit entity to provide it with information collected through Research Network, whether personally identifiable or de-identified. 
  • We will never sell personally identifiable information. 
  • We will never use or disclose personally identifiable information for commercial purposes.
  • We will never build a personal profile of a student other than to facilitate scientific services.
  • We will always support access to and correction of personally identifiable information by students or their parents.

Consistent with the above assurances, Character Lab commits to comply with all of the requirements of the K-12 School Service Provider Pledge to Safeguard Student Privacy, available at https://studentprivacypledge.org/privacy-pledge.
 

What student information is collected through Research Network?

Research Network seamlessly connects schools with character development researchers. Researchers create activities that they make available through Research Network, which come in various forms including but not limited to surveys, open-ended responses, short video clips, and gamified tasks.  Schools that connect with those researchers make Research Network available to their students, who can then participate in those activities.

To participate in Research Network research activities, and for initial validation purposes, students will be asked to create accounts by providing their school email address, student ID number, and school information. Teachers may also create accounts for students by providing their name and/or student ID number, and may input other information related to their students’ character assessment tests through Research Network.

Students will log on to the platform with their email address or ID number and a password, and will use the platform to perform the research activities.  Through the research activities, students may provide responses to research questions related to character development (e.g., grit, growth mindset, gratitude), perform tasks (e.g., trace a star backwards, identify missing pieces of a matrix), or provide responses to questions after taking part in some sort of task (e.g., watch a video, write a letter).

In addition, we may collect certain technical, non-personal information about students’ use of Research Network, such as:

  • Browser type, language, plug-ins, Internet domain and operating system;
  • Internet Protocol (IP) address;
  • Unique device identifiers, including mobile device identification numbers, that may identify the physical location of such devices;
  • Information collected through cookies, which are small text files stored on users’ computers to save information about the use of websites, such as a student’s progress through a particular activity or series of tasks when using Research Network; and
  • Information related to students’ interactions with Research Network, such as the type of content viewed on Research Network.

We will never use this information to build a personal profile of a student other than to facilitate scientific services.

 

How does Character Lab use and disclose personally identifiable information collected through Research Network?

We use the personally identifiable information collected through Research Network to provide our research services, including as needed to maintain, develop, support, improve, analyze, or troubleshoot those services.  We will never use or disclose personally identifiable information for any purpose other than as authorized by the school.

Because Research Network was created to connect schools and researchers, information collected through Research Network is provided to researchers, as authorized by the school, in order for them to conduct their research.  However, Character Lab does not disclose personally identifiable information collected through Research Network – such as names and contact information – to researchers unless authorized by the school.  This means that, unless authorized by the school, researchers – including, in some cases, researchers affiliated with Research Network – will only receive de-identified student information and will not be able to identify individual students from the information they receive through Research Network with reasonable certainty.

This is how it works.  Information collected from students through Research Network is stored by Character Lab, and may include personally identifiable information.  As a default rule, Research Network de-identifies student personally identifiable information before providing it to researchers, so that researchers cannot identify individual students with reasonable certainty when conducting their research.  This means that for the vast majority of our studies, researchers will only receive de-identified student information.

In some limited circumstances, and only when authorized by the school, Character Lab will disclose student personally identifiable information to a researcher.  Additionally, it is possible that some students may volunteer personally identifiable information in a free-form response that is provided to a researcher.  Whenever a researcher receives personally identifiable information, the researcher is strictly required to use the information only in support of the study.

Otherwise, Character Lab will not use or disclose student information collected through Research Network except in the following circumstances:

  • When directed or consented to by the student (or the student’s parent or guardian) or teacher who input the information, or by the administrator of a school’s account;
  • To service providers who work on our behalf and who will use the information in furtherance of our operations, in accordance with our privacy commitments;
  • In response to subpoenas, court orders, legal process, or to comply with government reporting obligations pursuant to law;
  • When we believe in good faith it is necessary to protect the safety of students or others, or to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of Research Network;
  • To service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets in bankruptcy or otherwise. This means that if some or all of our assets are acquired or otherwise transferred, including in bankruptcy, the acquirer will be permitted to maintain the student information transferred, subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law.

We will never use or disclose student information for commercial purposes, sell personally identifiable information, or partner with any for-profit entity to provide it with information collected through Research Network whether personally identifiable or de-identified.

 

What rights do schools and parents have with respect to personally identifiable information collected through Research Network?

Research Network remains under the direct control of the school for the personally identifiable information it receives, and uses personally identifiable information only for purposes authorized by the school.  Therefore, schools retain the right to ask Character Lab to access, correct, or delete personally identifiable information collected through Research Network, and Character Lab will always support access to and correction of personally identifiable information by parents consistent with legal requirements.

Because Research Network remains under the direct control of the school, parents who may have any concerns about the collection or use of students’ personal information through Research Network should contact their school. If you are not sure who at your student’s school will be able to help, feel free to contact us at privacy@characterlab.org.

 

How does Character Lab secure student information collected through Research Network?

We maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of personally identifiable information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.

Character Lab may use one or more third-party service providers (“Vendors”) to help host the services.  Each Vendor has been vetted by Character Lab with respect to the Vendor’s representations about how personally identifiable information is transmitted, stored, processed, and maintained by the Vendor.

 

What obligations does Character Lab have with respect to students’ civil rights?

Although civil rights obligations under federal or state law apply to the schools that partner with Character Lab, Character Lab will use commercially reasonable efforts to provide any legally required accommodations under such legal requirements, including those that prohibit discrimination against students with disabilities and English Language Learners.

 

Will Character Lab make changes to this Privacy Policy?

We will not make changes to this Privacy Policy that would give Character Lab the ability to use personally identifiable information in a way materially inconsistent with this Privacy Policy or any contractual requirements with schools, without first providing prominent notice to schools to allow them to choose whether to continue to use Research Network in accordance with the new Privacy Policy.

 

Contact us

If you have any questions about this Policy or our use of personally identifiable information collected through the Services, please visit our Frequently Asked Questions or contact us at privacy@characterlab.org.

This Privacy Policy is effective as of August 18th, 2017.