Last Modified: January 14, 2022.
We recognize the importance of safeguarding the personal information of individuals who use our platform and we make every effort to protect that information and to respect the privacy of these students.
1. About W!SE
Working in Support of Education (“W!SE” or the “Organization”) is an educational nonprofit that provides financial education, college and career readiness programs, and services, to students, educators and at-risk adults. We offer our services to educational institutions across the United States.
2. What this Privacy Statement Addresses
W!SE works with educational institutions who are subject to the Family Educational Rights and Privacy Act and its implementing regulations (“FERPA”). As an educational service provider to these institutions, the Organization adheres to standards set forth in FERPA regarding the privacy and security of students’ personal information (see below, Personal Information Under FERPA). In keeping with these requirements, W!SE has implemented data security systems and processes to protect students’ personally identifiable information (“Personal Information”), as defined under FERPA (20 U.S.C. 1232g ) and its implementing regulations (34 CFR Part 99).
This Personal Information includes:
(a) The student’s name, gender grade and email address
(d) A personal identifier, such as the student’s school ID.
(e) Other indirect identifiers, such as the student’s date of birth
(f) Other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or
(g) Information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
The following privacy statement (“Privacy Statement”) applies to the W!SE internet-based and mobile application-based testing platform (the “Platform”).
NOTE that the Platform is made available to high school students and intended for students ages 14 years and older as well as their teachers.
3. Personal Information that We Collect
When you register on the Platform, W!SE will collect the following Personal Information that you provide us:
a. Contact information and common identifiers: name, gender, grade, birth date, school ID, email address
b. Login details: user ID/identifying tag or username and password
c. Assessment-related information: information regarding your test status and scores, test title, test date (including data and time stamps), test item responses, and your associated educational institution
4.What We Do with the Personal Information that We Collect
The information that we collect via the Platform is used to help carry out and support the educational services that we provide educational institutions. This includes:
a. Creating log-in details for Platform users
b. Ensuring the accuracy of internal recordkeeping
c. Associating digital badges to specific users/test takers
d. Linking certifications to users/test takers
e. Troubleshooting any technical issues you may have on the Platform
f. Better understanding how you use and access the Platform in order to improve our services
g. Developing aggregated reports and related analysis regarding the Platform
h. Complying with legal obligations
5. How We Share Personal Information
W!SE is provided access to certain student Personal Information under FERPA, 34 CFR Part 99.31(a)(1)(i). We share the Personal Information that we collect with,
a. Authorized entities: If you access the Platform through an educational institution, we will share certain Personal Information with that institution or its designated representatives. This Personal Information may include: testing progress and completion, assessment scores, email address, user ID/identifying tag or username
c. Service providers: We employ third party entities to provide specific services related to the Platform, including hosting and maintaining the Platform. These service providers are subject to the same data privacy and security measures as W!SE.
d. Organizational transfer: In the event of a merger, or other transfer of all or substantially all W!SE assets, dissolution, reorganization, or other similar action, we may transfer Personal Information to a third party that is party to the transfer.
e. Aggregate and de-identified information: We may provide aggregate, anonymous or de-identified information about users and the Platform. For instance, information regarding the number of users who have accessed the Platform or the educational progress of categories of users.
6. Personal Information and Consent Under FERPA
FERPA is a federal law that protects the privacy of student education records. It applies to educational institutions that receive funds through the U.S. Department of Education. W!SE is an education service provider and “School Official” (as defined by FERPA) to impacted educational institutions. As a School Official, W!SE works with the institutions it services to ensure compliance with FERPA. This includes limiting disclosures of students’ Personal Information in the form of education records. W!SE will only disclose this Personal Information in the following contexts, which are recognized under FERPA:
a. Consent: An education record may be disclosed to a third party if a valid consent from the student, or student’s parent for children under the age of majority, has been obtained in writing (may be electronic), signed and dated, specifying the records that may be disclosed, stating the purpose of disclosure, and identifying the party or class of parties to whom the disclosure may be made.
b. School Official: Educational institutions may disclose education records to School Officials, provided there is a legitimate educational interest served by the disclosure.
c. State and Local Educational Authorities: An education record may be disclosed without consent to an authorized representative of state and local education authorities for audit and evaluation purposes.
d. Research: An education record may be disclosed to an organization conducting a study for or on behalf of an educational institution, to develop, validate, or administer predictive tests or improve instruction.
Students, or parents of students that are under the age of majority, should consult their educational institution about their rights under FERPA, which include the right to correct or delete any inaccurate data within educational records.
8. Where We Store Personal Information
The Personal Information that we collect and maintain is stored in a secure data center located in the U.S.
9. How Long We Retain Personal Information
W!SE holds Personal Information only as long as necessary to carry out the purposes for which we collect and use it. We follow applicable laws and industry standards for record retention.
10. What We Do to Protect Personal Information
Protecting the Personal Information entrusted to us is important to our Organization. W!SE has implemented and maintains reasonable and appropriate physical, administrative and technical safeguards to help us protect Personal Information from accidental loss, unauthorized access, use, destruction or disclosure, and to maintain the accuracy and ensure appropriate use of Personal Information. We follow generally-accepted industry standards to do so. However, no data transmissions over the Internet is guaranteed to be secure.
If you believe that your account information or device that you use to access the Platform has been lost or stolen or that someone is using your account without your permission, you must notify W!SE immediately to minimize your possible losses.
11.How to Contact Us with Any Questions
12. Changes to this Privacy Statement
W!SE reserves the right to modify this Privacy Statement at any time, including to address any revisions in applicable laws and regulations, industry standards, or technological developments. Such changes will be posted to this webpage, with the date of the revision published at the top of the Privacy Statement.