Student Privacy Pledge for Institutional Customers

Updated February 2021

Please note, this student privacy pledge is for Institutional Customers only. For all direct to consumer services, please refer to the Terms of Sale policy here.

A Trusted School Partner

Marco Learning^® appreciates the sensitivity of student data issues for schools, parents, guardians, and students. As our first and top priority prior to launching, Marco Learning engaged Franczek Radelet, a premier education firm, to assist with understanding and assessing student records and privacy issues associated with our company. As a result, this policy was created to ensure that our practices complied with all student privacy and student data laws and guidelines and met all federal legal protections for personally identifiable student records.

Compliance with these privacy laws primarily is the responsibility of school districts, schools, and school employees. Similarly, the penalties for non-compliance primarily fall on the same. At Marco Learning, however, we take our commitment to student privacy very seriously. We strive to be a trusted school partner, and as such, we are committed to complying with the relevant laws even when they do not directly relegate Marco Learning.

Our Three-Pronged Approach to Student Privacy

Marco Learning^® appreciates the sensitivity of student data issues for schools, parents, guardians, and students. Federal and state laws require confidentiality for any student identifying records or information. This data includes any and all Personally Identifiable Information (PII) and other non-public information (“Data”) that an administrator, teacher, or student shares on Marco Learning’s learning management system or web application (“Site”). Data include, but are not limited to, student data, metadata, and user content.

Our three-pronged approach to ensuring compliance with student records privacy is as follows:  

First, Marco Learning readers and teachers are required to sign a confidentiality agreement that they may not re-disclose information shared with them with any third party or use the information shared for any purpose other than the agreed-upon work with the student, teacher, or administrator who provided the information. With regard to the scoring and feedback of student work, Marco Learning readers do not work directly with students. All file sharing happens digitally through our secure Site. With regard to live online review sessions and other live student events, all communication between Marco Learning teachers and students happens through our secure online webinar chat platform which is monitored by Marco Learning staff. As undergraduate students, graduate students, current and former teachers, and tutors, Marco Learning readers and teachers take their legal responsibilities seriously as compliance directly relates to their academic and professional lives.

Second, we require proper approvals from an authorized school administrator before commencing any scoring and feedback work and before granting students access to the Site. Per our terms of service, upon issuance of a Purchase Order or payment of an invoice, an authorized administrator agrees that the school or district’s notification of FERPA rights is broad enough to notify parents, guardians, and eligible students that entities like Marco Learning can be deemed school officials. Since Marco Learning has legitimate educational interests in the student information it receives, Marco Learning shall be deemed a “school official” in accordance with school or district policy.

Third, we as a company collect as little data as possible about students and will not use student data provided to us by schools or teachers to advertise or market to students or their parents. Student-identifying records or information on the Site may be shared with administrators, teachers, and other school employees pursuant to the school district’s policies and procedures. Advertising or marketing may be directed to schools or districts only if student information is properly de-identified.

Note, students 13 years of age or older can register online to access free and paid Marco resources and events beyond the scope of school contracts by providing their name and email address. In doing so, students can choose to opt-in (and opt-out) of email marketing.

How We Use Data

Student-identifying records or information on the Site may be shared with Marco Learning employees for quality control measures. We will use Data only for the purpose of fulfilling our duties and providing services under our agreements with schools and for improving services. Marco Learning may use de-identified Data for product development, research, or other purposes.

De-identified Data will have all direct and indirect personal identifiers removed. This includes, but is not limited to, name, ID numbers, location information, and school ID. Furthermore, Marco Learning agrees not to attempt to re-identify de-identified Data and not to transfer de-identified Data to any party unless that party agrees not to attempt re-identification.

School partners understand that we will rely on one or more subcontractors to perform our services. We agree to share the names of these subcontractors with school partners upon request. All subcontractors and successor entities of Marco Learning will be subject to the terms of this Privacy Pledge.

Data Security

We store and process Data in accordance with industry best practices. This includes appropriate administrative, physical, and technical safeguards to secure Data from unauthorized access, disclosure, and use. We will conduct periodic risk assessments and remediate any identified security vulnerabilities in a timely manner.

Marco Learning will also have a written incident response plan, to include prompt notification of school partners in the event of a security or privacy incident, as well as best practices for responding to a breach of PII.

We will notify teachers and school partners immediately upon any material changes to this privacy policy.

A Note About Our Google Drive Integration for Teachers

If a teacher chooses to share student work or assessment materials with Marco Learning via our secure Google Drive API, they will see a message the first time they attempt to connect their Google account. The message will read: “Marco Learning File Sharing wants to access your Google Account. This will allow Marco Learning File Sharing to: See, edit, create, and delete all of your Google Drive files.”

The access “scope” we request is broad so that our users don’t have to re-authenticate their Google account every time they want to choose a new file or folder to share. However, programmatically, we do not access any users’ Google Drive files or folders except for the specific files or folders the user explicitly selects containing the student work, rubrics, exemplars, and other supporting documents during assignment creation.

For more information, please contact us.