Vendors I-Q

iChineseEdu (for iChinese Reader)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. PII is used to set up accounts for teachers and students, and connecting with SSO. 

Type of PII that the Entity will receive/access: Student PII and Other (teacher’s information, class assignment, and students’ class assignment)

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. AWS.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. “All PII data is stored in the AWS database, which can’t be access directly. Customers need accounts to use the app. The APIs relative to PII data need to be called with authtoken, which can be got by login successfully. SchoolAdmin account can access teachers and students PII data in the school, teacher account can access teacher and students PII data in the class, student account can access his/her PII data, parent account can access his/her children’s PII data.”

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Illuminate Education

The exclusive purposes for which PISI will be used: The provision, implementation, administration, and/or maintenance of K-12 education technology products and services related thereto.

How you will ensure that the subcontractors, persons or entities that you will share the student data or teacher or principal data with, if any, will abide by data protection and security requirements: Any and all subcontractors or other authorized persons or entities that Illuminate shares data with will be required to enter into strict confidentiality provisions in accordance with similar terms contained herein, and Illuminate retains the right to demand certification of compliance to said terms.

When the agreement expires and what happens to PISI upon expiration of the agreement: There is no one set term for the non-disclosure agreement, as individual schools may purchase Illuminate’s products or services at different times and for different periods. Within thirty (30) days of the termination of any license or data sharing agreement, Illuminate destroys all PISI. The data privacy and security terms of Illuminate’s agreement with NYC DOE will remain in effect for as long as Illuminate is in possession of NYC DOE confidential information. [NYC DOE additional information: The current agreement became effective starting on January 24, 2020 and remains effective through the period during which Illuminate Education, Inc. possesses or otherwise is in control of covered protected information, which varies depending on the services a given school purchased from Illuminate Education, Inc.]

If and how a parent, student, eligible student, teacher or principal may challenge the accuracy of the student data or teacher or principal data that is collected: Pursuant to its contractual obligations, the Recipient will work with the NYC DOE in processing challenges to the accuracy of student data in the custody of the Recipient. Challenges should be emailed to studentprivacy@schools.nyc.gov or mailed to the attention of the Chief Privacy Officer Rm 308, NYC Department of Education, 52 Chambers Street, New York, NY 10007. [NYC DOE additional information: such requests, including requests for copies of student data, may be sent to studentprivacy@schools.nyc.gov]

Where the PISI will be stored (described in such a manner as to protect data security), and the security protection taken to ensure such data will be protected, including whether such data will be encrypted: All PISI data is hosted primarily with Amazon Web Services, and there are select products hosted with Google Cloud Platform, which are being migrated to AWS. AWS hosts the data in the United States. Either provider’s SOC2 report is available upon request or can be accessed by contacting AWS or GCP directly.

How the data will be encrypted (described in such a manner as to protect data security): Data is encrypted at both rest and in transfer in accordance with NIST Cybersecurity Framework requirements.

Imagine Learning LLC

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Imagine Learning provides digital K-12 core, supplemental and intervention courses for each grade level. Our innovative teaching solutions use insights from real-time data to meet each student where they are and enable their success in class today and for a lifetime of learning. Users must create an account to access the product site. We use PII to create these accounts for students and teachers. Products include:

Core

• Imagine EL- A comprehensive, content-based K-8 core language arts program that utilizes real-world compelling texts to engage and excite learners.
• Illustrative Math- Offers the highest quality core math curricula for grades K–12, powered by a best-in-class integrated learning experience.

Supplemental

• Edge (Courseware)- Dynamic courses help students in grades 6–12 maximize their potential. Initial credit and credit recovery courses adapt to each student's unique learning journey.
• Purpose Prep- A CASEL-aligned social and emotional learning program for your primary and secondary students, as well as for your faculty and staff.
• Imagine Galileo-A forward-thinking ELA, SLA, math, science, and College Prep benchmark and formative assessment system for K–12 that offers a powerful blend of convenience and flexibility.
• Imagine Espanol- A rigorous and personalized program for Spanish language and literacy development in grades K–2, building the foundational skills of bilingualism, biliteracy, and cultural competency.
• Imagine Language & Literacy- Accelerate reading and language development in PreK-6 with our personalized learning solution designed to complement any core literacy program.
• Imagine Lectura- Empower bilingual students in grades 3–5 to unlock comprehension of authentic Spanish texts and succeed with grade-level learning tasks.
• Imagine Math- A supplemental math program that builds students' aptitude to solve problems and justify reasoning both inside the classroom and in day-to-day life, ultimately moving them beyond computation to real comprehension.
• Imagine Math Facts- With award-winning gamification, make practicing fluency in addition, subtraction, multiplication, and division fun, fast, and effective for elementary students.
• Imagine Reading- Scaffold learning for students in grade 3–8 using a library of exemplary genre texts to pique interest and deepen comprehension and conversation.

Intervention

• MyPath- An intervention solution for math that delivers targeted, age-appropriate learning paths for all students, and targets achievement gaps using our intuitive Smart Sequencer™ technology.
• Pathblazer- Is a personalized intervention program for K–6 designed to accelerate struggling learners in math and reading toward grade-level achievement using data-driven learning paths.

Instructional Services

• Imagine Learning virtual instructors are highly qualified, certified teachers who prioritize student success in K–12. They work across time zones and devices to provide students with the personalized instruction and the support they need to learn, grow, and reach their full academic potential.

Type of PII that the Entity will receive/access: Student PII and APPR PII (Identifiable Teacher or Principal Annual Professional Performance Review Data).

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Other: Upon the earliest of any of the following (i) whenever requested by the BOE, (ii) whenever the Processor no longer needs the Confidential Information to provide the Services to the BOE, (iii) whenever a BOE school or office ceases use of a product or service of the Processor, with respect to the Confidential Information Processed for the school or office with respect to that product or service, or (iv) no later than upon termination of this Agreement, the Processor shall promptly (a) with respect to physical copies of Confidential Information, surrender, or if surrender is not practicable, securely delete or otherwise destroy Confidential Information and (b) with respect to digital and electronic Confidential Information, securely delete or otherwise destroy Confidential Information remaining in the possession of the Processor and its Authorized Users, including all hard copies, archived copies, electronic versions or electronic imaging of hard copies of such data.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. AWS and Microsoft Azure.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. In addition to the protections afforded by our cloud hosting providers, practices employed at Imagine Learning to protect personal data include, but are not limited to:

• Data encryption. Data is encrypted in transit and at rest.
• Access. Access to personal information is restricted to a limited number of Imagine Learning employees who need such access to perform their job.
• Data Systems Monitoring. Imagine Learning employs several third-party services that continuously monitor and scan our online services for vulnerabilities and misconfigurations. Employees dedicated to operating our services monitor these services and receive automated alerts when performance falls outside of prescribed norms.
• Incident Response Plan. Imagine Learning regularly reviews and maintains an incident response plan.
• File Transfer Protocol. Data is securely transferred to Imagine Learning using File Transfer Protocol (FTP) over secure (SSL/TLS) cryptographic protocol.
• Firewalls. Anti-virus software and firewalls are installed and configured to scan our systems. The firewall is periodically updated and configured so that users cannot disable the scans.
• Security audits. Imagine Learning conducts security audits and code reviews, both by outside providers and by executive summary.
• Secure programming practices. Imagine Learning software developers are aware of secure programming practices and strive to avoid introducing errors in our applications (such as those identified by OWASP and SANS) that could lead to security breaches.
• Account protection. Each user of Imagine Learning is required to create an account with a unique account name and password. Single Sign-On (SSO) users are authenticated with secure tokens.
• Facility security. Imagine Learning is located inside the continental United States. Physical access is protected by electronic access devices, with monitored security and fire/smoke alarm systems.
• Security Breach. In the event of a security breach that results in unauthorized release of personal data, Imagine Learning will notify affected customers of such breach, will investigate, and will restore the integrity of its data systems as soon as possible. We will fully cooperate and assist with required notices to those individuals affected by such breach.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

In Class Today

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. In Class Today will receive PII for the exclusive purpose of implementing an attendance support program. The program includes the analysis of student attendance data to select students most likely to benefit from the program, and the delivery of mailed attendance letters to the parents and guardians of selected students.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. Amazon Web Services, Moonlight BPO, Box.com, Files.com, and Twilio.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. All Protected Information is encrypted to a minimum 256-bit encryption standard, both in transit and at rest.

Only those In Class Today personnel and subcontractors who need to access Protected Information to perform the services outlined in the contract will be administratively, operationally, and technically authorized to access that information.

Access to Protected Information is password-protected, and strong passwords are enforced and stored only in encrypted vaults.

All systems that are used to store, access, transmit, or otherwise use Protected Information enforce a one user, one account policy. Within all systems used to store, access, transmit, or otherwise use Protected Information, each individual’s access will be limited to the Protected Information they need to access in order to perform the service.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

Inspiring Minds

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Inspiring Minds will be developing leadership skills though basketball, martial arts and a youth conference for approximately 75 middle school students. We will need access to names, addresses, phone numbers and email addresses of the students participating in our program.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE's option and written discretion, in a format agreed to by the parties. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor. Information will be collected and stored through a google survey application that transfers all data to an excel document.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Confidential information must be removed from desks, computer screens, and common areas unless it is currently in use. Confidential information will be stored on an encrypted excel document. Confidential data must not be 1) transmitted outside the company network without the use of strong encryption, 2) left on voicemail systems, either inside or outside the company's network.

• Confidential data requires additional security controls in order to ensure its integrity. The company requires that the following guidelines are followed:
• Strong Encryption. Strong encryption must be used for confidential data transmitted external to the company. If confidential data is stored on laptops or other mobile devices, it must be stored in encrypted form.
• Network Segmentation. Separating confidential data by network segmentation is strongly encouraged.
• Authentication. Strong passwords must be used for access to confidential data.
• Physical Security. Systems that contain confidential data should be reasonably secured.
• Printing. When printing confidential data the user should use best efforts to ensure that the information is not viewed by others. Printers that are used for confidential data must be located in secured areas.
• Faxing. When faxing confidential data, users must use cover sheets that inform the recipient that the information is confidential. Faxes should be set to print a confirmation page after a fax is sent; and the user should attach this page to the confidential data if it is to be stored. Fax machines that are regularly used for sending and/or receiving confidential data must be located in secured areas.
• Emailing. Confidential data must not be emailed outside the company without the use of strong encryption.
• Mailing. If confidential information is sent outside the company, the user must use a service that requires a signature for receipt of that information.
• Discussion. When confidential information is discussed it should be done in non-public places, and where the discussion cannot be overheard.
• Confidential data must be removed from documents unless its inclusion is absolutely necessary.
• Confidential data must never be stored on non-company-provided machines (i.e., home computers).
• If confidential data is written on a whiteboard or other physical presentation tool, the data must be erased after the meeting is concluded

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Instructure (for Canvas)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Instructure is providing Canvas LMS which is a software-as-a-service learning management system used by K-12 schools. Canvas LMS is used by learning institutions, educators, and students (collectively “end-users”) to access and manage online course learning materials and communicate about skill development and learning achievement. Canvas LMS includes a variety of customizable course creation and management tools, course and user analytics and statistics, and internal communication tools.

Instructure is receiving and accessing PII via Canvas LMS to (a) provide secure end-user access to Canvas LMS, (b) provide teaching and learning services (such as classes, quizzes, assignments), (c) facilitate communication between educators and students about courses and related work, (d) permit uploads of educator and student content related to their courses, and (e) provide course related analytics the learning institution.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e., Amazon Web Services.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Instructure maintains administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of personal information processed by Canvas LMS, as follows:

• Security policies are reviewed and approved by the executive leadership of Instructure on an annual basis.
• Canvas LMS is regularly assessed and tested by security staff and third parties.
• Use of Canvas LMS and network access policies are required in order to control and limit access to internal systems.
• Physical access to systems containing pesronal information is restricted.
• Access to Canvas LMS is based on the principle of least privilege, separation of duties, and is regularly reviewed.
• Applicable and necessary security patches are kept up-to-date.
• Use of default system passwords is prohibited and the use of a public/private key exchange is mandated on all systems including Canvas LMS.
• An employee information security policy is maintained that addresses employee responsibilities, including protection of confidential information.
• Employees receive annual security awareness training and must sign confidentiality agreements as a condition of employment.
• Remote access by employees to internal control and management systems is restricted and requires two-factor authentication.

Access Limitations

• Instructure restricts access to personal information only to those employees who have a need to know or otherwise access personal information to enable Instructure to perform its obligations under the Agreement; provided that (a) a background check has been conducted of its employees, and (b) such employees are bound in writing by obligations of confidentiality sufficient to protect personal information in accordance with requirements herein.

Personal Data Transmission

• All access into Canvas LMS utilizes secure protocol HTTPS; All clear text HTTP connections are disabled by default.
• Copying of personal information outside of Canvas LMS operations environment by any employee of Instructure is restricted by policy and only permitted for legitimate business needs.
• Personal information is transmitted into and out of Canvas LMS via secure TLS exclusively; SSL is disabled by default.

Data Storage, Retention and Availability

• Data retention timelines are defined for all elements of Canvas LMS.
• Instructure will ensure back up of Canvas LMS on a daily basis onto an electronic storage medium and shall store all such backups in separate geographic locations. Personal information contained in Canvas LMS is transmitted using secure protocols, on dedicated link, and stored in a secured facility for backup.

Security Breach Response

• Instructure maintains a security incident response plan and a team of personnel trained to identify, investigate, and respond to security issues.
• In the event of a security breach impacting personal information, Instructure will:
  • take immediate steps to remedy the breach;
  • notify the customer as soon as is practicable; and
  • take any other prompt actions towards prevention of any additional security breach.
• In any notification to the customer, Instructure shall, at a minimum:
  • provide a description of the incident, the personal information accessed, the identity of affected third parties, if any, and such other relevant information determined by Instructure, and
  • designate a single individual as a point of contact for the customer.

Third Party Testing

• Instructure contracts annually with a reputable third party security firm to conduct a comprehensive security audit (penetration test and web application vulnerability tests) of Canvas LMS.

Compliance

• Data center providers for the Canvas LMS operations environment maintain an AICPA SOC2 Type 2 report or a successor standard.
• Instructure maintains and follows change management processes. All changes to the Canvas LMS production environment are risk-assessed, logged, and approved. Releases to the Canvas LMS production environment are promoted through a pre-production test environment.
• The Canvas LMS operations environment is separate from the Canvas LMS development and staging environments.
• The Canvas LMS environments are separate from Instructure’s corporate IT environment.
• Logical access to the Canvas LMS infrastructure is restricted using the principles of least privilege and need-to-know.
• Access to all Instructure networks and systems are controlled by an authentication method involving a minimum of a unique user ID/password combination. Privileged users and administrators must use strong authentication.
• Remote network access to Canvas LMS is secured by an authenticated VPN.
• Canvas LMS is hosted in a Tier 3 SOC 2 Type II certified computing facility equipped with fully redundant power backup and fire suppression systems, 24/7 security guards, mantraps, controlled access, biometric authentication, and video surveillance.
• Security relevant events, including login failures, use of privileged accounts, changes to access models or file permissions, modification to installed software, or operating systems, changes to user permissions or privileges or use of any privileged system function, are logged on all systems.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

Instructure (for Mastery Connect)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: Multiple dates depending upon the relevant Services Agreement(s).

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Instructure is providing MasteryConnect which is a software-as-a-service K-12 digital assessment management system. We limit our collection and use of personal information only to those elements required to operate our Products. Please note that if we process your personal information for a purpose other than the purpose for which it was collected, we will provide you with notice in advance of the new processing and obtain consent if required. We do not engage in automatic decision making, advertising to students, or profiling. We use the information described above to provide, analyze, and improve our products, including to:

• Create and maintain your account
• Identify you as a user
• Notate and assign support tickets
• Provide, operate, maintain, and improve our Products
• Personalize and improve your experience
• Contact you and communicate with you, including to respond to your comments or inquiries
• Provide customer support
• Solicit feedback about our Products, including by asking you to respond to surveys or questionnaires (with your permission)

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Instructure takes student privacy seriously. Instructure’s Mastery Connect SaaS product has robust administrative and technical controls to make sure that their information stays private. We've built our operations around international standards such as ISO 27001 and are audited by third parties to make sure that we're actually doing what we say we're doing. We use Amazon Web Services to host our software and they have technical and physical controls designed (and audited) to store everything from students’ homework to top secret documents at the FBI. We take security and privacy seriously and you can learn more at https://www.instructure.com/products/canvas/security

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Internationals Network for Public Schools

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: 7/1/2021 - 6/30/2023

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Internationals Network for Public Schools provides contracted professional development and support services to the 15 NYC-based International High Schools and 1 Middle school that fall under the NYC Department of Education. All services focus on academic success of English Language learners who are enrolled in those schools. Services include workshops, professional development one-on-one and in small groups, curriculum development, working groups, professional learning communities and leadership development and support. Data compiled by Internationals Network for Public Schools are used exclusively for program improvement and support of individual NYC public schools. Internationals Network for Public School does this through the analysis of student enrollment, student attendance, overall GPA, credit accumulation, grade advancement, test scores, graduation rates and discharge rates data. This analysis supports school leaders and educators in the implementation of educational procedures and processes that help advance curricular and instructional goals within our network of schools in NYC with services listed below:

• Professional development with teachers, school leaders, counselors, instructional coaches and parent coordinators
• Strategic data check-ins and inquiry sessions with school leaders.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. All data is kept in password-protected files accessible only by authorized staff members who have been vetted and fingerprinted by the NYCDOE and our organization. At no time will any data be bought, sold or transmitted to vendors for commercial purposes.

Several administrative, technical and physical procedures are used to ensure that Student PII data is protected. For one, the use of data with student identifiers is restricted to staff working directly with that school to support individual students, and whenever possible, aggregated data are preferred to student level data when sharing program data internally. Internationals Network accesses data from NYCDOE ATS/STARS system. Internationals Network stores this data in Google Drive to fulfill the programmatic services. Google Drive is only used to store this data. Data stored is password and access restriction protected. No confidential data may be shared with any personal account. Outside of explicitly utilizing Google Drive for storage, we do not grant access to restricted folders containing student PII, with Google employees. Data stored is password and access restriction protected. No confidential data may be shared with any personal account. Student PII are never shared via email attachments nor via “public to the web" sharing methods. Other physical safeguards are taken regarding Student PII data access by ensuring data is never saved to a personal machine or unauthorized storage device. Furthermore, Virtual Private Networks (VPNs), are used as an additional layer of security if and when needing to access student PII data remotely via a non-INPS and/or Staff secured internet connection. When needed, authorized storage devices are obtained from the technology team. Furthermore, where printouts are made with student PII they are shredded immediately after use.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Intrado (for SchoolMessenger)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Data is stored in School Messenger databases for the express purpose of allowing school and district administrators to contact parents / guardians with helpful information about their student. Lntrado makes no use of the data internally.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor. lntrado's instance of AWS is used to house SchoolMessenger Communicate and lntrado's instances of Microsoft Azure are used to house SchoolMessenger Presence and SchoolMessenger CustomApp.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. All SchoolMessenger solutions are built to adhere to industry and security best practices. All session information (including data exchanges between school/district systems and the Schoo Messenger service) is protected by 256-bit SSL encryption (TLS 1.2). All data is encrypted at rest (using an AES cipher). Further, direct access to the hosts is protected by SSL and SSH and no clear channel connections are allowed. Further, SchoolMessenger separates all customer data into separate logical secure database partitions. Database access requires authorization via a separate authentication server.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

IXL Learning

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII.

• Wyzant: As the largest and most widely used tutoring service in the United States, Wyzant helps learners and administrators get results that matter. Founded in 2005, Wyzant has a community of over 65,000 educators and professionals offering students personalized high-dosage tutoring in more than 300 subjects, including math, English, and science. The Importance of PII for Wyzant is that Student basic information (Name, Grade Level, and/or Class) is needed so that educators can identify specific student data for the purposes of knowing how best to support the student's educational needs.
• IXL Math: NYS Next Generation P-12 Learning Standards aligned. On IXL, students receive the support they need to reach any math milestone. While learning, immediate feedback and step-by-step answer explanations help them quickly understand and correct their mistakes. When students are ready to tackle something new, IXL Recommendations offers personalized skill suggestions that help them strive for mastery, address trouble spots, and more. With IXL, students become active and engaged learners, equipped with the tools they need to excel. The Importance of PII for IXL Math is that individual student Math assignment data collected is under their basic information (Name, Grade Level, and/or Class) so that educators can identify specific student data for the purposes of knowing how best to support the student's educational needs.
• IXL Language Arts: IXL Language Arts is NYS Next Generation P-12 Learning Standards aligned bringing the fundamentals of writing to life in a personalized, engaging environment that features interactive questions, fun visuals, and playful content. Students encounter rigorous questions adapted to their abilities, allowing them to engage with reading comprehension, grammar, word choice, and composition in new and exciting ways. Whether you are teaching students the basics of phonics or helping them understand complex ideas like writing style and tone, IXL supports you. Crucial skills are broken down into adaptive building blocks to ensure understanding and reinforce critical thinking outside of reading instruction. Your students will learn to weigh the subtleties of any text, as well as develop the language mechanics to express their own unique voices. The Importance of PII for IXL Language Arts is that individual student Language Arts assignment data collected is under their basic information (Name, Grade Level, and/or Class) so that educators can identify specific student data for the purposes of knowing how best to support the student's educational needs.
• IXL Science: IXL's in-depth content covers hundreds of skills and is aligned to the Next Generation Science Standards and NYS standards, providing support to teachers for any science curriculum. With compelling, interactive skills, IXL drives mastery of:
  • Physical science: properties of matter, force and motion, energy and heat, atoms and molecules, electricity and magnetism, chemical reactions, waves.
  • Life science: plant and animal systems, genetics, life cycles, ecosystems, traits and adaptations, cells, natural selection, conservation.
  • Earth science: fossils, weather and climate, rocks and minerals, plate tectonics, astronomy, natural resources.
  • Plus science literacy, experimental design, engineering practices, units and measurement, and much, much more! The Importance of PII for IXL Science is that individual student Science assignment data collected is under their basic information (Name, Grade Level, and/or Class) so that educators can identify specific student data for the purposes of knowing how best to support the student's educational needs.
• IXL Social Studies: NYS Next Generation 2-8 Learning Standards aligned. IXL offers crucial tools for understanding history-including primary sources, maps, and data sets-in a fresh, expansive format that ignites students' enthusiasm for social studies. Topics include:
  • Geography: oceans and continents, countries and regions, U.S. states and capitals, letter-number grids, latitude and longitude
  • U.S. history: colonial period, Revolutionary War, Civil War, the Great Depression
  • World history: ancient civilizations, Greece and Rome, Middle Ages, Renaissance, Early Americas, Age of Exploration
  • Civics: the three branches of government, checks and balances, state and local government
  • Economics: natural resources, costs and benefits, supply and demand, trade and specialization
  • Plus economics, historical figures, holidays and cultural celebrations, and much, much more! The Importance of PII for IXL Social Studies is that individual student social studies assignment data collected is under their basic information (Name, Grade Level, and/or Class) so that educators can identify specific student data for the purposes of knowing how best to support the student's educational needs.
• IXL Analytics: IXL's reports are flexible, helping you uncover student data at every level. Get a full overview of school-wide trends, or drill down into grade or classroom level data - and teacher-level insights to assess progress and growth for individual learners. No matter what data you need, IXL's reports enable you to make meaningful decisions in every situation. IXL Analytics are a series of reports educators can run to analyze the progress students are making within IXL as they are working through the subject skill questions that have been assigned to them. These reports aggregate student data showing progress towards grade level standards in Math, ELA, Science, Social Studies and Spanish. Educators can then use this information for targeted instruction, small-group instruction, or one-on-one work with students. What is more, IXL Analytics allows teachers to monitor students' work on a given skill in real time, thus making this formative component an ideal tool for both differentiated instruction. The Importance of PII for IXL Analytics is that Student basic information (Name, Grade Level, and/or Class) is needed so that educators can identify specific student data for the purposes of knowing how best to support the student's educational needs.
• IXL Spanish: With IXL, students build Spanish fluency in a supportive environment that allows them to learn at their own pace. Our skills focus on making learning both purposeful and relevant. Students apply grammar and vocabulary to real-world scenarios and interact with more than 1,000 words in dozens of different contexts. Topics like verb conjugation and prepositions get a fresh spin with interactive question types, fun visuals, and intriguing narratives. We put the joy of learning a new language front and center as students discover a whole new way to communicate. The Importance of PII for Spanish is that individual student Spanish assignment data collected is under their basic information (Name, Grade Level, and/or Class) so that educators can identify specific student data for the purposes of knowing how best to support the student's educational needs.
• Real Time Diagnostic: IXL's Real-Time Diagnostic quickly assesses students' grade-level proficiency, and provides you and your teachers with insights that help you 1) Get data you would normally receive from NYS assessments, 2) Determine student placement in programs, 3) Meet each student's needs with personalized learning plans. IXL Real-Time Diagnostic assesses students across concepts in the K-12 curriculum and delivers up-to-the minute insights on their grade-level proficiency in math and English language arts (ELA). Using these insights, IXL creates personalized action plans that guide every learner to the exact skills that will help them grow. To measure a student's knowledge levels, the Real-Time Diagnostic applies item response theory (IRT) models to estimate the numeric scores for a set of strands (i.e., a broad category of skills). For math, the strands include (a) Numbers & Operations, (b) Algebra & Algebraic Thinking, (c) Fractions, (d) Geometry, (e) Measurement, and (f) Data, Statistics, & Probability. For ELA, the stands include (a) Vocabulary, (b) Grammar & Mechanics, (c) Reading Strategies, and (d) Writing Strategies. The overall diagnostic scores for math and ELA are weighted averages of the strand scores. The Importance of PII for Real Time Diagnostic is that Student basic information (Name, Grade Level, and/or Class) is needed so that educators can identify specific student data for the purposes of knowing how best to support the student's educational needs.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE's option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. Amazon Web Services (AWS} (a cloud hosting and data analytics provide), Century Link (used for telecommunications), Google G Suite (a cloud computing, productivity and collaboration tool} and Salesforce Inc. (a Customer Relationship Management (CRM) Solution); and using an entity-owned and/or internally hosted-solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. We have implemented a variety of physical, administrative and technological safeguards designed to preserve the integrity and security of the personal information we collect and to protect against unauthorized access to data. These include internal reviews of our data collection, storage, and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We restrict access to personal information to IXL employees, contractors, and agents who need to know that information in order to operate, develop, or improve our services. Details are further outlined in our Data Processing Addendum. IXL provides encryption for customer data as follows:

• Network connections to IXL' s production environment utilize Transport Layer Security (TLS) or Secure Shell (SSH);
• All data stored in IXL' s production environment is encrypted at rest using AES-256 bit encryption; and
• All data stored on IXL-owned laptops is encrypted at rest. IXL employs automated log collection and audit trails for production systems.
• Connections originating from untrusted networks segments will be governed by firewall rules and other security safeguards that grant the minimal access required to access the intended service provided by the company.
• System passwords and access keys are stored in a privileged location accessible only to IXL security administrators, and all credentials are changed from factory default settings.
• Production systems receive regular maintenance to apply security patches; and
• Physical access to systems requires security RFID badges and biometric authentication, and is limited to IT staff performing physical maintenance.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

I’RAISE Girls & Boys International Corporation

Type of Entity: Community-Based Organization or Not-for-Profit

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. I’RAISE Mental Health Program provides clinical therapy and mental health services to students in grades K-12. Licensed clinicians and therapists need to have access to student academic records and psychological records (if applicable) in order to provide therapeutic treatment and mental health services to students.

It is necessary for I’RAISE to receive and access student PII for the purposes of conducting counseling services. This type of service requires clinicians to effectively assess and treat participants of the program.

As part of I’RAISE process, our clinicians/therapists collect the following information:

• Student academic records
• Student psychological records maintained by the DOE.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. Amazon Cloud; and using an Entity-owned and/or internally hosted-solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. The agency maintains and stores all student PII information in a manner consistent with the New York Child Data Privacy and Protection Act, S9563. The agency stores all student electronic and physical records in a manner consistent with the Health Insurance Portability and Accountability Act of 1996 (HIPPA).

Physical Safeguards – I’RAISE stores student PII in a locked file cabinet on each school site; this includes student academic, counseling, and psychological records. Only I’RAISE personnel authorized to access student PII has access to these secured filed cabinets onsite.

Technical Safeguards – I’RAISE therapists upload electronic copies of student PII into the company cloud owned by the agency. The cloud is password protected and only authorized personnel (therapists treating students) have access to the student’s PII. The agency has an active business associate agreement with Amazon cloud service which ensures the safe and secure storage of our students PII.

Administrative Safeguards – I’RAISE Clinical Deputy Director is responsible for overseeing and ensuring the safe and secure storage of student records and student PII. The Clinical Deputy Director conducts monthly audits of student PII to ensure all safeguards are in place and to mitigate any potential data privacy and security risks. To mitigate data privacy and security risks, the Clinical Deputy Director trains and manages the authorized personnel (therapists and social workers). Additionally, I’RAISE IT Director conducts monthly security checks of the agency and checks for any potential security and privacy risks. The IT Director works alongside the Clinical Deputy Director to ensure the agency is in compliance with the safe and secure storage of students’ PII in a manner that aligns with the New York City Department of Education.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Jigsaw Learning (for TeachTown)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. TeachTown provides standards-based core curriculum for students with moderate to severe disabilities. The student emails and names are needed in order to make them individual accounts to track progress.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. AWS in the US.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. TeachTown is committed to maintain strong privacy and security protections. The privacy and security of this information is a significant responsibility, and we value the trust of our students, parents, and staff. TeachTown secured a Chief Information Security Officer (CISO) and Chief Data Privacy Officer in 2021. TeachTown’s Privacy Program is responsible for creating, maintaining, communicating, and enforcing a comprehensive privacy control environment to ensure the company meets its legal, contractual and other organizational requirements for Processing Personal Information. TeachTown complies with its responsibilities under all applicable state and federal laws and regulations that protect the confidentiality of personally identifiable information and Student Data, including the Federal Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. 12329(g); Children’s Online Privacy Protection Act (COPPA), 15 U.S.C 6501-6502; Protection of Pupil Rights Amendment (PPRA), 20 U.S.C 1232; and applicable State laws governing the protection of personally identifiable information from students’ educational records (“Student Data”), including New York Education Law Section 2-d and Part 121 of the Commissioner’s Regulation.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

JumpRope

Type of Entity: Commercial Enterprise

Contract/Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. JumpRope collects and processes Protected Information input by NYC DOE teachers and administrators for the exclusive purpose of providing the NYC DOE with the services and support to which NYC DOE has subscribed via the Agreement. NYC DOE determines the type and scope of Protected Information it houses on JumpRope and how such Protected Information is used on JumpRope. JumpRope does not collect any Protected Information directly from the end user. School administrators and teachers may input Protected Information into JumpRope about themselves or about students enrolled with NYC DOE. Examples of Protected Information NYC DOE might input on JumpRope includes student name, birthdate, grade level, home address, and parent or guardian contact information, attendance-related information, student grades, and student-related comments that are associated with grades. NYC DOE may house and process Protected Information on JumpRope in a variety of ways to achieve NYC DOE’s gradebook, curriculum and development goals.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. Amazon Web Services.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. As part of JumpRope’s Information Security Program, JumpRope protects data using a series of industry-standard encryption and data security safeguards. Company policy requires the use of only proven, standard algorithms as the basis for encryption technologies. All keys used for encryption and decryption must meet complexity requirements described under Password Security. The company reviews algorithms, key length, and complexity annually and upgrades as technology allows. Users accessing JumpRope’s information systems must be properly authenticated with a strong encryption method invoked prior to their password being requested. Company policy requires that passwords are never stored online without encryption. All mobile devices containing stored data must use an approved method of encryption to protect data at rest. Laptops must employ full disk encryption with an approved software encryption package. No Protected Information may exist on a laptop in cleartext. Depending on the method of transmission and recipient of the data, Protected Information will be encrypted using appropriate protection methods such as Rights Management Services (RMS) or password protected using strong password methodology and transmitted only via JumpRope devices.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.

Jupiter Ed

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Jupiter Ed is an online Gradebook, Learning Management System (LMS) and Student Information System (SIS). Our LMS includes our gradebook, remote learning features, online assignments and tests, including an online essay grader. There are messages (email and text) and discussion forums for teacher/parent and student communication. The student information system module also includes report cards, transcripts, attendance, discipline records and scheduling. Schools can also select online enrollment and online payment modules. Our products can be used with students from pre-school through high school levels. We also offer both in-person and online teacher and administrator trainings. Schools have the option to enter PII into Jupiter but it is not required. See a detailed list of each module here: https://jupitered.com/modules.php.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will not share PII with subcontractors, outside persons, or third party entities.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using an Entity-owned and/or internally hosted-solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

• Jupiter stores PII on dedicated servers, not shared infrastructure.
• Jupiter encrypts PII in transit using industry standard SSL technology.
• Jupiter encrypts data at rest using industry standard HDD encryption.
• Jupiter employs intrusion detection software to safeguard critical infrastructure.
• Employee access to Jupiter servers is managed via VPN.
• PII is transmitted across infrastructure using encrypted channels, never via “thumb drive”, email, or other insecure method.
• Jupiter uses automated systems to destroy PII when a customer has not renewed their contract. No manual action by staff is required.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

K Systems Solutions

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 10/23/2023 – 10/22/2024

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. KSS will provide a consultant who will be working on The NYC School Transportation Modernization Project as part of OPT operations’ Planning and Innovation team. This project will solve problems for caregivers, students, school administrators, drivers (external stakeholders) and OPT staff (Internal stakeholders). This is an extensive business process reengineering initiative involving change in business processes, use of new products and replacing of old applications.

The consultant will provide deliverables including but not limited to: Managing, monitoring, tracking milestones. Additionally, the consultant will be collecting, maintaining, and revising requirements. Lastly, the consultant will be testing, training, and releasing projects. PII will be obtained and maintained during the requirements gathering process. Also, PII will be accessed during testing and training initiatives. The consultant will also potentially be exposed to PII during various project meetings.

Type of PII that the Entity will receive/access: Student PII. “It’s possible that the Staffing Consultant will also have access to the PII for the following groups: caregivers, students, school administrators, drivers (external stakeholders) and OPT staff (Internal stakeholders).”

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: “The on-site consultant represented by K Systems Solutions will only be accessing data.”

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. No PII will be stored or hosted by Entity.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

• In our policy, we have reiterated that the employees must read and understand the data privacy and procedure in safeguarding all sensitive information in compliance with the US law (see the Information security policy).
• Regular Auditing and Monitoring: Monitor systems and networks for unusual activities or unauthorized access. Regularly review access logs, audit trails, and security alerts to detect and respond to threats.
• All employees undergo mandatory data privacy and security training upon onboarding and annually thereafter. Making data privacy and security training a mandatory component of the onboarding process is crucial to ensure that all employees are equipped with the knowledge and awareness needed to protect sensitive information.
  • All employees must be trained in the following key data privacy regulations: FERPA and NY Education Law 2-d, etc.
  • Employees will be provided with a comprehensive training module that covers key topics such as data classification, access controls, encryption, incident reporting, and compliance with relevant regulations.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “The on-site consultant represented by K Systems Solutions will only be accessing PII.”

Kaplan K-12 Learning Services (for DREAM program)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 1/1/2022 – 12/31/2028

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Kaplan works with the NYC DOE Office of Equity and Access to support the DREAM program, and its students and teachers. For the SHSAT prep program beginning early July 2022, Kaplan will SHSAT prep books, Kaplan SHSAT Practice Test kits and assessment reporting. PII (i.e. OSIS number) will be used for reporting assessment results.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor: Amazon (AWS)

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

• Kaplan will maintain compliance with all state, federal, and local data security and privacy requirements through implementation of security controls governed by an Information Security Management System (ISMS) that is based on ISO 27001 requirements.
• The following security controls, governed by the ISMS, are in place to protect the Pl it will receive under the contract:
  • Strong access controls, including utilization of unique usernames (in this case, the student number), strong password requirements, and requirements for heightened privileges (which are reviewed on a regular basis) to access the backend system for in-scope activities;
  • Protection of data at rest within the AWS environment using best practices encryption standards and algorithms in compliance with ISO 27001 standards. Such data encryption includes use of 2048-bit RSA encryption, utilization of AWS KMS for key management (creation, management, and destruction), and protection of key exchange standard integrity through the use of security certificates created and maintained within the AWS environment using AWS's CMS;
  • Protection of data in transit using similar industry-recognized best practice encryption standards and algorithms in compliance with ISO 27001 standards. This includes strict usage of TLS 1.2 or better with HTTPS. Data that is in transit within Kaplan's environment (e.g., from the AWS instance to Kaplan employees) is protected through use of an encrypted-tunnel VPN;
  • Protection of network and other communication channels through a zero-trust network design with micro-segmentation principles; such design is created through utilization of Zscaler's zero trust network technologies, implementation of advanced firewalls (including web application firewalls and NGFWs), and creation and use of DMZs (using Zscaler's proxying technologies coupled with installed firewalls); Kaplan also requires use of an encrypted-tunnel VPN (AES-256 encrypted P2P tunnel) with MFA for remote access;
  • Physical and environmental controls managed by AWS that are in compliance with ISO 27001, SSAE 18 SOC 2 Type 1 and Type 2, and other industry standard requirements; and
  • Constant vigilance over its systems through use of in-depth logging and monitoring practices, utilities, and software. Kaplan's assets, networks, and users are monitored through collection and analysis of log data in Alertlogic SIEM and other utilities, including Orea, Qualys, and Crowdstrike. Kaplan also uses AlertLogic, Orea, Qualys, and Crowdstrike socs to monitor Kaplan's environment and alert Kaplan's information security teams to potential malicious activity. Alerts from these organizations are reviewed by Kaplan's SecOps team immediately; logs collected are reviewed on a daily basis as well.
• Kaplan's ISMS serves as the framework for implementing security controls that ensures compliance with New York State Education Law§ 2-D and the NYC DOE's Parents' Bill of Rights for Data Privacy and Security. In general, maintaining a data security and information privacy program that is based on ISO 27001 controls ensures that Kaplan maintains compliance with all major international, national, state, and local laws, regulations, and standards. More particularly, the ISMS and associated security controls listed above as well as the further security controls placed on Kaplan's systems, networks, and data ensure that the rights prescribed in the Parents' Bill of Rights for Data Privacy and Security are protected and provided to NYC DOE. Beyond the security controls listed above, Kaplan also maintains a data privacy mailbox through which data access requests can be made. Kaplan privacy officers will review the requests against what is allowed by the Parents' Bill of Rights for Data Privacy and Security as well as what is allowed by New York state law, US federal law, and international law, and provide access, allow for changes and/or deletion, and other activities permitted by these legal and regulatory sources.
• Kaplan's use of AWS and the security controls in place as governed by Kaplan's ISMS allows for continual data backups placed in hot standby for immediate availability within the AWS environment. Snapshots of Kaplan's applications and data are taken throughout the day and stored concurrently in multiple secondary/fallback AWS data center locations. Confidentiality, integrity, and availability are therefore ensured through this backup and immediate availability scheme taken together with Kaplan's access controls, encryption protocols, and other security measures.
• Kaplan requires extensive training for its personnel who will be interacting with or handling in­ scope data or systems. Such training covers, inter alia, the following topics: proper data labeling and handling; proper use of Kaplan assets (including use of Kaplan workstations, remote access to Kaplan's systems, and general acceptable use policies); maintaining compliance with applicable international, national, and local information security, data privacy, and other laws, regulations, industry standards, and contractual obligations. Such training is provided in general form during the onboarding process and thereafter throughout the year in more particular form per subject/topic area, culminating in requirements to retake the general course at the two year mark.
• Kaplan maintains strong access controls on all aspects of its environment and ensures such controls are implemented through a vigorous and well maintained user rights management program. The user rights management program is managed, reviewed, updated, and overseen by an internal Identity and Access Management (1AM) team; the 1AM team is in turn responsible for access provisioning and deprovisioning (implemented through AD/Azure AD), privilege reviews (performed through Archer URM software), and ensuring compliance with Kaplan's strict password requirements, amongst other responsibilities. Of particular note, access to in-scope systems that host client data is tightly controlled by Kaplan's 1AM team, with any provision of access privileges reviewed on at least a quarterly basis for heightened privileges and twice a year for all other access.
• Only a select few organizations, third-party contractors, and subcontractors have access to the in­ scope data. The primary subcontractors that will be used in this relationship are used for hosting purposes and legitimate business, legal, and technical activities within Kaplan's environment. They are contractually restricted from accessing the data without explicit authorization from Kaplan.
• Subcontractors for the in-scope relationship are limited to those used to host Kaplan services (e.g., AWS) and those required for internal critical business functions (e.g., legal, business, and technical activities). They are all contractually restricted from accessing in-scope data without explicit written permission from Kaplan.
• In the event of a data security incident, Kaplan follows an incident management procedure that is part of its ISMS. This procedure includes steps for internal alerts, investigations, remediation, and, importantly, communicating information concerning the breach to affected third parties. Such external communications will be performed at the direction of the Vice President of Information Security and Privacy, or as applicable, the NYC DOE, within the time periods required by applicable laws and regulations.
• Kaplan's systems, ISMS policies and procedures, and security controls are tested multiple times throughout the year through external audits, internal audits, penetration tests, and vulnerability assessments. This includes external audits for ISO 27001 purposes; internal audits for purposes of ISO 27001 certification, PCI and SOX compliance, and sound risk management practices; and penetration tests and vulnerability assessments to identify vulnerabilities in Kaplan's systems and remediate those vulnerabilities immediately.
• Data will either be returned to NYC DOE or permanently deleted in accordance with the Agreement.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Khan Academy

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: Contract Start Date coincides with the start date of the contract entered into by the DOE (or school within the NYC DOE school system) for Khan Academy Districts service and contract expires at the end of the school/school district’s subscription to the Khan Academy Districts service.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Khan Academy is a non-profit organization that provides access to a free website located at http://khanacademy.org and related mobile applications (together “Website”), through which it provides educational services, including, but not limited to, educational content, products, and services (together, the "Services"). The Services include a wide range of content and learning activities, including instructional content and exercises aligned to core curriculum, test practice courses, a personalized learning dashboard, and other learning activities and education programs. Access to the Website and educational content is made available for free. Standard features, including account creation and the ability to assign lessons to and monitor learning progress, are also available for free. Content can be viewed without creating an account; however, for most school use, individual user accounts are created for each individual student, teacher, or other user. The accounts may be used for work in the classroom or for at-home learning.

In addition to free standard features, Khan Academy offers supplemental services to school districts and educational agencies to facilitate implementation by the district or agency, under paid subscriptions. These supplemental services include MAP Accelerator, which uses scores from a standardized assessment (known as MAP Growth scores) and the Khan Academy personalized learning system to give each student custom learning paths, while educators get real-time data to inform instruction. In order to provide MAP Accelerator each student is registered with an individual user account on the Website. In addition to providing personalized learning plans specific to the MAP Accelerator, user accounts provide access to all of Khan Academy's content and standard features.

Khan Academy’s use of personally identifiable information may vary based on the services or programs selected, but generally includes use (i) to provide students with individual Website accounts; (ii) to provide adaptive and/or customized learning features of the Service and educational programs offered through the Service; (iii) to allow teachers and other school personnel, and parents and coaches associated with students, to review and evaluate student educational achievement and progress on the Service; (iv) to provide school personnel with insights regarding student learning and (v) to communicate with users regarding use of the Service and provide information regarding educational and enrichment programs.

Parents may learn more about Khan Academy’s services by viewing our terms of service and privacy policy, each of which are available on the Website. Parents are able to establish parent accounts on the Website and to associate the parent account with their child’s account in order to view their child's progress and assist them with at-home learning.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. Google.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Khan Academy has established technical and administrative safeguards designed to help protect personally identifiable information from unauthorized access, disclosure, use or acquisition by an unauthorized person, including when transmitting and storing such information. A summary of Khan Academy’s security safeguards are set forth below:

Technical Safeguards

• Khan Academy knows that encryption is key to protecting data. We use industry standard encryption technology to protect data transmitted over the internet. The Khan Academy website is hosted on the Google Cloud Platform, and we rely on Google for server and datacenter security. All data on the Google Cloud Platform is encrypted at rest in accordance with Google’s security practices.
• We limit access to data on a need-to-know basis. Khan Academy uses role-based permissions to limit access to sensitive data and systems to our personnel who need it for a legitimate business purpose.
• We follow industry best standard practices in developing our software.
• Laptops provided to our employees for work purposes are managed to ensure that they are properly configured, regularly updated, and tracked. Our default configuration includes full-disk encryption of hard drives, on-device threat detection and reporting capabilities, and lock when idle for a specified amount of time. All laptops are securely wiped before we re-issue or dispose of them.

Administrative Safeguards

• All personnel are required to follow our Information Security Policy, which specifies how we protect data and comply with our security commitments.
• We employ a variety of methods to assess and manage risk, including policies, procedures, and use of industry standard tools to monitor and protect data and systems.
• Khan Academy has established a vendor management program which includes review of the security controls, privacy and data protection policies, and contract terms of our service providers upon initial engagement and periodically thereafter.
• Khan Academy has an incident response plan in place to identify and address any potential data or security incident.

Personnel

• Our employees are required to complete information security awareness training upon hire and periodically thereafter. Personnel are required to acknowledge and agree to our written information security policy and our employee handbook which, among other things, highlights our commitment to keep Student Education Records and confidential information secure.
• Employees that have access to Student Education Records receive training on applicable federal and state privacy laws.
• Khan Academy employees are screened with background checks prior to their employment with us.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

Kiddom

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Kiddom, Inc. is providing a cloud-based software service which enables teachers to instruct students with customizable curriculum served from the Kiddom platform. We receive PII in the form of names and emails during initial setup of class and school rosters, as well as optional guardian/parental names and emails. Our platform also allows students to upload digital files as a part of their school assignments.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. We are signatories of the Student Privacy Pledge, and our processes are subject to our privacy policy . PII is scrubbed from any dataset which is used for internal analysis. All disks are encrypted at rest (AES-256, keys are rotated yearly). All data is encrypted in transit (AES-128, certificates are rotated yearly) and at rest. Files are stored encrypted and are protected by permissioning, accessible only to authorized individuals. We follow the NIST Cybersecurity Framework Version 1.1 best practices.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

Kids Discover

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Kids Discover Online is a web-based application that offers educators and students access to a growing library of over 2,000 engaging science, social studies, and nonfiction articles, at 3 Lexile ® Reading Levels. Educator and Student PII is only needed/used to authenticate access to certain services that Kids Discover Online provides, such as a virtual Classroom, Gradebook, and Individual assigned Reading Levels. Through Kids Discover Online’s Library Media Plan, no Student or Educator PII is collected nor required in order to use or authenticate the services.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. Microsoft Azure.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

• Kids Discover Online requires a minimal amount of student data or teacher or principal data. In some instances, Kids Discover Online may not require the collection of any student data or teacher or principal data whatsoever.
  • Collecting a minimal amount of student data or teacher or principal data is the first step in mitigating cybersecurity risk. This in turn simplifies Kids Discover’s management and protection of such data, and requires less Kids Discover personnel that have (and need) access to such data.
• The Personally Identifiable Information that Kids Discover Online may collect is limited to the following student data or teacher or principal data:
  • Student Data PII
    • First Name and Last Name
  • Teacher or Principal PII
    • First Name and Last Name
    • Email Address
    • Job Title or Role
    • School Building Name and Address, including Zip Code
    • Kids Discover Online explicitly prohibits the collection of any other personally identifiable information for any Teacher or Principal that uses the service.
• Student data or teacher or principal data that is collected by Kids Discover Online and used to provide the services are protected in the following ways:
  • Access to any and all student data or teacher or principal data is limited to authorized Kids Discover personnel, and requires company issued credentials that are updated every 3 months. The number of Kids Discover personnel with authorization is limited to individuals that have received proper training, and fully understand their roles and responsibilities.
    • All authorized personnel have received training from IT professionals and senior executives at Kids Discover.
  • Student data or teacher or principal data that is collected by Kids Discover Online is stored in a cloud managed, enterprise grade Microsoft Azure SQL Server Database. The database utilizes the SHA1 hashing algorithm, with a hash sequence of 160 bits in length.
    • Data is automatically backed up every 24 hours.
    • Database capacity is 250GB, more than double the capacity needed to effectively store and run its contents.
    • Kids Discover Online utilizes three different development environments, including a local environment, staged environment, and production environment for both the database and general code base of the platform. This ensures that any testing, enhancements, bug fixes, data handling and/or data conversions are executed in two different test environments before being executed in a production environment (with live data).
    • Data that has been dormant for 12 months is automatically deleted from the database.
      • Data can be deleted within 24 to 48 hours by written request from any School, School District, Educational Agency, or Customer.
      • Data can be provided and delivered to any School, School District, Educational Agency, or Customer within 24 to 48 hours by written request.
  • Kids Discover Online’s database is virtually managed. Updates and upgrades are performed through Kids Discover’s Microsoft Azure account, utilizing Microsoft Azure’s market leading infrastructure and resources.
• Kids Discover utilizes a suite of tools afforded by Microsoft Azure to monitor, detect, and in turn alert Kids Discover personnel of any anomalous activity.
  • Kids Discover personnel are alerted in real-time to anomalous activity based on predetermined thresholds and triggers. Depending on the nature of the anomalous activity and subsequent alert, Kids Discover personnel are clear in their roles and responsibilities in terms of response time and prioritization.
• Once an anomaly is detected, authorized Kids Discover personnel will conduct an investigation.
• Information is then shared to the appropriate Kids Discover personnel, including Kids Discover Management, to determine the depth and magnitude of any further investigations and potential data recovery procedures needing to be conducted.
• If it is determined that an incident such as a data breach has occurred, and that any data may have been effectively altered or compromised from the resulting incident, Kids Discover personnel will then notify any customers, Schools, or Educational Agencies as defined in this document of the nature of the incident, whose data may have been affected.
  • It is important to note that Kids Discover views all customers as partners and will work diligently to communicate transparently to all stakeholders of any issues or incidents that have arisen.
  • Kids Discover will continue to communicate with any customers, Schools, or Educational Agencies until the issue has been resolved and rectified, and both parties agree about the best possible path forward.

Kids Discover will then work to restore, retrieve, correct, and improve any and all affected data, along with the systems, software, hardware, and general processes that resulted in the situation.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

Kinvolved (KiNVO)

The exclusive purposes for which Protected Information will be used: KiNVO is an app that is used by educators and administrators to inform parents of a student’s attendance. Educators and administrators can also send contacts information relevant to a student’s education, such as homework assignments, school event, and so forth.

How you will ensure that the subcontractors or other authorized persons or entities that you will share the student data or teacher or principal data with, if any, will abide by data protection and security requirements required by your non-disclosure agreement with the NYC DOE:  Kinvolved requires subcontractors or other authorized persons or entities to sign non-disclosure agreements and abide by company-driven privacy and security protocols.

When the non-disclosure agreement with the NYC DOE starts and ends and what happens to Protected Information upon expiration of the agreement: PISI is permanently deleted from Kinvoled’s database, Kinvolved does not maintain a record of PISI. Note: Data may exist in backups for a period of 35 days after the data is deleted from the database. [NYC DOE comment: The current agreement became effective starting on August 22, 2019 and terminates when all NYC DOE schools and/or offices cease using Kinvolved, Inc.’s products/services. The terms of the agreement remain effective through the period during which Kinvolved, Inc. possesses or otherwise is in control of covered protected information.]

If and how a parent, student, eligible student, teacher or principal may challenge the accuracy of the student data or teacher or principal data that is collected: Pursuant to its contractual obligations, the Recipient will work with the NYC DOE in processing challenges to the accuracy of student data and the custody of the Recipient. [NYC DOE comment: requests for copies of student data or to challenge the accuracy such data should be directed to your child’s school, or to studentprivacy@schools.nyc.gov.] 

Whether the Protected Information will be stored in the US or outside of the US (and if outside of the US, where), and the security protections taken to ensure such data will be protected (described in such a manner as to protect data security): PISI is stored in the United States.

How the data will be encrypted (described in such a manner as to protect data security): Data is encrypted in transit and at rest.

KiwiWrite Software (for KiwiWrite Math)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. KiwiWrite Software, LLC provides a web-based application named KiwiWrite Math, which provides to select students with specific need an online platform to act as an alternate means of entering and completing math or math-containing classwork or assessments. Minimal PII will be accessed that is needed to create and maintain student accounts.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e., AWS.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Physical safeguards are provided by AWS, our cloud provider. We do not store PII in any location except in our encrypted database on the cloud. Administrative safeguards to protect data include limiting access to a minimal number of authorized personnel who have a legitimate need for such access, and requiring confidentiality agreements for any personnel with access. Test environments do not use student data and have separate security keys. Technical safeguards include encryption of data in transit and storage, access controls, and implementing regular and encrypted backups.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

KneoWorld, Inc.

KPMG LLP 

Kweller Prep Tutoring and Educational Services

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 6/1/2023 – 5/31/2028

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. As a tutoring business, it is necessary for our Entity to receive and access Personally Identifiable Information (PII) of students to conduct its services. Our Entity needs this information to provide personalized and effective tutoring services to students. This information may include the student's name, age, grade level, academic performance, learning style, and any relevant medical or behavioral information.

Our Entity may also collect contact information such as email addresses, phone numbers, and addresses to communicate with students and their parents or guardians regarding tutoring sessions and scheduling.

It is essential for our Entity to maintain the confidentiality and security of the PII it collects, uses, and discloses. The Entity must comply with applicable data privacy laws and regulations governing the collection, use, and disclosure of PII, such as the Family Educational Rights and Privacy Act (FERPA) in the United States.

Our Entity will also implement appropriate safeguards to protect the confidentiality, integrity, and availability of the PII, such as secure storage, access controls, and encryption. Our Entity will also provide training to its tutors and employees on the proper handling of PII to prevent data breaches and maintain the privacy and security of its students' information.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; and using an Entity-owned and/or internally hosted-solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Kweller Prep will ensure that only individuals who will be working on a project that needs PII information will be allowed to use a PII machine.

• Machines accessing PII information will be allocated strictly for the use of accessing PII data.
• Information is protected by strong passwords, which include characters or more and a combination of numbers, uppercase and lowercase letters, and special symbols.
• A screen lock will be implemented on dedicated PII machines. The screen lock will be set to turn on within 5 minutes of inactivity.
• Breaches will be immediately brought to the attention of Kweller Prep’s Executive Director and technology security specialist. Our technology security specialist will then immediately evaluate and determine the extent and severity of the breach. Upon summarizing findings (no later than 1 day upon learning of the incident), we will report the incident to the appropriate NYC DOE department.
• PII will not be stored on personal computers.
• PII will not be stored on public computers.
• Kweller Prep will make every attempt possible to only store PII data on encrypted servers and not on locally encrypted computers.
• PII data will only be used, seen, or shared with people to fulfill the duties associated with the particular PII.
• PII data will not be left open on a screen when it’s not in use.
• Physical PII data (papers) will not be left unattended.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

L&G Research and Evaluation Consulting

Type of Entity: Research Institution or Evaluator

Contract / Agreement Term: 3/1/2023 – 2/28/2028

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. L&G Research and Evaluation Consulting, Inc. (L&G) is contracted to conduct an implementation and outcome evaluation of the 21^st Century Community Learning Centers grant awarded to the New York City Department of Education from July 1, 2022 until June 30, 2027. Our L&G team will support efforts to gain a better understanding of the value of grant-funded activities in meeting the needs of students and their families. This program, funded through a five-year federal grant administered by the NY State Education Department, is intended to offer much needed enrichment and educational supports to target students. In full compliance with the Request for Proposal (RFP) stipulations, L&G developed a meaningful and cohesive evaluation plan that can move the work forward towards meaningful, aligned results in the future.

Our implementation and outcome evaluation plan includes a mixed method qualitative and quantitative research design. We offer assistance with ensuring clients adhere to all state and federal reporting requirements. This typically involves the following: 1) development of program logic models; 2) assessment of program evaluability (Year 1 only); 3) site visits and program observations; 4) development and administration of surveys in fall and spring; 5) attendance and observation of advisory board meetings; 6) EZReports data management and generation of weekly data compliance repots, mid-year and final reporting, and 7) State monitoring visit support as needed. We offer ongoing quality control and technical assistance for all data collection, storage, monitoring and reporting. We work very closely with our schools to provide services that are research-based and support the program goals/objectives as determined by the core leaders.

All student, parent, and teacher data collected during the five years will be used exclusively to assess grant performance, improve program implementation, and support the NYC DOE with the meeting of grant goals and objectives. No other data other than what is required by NYSED and stipulated in the RFP will be collected during the life of the grant.

Type of PII that the Entity will receive/access: Student PII, APPR PII (Identifiable Teacher or Principal Annual Professional Performance Review Data), and Parent and Family Member PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will not share PII with subcontractors, outside persons, or third party entities.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using an Entity-owned and/or internally hosted-solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. L&G’s data storage plan addresses what gets stored, the location, when storage activities occur, who is responsible for management, how much data an organization stores, what it retains and destroys, and how storage takes place. Our plan ensures both the security and availability of the data.

Data storage can be electronic or nonelectronic formats (such as paper surveys), including data files and databases. Nonelectronic data is stored in locked cabinets at the L&G main office located at 55 Broadway, Suit 416, New York, NY 10006. The locker combination is only stored with tram members involved in entering the survey data into the computer. For electronic data storage, L&G uses password protected computers. The password is changed every 30 days and is only accessible to L&G staff members responsible for analyzing the data. Data storage requirements are thoroughly discussed with L&G staff both during onboarding of new staff and ongoing during annual retreats to ensure compliance with our internal data storage plan that protects confidentiality and safety of PII.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

Lakeshore Learning Materials (for SANDI/FAST)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 08/2022 – 07/2027

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. The SANDI/FAST is an online assessment designed to assess and monitor students with moderate to severe cognitive and low incidence disabilities. It is aligned with Common Core Learning Standards and includes subtests in English Language Arts, Math, Science, Social Emotional/Behavioral, Vocational/Transition-Education/Employment, and Vocational/Transition-Community. The SANDI-FAST also assesses student skills in Fine Motor, Gross Motor and Adaptive Daily Living. The SANDI-FAST is a performance based, periodic assessment aligned to grade-level Common Core State Standards (CCSS). The SANDI provides summative assessment data and measures academic growth over time. The FAST is a short-cycle benchmark assessment administered two times throughout the school year to target four essential standards at three levels. The SANDI provides a summative assessment that goes deeper than other tools into student learning and maintains a focus on individual student need, not just proficiency levels. Formative assessment (FAST) is based on the SANDI and administered as a part of the continuous progress monitoring of the pre/post and interim assessment opportunities built into the system. Student need areas are assessed and then aligned to grade level content standards, giving all students access to a rigorous and relevant education.

Type of PII that the Entity will receive/access: Student PII and Other: For each user (teacher, service provider, administrator) we collect their name and email address, and they are connected through the SANDI/FAST system to their assigned school and class, if applicable.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities (including any cloud services providers) and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the Entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Vendor selected “Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. Amazon Web Services.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. All access to the SANDI/FAST for NYCDOE personnel is managed directly by NYCDOE. This includes both provisioning user accounts with the appropriate role and authenticating accounts into the system. All outside access to the SANDI/FAST system is restricted to necessary personnel for the sole purpose of supporting the SANDI/FAST system and NYCDOE users. Multi‐factor authentication is implemented for all of the accounts used by the necessary personnel All application servers and workstations have anti‐virus and anti‐malware software for detecting malicious threats. A threat detection service is utilized to continuously monitor for malicious activity and deliver detailed security findings for visibility and remediation. All communication between the end user and the SANDI/FAST Online is encrypted. All confidential information is encrypted in transit and at rest.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

LAZEL (also called Learning A-Z)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 2/1/2023 – 1/31/2030

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII.

• Foundations A‐Z, Grade Level K‐5; Foundations A‐Z (NYC) (1 educator–12‐month license). Built on the Science of Reading, Foundations A‐Z is an online, K‐5 literacy program that empowers educators to teach foundational skills and inspires students with fun, purposeful practice.
• Raz‐Plus, Grade Level K‐5; Raz‐Plus (NYC) (1 educator–12‐month license) combines the power of Reading A‐Z and Raz‐Kids to delivers a vast collection of flexible ELA instructional resources, assessment, and engaging student reading practice to support differentiated instruction.
• Reading A‐Z, Grade Level PreK‐5; Reading A‐Z (NYC) (1 educator–12‐month license) includes a vast collection of printable and presentable reading resources, including grade‐level texts, lesson plans, and teaching materials, for whole‐class, small‐group, and one‐to‐one instruction.
• Raz‐Kids, Grade Level PreK‐5; Raz‐Kids (NYC) (1 educator–12‐month license) supports independent reading practice with a library of differentiated, interactive digital books and eQuizzes across grades K‐5.
• Raz‐Plus ELL, Grade Level K‐5; Raz‐Plus ELL (NYC) (1 educator–12‐month license) expands Raz‐Plus with a deep library of specialized literacy resources to support speaking, listening, writing, and reading for English language learners. Purchase of Raz‐Plus is required. (Requires Raz‐Plus.)
• Raz‐Plus Español, Grade Level K‐5; Raz‐Plus Español (NYC) (1 educator–12‐month license) is an add‐on component to Raz‐Plus that supports Spanish literacy with hundreds of authentic Spanish texts and transadapted instructional resources. Purchase of Raz‐Plus is required. (Requires Raz‐Plus.)
• Raz‐Plus Connected Classroom, Grade Level K‐5; Raz‐Plus Connected Classroom (NYC) (1 educator–12‐month license) expands Raz‐Plus with tools and resources designed to help educators create personalized, student centered learning paths for students in Grades K‐5. Purchase of Raz‐Plus is required. (Requires Raz‐Plus.)
• Vocabulary A–Z, Grade Level K‐5; Vocabulary A–Z (NYC) (1 educator–12‐month license) personalizes vocabulary instruction with an expansive online word bank used to create explicit vocabulary lessons and game‐based online practice.
• Science A‐Z, Grade Level K‐6; Science A‐Z (NYC) (1 educator–12‐month license) blends science and literacy into a captivating K‐6 curriculum. The program delivers thousands of resources including a library of English and Spanish text, science experiments, and hands‐on activities.
• Writing A‐Z, Grade Level K‐6; Writing A‐Z (NYC) (1 educator–12‐month license) is a supplemental writing solution that develops fluent, enthusiastic writers with explicit writing instruction, a fun online writing platform, and game‐based practice, for grades K‐5.
• Online Professional Development Webinar ‐ 1 hour: This online training session helps educators leverage the resources and tools available in each Learning A‐Z solution.
• Online Professional Development Workshop ‐ 6 hours: This online workshop, which is tailored to meet each school’s unique needs, helps teachers dig deeper into Learning A‐Z.

Learning A‐Z provides e-learning tools and resources. Our resources include lesson plans, classroom activities, and assessments, as well as thousands of grade‐level text and materials, and professional learning services. All content is delivered online in printable, projectable, and interactive digital formats, supporting whole‐class, small‐group, one-to‐one, and independent learning environments.

Only the data provided by the DOE is collected. DOE entered data is then available for the use of DOE educators and administrators as permissioned.

Certain activities on certain services allow children to create or manipulate content and save it on our services. Some of these activities do not require children to provide any personal information. If a service requests or allows a child to provide personal information in their created content, we will seek prior verifiable parental consent to collect that information. Examples of created content that constitute or may include Personal Information include the following:

• Student voice recordings: Children may record themselves reading texts, they may play the recordings back, and they may send the recordings to their teachers.
• Open‐text fields: Children may draft and submit written responses to various prompts
• Message sent to students by parents or teachers

Additional educational information is collected as the child progresses through the service, such as amount of time logged in, reading rate, and assessment scores. This information allows the service to adapt to the child and inform the teacher on the child’s progress.

Type of PII that the Entity will receive/access: Student PII

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities (including any cloud services providers) and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using an Entity-owned and/or internally hosted-solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. We maintain administrative, technical and physical safeguards designed to secure student data, as provided by NYC DOE, both during transmission and while in our custody. These safeguards include technical and operational measures, such as firewalls, routers, encryption (at rest and in‐transit), passwords, and vulnerability testing, as well as training, policies and procedures to limit access to NYC DOE provided data to authorized staff, contractors and agents that have a legitimate need to access such data for purposes of enabling us to deliver and support our products and services to the NYC DOE, and that are under appropriate contractual obligations of confidentiality, data protection and security.

No student PII is ever public. Our applications are designed to keep this information private and secure. It is never discoverable by the public.

• The Company has a formal onboarding and off‐boarding procedure where access to database assets are formally granted and revoked respectively; access is only granted to employees who need access to support the online products as we ascribe to the principle of least privilege.
• The Company provides student data privacy training to all employees and contractors who access our network.

The Company employs a 3rd party company to conduct both COPPA and FERPA compliance audits.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

The Leadership Program

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: 7/1/2022 – 6/30/2024

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. The Leadership Program provides the following services:

• Student In-Class and After School SEL (Social Emotional Learning)-based services both grant funded and directly purchase by schools in youth development, violence prevention, and mentoring.
• Professional Development services on a wide range of SEL-based topics including Embedding SEL practices in the classroom, Engaging Youth, Building Parent Relationships, Creating a Positive Classroom Culture, and Trauma Awareness.
• Parent Workshops on a wide range of SEL-based topics including Parenting Skills, Building a Relationship with Your Child’s Teacher, Supporting Your Child’s Academic Success, Financial Planning for College, and Family Healthy Lifestyle

In providing student support services, The Leadership Program is required to provide rosters and attendance sheets for students attending workshops that include student name, grade, and school for in-class workshops, for after school workshops we are required to utilize attendance sheets with student names and school and NYCDOE created registration forms that require the students’ name, school, address, parent names, parent phone numbers.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will not share PII with subcontractors, outside persons, or third party entities.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the Entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Vendor selected “Using a cloud or infrastructure owned tool hosted by a subcontractor.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

Implementation of Data Security and Privacy Contract Requirements

• The Director of Operations will keep abreast of current Data Privacy and Security regulations, policies, and procedures, will adapt organization policies as appropriate to adhere to those standards, and in collaboration with the Director of Programming will train organization employees on procedures to ensure data privacy and security.
• In order to ensure cyber safety, TLP utilizes an IT vendor, Altourage, who on an ongoing basis will conduct cyber risk assessment and monitoring, inform the organization of all current and relevant federal and NY state regulations regarding Data Privacy and Security, and advise measures and policies to comply, and provides staff training in cybersecurity and data privacy. Altourage does not provide any services to our clients, nor do they have access to client records or information.
• All employees are provided with the standards of data privacy and security required by law and are required to understand the applicable policies and procedures.

Administrative, Operational and Technical Safeguards and Practices

• Employee agreements require that employees align with the security requirements of any projects undertaken.
• TLP files and software are protected by a Smart Firewall and anti-virus and anti- malware software.
• Information that identified as PII is kept in separate files that are encrypted and password protected. Physical copies are kept in locked files.
• Access to PII permissions and authorizations are managed: only persons with a direct need-to-know will be given access to PII information and only while it is needed.
• User identities and credentials are issued, managed, verified, revoked, and audited for authorized devices, users, and processes
• User passwords will be changed at least every 120 days and must contain a complex mix of characters.
• Physical access to equipment and hard copy PII files are managed and protected through the above-mentioned practices 1-4; all files containing PII are stored in designated, encrypted folders and/or password protected.
• Remote access is managed through items II 1-4
• Once documents have been used for their intended purpose they will be securely deleted.
• Authentication for users, devices, and other assets are established for access to PII.

Training of Regulations and Procedures

• Employees with access to PII are provided with and are required to be familiar and understand all Data Security and Privacy policies and procedures.
• TLP will provide compliance training online and in person to employees with access to PII, who are required to attend. Ongoing training on cybersecurity is provided by Altourage through short online instructional videos with tests that employees are required to take.
• Supervisors will coach and monitor subordinates with access to PII to ensure they follow policies and procedures.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Learn by Doing (also called Albert or Albert.io)

Type of Entity: Commercial Enterprise

Contract/Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Albert.io offers curriculum supplements for grades 5-12. It focuses on interactive learning. Specifically, expertly created practice questions with explanations for core curriculum classes and test prep.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. Google Cloud and Amazon Web Services.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Albert.io is committed to maintaining the security and confidentiality of Student Information. It has designated a Security Compliance Officer (SCO), who is responsible for: (a) ensuring that the Company’s servers are protected against unauthorized access to the greatest degree possible; (b) limiting employee access to Student Information to whatever extent is required for them to perform their job functions; and (c) regularly training employees in data security procedures to further ensure compliance with company data security policies.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology."

LearnerPal

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. LearnerPal provides teachers and students with out of the box content in the form of questions, answers, and videos to create and assign learning activities, or assessments. Teachers can add to the content library, or simply select from premade activities to assign to their students to engage, enhance or assess their daily classroom learning. PII is needed for creating student logins and assigning tasks.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. Amazon Web Services.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. LearnerPal maintains an audit trail of all data that is sent to the system. All user access and events are tracked and no resource has access to the data storage in order to preserve the integrity of the data. All information is stored in AWS and is encrypted at rest and in transit. The data never leaves AWS and is not accessible to anyone in LearnerPal or outside the school users. All users have to authenticate into the system and based on their access privileges, can access only the data for their school.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

The Learning Internet (also called Learning.com)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Learning.com collects the minimum student data required in order to connect teachers and students with our K-12 digital skills online curriculum. This includes providing teacher facilitation tools to support instruction and practice of those digital skills. Specific fields we collect and how we use them are detailed in our publicly posted Subscriber Privacy Policy at https://www.learning.com/subscriber-privacy-policy/.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities (including any cloud services providers) and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. AWS.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. The security of your data is of utmost importance to us. We employ industry best practices with respect to personnel and technology to minimize risks of unauthorized access or misuse of PII. We conduct background checks during our recruiting and hiring process to ensure good stewardship of your data. All personnel must complete annual security training that includes guidance on safe handling of data and a review of responsibilities under applicable laws and contracts. We limit access to PII to those who require it in service of our educational purpose. We secure your data by various technologic means, such as firewalls, monitoring, and vulnerability scans to minimize the changes of a breach. Our servers are all physically located within the United States using secure AWS cloud services. All data transmitted between your devise and our servers uses industry standard SSL encryption. All data in our custody is stored using FIPS compliant encryption. We employ an independent firm to conduct penetration testing of our systems, keep up to date with all security patches and software versions, and are vigilant about mitigating any newly discovered vulnerabilities. Our comprehensive security program implements a security in depth methodology by addressing security on every level to ensure information is protected in the event any one layer is compromised. Internal policies and procedures are aligned with NIST 800-53 and all stored data is encrypted.

User accounts are required to access our services and use role-based access to ensure only authorized data can be accessed. You are the only person who can log in with your account and access your data. Learning.com will never ask you for your password and you should never give it to anyone. Ultimately, you are responsible for maintaining the secrecy of your password. Also remember to sign out properly and close your browser window when you have finished using our service. This helps ensure your information remains secure in the event the computer you used is physically accessible to others. 

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

LES Global

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 7/1/2022 – 6/30/2024

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. LES GLOBAL, LLC (L.E.S) provides crisis prevention services to underserved families, over aged & under credited students experiencing social and emotional hardships and at- risk of not graduating high school. We support Schools and Communities and their scholars who struggle to meet NYC educational requirements, for schools’ promotion and or graduation by utilizing our ROADS Logic Model: Removing Obstacles Achieving Dreams. The ROADS Program handholds students struggling to complete work or get to school on time while communicating with teachers to ensure work is complete, we initiate transfers to more suitable schools in the best interest of the student and we also locate missing students who don’t come to school in hopes of getting them back into an educational setting.

Our trained staff, advocates and social workers must access PII information in order to comply with transferring of students for the R2A program. Students’ records, grades, IEP information, parent contact information, attendance reports and Record for Graduation Certification of Students (RGCS) Report in order to create an individual educational plan for each student. The student’s information and graduation reports are used to identify the number of credits they currently have, how long it took them to get them, how many they need to graduate, if they will age out of high school before classes are complete, to determine a suitable alternative educational solution, to understand the students struggles and be able to advocate on their behalf and to their parents and to compare it to their transcripts. All DOE transfer schools require students’ records be printed and provided before students can be accepted into their schools. Student records such as Immunizations must be provided to the schools by the students’ parents but are also required for acceptance into programs. Some students in the ROADS program can retake classes and receive tutoring which leads to graduation while others require transfer to alternative schools more suitable and then we have displaced students we find across the country that we enter into a new educational program. Students and families have access to our social workers as well, in order for social and emotional support to be successful, these professionals must access records in order to properly assist these families. Ultimately, we do whatever is necessary to assist the underserved students to be successful too and through high school.

All PII data requested is a requirement of the DOE transfer process or is necessary to make an alternate & individualized plan for a student to promote the best graduation outcome. Data/reports required as follows:

Transcripts/grades: Used in all LES ROADS to determine a students alternative learning approach and approach to graduation success. Transcripts shows the types and levels of classes a student took from grades 9 through 12 and also shows how many pass/fail classes a student took and may include any courses a student dropped or failed to complete.

Individualized Education Program (IEP): An IEP lays out the special education instruction, supports, and services a student needs to thrive in school. This information is used for students with IEPs only to ensure a student is receiving full accommodations necessary.

Parent/Guardian Contact Information: LES uses this contact information to gain permission for students under 18 to get services from LES. This information is also used to locate missing students and make house calls as part of the ROADS Road to Dropout Prevention Program. This is used in ALL ROADS Programs as parents must remain apart of the students individualized plan.

Attendance Reports: Reviewing these reports allows staff to determine the type of school suitable for a student. Due to various personal needs some students require a school setting in the evening, or one with job/school combos or even online schools. This allows individualized plans based on family needs. Used in all ROADS Programs.

Record for Graduation Certification of Students Report (RGCS): This report sums up a students ability to graduate, if they are about to age out of school and tracks their high schools success and failures. Used in all ROADS Programs.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the Entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Vendor selected “Using a cloud or infrastructure owned tool hosted by a subcontractor.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. LES considers security of PII to be of utmost importance. We safeguard PII through a combination of policies, procedures, training, segregation of duties and robust systems, security and technology. We mitigate data privacy and security risks by following and adhering to industry protocols, standards and practices, employing up to date technology, training and segregation of duties and user access controls. We also perform background checks on our employees, encryption of confidential information in transit and at rest, and limiting user access to confidential information based on role.

• LES uses Google workspace: A cloud-first, browser-based approach that is constantly updated – no need for local devices, native apps, or email attachments. It has built in controls, encryption, and verification with a Zero Trust approach that enables employees to work from anywhere and eliminates the need for VPNs.
• Email: PII information is never shared via email. We use the workspace to share information within the organization only.
• Computers: Are password protected and remain at DOE schools.
• Data Security Training: All staff must take yearly training on Data Security
• Staff: Access to PII information can be eliminated at any time with the click of a button by management for any reason.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Lexia Learning Systems

Lexia Voyager Sopris (formerly Voyager Sopris Learning)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 5/01/2021 – 6/30/2028

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Lexia Voyager Sopris Inc. provides online and print professional development, assessment and educational curricula for students including the following programs:

• Vmath: This program is a targeted math intervention program for struggling students in grades 2–8 that provides additional opportunities to master critical math concepts and skills.
• Vmath Live: This program empowers students in grades K–8 to master math content at their own pace in a motivating online environment.
• LANGUAGE! Live: This program provides foundational and advanced reading intervention including peer-to-peer instruction; for Grades 5–12.
• eSolution: This supplemental program extends timed, paired readings to include complete online vocabulary expansion and comprehension lessons.
• TransMath: This program is a comprehensive math intervention curriculum that targets middle and high school students who lack the foundational skills necessary for entry into algebra and/or who are two or more years below grade level in math.
• REWARDS: This program provides blended reading and comprehension intervention for Grades 4-12 with goals to increase fluency rates, deepen comprehension of informational and content-area texts, and increase precision in sentence writing.
• Step Up to Writing: This comprehensive K-12 program offers multisensory writing strategies that develop ability to create thoughtful, well-written compositions across all content areas.
• LETRS: The LETRS® (Language Essentials for Teachers of Reading and Spelling) Suite is professional learning that provides educators and administrators with deep knowledge to be literacy and language experts in the science of reading. LETRS teaches the skills needed to master the fundamentals of reading instruction—phonological awareness, phonics, fluency, vocabulary, comprehension, writing, and language.
• Voyager Passport: This program provides blended literacy intervention for Grades K-5.
• Reading Rangers: This program provides online reading practice for Grades K-5.
• Only a minimum amount of personally identifiable student data required for the setup of the system is requested. We require student first name, student last name, and student identification number.

Additional data, not specific to the student, is also required to complete system setup, including the teacher first and last name, class name, grade level, and school name. Student demographic data, for the purposes of optional disaggregated reporting, is requested separately from the initial setup data and is obtained only with written permission from your district. This information is not shared and is used to track student progress and achievement within the proposed solution.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities (including any cloud services providers) and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Vendor selected “Using an Entity-owned and/or internally hosted-solution.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. We maintain administrative, technical and physical safeguards designed to secure student data, as provided by NYC DOE, both during transmission and while in our custody. These safeguards include technical and operational measures, such as firewalls, routers, encryption (at rest and in‐transit), passwords, and vulnerability testing, as well as training, policies and procedures to limit access to NYC DOE provided data to authorized staff, contractors and agents that have a legitimate need to access such data for purposes of enabling us to deliver and support our products and services to the NYC DOE, and that are under appropriate contractual obligations of confidentiality, data protection and security.

No student PII is ever public. Our applications are designed to keep this information private and secure. It is never discoverable by the public.

• Voyager Sopris is ISO-27001 certified.
• The Company has a formal onboarding and off-boarding procedure where access to database assets are formally granted and revoked respectively; access is only granted to employees who need access to support the online products as we ascribe to the principle of least privilege.
• The Company provides student data privacy training to all employees and contractors who access our network.
• The Company employs a 3rd party company to conduct both COPPA and FERPA compliance audits.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

LibraryPass

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. To enable authentication of a student and to provide access to the Comics Plus service.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. Amazon Web Services.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Library Pass takes security measures very seriously. Security is broken up into two separate sections.

Policies and Procedures - LibraryPass currently has security policies and procedures for each of the following areas:

• Access Control
• Audi and Event Logging
• Cloud and Network Security
• Data Backup and Restoration
• Data Protection and Encryption
• Incident Response
• Password Management
• Software Development
• Website and Software

These policies allow LibraryPass to monitor and manage all users with internal access as well as update security access as needed.

Technical

• Network Security
  • User Access
    • IAM Access Keys are used with specific IAM roles defined to limit access to different AWS resources
    • Password are rotated every 90 days
    • VPC and Security Groups
    • Server access is limited to security group access even to each other and DB
    • All servers are on different VPC networks depending on functionality.
  • Firewall
    • Web Application Firewall for AWS to have firewall and bot detection
    • IP2 Location
    • IP2 Location services for routing of traffic to specific security protocols.
• Content Security
  • Streaming
    • We use end to end encryption when transmitting any data to/from the client and our servers in the form of SHA256 RSA encryption and validated with an SSL certificate.
    • Users are authenticated using different authentication methods set up per the institution's specific requirements. Passwords stored in our database are hashed using a strong one-way hashing algorithm with a random salt per user.
    • All API communication uses a combination public and private key for validating access to protected data. The keys are encrypted along with unique user information and encrypted with SHA256. Keys are rotated every 6 months and kept in private environment files on the servers only.
    • URLs and API calls for the pages data is tied to the logged in user with secure keys and server side sessions. API calls are also time based so they expire after a short period of time.
    • The data for pages (URL or Image Data) is never added into the HTML DOM so users are not able to just view the source or easily grab the list of URLs for the images/pages that are displayed.
    • Once Image files are loaded into the browser’s memory, they are drawn into an HTML5 canvas which eliminates the ability for users to simply copy the image from the context menu (right-click).
  • Download for offline reading
    • We use end to end encryption when transmitting any data to/from the client and our servers in the form of SHA256 RSA encryption and validated with an SSL certificate.
    • We have a proprietary file format named CB files.
    • Our CB files implore an unpublished file/data format that contains image data, indexing information and other metadata.
    • The content in the file is secured with a unique hash that needs to be validated before content can be read. The unique hash is a combination of file metadata and user information.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

LightSail

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 7/1/2022 – 6/30/2023

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. To fulfill the services requested by NYC DOE. Specifically to provide to schools LightSail’s Online literacy platform providing initial and ongoing Lexile and standards aligned assessment, full book/novel reading experience, accommodations for struggling readers and data and reporting on reading performance and engagement. The platform comprises a patented educational e-reader and an adaptive e-book library.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “will not share PII with subcontractors, outside persons, or third party entities.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Entity selected “Using a cloud or infrastructure owned tool hosted by a subtractor, i.e. Microsoft Azure Cloud.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Here is a summary of controls in place:

• Information Security Governance
  • A comprehensive set of Information Security Policies
  • A governance structure with defined roles and responsibilities
  • Periodic security assessments (internal/ external)
• Operational Security
  • Role-based access controls following the least privileged principal
  • Strict password controls with multi-factor authentication
  • Incident management for responding to and containing incidents
  • Backups and disaster recovery plans for resilience
  • Physical security for accessing corporate assets/ facilities
  • Comprehensive vulnerability management program with automated assessments
  • Secure system development approach with OWASP compliance
  • Centralized logging and monitoring with automated alerts
  • Network segmentation with firewall protection
• Data Security
  • Data classification scheme
  • Data encryption at rest with AES256bit or higher keys and in transit using TLS 1.2or higher
  • Data retention schedules
• People Security
  • Background checks and code of conduct acceptance before employment
  • Continuous security awareness training
  • Employment termination/ change of responsibilities processes

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Lilo Consulting (also called Sync Grades)

Type of Entity: Commercial Enterprise

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Sync Grades is a software service, providing schools with a dynamic platform to track student attendance and other related and approved data over different periods in time.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities (including any cloud services providers) and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201

Security and Storage Protections. Describe where PII will be stored or hosted. Vendor selected “Using a cloud or infrastructure owned tool hosted by a subcontractor.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

• The Sync Grades platform is hosted by Amazon Web Services (AWS). AWS facilities are guarded by professional security staff utilizing video surveillance, intrusion detection systems, and other electronic means. Electronic intrusion detection systems are installed within the data layer to monitor, detect, and automatically alert appropriate personnel of security incidents. Ingress and egress points to server rooms are secured with devices that require each individual to provide multi-factor authentication before granting entry or exit.
• Access to Sync Grades servers and hosting services is controlled by a two-factor authentication, and only accessible using a secure VPN.
• Sync Grades requires passwords to have a minimum 8 characters, must contain alpha, numeric and punctuation. Active monitoring will deny access after multiple failed attempts (firewall and account suspension).
• Sync Grades operational access requires 2-factor authentication (ssh-keypair and generated PIN from restricted VPN and IP points).
• Sync Grades utilizes a centralized secure management system of all users and access levels.
• Each system monitors all data transports, which are encrypted either via SSL/TLS or SSH within a VPN based environment. The primary service request are signed with an HMAC-SHA1 signature, which measures, monitors, and calculates from the request and the user’s privacy key.
• The system will log all inboard and outboard requests, which are executed at the network, application, and persistence layers. This encompasses, but is not limited to os syslog, application logs, HIDS, and database calls both within and outside the Sync Grades VPN.
• The Sync Grades configuration build and system provisioning is executed through version control and a centralized build configuration management tool. The system requires authentication and records the audit log of all infrastructure changes including but not limited to:
  • VM provisioning
  • package versions, identification and installation
  • input and configuration settings
  • application version deployment
  • network segment deployment

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Limosys

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 7/1/2023 – 6/30/2027

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Payment Accounts for Rideshare Services where we will provide ground transportation services.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: “Will follow NYCDOE instructions. We can do both [securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII].” In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. AWS; and using an Entity-owned and/or internally hosted-solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. All personally identifiable information (PII) collected will reside in an Amazon secured data structure, encrypted and/or tokenized. PII is separated into components that can only be put back together by our system interface. Logging into the system interface requires a unique user and password. Users are set with a need-to-know access level that matches their operational role.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Literably

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: 8/1/2022 – 7//31/2023

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Literably is an online elementary reading assessment. We receive PII in order to provide and improve our services to schools.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. All PII is stored on a password protected encrypted database located on a remote server. Literably conducts routine security audits and employs the use of monitoring software to track security risks within the dependencies that are used to build the product. Further, our employees and contractors are required to protect personal information in a manner consistent with our Privacy Policy.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Literacy Resources (for myHeggerty)

Littera Education

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. or accessing PII. Littera’s Academic Support Platform is designed to enable schools and districts to design, deliver, and monitor tutoring programs that are customized to address the needs of their students. Information we receive includes student name, email address and/or unique identifier. This information is used for assigning students to tutoring sessions inside the platform.

Within the platform, an identified staff member can easily assign students to tutoring sessions and monitor their progress by viewing student attendance and tutor feedback. Sessions can either be centrally assigned or classroom teachers can be given the ability to assign their students to tutoring sessions once they identify a need. Once students are receiving tutoring, the platform provides program managers, teachers, administrators, and other stakeholders with access to real-time tutoring delivery data, including attendance, number of sessions completed, student feedback, and tutors’ notes on student progress.

The Littera platform also provides districts with exclusive access to a new literacy tutoring curriculum created specifically for high dosage tutoring models by Columbia Teachers College Reading and Writing Project (TCRWP). This K-6 literacy tutoring curriculum is designed to be delivered through the Littera tutoring management platform, in order to ensure that students receive instruction according to the research-based principles of high dosage tutoring.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Vendor selected “Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. Amazon Web Services.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Littera Education places the utmost importance on privacy, safety, and security. All transmission of files or data to organization roster systems is done securely via HTTPS, using industry standards. When files are uploaded, they are stored in encrypted, non-publicly accessible databases. Littera uses Amazon Web Services (AWS) as its cloud hosting provider. The database along with all the cloud infrastructure is hosted inside a private virtual cloud (AWS VPC). Only a limited number of personnel have access to this VPC.

Development and staging environments each have their own environment, so they are completely isolated from the production infrastructure. Littera does not copy data from production to staging or development for the purpose of testing. The development environment suits all of developers' needs, so they do not have access to production infrastructure and data.

Our cloud hosting provider, AWS, is responsible for all physical data safeguards. AWS is a reliable and scalable platform that hosts many of the world’s largest companies. From an administrative standpoint, when new employee accounts are created, they are based on the principle of least privilege. Modifications to access must be approved by an authorized employee. All employees are required to undergo information security training and adhere to Littera’s information security policies. Littera has a detailed security policy which can be shared upon request.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

LiveSchool

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. LiveSchool uses the data for the sole purpose of using the LiveSchool platform to improve student behavior and contribute to student success.

LiveSchool uses the data to set up sites for the partner schools. These sites organize students by grade and class rosters so administrators and teachers can easily find students and issue points and make comments. All the student feedback is created by administrators and teachers. LiveSchool provides the platform to capture the information and report on key trends for students, classes, grades and across the school.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. Amazon Web Services.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. All data in the LiveSchool service is stored using industry best practices and technologies, including:

• A Virtual Private Cloud compartmentalizing all machine-to-machine communication services within the cloud.
• AWS RDS database servers are firewalled from all external machines on the internet.
• Operational intelligence monitoring scripts for proactive monitoring of system service levels.
• Verbose logging of application and database access activity.
• LiveSchool databases are configured to store information encrypted at rest.

All data exchanged between the LiveSchool platform and web/app clients of users is sent via 256-bit Advanced Encryption Standard (AES) Secure Sockets Layer (SSL) technology.

LiveSChool uses security groups to limit inbound and outbound network traffic to or from each Amazon EC2 and RDS instance. Traffic which is not explicitly allowed to or from an instance is automatically denied.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

Logikcull

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 1/1/2023 – 12/31/2023

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Tools like Adobe and Outlook weren’t designed for public records requests. Logikcull lets you eliminate slow, painstaking manual review, so you can work ten times faster with one tenth the resources. Just drag & drop, and let Logikcull automatically organize, OCR, and deduplicate your files. From there, you can quickly review, redact, and produce documents Logikcull surfaces as responsive.

Type of PII that the Entity will receive/access: Other: Logikcull may store DOE records containing student PII, APPR PII, and other personally identifiable information pursuant to the terms of the services.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Subcontractors are used for cloud storage.

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. AWS.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Logikcull values customer trust, and has established a culture and control environment dedicated to doing the right thing and protecting the integrity of its customers data. To this end, Logikcull complies with SOC 2 and HIPAA, and is hosted in AWS SOC 2, HIPAA and FedRAMP moderate compliant data centers. Logikcull and its hosting providers together employ administrative, technical and physical safeguards designed to protect customer data including but not limited to:

• Permissions-based user roles to control access to data
• Encryption at rest (AES-256)
• Encryption in transit (TLS 1.2)
• Virus scanning and malware detection applied to every uploaded file
• Multiple availability zones and daily backups to ensure continuous availability
• Vulnerability scanning, pen testing and a continuous bug bounty program
• Annual risk assessments
• Secure change management guided by a secure SDLC and enforced review and testing processes

To learn more about Logikcull's privacy practices please see https://www.logikcull.com/privacy-policy.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

MaiaLearning

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services, and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Student information is added so that school educators and counselors may access and guide them through the college and career planning platform. Students use the SSO to login to the platform and plan for their potential careers, develop their academic plans, research, and build college lists that they plan to apply to. Students ask for recommendation letters from teachers. Teachers write and submit recommendation letters in the platform for students. Counselors will prepare additional documents in support of applications [and] upload their transcripts and send them electronically to colleges where students have applied. Students eventually record their admission decisions which is stored as outcomes data for analysis in the future to guide other students. Parents have access to the platform and can view their child’s progress in read-only mode. Student information is not visible or accessible from any person or entity outside of the school and the parents. Students may opt-in to provide their contact information to colleges where they are interested to apply.

Type of PII that the Entity will receive/access: Student PII and Other: Educators First Name, Last Name, Email.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities (including any cloud services providers) and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written director, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Entity selected “Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. AWS.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

Safeguards

• In all aspects, MaiaLearning maintains a least-privilege model of access to data. This applies to administrative, operational and technical safeguards alike. Permission to access systems, whether it is Custom Support, CRM, Systems Administration tools, User Provisioning, or the product internal permissions are controlled and provisioned according to our Application Use Policy and approved by the MaiaLearning CTO or delegated administrator.

Administrative Safeguards

• Access permissions to all systems are approved prior to granting.
• Employee and Contractor Onboarding and Offboarding Policy ensure that granted permissions are documented and ensures that all rights are revoked on offboarding.
• All policies are reviewed annually to ensure they meet the security needs they are designed to protect and to ensure they are in compliance with applicable law and contractual obligations.
• Risk assessments are performed annually on all processes, and as required for new processes and systems.

Operational Safeguards

• MaiaLearning Security staff conduct periodic role appropriate training to all staff. Additionally, staff are required to take annual refresher security training appropriate to their role.
• The Data Transfer Policy governs how protected information is handled by MaiaLearning staff to ensure that due care is taken when transfer data from a customer representative to the system, when usage of automated systems cannot yet be utilized by the customer.
• MaiaLearning System Maintenance Policy governs all production and managed system to require they are upgraded in a timely and appropriate manner. Where an automated update system is available it should be used, unless an exception is documented, i.e. an untimely system outage would result. Automated updates are set on schedules appropriate to our users.
• MaiaLearning Disaster Recovery Procedure covers how we manage a complete failure of our primary systems provider. All configuration that can be, is maintained as infrastructure as code and committed to source code control. Source code control is not with our primary systems infrastructure provider.
• MaiaLearning Backup and Recovery Procedure requires all data to be backed up outside the region of service. For instance, data primarily served from the wester United States is backed up in the eastern United States, in accordance with contractual obligations and data location restrictions.

Technical Safeguards

• Under least access permissions all access to systems requires prior approval. Access to system command line is restricted to individual login and requires VPN access with MFA. Command line access is granted only to operations staff that have a need to access.
• Administrative access to systems is generally managed through web interfaces. These are also least privilege and access controlled to individual users and require MFA. Access to administrative applications is granted by approval of the CTO or delegated administrator.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Mastery Coding

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. All potential PI is provided within our platform merely to access [the] platform. The PI is limited to the discretion and imagination of the instructor whereby no PI that Mastery Coding receives or retains has unique value outside the Enterprise and is not in any way verified to be accurate or identifiable and is merely used as a login identifier for a course. Additionally, from students we only collect first name, last name, and classroom ID number. The concatenated integrity of this information is up to the teacher’s discretion. This information is primarily required to create student accounts that in the platform provide teachers the visibility to monitor individual student progress and is not used outside the platform.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

“We utilize an internal and proprietary Learning Management System/Platform (LMS). The platform provides protections for students and teachers at levels set forth by local, state, federal, and school district laws/policy. We have no subcontractors that will receive student data. All student data is controlled and managed by Mastery Coding exclusively. No one outside Mastery Coding has access to student data."

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. AWS.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Mastery Coding has adopted a set of policies and safeguards that cover all aspects (administrative/technical/physical) of student and teacher PI. All student data is securely stored in an encrypted database. The data is only transferred securely on request using https requiring an authentication token that our platform creates.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Mathletics 3P Learning Inc.

McGraw Hill LLC

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 4/1/2022 – 3/31/2029

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. or accessing PII. McGraw Hill offers multiple digital platforms that will collect Personally Identifiable Information (PII):

• ConnectED: A digital platform for delivering our PreK-12 content to teachers and students
• Connect: A digital platform for delivering content and learning tools for the higher education market.
• Open Learning: Provides K-12 and higher education instructors the opportunity to customize their McGraw-Hill courses by integrating their own content, open educational resources (OER), and other sources within a McGraw-Hill digital environment.

McGraw Hill will use personally identifiable information (“PII”) to provide the requested service or to process transactions such as information requests or purchases in order to meet our contractual obligations to the DOE institution that has subscribed to our products and services. We will also process DOE PII to meet our legitimate interests, for example to personalize your experience and to deliver relevant content to DOE; to maintain and improve our services to the DOE; to generate and analyze statistics about DOE use of the services; and to detect, prevent, or (if permitted by law) to respond to fraud, intellectual property infringement, violations of law, violations of our rights or our terms of use for McGraw Hill online products and services, or other misuse of the services. Except as described in this notice, we limit the use, collection, and disclosure of DOE PII to deliver the service or information requested by the DOE. We do not collect, use, or disclose PII that is not reasonably related to the purposes described within this notice without prior notification. Your information may be combined in an aggregate and de-identified manner in order to maintain and/or improve our services.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. Amazon Web Services.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. McGraw Hill utilizes the most up-to-date security systems and 24/7 monitoring. McGraw-Hill also has very strict internal processes to safeguard customers’ data, and all applications are built in compliance with federal regulations including FERPA. System penetration testing, vulnerability management and intrusion prevention is managed in conjunction with our third-party infrastructure provider. The application logs security-relevant events, including information around the user, the date/time of the event, type of event, success or failure of the event, and the seriousness of the event violation. User authentication communication and storage is protected by 256-bit advanced encryption standard security.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Metis Associates

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 8/1/2022 – 7/31/2027

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Metis conducts evaluation research for numerous entities, including the NYCDOE, to determine the impact and efficacy of strategies/programs/efforts to improve school and student-level outcomes such as academic achievement, behavior (e.g., attendance, discipline), and socio-emotional development. Most of these evaluations utilize data analyses that require additional information to control for possible confounding factors to “isolate” the treatment effect, including student characteristics such as sex, race/ethnicity, poverty status, and the like.

As the unit of measurement for these efforts is typically at the student level, these evaluations require student-level data to appropriately determine intervention effectiveness, particularly for longitudinal models wherein baseline data is used to comparatively determine growth after treatment. All data are typically requested without any direct student identifiers (i.e., without NYC BOE – Non Disclosure Agreement student names or OSIS ID numbers), but are considered PII due to data elements required to carry out the studies properly (e.g., DBN, poverty status, student with disability flag).

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using an entity-owned and/or internally-hosted solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Metis Associates’ technologies, safeguards, and practices align with the NIST Cybersecurity Framework. Our administrative, technical and physical structures ensure PII is protected and that we mitigate all data privacy risks. Sensitive data are stored in file servers, databases, and on temporary storage.

For data at rest scenarios, we use a shared mapped drive and a SQL database server:

• A Windows server is used to host the shared drive. Data access is controlled by domain group policy and NTFS permissions.
• A Windows server hosting a Microsoft SQL instance is also used to store sensitive data.
• Data access is controlled by domain group policy.

For data in motion scenarios, we use two file share web applications:

• A Linux Ubuntu server hosting a Secure FTP application is used to share sensitive data with clients. User access is controlled by local accounts and complex passwords. Once the data is collected, it is then moved to our shared drive. All data is subsequently deleted from the SFTP server.
• A Linux Ubuntu server hosting a web file-sharing application is also used to share sensitive data with clients. User access is controlled Domain Group Policy. Once the data is collected, it is then moved to our shared drive. All data are subsequently deleted from the server.

Individually identifiable data are processed expeditiously and stored on a secure server. Once processed, all data are maintained in a Microsoft SQL Server database with differential security access to confidential data elements (e.g., student name, student ID) restricted to authorized personnel. All backup data files - Including media upon which data were transferred from the originating agency - when not in use are maintained in a locked facility. Strict controls are maintained with respect to the location of removable disks and the identification of the data files stored on them. For larger projects requiring a centralized data repository, the repository itself is managed by a small group of data analysis specialists and individual data are only released to internal staff when necessary. Individual-level data are never transmitted electronically, nor permitted to be stored on removable media (e.g., usb thumb drives, magnetic media) - except for the aforementioned backups. At the end of project life, data will either be destroyed or returned when it is no longer needed or at the end of the agreement. Finally, unless consent Is specified by the originating agency, raw unit-record data are never released to clients, nor are any data that would contain information that could possibly link analysis results to individuals.

We have a detailed Data Security Action Plan in place that guides our activities to ensure we implement all state, federal and local data security and privacy contract requirements over the life of our data-sharing agreements. Furthermore, we have an independent cybersecurity firm conduct quarterly external and internal vulnerability scans to ensure our network is secure.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Microsoft

Notice and Controls on use of Subprocessors: Microsoft may hire third parties to provide certain limited or ancillary services on its behalf. Customer consents to the engagement of these third parties and Microsoft Affiliates as Subprocessors. The above authorizations will constitute Customer’s prior written consent to the subcontracting by Microsoft of the processing of Customer Data and Personal Data if such consent is required under the Standard Contractual Clauses or the GDPR Terms. 

Data Retention and Deletion: At all times during the term of Customer’s subscription, Customer will have the ability to access, extract and delete Customer Data stored in each Online Service.

Location of Customer Data at Rest: For the Core Online Services, Microsoft will store Customer Data at rest within certain major geographic areas (each, a Geo) as follows:

• Office 365 Services. If Customer provisions its tenant in Australia, Canada, the European Union, France, India, Japan, South Korea, the United Kingdom, or the United States, Microsoft will store the following Customer Data at rest only within that Geo: (1) Exchange Online mailbox content (e-mail body, calendar entries, and the content of e-mail attachments), (2) SharePoint Online site content and the files stored within that site, (3) files uploaded to OneDrive for Business, and (4) project content uploaded to Project Online.
• Microsoft Intune Online Services. When Customer provisions a tenant account, Customer selects an available Geo where Customer Data at rest will be stored. Microsoft will not transfer the Customer Data outside of Customer’s selected Geo except as noted in the “Data Location” section of the Microsoft Intune Trust Center.
• Microsoft Business Application Platform Core Services. If Customer provisions its tenant in Australia, Canada, Asia Pacific, India, Japan, the European Union, United Kingdom, or the United States, Microsoft will store Customer Data at rest only within that Geo, except as noted in the data location section of the Microsoft Business Application Platform Trust Center.
• Microsoft Azure Core Services. If Customer configures a particular service to be deployed within a Geo then, for that service, Microsoft will store Customer Data at rest within the specified Geo. Certain services may not enable Customer to configure deployment in a particular Geo or outside the United States and may store backups in other locations, as detailed in the Microsoft Trust Center (which Microsoft may update from time to time, but Microsoft will not add exceptions for existing Services in general release).
• Microsoft Cloud App Security. If Customer provisions its tenant in the European Union or the United States, Microsoft will store Customer Data at rest only within that Geo.
• Microsoft Dynamics 365 Core Services. When Customer provisions a Dynamics 365 Core Service to be deployed within an available Geo, then, for that service, Microsoft will store Customer Data at rest within that specified Geo, except as described in the Microsoft Dynamics 365 Trust Center (which Microsoft may update from time to time).
• Windows Defender Advanced Threat Protection Services. When Customer provisions a tenant account, Customer selects an available Geo where Customer Data at rest will be stored. Microsoft will not transfer the Customer Data outside of the Customer’s selected Geo except as noted in the “Data Location” section of the Microsoft Trust Center.

MobyMax

Moozoom Education

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Utilizing moozoom's live-action bite-size SEL movies, the entity goal is to have the school's climate team work with classroom teachers to implement lessons and activities that help to increase student engagement and address students' social and emotional health. Because of moozoom ease of use and delivery of social and emotional skills, moozoom will support Tier 1, 2, and 3 interventions. Four(4) data assessment streams, including a research-based pre-post survey measuring skills acquisition in real time, will allow the entity to assess school climate improvement at all times

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Vendor selected “Other: Data will be returned or destroyed upon termination of services. The DOE need not request that data be destroyed or returned once services have been completed.” In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. Amazon Web Services.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. All PII is encrypted at both rest and in transit. All access to PII is limited via role based access within the company and security training is mandatory for all employees who have access to any PII. moozoom has several security measures in place to ensure we are applying security best practices from code development to the infrastructure that hosts the PII (e.g. Monitoring Tools, Static Code Analysis, Vulnerability Scanners, etc).

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Mouse.org

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: 11/1/2023 – 11/1/2030

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Mouse.org provides The Board of Education of the City of New York with access to Mouse Create, a website and online learning application featuring STEM-related projects designed to facilitate student learning. Mouse Create content is password protected and accessible at https://create.mouse.org/.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor. "Mouse Create is hosted using cloud architecture owned and managed by DigitalOcean, a reliable cloud services subcontractor with 99.99% uptime. Terraform is used to configure, automate, and update the DigitalOcean cloud infrastructure including Linux-based virtual private servers running Mouse Create. All information including Confidential Information and Protected Information are collected and stored using TLS 1.3 grade encryption with 256-bit size and stored using AES-256 encryption. Mouse stores Confidential Information and Protected Information in a secure manner and safeguards it from unauthorized access in a secure, restricted-access database."

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Applications provided by Mouse.org operate separately and independently of DOE and DIIT systems and Mouse is contractually obligated to comply with privacy and security policies mandated by DOE. The Student PII required by Mouse applications is limited to Student first and last name and year of birth. Additionally, at Student’s option, Students may provide their email address, date of birth, gender, and ethnicity. Mouse applications ask students to provide their name only for the purpose of allowing teachers to identify and track assignments completed by students in their class. Teachers do not have access to the names of students or PII of students who are not in their classes. Email address is collected to aid in password recovery. Students using the application do not have access to PII provided by any other student. Within all Mouse applications, all database queries and SQL injections are limited and validated using predefined rules and encryption.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

Music and the Brain-Building for the Arts NY

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: 8/23/21 – 8/22/26

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Music and the Brain All Access, located at learn.musicandthebrain.org, is a cloud-based learning platform of the Music and the Brain program that gives partner school music teachers and students access to our sequential music lessons materials. Email address protected information will only be used for NYCDOE educators, administrators and students to gain access to the Music and the Brain All Access platform. Google login integration is in place.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

• Web application is running on a virtual machine (VM) server, provisioned and hosted by AWS, in a data center with specific physical and logical security controls that prevent and restrict access to computer systems and data storage.
• Access to Web application for updates and management tasks require administrator level permission and requires VPN connection and Multi Factor Authentication (MFA).
• All data (including PII or any other confidential information) is encrypted in transit (HTTPS TLS 1.2 / AES256).
• All data is stored in MySQL database and encrypted at rest using the Transparent Data Encryption (TDE) option using AES ciphers.
• Per MATB Data Privacy and Security Policy, access to PII and other confidential information is granted based on the principle of least privilege.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

My Robin Inc

Type of Entity: Publisher of Social and Emotional Learning Content

Contract / Agreement Term: 11/1/2022 – 10/31/20209

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII.  My Robin Inc provides a comprehensive online curriculum through engaging videos that teach skills and strategies for students to improve their social, emotional and mental health. To provide, analyze, and improve our Products. We use the information described in (5) below to provide, analyze, and improve our Products, including to:

• Create and maintain your account
• Identify you as a user
• Notate and assign support tickets
• Provide, operate, maintain, and improve our Products
• Personalize and improve your experience
• Contact you and communicate with you, including to respond to your comments or inquiries
• Provide customer support

De-identified or aggregate use. We may create and use de-identified or aggregate information – information removed of specific identifiers so that it cannot singly identify you (i.e., non-personal information) – for purposes only related to the services rendered.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

“Data is available for export from Canvas LMS via a variety of standards-based formats such as HTML and CSV at any point in time by our customers. Instructure is a sub-processor Robin (https://my-robin.com), requests to export or remove NYC DOE PII or other data in the system should be directed to them and they can use Instructure-provided tools to return or destroy DOE data. In the event that Robin terminates its contract with Instructure then 90 days after the end of the contract period Instructure will use AWS-provided methods to securely erase all Robin data (including NYC DOE data) from the system. My Robin Inc will destroy all data upon termination of services. If client requests, data will be returned to them via a secure platform.”

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e., AWS.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. My Robin Inc, who license’s Instructure’s Canvas platform, utilizes a combination of industry best-practices for administrative, operational, and technical safeguards to protect client data. For detailed information please see the following documents which have been included with this submission and are available online at https://inst.bid/canvas/lms/dl:

• Instructure Security white paper: A high-level overview of Instructure’s security policies and procedures including incident response.
• Instructure Business Continuity white paper: A high-level overview of Instructure’s business continuity policies and procedures including disaster recovery with sample RPO/RTO timelines.
• Canvas LMS Architecture White Paper: An architectural overview of the Canvas LMS web application including scalability, reliability, redundancy, and security.
• Canvas LMS HECVAT: An industry-standard questionnaire published by Educause covering Subprocessors, application security, authentication/authorization, business continuity, change management, data handling and classification, data center security, disaster recovery, networking, policies & procedures, incident handling, quality assurance, and vulnerability scanning.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

N2Y LLC

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. To provide the contracted services which include delivery and support of Software as a Service solutions for use by teacher and their students with special needs in the K-12 classroom.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. US-based Microsoft Azure data centers with cloud providers that are audited and certified for secure handling of data.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. n2y maintains safeguards to protect the security, confidentiality and integrity of PII received from the customer including encryption, administrative, technical and physical measures.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Nagarro Inc.

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 7/10/2021 – 8/31/2023

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Nagarro staff members will only have view-only access to the PII data. This is mainly required to help solve login problems of the staff and students to identify the caller and make sure we are resetting systems passwords for an identified staff member or student.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement: In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. The vendor’s response: “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted: No PII will be stored or hosted by Entity.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

• To the extent possible, services are delivered from our ISO 27001 certified New York City facility
• All PII is hosted and processed on DOE systems and infrastructure, and
• All employees undergo periodic training on data security.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. The vendor’s response: “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology."

NCS Pearson (for Certiport)

The exclusive purposes for which Protected Information will be used: Protected Information is collected from individual students to create an individual user account. This individual user account allows students to manage personal information, manage certification examination registration, view a record of certification exams taken and passed, print duplicate copies of certification certificates for certification exams passed. The user account allows the user to manage and control their personal information and certification exams after graduation – including capturing future certification the user may earn.

How you will ensure that the subcontractors or other authorized persons or entities that you will share the student data or teacher or principal data with, if any, will abide by data protection and security requirements required by your non-disclosure agreement with the NYC DOE: Certiport uses two subcontractors that to deliver the Certification Exams that Certiport offers. One subcontractor provides exam drivers to launch and run exams. This subcontractor only has access to a candidate’s name. The candidate’s name is only accessible through logs generated by the drivers – logs are accessible only to employees of the subcontractor that have a specific need and purpose to access them. This subcontractor is under a confidentiality agreement with Certiport and has technological and administrative controls designed to protect data.

The second subcontractor we use provides 1st-level tech support for candidates. This subcontractor needs the ability to look up candidate accounts, view candidate profiles and exam results in order to provide candidates with basic tech support services. This subcontractor is under a confidentiality agreement with Certiport and has technological and administrative controls designed to protect data.

When the non-disclosure agreement with the NYC DOE starts and ends and what happens to Protected Information upon expiration of the agreement: Protected Information is retained until the individual that has the associated account (or their legal guardian) requests deletion. The individual account holder may request deletion of certifications from a specific program sponsor (i.e. deletion request of all Microsoft exam records) or the deletion of their entire account. When deletion of the entire account occurs, all certifications earned are also deleted – they are no longer verifiable or valid. This means that the individual will be required to register for a new account and re-take exams if they wish to regain certification.

If and how a parent, student, eligible student, teacher or principal may challenge the accuracy of the student data or teacher or principal data that is collected: Parents, students, eligible students, teachers or principals may challenge the accuracy of the student data or teacher or principal data that is collected by Certiport by logging into the candidate’s account (candidate means any user that is authorized by the District to take a Certiport certification exam; this may include a student, teacher, teacher’s aid, principal, etc.), navigating to the candidate’s profile page, and editing/updating the incorrect or inaccurate data. Certification exam results are not challengeable and will not be changed or modified at the request of any individual.

Whether the Protected Information will be stored in the US or outside of the US (and if outside of the US, where), and the security protections taken to ensure such data will be protected (described in such a manner as to protect data security): All of our data is stored in a secure data center within the US. The database is behind multiple levels of protections, and is encrypted-at-rest. All access to the data utilizes secure, individual accounts and secure data transfer.

How the data will be encrypted (described in such a manner as to protect data security): The databased is encrypted-at-rest. Additionally, key data such as passwords are AES-256 encrypted.

NCS Pearson (for Periodic Assessment Program)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 8/1/2021 – 7/31/2026

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. or accessing PII. Pearson will support NYCDOE by delivering the technology and services to support the NYCDOE’s Periodic Assessment Program. Pearson will receive and access PII to complete the services outlined in the Periodic Assessment contract. Specifically, the data will be used to allow students to access assigned assessments by their classroom teacher in regard to the New York City Periodic Assessments. Student data will also include scored assessments used by classroom teachers and the NYC school district.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Pearson takes the privacy and security of customer and company information seriously. To protect sensitive assessment data, such as test items and student confidential information, Pearson employs recognized industry standard security measures to safeguard the confidentiality, integrity, and availability of customer data and the services we provide.

Our information security policies and standards are based on the ISO/IEC 27001 information systems security framework and align with the NIST catalogue of security controls. This ongoing alignment with NIST reflects our commitment to ensure our information security program remains current and appropriate to address the evolving threats to information security and data privacy.

System Security and Resiliency

• In accordance with security best practices, multiple layers of security exist in the computing environment to reduce the risk of unauthorized exposure of customer data. These protections include not only preventive controls designed to stop security incidents from happening, but also detective controls to inform us in the unlikely event a security control failure occurs. Along with the resilient and reliable design of our assessment platform, Pearson leads the industry in its ability to protect against and mitigate the effects of distributed denial of service (DDoS) attacks.

Staff Training Requirements

• When employees and staff augmentation resources begin working for Pearson, they must sign an acknowledgement of their obligation to adhere to the Pearson Global Information Security Policies and follow the company’s implementation guidelines and standards. On an annual basis, members of the Pearson workforce must complete information security training that is designed to ensure they not only maintain awareness of their responsibility to protect customer and company information, but also to help ensure they are educated regarding changes in the ever-evolving information risk universe.

Need to Know and Least Privilege

• Pearson provides access to systems based on need to know and in accordance with the principle of least privilege. If a workforce member does not have a business need for access, they do not get it. And where access is authorized, user accounts are assigned the minimum level of privilege necessary for their role.
• These principles also extend into the assessment services we provide. Customer staff who have been assigned to administration roles in service solutions have the ability to place staff and students into specific roles with privileges appropriate to them. In this way, the administration of the assessment platforms can conform to role-based access needs of each customer.

Entitlement Review

• A review of users and the permissions assigned to them is performed periodically, as well as when staff change positions and employment statuses change. This helps to ensure on-going adherence to our commitment to grant access based on need to know and according to the principle of least privilege.

Data Classification

• Pearson’s Global Information Security Policies and Standards define a three-tier data classification level (DCL) scheme. DCL3, the highest classification tier, denotes customer and Pearson intellectual property, data subject to US and International data security and privacy regulations, and data requiring comparable protections as defined in contracts. DCL3 classified data requires the most stringent information security controls. Given the nature of the services we provide to customers, practically all of our systems are designed with the baseline assumption that the data it maintains and processes is DCL3.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Nearpod

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. For the exclusive purpose of delivering and supporting Nearpod's software services, including supplemental instruction, and formative assessment content and activities for authorized school and district users, including parents, teachers, and students.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. AWS.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Nearpod will ensure that only the employees, contractors, and sub-processors who have a “need to know” access to any Protected Data, actually have access to the Protected Data by instituting separate types of user-permissions on the Nearpod platform back-end. Additionally, Nearpod will ensure that all employees, contractors, and sub-processors sign confidentiality agreements and nondisclosure agreements that limit the use of the data that is received in the course of their relationship with Nearpod to the limited purpose of providing the services needed to provide the Nearpod services to district.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

NetSupport (for Classroom.cloud)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Classroom.cloud is a teaching/instruction, monitoring and student engagement tool used to better manage technology in the classroom. It is cloud-based and hosted by NetSupport Incorporated. PII collected is used solely for the creation of classes and identification of students within the platform and is not shared with any third-party. We use this data to provide information/evidence about what learners are doing during and outside of lessons, to monitor the safety of students, and to provide schools with the information and tools necessary to delivery technical and instructional support.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYCDOE, or a successor contractor at the NYCDOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. Microsoft Azure.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. We have organizational and technical measures in place to safeguard and secure the information we hold, based on standard industry privacy practices. More information can be provided on request as we prefer not to publicly publish too much security information as a measure to protect our services. Our infrastructure undergoes rigorous testing and security review to ensure PII is protected. Any potential risks will be made known to users through direct communications from us, as well as options for mitigating potential risks/threats.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

New Beginnings Performing Arts Studio

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: 6/01/2023 – 5/31/2028

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. New Beginnings Performing Arts Studio is committed to its mission to expose adolescents and adults to life experiences through the performing arts.

The New Beginnings Dance program meets the complex needs of today's dance students enabling them to develop as both highly versatile dancers and well-educated adolescents. This program provides an introduction to the study of dance cultures in diverse contexts around the world. They are offered a broad curriculum of dance techniques that allow them to become equally proficient and well-grounded in traditional and cultural based techniques.

This course was developed in alignment with the New York City Department of Education’s Blueprint for Teaching and Learning in the Arts: Dance, Grades PreK-12. The Blueprint is the

New York City Department of Education’s curriculum framework for instruction and notes indicators for student achievement in dance at various benchmark grades (2nd, 5th, 8th, and 12th). The Blueprint is directly aligned with the NY State Learning Standards for the Arts.

This program exposes students to pro-social activities preparing them for social and academic success through the performing arts. Students would meet on a daily basis to learn skills that will build self-discipline and self-control through dance, movement, and sound. These items would in turn build self-esteem, confidence and character, allowing them to learn in a positive and fun atmosphere.

We would need student names and classes to keep attendance.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities (including any cloud services providers) and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. No PII will be stored or hosted by Entity.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

• Password Protected
• Firewall
• All students documents are filed electronically in password protected database

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor wrote “will not be storing PII.”

New York City Outward Bound Center

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: 7/01/2015 – 6//30/2023

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. NYC Outward Bound Schools receives student level data including names, student number, school, demographic information and performance data such as attendance and end of semester grades directly from the DOE and partner schools. We use this data to assess the impact of specific programs and services that are delivered to schools so that we can ensure that resources are being used effectively. At times we disaggregate the data by gender, race, special education or MLL status to assess impact on sub-groups of students. The programs we study include professional development, coaching and student community building.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks.

• 256-bit SSL/TLS encryption is used for files in transit and 128-bit AES keys for files at rest.
• Access to information is limited to authorized individuals who require it to perform their job functions.
• Authorized individuals who have access to confidential data receive training on federal and state laws governing the confidentiality of such data.
• When staff employment is terminated, the employee’s accounts are disabled and passwords are changed.
• In the unlikely event of a security breach, New York City Outward Bound Center, Inc. will activate an incident handling procedure, conduct a thorough investigation, and contact the appropriate stakeholders as required by law.
• Third-party partners are vetted for their ability to comply with the security requirements outlined by NY State and NYC DOE.
• Other safeguards include, but are not limited to, physically secure data centers, up-to-date firewall rules, regular third-party security audits, and logical access controls of data.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

New York Mission Society

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Mission Society engages in continuous improvement and monitoring in partnership with DOE partners at the seven school we partner with which uses PII data to look at trends and outcomes. The results from these data monitoring activities provide the Learning to Work program, Principal, and school administration with the information necessary to create goals and establish areas of focus. This continuous improvement and monitoring of data is essential to our understanding of what is working well and what needs improvement. Also, PII data is also used to assist student with their post-secondary planning i.e. applying to college, financial aid applications for college and job applications, etc.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and

written discretion, in a format agreed to by the parties. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e., Google and Microsoft, and using an Entity-owned and/or internally hosted-solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Mission Society collects personally identifiable information (PII) from students who participate in their education programs. Prior to obtaining PII data all students over the age of 18 must complete a data collection consent form that asks the students permission to share their PII data with Mission Society. Students under the age of 18 must have a parent or guardian sign the data collection consent form. All PII data is entered into a password protected cloud based database that employs current industry standards and legally required technical, organizational, and physical safeguards designed to protect the PII information that Mission Society collects. Mission Society staff are sufficiently trained on how to safeguard PII data. Mission Society does not sell, use, or disclose PII data for marketing, advertising, or other commercial purposes. Mission Society does not maintain copies of PII data once it is no longer needed for the agreed upon educational purpose and in accordance with DOE contract mandates.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

NIA Community Services Network

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: 8/31/2023 – 8/30/2028

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. NIA Community Services Network will provide student support services as contracted in the categories of recreation/sports, family support services, and academic skills enhancement. PII may be collected for purposes of student enrollment and tracking of student outcomes related to program services

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; and using an Entity-owned and/or internally hosted-solution. “If data are transferred via a cloud-based tool, NIA will use a secure Sharepoint link to transfer and store data, ensuring that only those who require access are granted access.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. NIA commits to implementing all state, federal, and local data security and privacy contract requirements over the life of the agreement, consistent with NYC DOE’s data security and privacy policy, as well as the requirements of NYC DOE’s Parents’ Bill of Rights for Data Privacy and Security. The following outlines the data security protocols and measures in place to ensure compliance with all requirements.

NIA has administrative, operational and technical safeguards and practices in place to protect any Protected Information that we may potentially receive under the contract. This includes, but is not limited to:

Administratively:

• NIA staff and its subcontractors are required to hold Confidential Information in strict confidence. NIA staff and subcontractors will only disclose Confidential Information to other staff who need to know the information in order to carry out tasks and only to the extent justifiable by that need.
• NIA will only use Confidential Information collected for projects that fall under the agreement for specific project purposes. NIA and its subcontractors will not use Confidential Information for its own benefit or for the benefit of another, or for any use other than specified in the agreement.
• NIA will never sell, license or distribute any Confidential Information collected as part of this agreement.

Operationally and technically:

• NIA will store all Confidential Information on its local secure server. NIA's servers are located in the NIA main office, with access limited to executive staff and key administrative workers. Our servers are monitored and managed by an off-site external IT company. Servers are encrypted, and data is backed up by our IT provider.
• Confidential Information may never be stored on personal technology devices at any time. NIA will not incorporate any Confidential Information into any database or any medium other than required for this agreement.
• NIA will ensure end-to-end encryption when data is in motion and at rest to preserve safety of data at all times.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

No Tears Learning (also called Learning Without Tears)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 3/27/2023 – 7/1/2024

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Contractors receives and access PII for the limited purpose of license administration of digital products and services purchased by EA.

As part of any online application that a student uses from our company, the student’s name, grade, class and school are needed to license them for the appropriate graded license to set up their account, and define classes in the teacher’s application. This is information that is provided as part of our rostering process and allows for teachers to review progress of specific students in our teacher application. Additionally, the students first name and first letter of last night is used for display purposes in the application profile (so student knows they are in their own workspace).

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor; i.e. “Amazon Web Services encrypted databases and Object Based Storage (S3) where all traffic Is encrypted in transit. Access to data is by least privilege throughout.”

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Privacy for all user data is critically important to us, and we have put into place best practices to safeguard its access and usage. Listed below are more specific safeguards we have in place:

• Access control – Zero-Trust model is in place, only security and system administrators can view.
• Auditing – Logging and reviewing our PII access.
• Encryption – PII is encrypted to make it unreadable for any user without access.
• Tokenization – PII is replaced by a unique identifier to prevent unauthorized access.
• Data Security – All data classified as PII is stored in a secure server hosted by a third party cloud infrastructure service utilizing security best practices by default.

Because all of our data is hosted in the cloud environment at AWS, we are able to leverage Amazon’s implemented physical safeguards to protect our customers data. No current employee has physical access to machines with protected data. Our administrative safeguards ensure that any employee that is terminated has their access to our servers/infrastructure immediately revoked. Additionally, access to sensitive data in production is on a “need only” basis, and account access is extremely limited – for instance: the CEO, CFO nor CTO have access to any production-level data. If there are other specific safeguards that the district is curious about, please let us know.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.” 

NoRedInk

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. NoRedInk provides a comprehensive, online, adaptive, mastery-based writing curriculum for grades 3-12 that is aligned with the New York State Standards. We collect the following PII in order to provide, maintain, and improve NoRedInk:

• Student name, grade, email (optional), teacher names, school – required to create student accounts and associate them with the correct account and teachers
• Student assessment data (NoRedInk benchmark, diagnostic and growth assessments – required to assess student skill mastery, monitor progress and growth
• Student generated content (writing) – required for students to complete NoRedInk writing assignments and activities in order to receive teacher feedback and assignment grades to support their improvement

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities (including any cloud services providers) and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subtractor, i.e. AWS.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. All PII is stored in a secure environment on servers located in the United States (Amazon Web Services). Only the administrators of the cloud infrastructure provider have physical access to the data centers from which our service is hosted; the cloud infrastructure provider maintains security procedures compliant with a variety of US and international standards to ensure physical security of their data centers. It is our policy to prohibit storing any user data on employee devices.

Access to the NoRedInk production servers and database is permission controlled. We are able to revoke access remotely for any individual.

All NoRedInk users require a password-protected login in order to access the application. Teachers and students can register with a unique username and a password, or use Google SSO or Clever SSO.

All user data, including login credentials, provided in the use of the online service is encrypted in transmission using HTTPS. User data, including passwords, is encrypted at rest in our database. 

We have 24/7 security scanning, monitoring and alerts with a team on call for any required incident support. These systems also detect any required security patches or updates for our system.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Notable (also called Kami)

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 6/30/2022 – 6/30/2023

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Kami is a digital learning platform that allows teachers and students to annotate on documents, PDFs, images (or any other resource) using a variety of tools to increase accessibility, engagement, and collaboration. With Kami, teachers will find heaps of new ways to level up their documents, PDFs, images, activity sheets (or any other learning resources) to interactive and engaging learning environments. From there, teachers and students can collaborate in real-time through live annotations, video and audio recordings, drawings, and much, much more.

To summarize our purpose for receiving/accessing PII, we use the data you share with Kami solely to provide you the Kami service, to improve it, and to keep you updated about new developments. We use the PII for sign in purposes (using SSO). Kami collects limited personal information from students, including email address, first name, and last name. This information is not shared outside of the school or with any third parties except those needed for the provision of the service as outlined in our privacy policy here: https://www.kamiapp.com/privacy-policy/.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities (including any cloud services providers) and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. AWS and Google Cloud Platform.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Your data is protected using streaming replication to geographically distributed backup servers and log shipping to secure storage. We create daily backups using multiple independent systems and store them across multiple different providers. Our backups are encrypted on dm-crypt encrypted disks with strong passwords. Data is stored in physically secured google data centers, PII remains in the cloud and is never downloaded to local or mobile devices. Access to systems storing PII is restricted to staff needing it to provide the service. Staff are subject to police background checks, staff receive training on handling PII and recognizing and dealing with cyber threats upon joining and regularly thereafter.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

NoteFlight LLC

The exclusive purposes for which Protected Information will be used: To provide the services for teachers and students to learn music composition and performance in a private web-based environment.

How you will ensure that the subcontractors or other authorized persons or entities that you will share the student data or teacher or principal data with, if any, will abide by data protection and security requirements required by your non-disclosure agreement with the NYC DOE: All subcontractors sign DPAs, follow the same protocols as we do, and go through training.

When the non-disclosure agreement with the NYC DOE starts and ends and what happens to Protected Information upon expiration of the agreement: This agreement begins upon execution and ends upon written notice that services are no longer needed, and the district can request deletion of data. [NYC DOE comment: the agreement was signed on 12/20/2020 and updated on 8/6/2021.]

If and how a parent, student, eligible student, teacher or principal may challenge the accuracy of the student data or teacher or principal data that is collected: Pursuant to its contractual obligations, the Processor will work with the NYC DOE in processing challenges to the accuracy of student data in the custody of the Processor. 

Whether the Protected Information will be stored in the US or outside of the US (and if outside of the US, where), and the security protections taken to ensure such data will be protected (described in such a manner as to protect data security): Amazon Web Servers, Northeast Region 1, Northern Virginia. Data is encrypted in motion and at rest, with the service running AWS Elastic Beanstalk Instance clusters and SSH keys. 

How the data will be encrypted (described in such a manner as to protect data security): Hash and key, SSL, Database encrypted at rest and in motion. 

NTT DATA, Inc.

The exclusive purposes for which Protected Information will be used: The New York City (NYC) Department of Education (DOE) has a requirement for supporting the Learn at Home initiative brought about by the Coronavirus pandemic that has caused the DOE to close its schools for the safety of the students and DOE staff. To continue to meet the education needs of its students, the DOE Learn at home program requested that NTT DATA, Inc., manage the distribution of iPads and smart devices to students and teachers who do not have computer access at home. 

How you will ensure that the subcontractors or other authorized persons or entities that you will share the student data or teacher or principal data with, if any, will abide by data protection and security requirements required by your non-disclosure agreement with the NYC DOE: NTT DATA, Inc., works with Custom Computer Specialists as their sub-contractors. Only authorized personnel from NTT DATA’s sub-contractor will be allowed to access the protected information in order to carry out and perform required services. All authorized users will be contractually bound by an agreement that will include confidential and data security obligations. In addition, all authorized users with access to confidential information will be trained to understand the privacy and data security obligations of this Agreement.

When the non-disclosure agreement with the NYC DOE starts and ends and what happens to Protected Information upon expiration of the agreement: All confidential data and PII will be securely stored and access will only be grated to authorized users for the purpose of providing services to the extent mentioned under the contract. Upon completion of project and/or termination all data will be securely destroyed or returned to DOE. [NYC DOE comment: The current agreement became effective starting on June 18, 2020, and terminates when all NYC DOE schools and/or offices cease using NTT DATA, Inc.’s products/services. The terms of the agreement remain effective through the period during which NTT DATA, Inc. possesses or otherwise is in control of covered protected information.]

If and how a parent, student, eligible student, teacher or principal may challenge the accuracy of the student data or teacher or principal data that is collected: Pursuant to its contractual obligations, the Recipient will work with the NYC DOE in processing challenges to the accuracy of student data in the custody of the Recipient. [NYC DOE comment: requests for copies of student data or to challenge the accuracy such data should be directed to your child’s school, or to studentprivacy@schools.nyc.gov.]

Whether the Protected Information will be stored in the US or outside of the US (and if outside of the US, where), and the security protections taken to ensure such data will be protected (described in such a manner as to protect data security): Data will be accessed in US and securely on SharePoint. Access to the data is strictly issued based on job requirement and at the minimal to perform the same. The customer data shall be logically and physically separated from other customer data. Data shall be periodically backed up based on the customer requirement. NTT DATA Services encrypts the data at rest which resides in our environment and data in motion which leaves our environment using industry standard cryptographic techniques. In this way confidentiality, integrity and availability of the data in ensured in NTT DATA Services. 

How the data will be encrypted (described in such a manner as to protect data security): NTT DATA Services encrypts the data at rest which resides in our environment and data in motion which leaves our environment using industry standard cryptographic techniques.

NWEA

Type of Entity: Community Based Organization or Not-for-Profit

Contract / Agreement Term: 6/30/2022 – 7/1/2023

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. NWEA receives PII in order to provide educational assessments and associated services.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. AWS; and using an entity-owned and/or internally hosted-solution.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. NWEA’s administrative, technical and physical safeguards can be found at: NWEA's Map Growth Security Whitepaper.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

OmniLearn

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 6/30/2021 - 6/30/2023

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. OmniLearn staff provide hands-on STEM lab instruction for pre K -12 students and Professional Development for teachers in Brooklyn, Queens, and the Bronx. We are subcontracted by CBO’s (Community-Based Organizations) for teaching labs in Community Schools and named as vendors in 21st Century Community Learning Center Grants. Student signatures are collected each day we teach a lab for 2 purposes: 1) Evaluators must submit evidence that the schools have met the requirements set by the grant providers for Numbers of students participating in the lab program on each of the dates throughout the school year. Copies of the daily sign-in sheets are kept in a binder at the school for inspection by the NYS Education Department; and 2) OmniLearn is required to submit attendance reports to the NYC DOE to be paid. We count the number of students from the sign-in sheets and send the totals from each date in each school with our invoices for the Principals’ signatures. No student names are included in the attendance reports.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third-party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. Using a cloud or infrastructure owned tool hosted by a subcontractor, i.e. Microsoft OneDrive.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. If signatures have been scanned into OmniLearn’s Google Drive for record-keeping, OmniLearn implements an IT infrastructure which conforms with the requirements of PCI or HIPAA including a Cisco UTM firewall, the cloud-managed firewall and anti-virus system, complex passwords, encrypted backup, auto-locking screens, and remote wipe technology. Once payment is made, signatures are removed from the drive.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. Vendor selected “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology."

Ookla

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 2/15/2021 – 8/14/2022

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. Ookla is licensing Ookla-owned Cell Analytics data. We are also licensing a Speedtest Powered Mobile SDK. The Mobile SDK may be run by the NYCDOE on its Learn@Home app. The Mobile SDK generates test results of those end users that take a Speedtest. Ookla processes these test results only for the purpose of providing the SDK and providing subsequent data to NYCDOE.

Type of PII that the Entity will receive/access (check all that apply): Student PII and Other. We receive location and IP address of any end user that takes a Speedtest in the app in which the SDK is included.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. The vendor’s response: “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely transfer PII to NYC DOE, or a successor contractor at the NYC DOE’s option and written discretion, in a format agreed to by the parties; and securely delete and/or destroy PII.

Challenges to Data Accuracy. The Entity agrees to the procedure outlined below:

In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted: Using a cloud or infrastructure owned tool hosted by a subcontractor.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. Data is stored in secure datacenter facilities hosted by Amazon Web services. All data is fully encrypted at rest using EBS encryption based on the industry standard AES-256 cryptographic algorithm.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. The vendor selected: “Entity agrees that PII will be encrypted in motion and at rest using industry-standard data encryption technology.”

Open Assessment Technologies

Type of Entity: Commercial Enterprise

Contract / Agreement Term: 10/1/2023 – 9/30/2030.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. OAT leverages TAO, its cutting-edge test delivery platform, to facilitate the administration of online World Language assessments for the NYC DOE. It is important to highlight that the system does not retain any personally identifiable information (PII). The Department of Education and OAT will work to implement a single-sign-on solution which does not share PII, using industry-standard data protection measures.

Type of PII that the Entity will receive/access: Entity will not receive or access PII (do not choose this response if Entity’s services or products permit users to store PII on a platform that the Entity or its subcontractors host).

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. “As noted above, no PII is stored in the system. All data at rest and in flight are encrypted as required by our ISO 27001 certification process.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: “As noted above, no PII is stored in the system.”

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the Office of the Chief Information Officer, the Division of Instructional and Information Technology, New York City Department of Education, 335 Adams Street, Brooklyn NY 11201.

Security and Storage Protections. Describe where PII will be stored or hosted. No PII will be stored or hosted by Entity.

Describe the administrative, technical and/or physical safeguards to ensure PII will be protected and how the Entity will mitigate data privacy and security risks. The TAO solution, as used for NYC DOE, does not store any identifiable details of test takers in its platform. The assessment is launched with an anonymous identifier for each test taker, which is also used to retrieve the results. Through a de-identified sign-on process, the OAT and the DOE avoid sharing any personally identifiable information of students.

Encryption. Pursuant to New York Education Law 2-d, PII must be encrypted while in motion and while at rest. By checking the box below, Entity agrees that PII will be encrypted using industry standard data encryption technology while Protected Information is in motion and at rest. “As noted above, no PII is stored in the system. All data at rest and in flight are encrypted as required by our ISO 27001 certification process.”

OpenMethods

Type of Entity: Commercial Enterprise

Contract / Agreement Term: The Agreement covers multiple products, services and/or DOE schools and offices, and so Start and End Dates vary by product, service, and DOE schools and/or offices.

Describe briefly the project/evaluation/research you are conducting or participating in, and/or the commercial product or service you are providing. Describe the purposes for which you are receiving or accessing PII. OpenMethods provides tools that allow call center agents to handle interactions more efficiently and accurately; giving them the ability to answer calls, and automate processes, within the primary application they use to track constituents’ issues. OpenMethods products do not store any additional personal data than that which has already been provided, and never sell any data to other entities.

Type of PII that the Entity will receive/access: Student PII.

Subcontractor Written Agreement Requirement. In accordance with New York Education Law 2-d, the Entity may not share PII with subcontractors without a written agreement that requires each of its subcontractors to adhere to, at a minimum, materially similar—and no less protective—data protection obligations imposed on the Entity by the Agreement with the NYC DOE and by applicable state and federal laws and regulations. Vendor selected “The Entity will utilize subcontractors or third party entities and agrees not share PII unless similar data protection obligations contained herein are imposed on each subcontractor or third party, in compliance with applicable New York State and federal law and using industry standard best practices for data privacy and security.”

Data Transition and Secure Destruction. Upon expiration or termination of the Agreement, the Entity shall: Securely delete and/or destroy PII. In its agreement with the DOE, this entity has agreed to return and securely delete or destroy PII whenever any of the following occurs first:

• whenever requested by the DOE
• whenever the entity no longer needs the PII to provide services to the DOE
• whenever a DOE school or office ceases use of a product or service of the entity, for the PII that pertains to that school or office
• no later than upon termination of this Agreement

In addition, the entity has agreed that to the extent practicable, it will not retain PII for more than one school year after the school year in which the data was received, unless it is required to retain it for longer by law.

Challenges to Data Accuracy. The Entity agrees to the procedures outlined below: In accordance with N.Y. Education Law 2-d, parents, students, eligible students, teachers, or principals may seek copies of their PII, or seek to challenge the accuracy of PII in the custody or control of the Entity. Typically, they can do so by contacting the NYC DOE using the email address or mailing address below. If a correction to PII is deemed necessary, the Entity agrees to facilitate such corrections within 21 days of receiving the NYC DOE’s written request. The Entity must forward the request to the NYC DOE as soon as practicable in order for the DOE to authenticate the identity of the student or parent, and to advise the Entity on how to process the request. All requests for copies of PII or requests to challenge the accuracy of PII should be directed to the following email address: studentprivacy@schools.nyc.gov or in writing to the O