Last updated: August 21, 2020.
At LEAD, we are dedicated to protecting the privacy of our students, clients and their families. LEAD, its 24/7 crisis text line program called Text-A-Tip, along with its web-based and mobile applications (“Applications”) make up a suite of services (collectively, “the Services”) owned and operated by LEAD (“the Company”, “we”, “us” or “our”), a 501(c)(3) non-profit corporation based in the State of Illinois. LEAD interacts with students and clients through its services, which include live text conversations, emotional health inquiry, and management tools that enable school staff to support the emotional needs of students throughout the day. The privacy of our adult users: teachers, school social workers, school psychologists, school counselors, school staff, school administrators (collectively, “Educators”), and parents or legal guardians (collectively, “Parents”), and the privacy of children and students (collectively “Children”) who use LEAD’s Services are extremely important to us. We’ve created this Privacy Policy to clearly communicate how we protect, disclose and use the information we collect when LEAD Services are used. LEAD has developed privacy practices to align with applicable laws, including the Family Education Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”) and the Health Insurance Portability and Accountability Act (“HIPAA”).
INFORMATION WE COLLECT
Educators and Parents
When creating an account, educators and parents are asked for the same personal information: first and last name, school, email address, password and role. After registration, they may create profiles for their students and input personal information for them.
Children
Personal: When creating profiles for children, educators and parents are asked for the child’s first and last name, email address, school, grade, birthdate, homeroom teacher and gender.
Emotional, Behavioral & Experiential: Through the use of the student facing Services, children and teenagers record and report how they’re feeling, including how those emotions feel, how much energy they have for the day ahead, if they’ve slept well, if they’re experiencing bullying and other related topics.
HOW WE USE THE INFORMATION
LEAD is committed to protecting the personal information of our users. We do not sell or rent user information to anyone, ever. We also pledge not to collect, use, or share user information for any purposes beyond the authorized educational and social-emotional purposes for which we have been authorized. Our primary goal in collecting information is to provide and improve our Services for your use, to support students and clients in their social emotional learning, and to provide immediate crisis intervention when necessary. The personal information we collect from parents, educators and students is used to provide and improve LEAD services and to notify you of any changes in our services. The emotional behavioral and experiential information we collect from students is used by educators to better understand the experience of the students they support. This information is sent to an easy-to-understand dashboard which educators can access on a daily basis. Educators use this information to track the emotional experience of their students so they can respond to behavioral escalations and student needs in real-time, to inform their use of interventions, to carry out interventions and to track the efficacy of interventions. Furthermore, LEAD will not permit behavioral targeting of advertisements in any way, shape or form.
DATA ACCESSIBILITY
Student personal information may be accessed by educators for review and correction at all times, either through school staff or by logging into their account. No personal information will be shared with any other third party at any time.
DATA RETENTION
LEAD does not retain student personal information for longer than necessary to deliver services. If a student profile is inactive for more than 12 months, student data will be deleted immediately from all servers and technologies used by LEAD.
DISCLOSURE OF YOUR INFORMATION
Information that is shared with schools is done so for the sole purpose of realizing our vision of creating better life outcomes for all students. We will only share student information consistent with the principles that are outlined in this Policy. LEAD will only contract with future schools and school districts that are consistent with the principles we’ve outlined in this Policy.
SUCCESSOR ENTITIES
If LEAD is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and a prominent notice on our website, of any change in ownership or management, with options regarding your personal information including removing it from LEAD systems entirely, when possible. Any company acquiring all or a part of LEAD’s assets will be required to agree to the terms of the Privacy Policy detailed here.
CHILDREN’S PRIVACY
We are proud to be in compliance with the Children’s Online Privacy and Protection Act of 1998, 15 U.S.C. 6501–6505 (“COPPA”), the Family Educational Rights and Privacy Act of 1974, 20 U.S.C. § 1232g; 34 CFR Part 99 (“FERPA”) and Health Insurance Portability and Accountability Act of 1996, Public Law 104-191 (“HIPAA”). We securely store all information provided by our student users, and remain current on all applicable laws concerning student data.
PROTECTION OF YOUR INFORMATION
LEAD maintains a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of student personal information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. We understand, however, that no system is perfect, and we cannot ensure or warrant the security of any or all of the information you transmit through our services. LEAD systems, however, are end-to-end encrypted, and are fully HIPAA and FERPA compliant, with active HIPAA Business Associate Agreements (BAA) in place.
NOTICE OF CHANGES TO PRIVACY POLICY
We reserve the right to make changes to this Privacy Policy at any time. When changes are made to our Privacy Policy, you, as the Site user, will be made aware through a popup banner where you can provide consent to the changes. Furthermore, our Privacy Policy will indicate the date it was last updated.
You can reach us directly at info@golead.co regarding LEAD’s Privacy Practices or specific concerns about your personal information.
