Character Lab is a trusted nonprofit organization that connects researchers with educators, students, and other youth to cultivate the conditions that lead to social, emotional, academic, and physical well-being for young people everywhere. We are on a mission to advance scientific insights that help kids thrive.
What PII is collected through Research Network?
Through the Research Network platform, we collect information from youth participants that can be used to identify those participants with reasonable certainty (i.e., PII). The PII we collect may depend on whether a youth participant is accessing the platform through their school, parents, or themselves:
- To participate in Research Network research activities and access the platform through our partnerships with schools, students at those schools will be asked to create accounts by providing their school email address, student ID number, and school information. Schools may also create accounts for students by providing their name and/or student ID number, and may input other information related to their students’ character development through Research Network.
- To participate in Research Network research activities and access the platform outside our partnerships with schools, youth participants may be asked to create accounts by providing their email address, first and last name, birth date, state and zip code of residence, and parent or legal guardian email address in addition to basic demographic information. After completing an age verification process, we will contact the parent or legal guardian of those youth participants who are not old enough to consent for themselves (17 years or younger in most states) to obtain parental consent.
What commitments does Character Lab make to protect the privacy of PII?
- We will not collect, use, share, or retain PII for any purpose other than as authorized.
- We will not share PII with a researcher unless authorized and then only subject to strict protections.
- We will not partner with any for-profit entity to provide it with PII collected through Research Network.
- We will not sell PII.
- We will not use or disclose PII for commercial purposes.
- We will not build a personal profile of a student other than to facilitate our scientific services, which support educational or school purposes.
- We will support access to and correction of PII by research participants or their parents.
- We will maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of PII 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.
Consistent with the above assurances, Character Lab commits to comply with all of the requirements of the K-12 School Service Provider Pledge to Safeguard Student Privacy 2020.
What is the K-12 School Service Provider Pledge to Safeguard Student Privacy 2020?
The K-12 School Service Provider Pledge to Safeguard Student Privacy 2020 (“Student Privacy Pledge”) is a voluntary and legally enforceable pledge by K-12 service providers to carry out responsible stewardship and appropriate use of student PII (i.e., PII collected through our partnerships with schools). By taking the pledge, service providers agree both to support the effective use of student PII, both to support the effective use of student PII and to safeguard student privacy and information security. The Federal Trade Commission or state Attorneys General have legal authority to ensure signatories to the pledge maintain their commitments. Character Lab is a signatory of the Student Privacy Pledge, and we commit to comply with all of the requirements of the Student Privacy Pledge. For more information, please visit https://studentprivacypledge.org/.
How does Character Lab protect the privacy of PII disclosed to researchers?
This is how it works. Information collected from research participants through Research Network is stored by Character Lab, and may include PII. As a default rule for research authorized by schools, Research Network anonymizes PII before providing it to researchers, so that researchers cannot identify individual participants with reasonable certainty when conducting their research.
It is possible that some research participants may volunteer PII in a free-form response that is provided to a researcher, or that some schools or parents will authorize research involving the collection of PII, for example during participation in a video interview. If a researcher receives PII, the researcher is required to use the information only in support of the study and consistent with our policies.
Does Character Lab use any other service providers to help provide Research Network?
To help host the services, Research Network may use one or more third-party service providers (“Vendors”) that have been vetted by Character Lab with respect to the Vendor’s representations about how PII is transmitted, stored, processed, and maintained by the Vendor. For PII collected through our partnership with schools (“Student PII”), Character Lab will enter into an appropriate agreement with each Vendor that comports with Character Lab’s role as a School Official and as a Research Studies provider under FERPA.
Can schools use Research Network in compliance with FERPA?
Yes. Research Network enables schools to comply with the federal Family Educational Rights and Privacy Act (“FERPA”).
FERPA applies to “educational agencies and institutions” that receive federal funding from the Department of Education. For example, most K-12 public schools are subject to FERPA. Because Character Lab is not an “educational agency or institution,” it is not directly subject to FERPA. However, to the extent that Character Lab collects student PII about a school’s students through Research Network, FERPA may require the school to impose certain restrictions on how Character Lab can use and disclose that information.
Under FERPA, schools can permit third parties like Character Lab to collect student PII on its behalf, without parental consent, in limited circumstances, including: (1) where Character Lab serves in the role of a “School Official” as defined by FERPA, and (2) where Character Lab facilitates particular research studies under FERPA.
Under FERPA, contractors, consultants, volunteers, or other parties to which an educational institution has outsourced institutional services or functions may be considered “School Officials.” A school may allow Character Lab to handle student PII on its behalf where Character Lab serves in the role of a “School Official.” Character Lab serves the role of a “School Official” where it:
- performs an institutional function for the school for which the school would otherwise use its employees;
- remains under the direct control of the school for the student PII it receives; and
- uses the student PII only for authorized purposes, and does not disclose the student PII to other third parties unless otherwise authorized by the school or allowed by FERPA.
In guidance on how schools can comply with FERPA when using online educational services, the U.S. Department of Education has indicated that these criteria can be met through a signed agreement that restricts the online educational service from using student PII for unauthorized purposes. Character Lab’s agreements with schools provide schools with the authority to control Character Lab’s use, maintenance, and re-disclosure of student PII consistent with these requirements.
As discussed above, Character Lab discloses only anonymized data to researchers unless specifically requested by schools. Such disclosures are not re-disclosures of student PII and therefore are not restricted by FERPA.
FERPA separately allows schools to disclose student PII to Character Lab and researchers where:
- the student PII is used to conduct studies for or on behalf of the school to (a) develop, validate, or administer predictive tests, (b) administer student aid programs, or (c) improve instruction;
- the study is conducted in a manner that does not permit personal identification of students by individuals other than employees, contractors, and agents of Character Lab and the researchers that have a need to access the information for the authorized purposes;
- the information is destroyed when it is no longer needed for the purposes for which the study was conducted; and
- the school enters into an appropriate written agreement with Character Lab, with certain elements specified by FERPA.
Can schools use Research Network in compliance with the Protection of Pupil Rights Amendment?
Yes. The Protection of Pupil Rights Amendment (“PPRA”) is a federal law that allows parents to decide whether their children, while in school, may participate in a survey, analysis, or evaluation that reveals information concerning certain sensitive topics, such as political affiliations, religious practices, and income.
Character Lab’s policy is that schools and researchers may not use Research Network to conduct research intended to reveal information concerning topics covered by the PPRA. Therefore, the PPRA is not implicated by a school’s use of Research Network in accordance with this policy.