Character Lab is a trusted provider of school research services working to deepen understanding of student character strengths like grit, gratitude, curiosity, and self-control. We are on a mission to advance scientific insights that help kids thrive.
We have developed our online Character Lab Research Network (“Research Network”) platform to seamlessly connect schools with character development researchers. Researchers create activities that they make available through Research Network, which come in various forms including but not limited to surveys, open-ended responses, short video clips, and gamified tasks. Schools that connect with those researchers make Research Network available to their students, who can then participate in those activities.
What student PII is collected through Research Network?
To participate in Research Network research activities, students will be asked to create accounts by providing their school email address, student ID number, and school information. Teachers 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.
Students will log on to the platform with their email address or ID number and a password, and will use the platform to perform the research activities. Through the research activities, students may provide responses to research questions related to character development (e.g., grit, growth mindset), perform tasks (e.g., trace a star backwards, identify missing pieces of a matrix), or provide responses to questions after taking part in some sort of task (e.g., watch a video, write a letter). Their participation is voluntary, and they may stop at any time.
What commitments does Character Lab make to protect the privacy of student PII?
- We will not collect, use, share, or retain student PII for any purpose other than as authorized by the school.
- We will not share student PII with a researcher unless authorized by the school, and then only subject to strict protections.
- We will not partner with any for-profit entity to provide it with student PII collected through Research Network.
- We will not sell student PII.
- We will not use or disclose student PII for commercial purposes.
- We will not build a personal profile of a student other than to facilitate our scientific services, which support educational/school purposes.
- We will not support access to and correction of student PII by students or their parents.
- We will maintain safeguards designed to protect the security, privacy, confidentiality, and integrity of student 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. 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 student PII disclosed to researchers?
Because Research Network was created to connect schools and researchers, information collected through Research Network is provided to researchers, as authorized by the school, in order for them to conduct their research. However, Character Lab does not disclose student PII collected through Research Network – such as names and contact information – to researchers unless authorized by the school.
This is how it works. Information collected from students through Research Network is stored by Character Lab, and may include student PII. As a default rule, Research Network anonymizes the student PII before providing it to researchers, so that researchers cannot identify individual students with reasonable certainty when conducting their research.
In some limited circumstances, and only when authorized by the school, Character Lab will disclose student PII to a researcher. Additionally, it is possible that some students may volunteer student PII in a free-form response that is provided to a researcher. Whenever a researcher receives student PII, the researcher is required to use the information only in support of the study and consistent with our policies.
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.
Where schools request Character Lab to allow researchers to have access to student PII to conduct their research studies, Character Lab enters into appropriate agreements with schools and with researchers to permit the disclosure of this information to researchers under this rule.
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.
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 student PII is transmitted, stored, processed, and maintained by the Vendor. Character Lab has entered 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.