Swank K-12 Streaming Data Privacy Policy
Swank K12 Streaming solution is a video streaming platform provided to schools and districts, enabling access to feature films and documentaries for educational support. We partner with hundreds of movie studios and independent film makers to offer a library of over 20,000 films to schools. K12 Streaming is a cloud based SaaS application hosted in the Microsoft Azure cloud.
What is the security model for this solution?
K12 Streaming is hosted in the Microsoft Azure Cloud using Azure App Services. Azure App Services provides 24-hour threat management and protects the infrastructure and platform against malware, distributed denial-of-service (DDoS), man-in-the-middle (MITM), and other threats. These safeguards reduce the risk of a potential malicious breach of student data.
Type of data we collect and purpose
Internet Address’s (IP Address) from the computer or device used to access the K12 Streaming platform are stored in the K12 Streaming database hosted in the Microsoft Azure cloud. The purpose for storing this data is to provide usage-reporting data to the school. Email addresses or a unique user name may be stored if provided by the school as part of the onboarding process. This data is also stored in the K12 Streaming database in the Microsoft Azure cloud.
Disclosure of information collected with third party contractors
We will not sell or trade any K12 Streaming data with third parties. Please contact our Swank Data Protection Officer for additional information.
Your Access to the information we hold
Parents (includes legal guardians or persons in parental relationships) can expect the following:
The right to inspect and review the complete contents of the data we may store in the K12 Streaming service which is limited to IP address, email address and username.
You also have the right to require inaccuracies of information be corrected.
Lastly, you have the right to request data deletion. See below for whom to contact to obtain access to your data and make necessary corrections.
Breach Notification Response Plan
In the event that sensitive data is accessed or obtained by an unauthorized individual, we shall provide notification as soon as possible and no later than within ten (10) days of the incident.
Swank Motion Pictures will follow this process when a breach event is declared. The security breach notification shall include a list of the types of personal information that is reasonably believed to have been the subject of a breach. If the information is possible to determine at the time the notice is provided, then either (1) the date of the breach, (2) the estimated date of the breach, or (3) the date range within which the breach occurred will be shared. The notification shall also include a general description of the breach incident, if it is possible to determine at the time the notice is provided. Updates will be provided when investigations have completed.
Student Data Privacy
Licensee (the school) represents and warrants that it has the authority to provide any necessary consent under the Children’s Online Privacy Protection Act (“COPPA”) on behalf of parents or guardians of students for Swank’s collection of their students’ personal information, as permitted by Federal Trade Commission guidance. Licensee understands that Swank is relying on Licensee’s consent on behalf of parents to collect personal information from students who are under the age of 13 in connection with Swank’s provision of the services. By enabling access for its students, Licensee confirms that it is authorizing Swank to collect and use limited personal information from students for the sole purpose of providing the services under this Agreement. For students aged 13 and older, Licensee further represents and warrants that it has the authority under applicable federal and state law, including any applicable state student privacy statutes, to consent to Swank’s collection and use of limited personal information from such students in connection with the services provided under this Agreement.
The parties acknowledge that in providing the services, Swank will receive limited personal information from the Licensee’s authenticated users, which may include individual device identifiers (e.g., IP address). Institutional email address, first and last name (“Student Data”) may be collected if SSO login protocols are used by the institution, first and last name (“Student Data”). Swank shall use Student Data solely for the purpose of providing, maintaining, and supporting the services as described in this Agreement. Swank shall not use Student Data for any other purpose, including but not limited to marketing, advertising, or selling Student Data to third parties. Nothing herein shall prohibit Swank from disclosing Student Data, when necessary, to service providers or vendors of Swank that Swank uses in connection with its provision of the services.
Swank acknowledges that it may be designated as a “school official” with a “legitimate educational interest” under the Family Educational Rights and Privacy Act (FERPA). Swank agrees to handle all personally identifiable information from student education records in accordance with FERPA and will not disclose such information except as permitted by law and the terms of this Agreement. Swank agrees to maintain reasonable administrative, technical, and physical security measures to protect the confidentiality and security of Student Data. Upon written request from the Licensee for the deletion of a specific user’s Student Data or to exercise any other rights available under FERPA, Swank will take commercially reasonable steps to delete such data from its systems or to fulfill the request. Swank will not respond directly to any requests Swank receives from students or parents to exercise their rights under FERPA, and instead, will direct all such requests through Licensee.
Questions Regarding This Privacy Policy
Please submit questions to DPO@Swankmp.com
Contact Information
If you have questions, concerns or feedback regarding this privacy policy, what data we collect, or what we do with the data collected, please contact:
Data Protection Officer Name: Kevin Dietz
Email: DPO@swankmp.com
Address:
Information Security
10795 Watson Road
St. Louis, MO 63127