Last Updated May 3, 2018
DATA PRIVACY BEST PRACTICES
PURPOSE OF INFORMATION COLLECTION
The Geo Listening Monitoring Service is a social media monitoring service that enables participating school or school districts to review contextually relevant publicly available posts for the purposes of better meeting the social and emotional needs of students in a more timely manner. Posts help identify issues affecting schools such as bullying, cyber-bullying, hate and shaming activities, depression, harm and self-harm, self-hate, suicide, crime, vandalism, substance abuse and truancy. The criteria for each client school is derived from state guidelines regarding school safety plans, district and school policies as well as the CDC’s Youth Risk Behavior Study, available here.
To accomplish this goal, our Monitoring Service reviews publicly available social media information, and then curates this information for context to provide participating school or school district designated staff with an accurate and timely report of posts that can help them intervene on behalf of students with regard to their specific need. Geo Listening only provides the information it curates to its participating school or school district client’s designated staff members.
WHAT INFORMATION IS COLLECTED
Geo Listening Monitoring Service allows participating school or school districts to review publicly available social media posts that are directly relevant to school/student safety and mental wellness. Public content from social networks is reviewed and provided to participating school or school districts.
Information reviewed and curated by our Monitoring Service from sites can include a student’s name, grade level, assigned school, social network usernames, date and timestamp of post(s), geo location if available via the Social Network Provider’s user interface and the full content of the public post along with the user’s profile image if no actual name is available on their page.
Geo Listening Monitoring Service does not monitor privatized social pages, text messages (SMS or MMS), email, phone calls, voicemails, browser history or other private content.
Geo Listening Monitoring Service analyzes and reports only publicly available posts that align with school or school district criteria, procedures and board policies related to school safety plans.
Geo Listening does not circumvent any personal privacy settings on any of the platforms from which it reviews content. Our Monitoring Service is intended solely to review publicly available information.
HOW INFORMATION IS USED
Information reviewed by Geo Listening Monitoring Service that falls into one of the school safety categories is aggregated into dynamic, daily or special reports, which our Monitoring Service provides to designated administrators of participating school or school districts. The gathered information is used solely for the purpose of generating these reports. Access to these reports is restricted to school administrators, and only accessible via their respective credentials assigned by their employer (school or district) to access and view the prepared reports. As a best practice, all clients are advised to purge the reports after they are reviewed and processed in accordance with their respective policies and state law where applicable. Geo Listening does not use the gathered information for any purposes other than providing our Monitoring Service to school or school district clients.
HOW INFORMATION IS SHARED AND DISCLOSED
To School Districts for Student and School Safety Purposes
As Required by Law
Geo Listening will disclose information where required by law and when Geo Listening believes disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order or legal process served on our website. Geo Listening will also purge any personally identifiable information (PII) regarding curated posts in accordance with any law that requires the deletion of records. PII is relevant to serving each client’s need. Once that need is met, industry best practices and existing rules of law regarding PII will be applied to any data. No PII will be maintained once a contract obligation is met and not continued. All PII that can be identified by way of school or district notification will be purged in accordance with law.
Acquisition or Other Transfer
Other than as described above, Geo Listening does not share or disclose the information that our Monitoring Service curates with any other third parties.
WHAT AND HOW LONG INFORMATION IS RETAINED
YOUR PERSONAL CHOICES
Access To and Amending Records
You have the right to access and amend any information Geo Listening Monitoring Service may have curated on you. You may access these records by contacting the Geo Listening Data Privacy Supervisor at:
ATTN: Data Privacy Supervisor
665 San Rodolfo Drive 124 B120
Solana Beach, CA 92075
How to Opt Out
If you would like to ensure that Geo Listening Monitoring Service does not monitor the content that you post through a social media platform or profile, you should ensure that your social media posts are non-public. Our Monitoring Service only reviews publicly available information. Therefore, if a social media platform includes settings that allow you to designate your posts as private, doing so will ensure our Monitoring Service will not review your posts.
Geo Listening has implemented a variety of commercially standard encryption and security technologies and procedures to protect information stored from unauthorized access. Please be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Geo Listening strives to use commercially acceptable means to protect all stored information, but we cannot guarantee its absolute security.
Geo Listening also maintains standard physical and electronic procedural safeguards that limit access to stored information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities related to the our Monitoring Services, need to access the information.
Compromise of Information
In the event that any information under Geo Listening’s control is compromised as a result of a breach of security, Geo Listening will take reasonable steps to investigate the situation and where appropriate, notify participating school or school districts of individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Geo Listening, through our Monitoring Service, does not knowingly collect or solicit any information from any individual under the age of 13 absent parental or guardian consent, nor do we direct any of our business practices or system outputs towards children under the age of 13.
Geo Listening is committed to respecting the privacy of children online and ensuring that our Monitoring Service is fully compliant with the Children’s Online Privacy Protection Act (COPPA). In the event that we learn that we have collected personal information from a child under the age of 13 without verification of parental or guardian consent, Geo Listening will promptly notify the participating school district representatives and delete any personal information associated with that child as quickly as possible. If you believe that we might have unauthorized information from or about your child who is under the age of 13, please contact our Data Privacy Supervisor at the contact information provided.
Social media platforms are required by COPPA to employ age-gate restrictions on the use of the platforms by children under the age of 13. The social media platforms from which our Monitoring Service reviews information are not directed at children under the age of 13. Geo Listening’s review and storage of publicly available information includes information from public websites and profiles that may have in error, or with the consent of the parents, granted accounts to children under the age of 13. While we assume age-gate verification processes of third party websites are effective, and make no warranty as to the verification practices of other websites and services, we will take reasonable steps to identify and delete any records that do not comply with COPPA.
Data Privacy Supervisor:
ATTN: Data Privacy Supervisor
665 San Rodolfo Drive 124 B120
Solana Beach, CA 92075