Data Privacy Policy
for Richer Picture® Subscribers

Last Updated: March 2020

Thank you for being a Richer Picture participant! Students and schools have used our online tools to create portfolios, earn badges and generate personal learning plans.

At Ideas Consulting, Inc. (the company that produces Richer Picture products and services), we are committed to data privacy. This policy document outlines our commitments.

(In this document, "you" refers to a student or educator user of our system and both "we" and "Richer Picture" refers to the company, Ideas Consulting. "School" refers to the school, district or other educational agency that has subscribed to our service. "Parent" refers to the student’s parent, guardian or other legally designated caretaker.)

We commit to:

What Data is Collected?

Richer Picture is a subscription service. When a school or district subscribes, we are provided with data to set up the accounts, including your name, grade level or graduation year, school identification number, and class schedule. Depending on the features included in your school’s subscription, we may also have contact information such as addresses, phone numbers or email addresses in order to contact parents and/or prepare reports such as transcripts. Schools may also upload other data about students (for example, test scores, course grades, credits earned, or days absent) to help with features such as Individual Learning Plans.

Through Richer Picture, students and teachers can add data on their own, such as assignments, classwork, samples of activities, goals for the learning plan, or reflections and comments. The work uploaded by students and teachers could include documents in any electronic format, such as (but not limited to) word processed documents, scans, spreadsheets, images, audio, video or presentations.

We consider all data to be confidential and to be owned by the student or school. "Data" in this policy includes all Personally Identifiable Information (PII) for all users, student data, staff data, and user content.

School Partners

We are glad to partner with schools, and our services are meant to support the educational missions of the schools. We ask that each school maintain a primary contact, who can then relay information between Richer Picture and the school’s stakeholders.

Designated individuals at each school will have the ability to grant or allow access to Richer Picture products by creating accounts and setting permissions. These school officials should understand that granting or allowing access to an individual means that individual will have access to student and/or staff information (whether by an intentional action, such as authorizing or creating a Richer Picture account for an individual, or by unintentional actions, such as a problem with a school’s own data governance or security practice). School officials need to ensure that any person who is given access to Richer Picture products has a legitimate need for access to the available information.

In cases where the Family Educational Rights and Privacy Act (FERPA) applies, access to certain student information remains the legal responsibility of the applicable school.

Richer Picture endeavors to use best practices regarding data privacy, and to be in compliance with all local, state and national laws. Should new policies be adopted by a school district or other agency, Richer Picture will be glad to comply, upon written notice of such new policy.

Student Information

FERPA and Education Records

The Family Educational Rights and Privacy Act (FERPA) defines "education records" are "those records, files, documents and other materials which (i) contain information directly related to a student; and (ii) are maintained by an educational agency or institution or by a person acting for such agency or institution."

PII from education records includes information, such as a student's name or identification number, which can be used to distinguish or trace an individual's identity, either directly or indirectly through linkages with other information.

FERPA requires that educational institutions and agencies that receive certain federal funds (for example, public schools) get prior consent from a parent or legal guardian before disclosing any education records regarding that student to a third party. As guidelines from the US Department of Education note, there are limited exceptions to this requirement; Richer Picture receives certain data from the education records since we act as "a contractor, volunteer or other party to whom the school has outsourced institutional services or functions."

Richer Picture only uses PII from students' education records to enable the use of Richer Picture products. Unless a school official expressly instructs otherwise, we will not share or reuse PII from education records for any other purpose. While we think those statements are clear, to avoid any doubt, we will not use student PII to target students or their families for advertising or marketing efforts or sell rosters of student PII to third parties.

Children’s Online Privacy Protection Act (COPPA)

The Children’s Online Privacy Protection Act (COPPA) is a federal law designed to protect the privacy of children under 13 years old. COPPA requires that Richer Picture provide parents with notice concerning what personal information is collected from children and how it is used or shared.

Richer Picture’s services are in compliance with the Children’s Online Privacy Protection Act of 1998. This section applies to all students of any age.

1. Individual children are not allowed to sign up for any Richer Picture product. The only way a child may obtain access to a Richer Picture product is through his or her school or parent.

2. Each school is responsible for providing data for student accounts for any Richer Picture product, as noted in the “What Data Is Collected?” section above. For information on how that data is and is not used, see the “Information About Students” and “We commit to” sections above.

3. School contacts and administrators can review, request to correct or delete, and/or refuse to permit further collecting or use of student PII. Any such request may be made by contacting us through the contact information listed in the “Contact Information” section below. Parents or legal guardians who request changes to student data should go through a school contact or administrator.

Schools Outside the United States

For schools outside the United States, Richer Picture’s data privacy policies will endeavor to be in compliance with that nation’s statutes. If there are any amendments and adoptions of this policy needed to comply with those statutes, those will be noted in linked documents.

Connections with Other Services

Your school may be using other services to collect data, and your school may authorize Richer Picture to send or receive data from those services. For example, most schools use a "student information system" (SIS) to build class rosters and schedules, and schools may want to send that roster information into Richer Picture to make it easier to organize information such as classroom assignments. Any transfer of data will only be performed when authorized by a school administrator.

Additionally, we use cookies expressly for managing users’ browser sessions for the convenience of the user. The acceptance and storage of cookies can be managed through your browser’s security settings.

A cookie is a small text file that is sent to your computer or mobile device by our server. We use cookies to collect tracking information and to remember information you have given us. This is done so that you don't have to reenter the information each time you connect to our online services. Most web browsers can be set to inform you when a cookie has been sent to you and provide you with an opportunity to refuse that cookie or to remove it later. Please note that if you remove or chose not to accept our cookies, you will need to reenter your information and reselect your preferences each time you use our online services.

If your school authorizes integration with Google and Google Classroom accounts, your school will be asked to grant Richer Picture certain permissions:

These permissions are necessary so that:

As with all other data, Richer Picture will not use or sell this information in any way other than the intended purposes stated in this document.

PII Disclosure and Retention

Information collected through this Site may be provided to companies or organizations who perform work for us under contract. Any such contractor will be held to the same privacy policies described in this document.

Richer Picture will not distribute to third parties any staff data or student data without the consent of either a parent/guardian or a qualified educational institution except in cases of Possible Student Situations (PSS), which may be reported to law enforcement.

If a student transfers from one district to another also using Richer Picture, we will transfer the student’s data upon a written request from an authorized individual from the receiving district.

Student or staff data might be disclosed in order to comply with a court order, law or legal process (including a government or regulatory request). Prior to disclosing data to any such legal request, we will provide the school with notice of the requirement so that, if the school so chooses, it could seek a protective order or another remedy. If after providing that notice we remain obligated to disclose the demanded student or staff data, we will disclose no more than that portion of data which, on the advice of our legal counsel, the order, law or process specifically requires us to disclose.

If a third party purchases all or most of our ownership interests or assets, or we merge with another organization, it is possible that we would need to disclose data to the other organization following the transaction, for example, to integrate Richer Picture with the other organization’s product offerings. If such a transaction would alter our practices relative to this Policy, we will give schools notice of those changes and any choices they may have regarding student or staff data. Furthermore, in the case of a merger or acquisition by another company, we will make sure the successor entity is subject to the same privacy commitments as set forth in this policy for any PII collected by us before the merger or acquisition.

There may be times where we de-identify Personally Identifiable Information, for purposes such as creating a report aggregating an entire school’s data. The U.S. Department of Education has published guidelines for how PII in education records can be de-identified . We may use de-identified information for the purpose of improving Richer Picture products and services. We will not attempt to re-identify de-identified data and will not transfer de-identified data to any party unless that party agrees not to attempt re-identification. We will use reasonable de-identification approaches and protect the privacy and security of the PII.

Data Security and Protection

Richer Picture has put measures in place that are designed to secure PII from accidental loss and unauthorized access, use, alteration and disclosure. This includes our use of SSL technology to encrypt data as it is transferred to and from Richer Picture. To safeguard against data loss, all Richer Picture data is stored in multiple databases with extensive redundancy and failover maintained at data centers located in two geographically dispersed locations in the United States. We maintain logs to track data modification and additional security measures have been implemented to prevent and identify data tampering. While we have taken these measures, we must acknowledge that the transmission of information via the Internet is not completely secure and, although we do our best to protect PII, neither we nor any other hosted service provider can guarantee the security of all personally identifiable information.

In the extremely rare case of a data breach, we will immediately notify all affected customers through the designated school contacts. It is the responsibility of our school contacts to contact parents or legal guardians regarding a data breach.

Data Removal Upon Expiration of Agreement

Upon the expiration or termination of any agreement/contract between a school or school district and Richer Picture, Richer Picture will deactivate all accounts, and provide a copy of all school data to the school’s designated contact. Upon acknowledgement that the school has received the data, Richer Picture will remove the data from all online servers.

Data Correction

We only accept requests to change data from school contacts and administrators. Parents or legal guardians who request changes to student data should go through a school contact or administrator.

Changes to this Policy

We may update this Policy from time to time. If we make material changes, the updated policy will be posted on this page. Users will see a banner (or similar notification) on the login page and will be able to click on an “I agree” button if they consent to the new policy.

Contact Information

If you have any questions about this policy, please feel free to contact us at:

Richer Picture Support
c/o Ideas Consulting, Inc.
134 Thurbers Avenue, Suite 118
Providence, RI 02905
Phone: (401) 785-0401