Privacy & Security Policy
What We Believe
Spotlight exists in order to make data more understandable, meaningful and useful to non-data-oriented users, ranging from parents to teachers and administrators.
We believe that data can be powerful, enough to shape the way we educate children, if parents, educators, administrators, policymakers and the public are able easily to understand it and put it to use. But if education data isn’t trusted by those very users, it will never be put to full use in education our kids. It is thus in Spotlight’s core interest to ensure that education data is transparent and trusted.
We commit to using data only for the betterment of instruction and operation in our schools and other education institutions. Spotlight uses data, ranging from student-level information to data about operating entire school districts or even state education agencies, to produce narrative-text reports enable this improved instruction and operation – and for no other purpose.
At base Spotlight complies with the terms of the Family Educational Rights and Privacy Act (FERPA). Well beyond this, though, Spotlight seeks to elevate the discussion about education data and its proper and effective use.
Who Uses Data at Spotlight
All Spotlight employees are committed to our vision of developing a greater sense of understanding and trust of education data, and all employees sign the Spotlight Data Privacy Pledge immediately upon hiring.
To this end, all employees are trained to ensure that student information is stored, used and transmitted securely, and generally to place privacy and security above all other priorities; while we do not see data privacy as being in conflict with Spotlight’s business objectives, employees are taught that if this ever comes to a decision, students’ privacy is a far more significant priority than advancing the business.
Spotlight restricts physical access and permissions to those for whom student data is relevant and necessary to perform their job functions and to complete work on behalf of school districts or other educational institutions. Spotlight’s founding executive team considers itself the “last line” and ultimately responsible in ensuring that student information is kept confidential.
How Data Is Transmitted and Used at Spotlight
Spotlight’s core technology serves as a reporting layer. This software temporarily makes use of data to derive and communicate insights; it is not a data collector or a data storage platform.
Typically Spotlight draws inputs, sometimes including student data, from the systems of our business partners – assessment platforms, student information systems or other data-gathering and –storing systems; occasionally we obtain data directly from a school district or other institution. Regardless, we enact the simple measure of minimizing the time that our system holds student data, and delete all data as soon as possible upon completing a project.
These partner relationships – both business partners and “direct” clients – are a fundamental aspect of Spotlight’s business and of our approach to privacy and security. Spotlight only conducts business with companies and organizations with proven policies and records of sound data security, and who share our dedication to providing customers with meaningful, useful information. Spotlight screens all prospective customers through a rigorous review process to ensure that their track records and processes are indeed solid.
In working with “direct” clients – school districts and other educational institutions – we provide guidance regarding the best means of securely transmitting data, and we seek their guidance regarding the degree of personal information necessary to produce reports that meet their operational and pedagogical objectives. Individual student information is a “last resort,” used only when it is the sole means by which to produce insights that will benefit those very students. Spotlight also weighs the need for types of personal information that can betray individual students’ identities (e.g., ethnic backgrounds of very small groups in a school or class) against the importance of using such information to derive useful insights.
When Spotlight does receive personally identifiable information (PII), we do so only through a dedicated, encrypted email address, firstname.lastname@example.org. If partners or clients send PII to other email addresses, we delete the file and the message immediately, and then send a fetch request from pii@ via Virtru, which ensures encryption. PII is then only processed on a single computer with an encrypted hard drive — the only computer that uses the pii@ email address — that never leaves the Spotlight office.
Regardless of the purpose for data use and transmission, Spotlight never uses student information for advertising purposes, either its own for on behalf of other organizations. In general Spotlight does not collect, use, or share personally identifiable information for any purposes beyond those authorized by a school or other educational institution, or by a student or parent, nor does Spotlight create student profiles for any purpose other than conducting educationally valid and valuable analysis.
Spotlight’s Security Measures & Practices
While Spotlight does not take on the same level of risk as companies and organizations that store student-level data over extended periods of time – and uses personally identifiable information only as a last resort in providing partners with data-driven insights – we nonetheless have enacted rigorous security measures and practices.
Spotlight’s system is built on Amazon Web Services, known for its “data center and network architecture built to satisfy the requirements of the most security-sensitive organizations.” We transferred an initial build of our system to AWS largely in order to make use of its proven security protections.
When developing new reporting instances, Spotlight’s production environments only use dummy data, up until the final testing phase. During this phase Spotlight obtains securely-transmitted, anonymized sample data from a partner organization; testing is completed by approved Spotlight staff and results are released to approved partner personnel. We then delete all student data.
In producing reports on behalf of our partner organizations – both business partners and educational institutions – Spotlight receives and sends data as encrypted files. These files are accessible only to approved users; personally identifiable information is stripped out of the files and replaced by unique, anonymous student identifiers. Student data is uploaded to Spotlight’s analysis system through a Secure Sockets Layer to ensure security throughout its use.
Thanks to the limited scope of our data use and to the security measures that we have put in place, Spotlight does not anticipate a security breach. Should this unlikely event occur, however, we will immediately notify any and all impacted parties, including business partners and districts or other organizations, both electronically and by telephone. If our partners’ jurisdictions require written notification, we will immediately comply. Our partners in other jurisdictions may also request written notification. After this initial contact, we will work closely with any and all affected partners and parties to minimize the impact of the breach, and until its effects have been resolved.
Data and Spotlight’s Future
As technology changes the way we understand and communicate student data, so must privacy policies. When this policy changes — as we anticipate that it will indeed need to change over time — we will update our partners and partners via email. These stakeholders will then have the opportunity to review and newly approve this modified policy. We will also provide methods for these partners easily to inform parents and students of these changes, and to provide these users with the ability to understand and approve the new policy.
Should Spotlight merge with or be acquired by another company or organization, we will first require that the new “partner” abide by this policy.
At Spotlight, we look forward to a time when data is no longer mysterious or difficult to put to use, regardless of who you might be – a data analyst, or a software engineer, or a teacher, principal, superintendent or parent. We know that this time will arrive only once education data are framed in a way that all of these users can easily put it to use, and only when we can all feel entirely confident in its security and anonymity. We work every day to move closer to that new paradigm.