PRIVACY POLICY

  • Privacy Policy Overview
    This Privacy Policy explains how ConductMonitor LLC (ConductMonitor) collects and uses information from its users who access the website and use the services, including ConductMonitor's treatment of personally identifiable information.
    ConductMonitor, its affiliates and vendors recognize the importance of data security and customer privacy to our customers. ConductMonitor strives to maintain effective and up-to-date technological and procedural safeguards for protecting personally identifiable customer information, including student information within the scope of the Family Educational Record Privacy Act ("FERPA") and Health Insurance Portability and Accountability Act ("HIPAA"), as described further below.

    Personally Identifiable Information (PII)
    "Personally Identifiable Information" means information collected by ConductMonitor on the website or otherwise provided by users through ConductMonitor mobile applications (apps) which contains identifiable information such as student names, photographs, student identification number, grade level, parent email addresses and/or phone numbers, usernames, or passwords.
    ConductMonitor will not disclose PII associated with your use of the website to any third parties not affiliated with ConductMonitor except as set forth in this Privacy Policy.

    Consent
    Generally, by providing us with Personal Information, we will assume that the user consents to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy, or as otherwise specified at the time of collection.

    Use of Cookies
    You acknowledge and consent to the use of "cookies" in connection with your activity on the website. These cookies are retained for as long as you are registered for the website. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser when you visit and revisit the website. Cookies permit us and our service providers to track the pages you visit and the content you view and are sometimes necessary for the proper functioning of this website. Although the information collected through cookies is not itself considered personal information, such information may enable us to relate your use of the website to other information we have collected about you, including personal information. If you do not want us to be able to store cookies on your hard drive, your browser’s help section should be able to instruct you how you can disable or filter cookies and how to arrange for your browser to notify you when you’ve been sent a new cookie. Disabling certain cookies may, however, limit your ability to use this website or certain features of the website.

    FERPA Privacy Policy
    To help you ensure that your educational institution complies with its obligations under FERPA, we are able as your educational services partner to confirm that ConductMonitor takes numerous measures to maintain the security and confidentiality of all student records by, for example, providing secure hosting facilities for the storage of student data that use encryption and/or physical security measures, as well as firewall protection and restricted, password protected access. ConductMonitor’s behavior documentation tools provide options that allow educational institutions to restrict or grant access to information by certain parties or "roles" within the platform. We also encourage all of our customers to help ensure that confidential information remains secure by using strong passwords and changing passwords frequently. Through its terms of use, ConductMonitor requires that users maintain their passwords in the strictest confidence and prohibits the use or posting of student identification numbers in any manner, or posting of other sensitive personal information by users. Given the complex nature of the services we provide, it is possible that our affiliates and/or third-party vendors may be involved in the hosting and maintenance of the data we collect. In these situations, such parties are bound by confidentiality obligations with respect to such data and are required to follow reasonable procedures to ensure data security. Except for the collection, analysis and use of demographic data (which would be aggregated separately from the students' personally identifying information), student data subject to FERPA is not stored or transferred by ConductMonitor for any purpose other than as reasonably necessary to maintain, support and improve the product for which the data is collected. ConductMonitor, does however, reserve the right to disclose student information without prior consent in certain extraordinary circumstances permitted under FERPA, including disclosures required by law or court order, in extraordinary circumstances to protect the health or safety of the student, as requested by the student’s educational institution and as may be reasonably required to investigate suspected academic misconduct or violations of ConductMonitor’s policies. ConductMonitor, in its role as a provider of centrally hosted behavior documentation tools to teachers, enters into a contractual relationship, through the Subscription Agreement, directly with the individual end-user, school, or local education agency. We believe the above information appropriately addresses questions posed by adopting institutions on how ConductMonitor addresses the FERPA guidelines on management of student consent and personally identifiable information. If you need further information, please contact us at privacy@conductmonitor.com.

    HIPAA Privacy Policy
    Business Associate. According to HIPAA rules (the Rule), ConductMonitor LLC (ConductMonitor) is considered a business associate (see Summary of the HIPAA Privacy Rule from the U.S. Department of Health and Human Services). A business associate is a person or organization, other than a member of a covered entity's workforce, that performs certain functions or activities on behalf of, or provides certain services to, a covered entity that involve the use or disclosure of individually identifiable health information. More specifically, the business associate service ConductMonitor performs on behalf of a covered entity is limited to electronic behavior documentation, data analysis, and data reporting.
    Business Associate Agreement. When a covered entity uses ConductMonitor to perform "business associate" services, the Rule requires that the covered entity include certain protections for the information in a business associate agreement (in certain circumstances governmental entities may use alternative means to achieve the same protections). In the business associate agreement, a covered entity must impose specified written safeguards on the individually identifiable health information used or disclosed by ConductMonitor. A covered entity may not contractually authorize ConductMonitor to make any use or disclosure of protected health information that would violate the Rule.

    Changes to Privacy Policy
    ConductMonitor may make changes to this Privacy Policy from time to time for any reason. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used. We will notify you via email or by posting an announcement on the website of any changes in the way we use PII. After changes in the Privacy Policy are emailed to users or posted on the website, users are bound by those changes.

    For More Information
    Contact us at privacy@conductmonitor.com if you have any comments or questions regarding this Privacy Policy.

    Effective date: November 6, 2012