Swank Digital Campus Data Privacy Policy

 

Swank streaming solutions are video platforms 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. Swank streaming solutions are cloud based SaaS applications hosted in the Microsoft Azure cloud.

What is the security model for this solution?

The Swank streaming platform is hosted in the Microsoft Azure Cloud using Azure App Services.  Azure App Services provide 24-hour threat management and protects the infrastructure and platform against malware, distributed denial-of-service (DDoS), man-in-the-middle attacks (MITM), and other threats.  These safeguards reduce the risk of a potential malicious breach of any data.  All data in our Azure SQL instance is encrypted at rest.

 Type of data we collect and purpose

Internet Address’s (IP Address) from the computer or device used to access the streaming platform are stored in the streaming cloud 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 or individual in order to facilitate additional levels of access with the streaming platform.  

Disclosure of information collected with third party contractors

We will not sell or trade any streaming data with third parties. Please contact our Swank Data Protection Officer for additional information. 

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. 

 

 

 

PPRA

Swank Motion Pictures does not collect, store or provide any student records with direct identifiers such as a student’s name or identification number, parent’s name, or address; and indirect identifiers such as a student’s date of birth, which when linked to or combined with other information can be used to distinguish or trace a student’s identity to third parties.  IP addresses, usernames and email addresses are collected for internal usage reporting.  Swank Motion Pictures does not share this data with any third party nor is it correlated with any user content data.  The data collected by Swank Motion Pictures complies with all data collection, privacy and security of the Protection of Pupil Rights Amendment (PPRA) (20 U.S.C. § 1232h; 34 CFR Part 98)

FERPA

Swank Motion Pictures does not collect, store or provide student data as described in The Family Educational Rights and Privacy Act (FERPA).  In accordance with this law, Swank Motion Pictures can attest that no student records with direct identifiers such as a student’s name or identification number, parent’s name, or address; and indirect identifiers such as a student’s date of birth, which when linked to or combined with other information can be used to distinguish or trace a student’s identity.  IP addresses, usernames and email addresses may be collected for internal usage reporting.  This data is never disclosed publicly and is never used for online contact.   Swank Motion Pictures complies with all data collection, privacy and security requirements in The Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g; 34 CFR Part 99.

COPPA

Swank Motion Pictures does not collect, store or provide student data as described Children’s Online Privacy Protection Act (COPPA).  Children under the age of 13 can access the streaming service.  In accordance with this law, Swank Motion Pictures can attest that no student records with direct identifiers such as a student’s name or identification number, parent’s name, or address; and indirect identifiers such as a student’s date of birth, which when linked to or combined with other information can be used to distinguish or trace a student’s identity.  IP addresses, usernames and email addresses may be collected for the sole purpose of internal usage reporting.  This data is never disclosed publicly and is never used for online contact.  Swank Motion Pictures complies with all data collection, privacy and security requirements described in the Children’s Online Privacy Protection Act (COPPA) 15 U.S.C. 6501–6505.

                          

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