Skill Struck’s mission of promoting equity in computer science education relies on the security and efficiency of our systems. We want our partner schools and their administrators, teachers and students to know that Skill Struck is a trustworthy guardian of sensitive data.
This document details our information and cyber security program. Principles of an effective security program include being threat-driven, using automation to scale, and balancing the investment between prevention and response. We regularly adjust our security practices to align with the NIST Cybersecurity Framework.
Our program has three focus areas: product security, infrastructure security, and IT security. The following sections describe each focus area and the set of security activities we practice within each.
The goal of Skill Struck’s product security efforts is to clarify the security and privacy impact of new features as they are being created to let Skill Struck engineering continuously improve the Skill Struck product safely.
We have an application security review process that applies to all new development projects. It includes threat modeling and code review. Security design reviews occur for any major change. We have a secure code review process that identifies high-risk code for manual review by our software engineers. We use automation in our software development build pipeline that analyzes code for potential vulnerabilities through unit tests.
Our engineer portal includes application security training material with secure coding guidelines specific to our technology stack, which all new engineering hires review.
We have an active bug finding program that includes a team reviewing the Skill Struck platform daily to ensure that all reported bugs are fixed in a timely manner. We’re responsive to security inquiries sent to email@example.com.
Skill Struck does not give log file information or student usage information to third parties, except (i) those service providers engaged to support and assist in administering Skill Struck’s Site, or (ii) in a sanitized form disassociated from IP address or other personal data, or (iii) as authorized or directed by the school. Skill Struck stores, transmits, and displays student data only via secure and FERPA compliant methods. Only selected members of the Skill Struck staff have access to student data, and are required to be FERPA certified and must log into the platform using 2-factor authentication.
Skill Struck protects against password brute forcing by rate limiting login attempts. After 5 failed login attempts, then the following guesses require ReCAPTCHA each time. Skill Struck salts and hashes passwords using SHA256, a high-cost hashing function recommended by NIST. Skill Struck requires two-factor authentication for administrator, teacher, and student account access.
Our infrastructure security efforts focus on accelerating the pace of our development teams by providing the underlying tools, systems, processes, and knowledge resources to build secure and privacy-protecting systems.
All of Skill Struck’s infrastructure runs in the cloud. Our primary cloud provider, AWS, conforms to security standards including PCI-DSS, HIPAA/HITECH, FedRAMP, GDPR, FIPS 140-2, and NIST 800-171. See https://aws.amazon.com/compliance/ for more details.
We have a change management process for our infrastructure that includes source code control, peer code review, logging, and alerts for unusual behavior. All production changes are deployed with an automated system that detects reliability issues and reverts problematic deploys. Our automation allows us to safely and reliably deploy code to production dozens of times per day.
Our availability is 99.9% or higher.
We have established a set of practices and tools to defend against automated Denial of Service (DoS) attacks against Skill Struck’s infrastructure. Skill Struck uses Cloudfront to defend against these attacks.
Since our service is based entirely in the cloud, our disaster recovery plan is based on best practices from AWS for maintaining resiliency in the case of disaster. We use multiple AWS availability zones to safeguard against single data-center issues.
Skill Struck generates data backups regularly and stores them securely with our cloud provider. All backups stored offsite are encrypted and deleted securely when they become obsolete - in no case longer than 60 days. Skill Struck’s production systems are housed in a tier-1 hosting facility that is monitored 24 hours a day, 7 days a week. Access to these systems requires prior written approval from Skill Struck management and all access is logged and monitored. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, Skill Struck cannot guarantee its absolute security.
We encrypt all Personally Identifiable Information (PII) in transit outside of our private network and at rest in our private network. All data is encrypted via SSL in transit and by rest by Amazon Web Services. We use industry standard cryptography (AES-256) and access control keys that are regularly audited and rotated. Read more about our security encryption with AWS by referring to their Encryption Reference Guide.
Skill Struck uses logical separation to process data in a multi-tenant environment. The code controls are tested before every production deployment. Data processing occurs in containerized environments with limited access to external resources. Services use ephemeral credentials for services to access data stores. All data is stored in the USA.
Skill Struck limits external access to network services by running them inside of a Virtual Private Cloud (VPC) and blocking all unnecessary ports from external traffic. Access to our production network is limited to necessary personnel, logged, and secured using multiple factor authentication. We use a bastion SSH host to gate all system-level access to production infrastructure.
Skill Struck maintains a centralized log for product and infrastructure events and metrics. Tightly access-controlled and integrity protected log backups are persisted to access-controlled archival stores on S3. All system-level actions performed in production environments with elevated permissions (sudo) are logged.
We have monitoring, alerting, and response processes for suspicious activity occurring in our infrastructure.
No secret data (passphrases, API keys, QR Codes for 2-factor, etc) are sent using tools like Gmail, Dropbox or Slack. We have purpose-built tools for storing and transferring this data in accordance with our security requirements.
We regularly update our operating systems images, container images, language runtimes, and language libraries to the latest known supported versions.
Our information security policy is documented in our Employee Portal. We have a Skill Struck Data Classification standard that describes the different types of data that our employees work with and how that data should be handled.
Our device policy describes best practices for device configuration and software usage for Skill Struck devices. It mandates full disk encryption for all devices that have access to sensitive data, the use of screen locks after a period of inactivity, and remote wipe capabilities. It also describes our permitted software and software update practices.
Our account policies state that all passwords should be securely stored and generated with a password manager, and mandates the use of 2FA for sensitive accounts. It also defines the OAuth authorization policies for accounts with sensitive data access (e.g. GSuite) and the techniques to avoid phishing.
Accounts are activated when an employee joins and deactivated when an employee leaves, using automated processes where possible.
We create a culture of security for all Skill Struck employees through activities like security awareness training, which is completed during onboarding. Our security program that details each of these components is documented in our Employee Portal. All new hires must read the information security policy and undergo information security training, and existing employees have regular refresher training.
We have a third-party software security review process that must be completed before using new services at our organization on official, company-owned devices. The level of verification varies based on the risk profile of the service in question.
All Skill Struck employees undergo criminal background checks and sign agreements barring any use of confidential information outside of the scope of their work with the company.
We have cyber liability insurance with coverage of 1 million US dollars. We also cater our cyber insurance coverage to specific schools and districts as needed.
We conduct an annual external security assessment of our applications. We make the reports associated with these assessments available for our users, on request.
In the event that Skill Struck management discovers that student data or personal information has been accessed or obtained by an unauthorized individual, Skill Struck shall provide notification to the school’s representatives within a reasonable amount of time of the incident, not to exceed 48 hours. Immediately following the discovery of the breach, Skill Struck’s security team will address and resolve the security deficiency accordingly. Such notification will be provided via email and a phone call to the school’s authorized student data privacy representative, and will include the following:
In addition to following this plan, Skill Struck will address each data security breach on a case by case basis, as well as conduct an inspection of its data security measures to improve them, directed by Skill Struck’s security director.
Please reach out if you have any questions concerning this cybersecurity policy.
Chief Privacy Officer
Skill Struck LLC629 E Quality Drive Suite 103
American Fork, UT 84003
Telephone: (801) 252-6768
We may collect data that alone or together with other data would reasonably allow us to determine the identity of a specific person (“Personal Information”). We may also collect data that, standing alone, tells us something about a person but does not reasonably allow us to identify a specific person (“Non-Identifiable Information”). We also may gather and store site-visitation data. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. The term “information” includes all of the above data.
We use different methods to collect information, including:
We solely determine our purposes for collecting your information. Some of these purposes may include:
We also may use your Personal Information to:
We reserve the right to use any student’s image or likeness, as well as any content your student may produce, whether through photographs, adaptations, displays, exhibits, or otherwise, in all markets, media, or technology now or later known. Any image or likeness will be used solely for the promotion, marketing, public education, and fundraising activities of Skill Struck, LLC, and will not include the name of any individuals therein unless otherwise agreed in writing by you. Neither you nor your child will receive any compensation for the use.
We may share your information with:
If we share your Personal Information with third-party purchasers or sellers, we will first anonymize your Personal Information.
While we at our sole discretion may choose to maintain methods to secure your information, we do not guarantee that your Personal Information, Non-Identifiable Information, or other data or communications will be secure. You are solely responsible for carefully handling and disclosing your Personal Information. Please refer to the Federal Trade Commission's website for more information.
We also do not guarantee that any third-party services you may access from our services provide safeguards to your privacy. We encourage you to read the privacy statements of the third-party products and services you use.
Your choices about how we use or collect your information. You can always choose not to provide us with certain information, but not providing that information may result in you being unable to use or purchase our services. If you have provided certain Personal Information to us, such as addresses, credit card numbers, or phone numbers, you may review and update this information at any time by going to your account settings page.
You may control information collected by cookies by updating your browser settings. If you do so, some of our services may not function properly. We may choose not to recognize or respond to any Do Not Track signals.
You may opt out from receiving commercial or promotional emails from us either by visiting your account settings page or by clicking the opt-out link in the emails we send you.
You can choose to opt out of certain data collections and usage:
Retention: After we deem your information no longer relevant to our purposes, we will take steps to have it deleted, aggregated, or made anonymous.
1555 N. Freedom Blvd.
Provo, Utah 84604
Even if Skill Struck courses are offered in conjunction with an outside partner, the partner will not receive any individual personal information from users of the Site, including children. Skill Struck may provide partners with aggregate or de-identified information about users.
As described in further detail below, we collect some personal information from children so that we can track their progress through our courses. Data is retained for education purposes only.
We may collect information about children directly from children, as well as automatically through a child’s use of our Site and Services. We will not require a child to disclose more information than is reasonably necessary to use our Services. A copy of a notice of our privacy practices as posted on the learning platform.
From children under 13, we utilize the date of birth to verify the child’s age but do not store the age. We only store whether or not the child is under 13. If a child is under 13, we collect the child’s first name, and last initial. We do not ask children for their full last name. Children must create their own usernames, but are not required to provide an email. We only use user name and email address (if provided) to track a child’s progress in our courses or to reset passwords; we will not contact a child using his or her email address or username. We may also collect additional demographic information (such as race and gender) from children; however, we do not associate this with the child’s name or other personal information and we use it only to compile aggregate and de-identified information about participants in our courses. Parents may ask us to stop collecting personal information from their child by emailing us at firstname.lastname@example.org. However, in such cases the child will not be able to take or complete our courses. If a parent directs us to stop collecting and using a child’s personal information, we must disable his or her use of our courses to ensure that no information is collected.
We may automatically collect the following information about a child’s use of our Site through cookies and other technologies: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Site; the length of time our courses were taken; Google Analytics statistics; the referring URL, or the webpage that led the child to our Site; language information; device name and model; operating system type, name, and version; and activities within our Site. We may also collect IP address, device identifier or a similar unique identifier from users of our Site, including children; we only use such identifiers to support the internal operations of our Site and we do not use such identifiers to collect information about the child outside of our Site.
We collect information about children’s performance and activities on our Site, including completion of courses. This information is for internal use only and will not be disclosed to other entities; however, we do not use this information in personally identifiable form for our own commercial purposes. Before we analyze or use any activity data for our own commercial purposes, we de-identify and/or aggregate such information.
We use personal information collected from children for the following purposes:
We de-identify and/or aggregate the information we collect from children under 13 before we use it for any other purposes, as noted below.
Unique Identifiers. We only collect and use unique identifiers, such as IP addresses, as necessary to operate our Site or Services, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and our Site and Services. We never use unique identifiers to track users across third-party apps or websites.
Aggregate or De-identified Information. We may use aggregate or de-identified information about children for research, analysis, and similar purposes. When we do so, we strip out names, e-mail, contact information, and other personal identifiers. We may use aggregate or de-identified information for the following purposes:
We do not sell children’s personal information, and a child may not make his or her personal information public through our services without their parents approval. In general, we may disclose the personal information that we collect about children to provide our Services, to comply with the law, and to protect Skill Struck and other users of our Services. For example, we may share children’s personal information as follows:
Parents have a right to review the information we have collected about their children and students, respectively, and to delete it, and to tell us to stop using it. To exercise these rights, you may contact us at email@example.com. You will be required to authenticate yourself as the child’s parent to receive information about that child. Please note that copies of information may remain in cached or archived form on our systems after you request us to delete it.
This COPPA Policy is current as of the Effective Date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. We will post any changes to this COPPA Policy on our Site, at skillstruck.com. If we make any changes to this COPPA Policy that materially affect our practices with regard to the personal information we have previously collected from a child, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.