In the delivery of our Services, D2L and its affiliates may engage and use data processors to assist in providing D2L Services who may have access to and/or process Client Data (“Subprocessors”). This page provides information regarding each of these Subprocessors including a description of the Subprocessor services, the type of data made available for processing, and the location of data processing. Terms used on this page but not defined have the meaning set forth in the applicable written agreement between your organization and D2L (the "Agreement").
Cloud Providers
Subprocessor: AWS
Purpose: Infrastructure as a Service provider.
Location of processing: USA, Canada, Australia, Republic of Ireland, Singapore, India, depending on the location of the customer
Degree of Personal Data Processing: None. The data is encrypted and cannot be seen by AWS, so they should not be considered a processor of the data.
Third-Party Apps in Brightspace Core (Client Facing)
Subprocessor: Bongo (optionally used if enabled in Brightspace)
Purpose:
Virtual Classroom: Schedule live discussions, office hours, video-based training, and more. Video sessions can be automatically recorded and seamlessly embedded directly into a course alongside other learning materials
Video Assignments: Deliver structured, video-based assessments that evaluate learners on speeches, presentations, and more. Instructors can easily grade video assessments and add time-stamped feedback, showing learners exactly where they need to improve.
Location of processing: The USA, Republic of Ireland, Canada (except video transcoding), Australia (except video transcoding), South America (except video transcoding, depending on the location of the customer
Degree of Personal Data Processing: User data – names and grades
Optional Third-Party Apps (Client Facing)
Subprocessor: Connected Shopping
Purpose: Course catalogue to enable the automated registration of learners into the Brightspace Learning Environment
Location of processing: USA, United Kingdom, Canada, Australia, Singapore depending on the location of the customer
Degree of Personal Data Processing: Basic registration fields captured such as First Name, Last Name, Address, Course Purchased, Date, Payment Method, Net Value of Sale, Tax, Gross Value of Sale, Discounts Received
Subprocessor: Domo
Purpose: Formatting of reports requested from the system by clients
Location of processing: The USA, Republic of Ireland, depending on the location of the customer
Degree of Personal Data Processing: User personal data within the system
Subprocessor: Critique^it
Purpose: Rich-media annotation and anonymous grading for assignments. Instructors and peers can add inline comments and markup to documents, presentations, and more.
Location of processing: The USA, Republic of Ireland, depending on the location of the customer
Degree of Personal Data Processing: User data - annotations and grades
Subprocessor: Integrity Advocate
Purpose: A software company that provides identity verification, participation monitoring, and examination proctoring for online training events.
Location of processing: Canada
Degree of Personal Data Processing: User data - Student ID for validation (which is deleted after a short period of time from its servers)
Subprocessor: Janison
Purpose: From authoring questions to receiving the data after the assessment event, Janison Insights is a suite of tools for running online exams and tests.
Location of processing: Australia, Europe, or Singapore depending on the location of the customer.
Degree of Personal Data Processing: Basic registration fields are captured such as First Name, Last Name, Email Address, as well as assessment data related to learners.
Subprocessor: Urkund
Purpose: An automatic text-recognition system made for detecting, preventing, and handling plagiarism.
Location of processing: USA or Europe depending on the location of the customer
Degree of Personal Data Processing: Email address, Linguistic style, IP address, Shibboleth identity, Name, Document (which may contain personal data in the text of the document), Email messages (which may contain personal data in the body of the message), Submission comments (which may contain personal data in the text)
Subprocessor: ShuffleLabs
Purpose: Custom software development company is the parent to the Integration Platform as a Service (iPaaS), ShuffleExchange. ShuffleExchange is an integration platform that runs the Brightspace Course Connector for Microsoft Teams which connects Brightspace to Microsoft Teams
Location of processing: The USA, the Republic of Ireland depending on the location of the client.
Degree of Personal Data Processing: First Name, Last Name, Email Address, User’s role in Brightspace
Platform Apps (Internal)
Subprocessor: AppDynamics
Purpose: Application Performance Monitoring tool that pulls metrics regarding how D2L applications are performing (primarily Brightspace), both from the server perspective (e.g. stack traces, errors, response times) and the Client perspective (e.g. browser, browser version, geodata)
Location of processing: USA
Degree of Personal Data Processing: The IP address is gathered as part of the Client data set. There is also a high-level overview as to what was being done in Brightspace; this involves metadata such as city, ISP, OS, and Browser. There are no user names or passwords.
Support
Subprocessor: ServiceCloud
Purpose: D2L’s ticketing systems
Location of processing: ServiceCloud - Canada
Degree of Personal Data Processing: Users’ first and last names along with email address, phone number, and email communication.
Subprocessor: Medallia
Purpose: Platform for client satisfaction surveys
Location of processing: Canada
Degree of Personal Data Processing: First name, Last Name, and email address
Subprocessor: D2L Subsidiaries (D2L Corporation (Canada), D2L Australia Pty. Ltd. (Australia))
Purpose: Providing implementation services and support
Location of processing: Canada and Australia
Degree of Personal Data Processing: User personal data within the system
Subprocessor: The Results Companies/Support Ninja (used if Controller purchases End User Support)
Purpose: End-user support
Location of processing: Mexico; other locations depending on the location of the client
Degree of Personal Data Processing: User personal data within the system