Published by: [Name of Education Department / Directorate] Effective date: [DD Month YYYY] Last updated: [DD Month YYYY] Version: 1.0
MG-COT (Multigrade Classroom Observation Tool) is an official application developed for and operated by [Name of Education Department] ("the Department", "we", "us"). The application is used by authorised education officials, supervisors, mentors, and monitoring staff to record structured observations of teaching and learning practices in multigrade classrooms.
This Privacy Policy explains what information the application collects, why it is collected, how it is stored and protected, who can access it, and what rights individuals have in relation to that information.
MG-COT is not a public consumer application. Access is restricted to officials authorised by the Department. Data collected through MG-COT is used exclusively for departmental purposes relating to education quality improvement, and is not sold, rented, or shared for advertising or commercial purposes under any circumstances.
By using MG-COT, authorised users agree to the practices described in this policy and to the confidentiality obligations set out in Section 12.
This policy applies to:
The MG-COT mobile application (Android [and iOS, if applicable])
The MG-COT web dashboard and reporting portal at [URL]
The servers, databases, and backups that store MG-COT data
All personnel who collect, access, process, or report on MG-COT data
This policy does not apply to third-party websites or services that may be linked from departmental communications.
The data controller — the entity legally responsible for information collected through MG-COT — is:
[Name of Education Department / Directorate] [Full postal address] Email: [official email address] Telephone: [official contact number]
The Department may engage technical service providers (for example, hosting or software maintenance vendors) who act as data processors strictly on the Department's written instructions. Such providers are bound by contract to protect the data and may not use it for their own purposes.
Collected when an official account is created and when the app is used:
Full name, designation, and employee/personnel number
Official email address and mobile number
Office, district, tehsil, and cluster assignment
Username and encrypted password credentials
Login timestamps and activity logs
School name, EMIS/school code, and address
Grade combinations taught in the observed multigrade classroom
Number of students present and enrolled on the day of observation
Physical classroom conditions, seating arrangement, and available teaching-learning materials
Teacher name, designation, and personnel number
Subject(s) and grades taught
Qualification and training history, where relevant to the observation
Observation ratings against the MG-COT rubric or indicator framework
Narrative comments, evidence notes, and improvement recommendations recorded by the observer
Post-observation feedback and agreed follow-up actions
Date, start time, and end time of the observation
Observer identity
Observation cycle or round number
Draft, submitted, and approval status
Device model, operating system version, and application version
Unique device or installation identifier
Application error reports and crash diagnostics
Data synchronisation logs and timestamps
Delete this section if the app does not use GPS.
If location permission is granted, MG-COT records the GPS coordinates of the device at the moment an observation is submitted. This is used solely to verify that the observation was conducted at the reported school, and to support geographic analysis of coverage. Location is not tracked continuously and is not collected when the app is closed or running in the background.
Delete or amend this section to match the app's actual capabilities.
Where the observation protocol permits, observers may attach photographs of classroom materials, displays, seating arrangements, or student work.
Media capture is subject to strict limits (see Section 5).
MG-COT does not collect:
Individual student names, roll numbers, dates of birth, or student-level academic records
Contact lists, SMS messages, call logs, or browsing history from the observer's device
Financial, health, or biometric information
Data from any application other than MG-COT
Observations take place in classrooms where children are present. The Department treats the protection of children as a primary obligation, and the following rules apply without exception:
No student-level data. MG-COT records information about teaching practice, not about individual children. Student information is recorded only in aggregate form (for example, "28 students present").
No identification of children. Observers must never enter a student's name, identification number, or any other detail that could identify an individual child into a free-text field.
Photography restrictions. Photographs must focus on classroom environment, materials, and displays. Where a photograph unavoidably includes children, faces must not be identifiable, and the photograph must not be taken at all unless the school head has given permission in accordance with departmental child-protection guidelines. Photographs of individual children are prohibited.
No audio or video recording of children. [Amend if the protocol expressly permits recording under specific safeguards.]
Safeguarding disclosures. If an observer becomes aware of a child-protection concern during an observation, it must be reported immediately through the Department's child-protection reporting procedure, and not recorded as observation data in the app.
Restricted access. Any media held in the system is accessible only to authorised officials with a demonstrated need, and is subject to the shortest retention period consistent with departmental requirements.
Children and their parents may contact the Department at the address in Section 3 with any concern about information relating to a child.
Information collected through MG-COT is used only for the following departmental purposes:
Purpose
Description
Instructional support
Providing individual teachers with structured, evidence-based feedback
Professional development
Identifying training needs and designing targeted teacher development programmes
Quality assurance
Monitoring the quality and consistency of teaching in multigrade settings
Resource planning
Identifying schools and clusters requiring additional materials or support
Programme evaluation
Measuring the effectiveness of multigrade teaching reforms over time
Reporting
Producing aggregated statistical reports for departmental and government use
System integrity
Verifying that observations are genuine, complete, and properly conducted
Observation data is a developmental tool. It is intended to support and improve teaching. Any use of individual observation data in a formal disciplinary or performance-management process may occur only in accordance with the applicable service rules and departmental policy, and the teacher concerned must be informed. [Amend this paragraph to reflect the Department's actual position.]
We do not use MG-COT data for advertising, marketing, profiling for commercial purposes, or automated decision-making that produces legal effects on any individual without human review.
The Department collects and processes this information in the exercise of its official functions relating to the supervision, monitoring, and improvement of public education, under [cite the relevant Act, rules, notification, or administrative order — e.g. the relevant Education Act / Right to Education legislation / departmental notification number and date].
Where applicable, processing is carried out in accordance with [cite applicable data protection or right-to-information legislation, if any is in force].
Access is granted on a strict need-to-know and role-based basis:
Role
Typical access
Observer / mentor
Their own observations only
School head
Observations conducted in their own school
Cluster / tehsil officer
Aggregated and individual data within their jurisdiction
District education officer
Aggregated and individual data within their district
Provincial / directorate staff
Aggregated data; individual data where duties require it
System administrator
Technical access for maintenance, subject to audit logging
Observed teacher
Their own observation records and feedback
Disclosure outside the Department occurs only where:
Required by law, court order, or lawful direction of a competent authority
Necessary for an audit conducted by an authorised government body
Necessary to protect the safety of a child or any other person
Shared as aggregated, anonymised statistics that cannot identify any individual teacher, observer, or student — for example in research publications, donor reports, or public dashboards
The individual concerned has given written consent
We do not sell, rent, trade, or otherwise make MG-COT data available to any commercial party.
MG-COT data is stored on [servers located at / government data centre / cloud service] within [country/jurisdiction]. Data is not transferred outside [country] except [state any exception, or write "no exceptions"].
MG-COT is designed to work in schools with limited connectivity. Observations may be saved locally on the observer's device and uploaded when a network connection becomes available. Locally stored data is encrypted on the device and is automatically deleted from the device once it has been successfully synchronised to the server.
Encryption of data in transit using HTTPS/TLS
Encryption of data at rest on servers and on the device
Individual named accounts with strong password requirements; shared accounts are prohibited
Role-based access control and least-privilege permissions
Automatic session timeout and remote deactivation of lost or stolen devices
Audit logging of access, modification, export, and deletion
Regular backups, held under the same protections as live data
Periodic security review and vulnerability assessment
Documented incident response procedure
If a breach occurs that is likely to affect the rights or interests of individuals, the Department will investigate without delay, take steps to contain and remedy the breach, notify the relevant authority where required by law, and inform affected individuals where there is a significant risk to them.
No system can be guaranteed to be completely secure. The Department maintains these safeguards as a matter of continuing obligation, and users must comply with Section 12.
Data type
Retention period
Observation records
[e.g. 5 years from date of observation]
Photographs and attached media
[e.g. 1 year from date of observation]
Location records
[e.g. 1 year]
User account records
Duration of the official's assignment, plus [e.g. 2 years]
Access and audit logs
[e.g. 3 years]
Aggregated, anonymised statistics
May be retained indefinitely
At the end of the retention period, records are securely deleted or irreversibly anonymised. Records subject to an ongoing audit, investigation, legal proceeding, or statutory retention requirement are retained until that requirement ends.
Subject to applicable law, teachers, observers, and other individuals whose information is held in MG-COT may:
Be informed of what information about them is held and how it is used
Access a copy of their own records
Request correction of information that is inaccurate or incomplete
Object or make representations regarding an observation record, and have their comments attached to the record
Request deletion of information that is no longer required for a lawful purpose
Complain to the Department, and thereafter to [name of oversight body or ombudsman, if applicable]
Requests should be sent in writing to the contact in Section 3. The Department will respond within [e.g. 30] days. Identity verification may be required. Some rights are limited where the information forms part of an official record that the Department is required to maintain.
Every authorised MG-COT user must:
Keep login credentials confidential and never share an account
Access only the records necessary for their official duties
Record observations accurately, fairly, and without personal bias
Never enter identifying information about individual students
Treat all observation data as official and confidential information
Not photograph, screenshot, copy, forward, or publish observation records or media outside authorised departmental channels
Not discuss the contents of an observation with anyone other than those authorised to receive it
Secure their device with a screen lock and report loss or theft immediately to [contact/helpdesk]
Report any suspected unauthorised access or data breach immediately
Misuse of MG-COT data may result in withdrawal of access and disciplinary action under the applicable service rules, in addition to any liability under law.
MG-COT requests only the permissions it needs to function:
Permission
Purpose
Required?
Internet / network access
Synchronising observations with the server
Required
Storage
Saving observation drafts and attachments offline
Required
Camera
Capturing permitted classroom photographs
Optional
Location (GPS)
Verifying the observation location at submission
Optional
Notifications
Reminders and sync alerts
Optional
Optional permissions may be declined or revoked at any time in the device settings; the corresponding feature will then be unavailable. MG-COT does not access contacts, messages, call logs, microphone, or other applications.
Amend to reflect the services actually used, or state "MG-COT does not use any third-party services."
MG-COT may use the following third-party components:
[e.g. crash reporting service] — receives anonymised technical error data only
[e.g. map or geocoding service] — used to display school locations
These services do not receive observation content, teacher information, or any data about students. Each is governed by its own privacy policy.
This policy may be updated to reflect changes in the application, departmental procedure, or law. The revised version will be published at [URL] and within the application, with an updated version number and effective date. Material changes will be notified to users through the application and through official channels before taking effect.
For questions, access requests, corrections, or complaints about this policy or about the handling of MG-COT data:
[Designated Data Protection / Focal Officer] [Name of Education Department / Directorate] [Full postal address] Email: [official email address] Telephone: [official contact number] Office hours: [days and times]
If you are not satisfied with the response, you may escalate to [name and address of the relevant oversight body, ombudsman, or appellate authority].
This document is an official publication of [Name of Education Department]. It should be read alongside the MG-COT Terms of Use, the Department's child-protection policy, and the applicable service rules.