I reviewed the criticisms (there are two authors) and think that they are more like 'chipping around the edges' than they are 'poking holes'. The first, Jim Siegl, a technology architect for Fairfax County Public Schools and co-chair of CoSN's Privacy Toolkit, complains that he found 126 privacy policies, not the 118 found in the EFF report, and that more applications than stated use encryption, based on a survey of https URLs. The second, Amelia Vance, policy counsel for education privacy at the Future of Privacy Forum, cites the first and adds "the report only mentions three of the 106 student privacy laws passed in 39 states since 2013." I think Siegl is worth reading on this, though I think it adds up to far less than a refutation of EFF.
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