Privacy Evaluation for Nearpod
Overview
Nearpod is a lesson delivery platform where teachers share interactive presentations with students, and students respond in a variety of ways. Although there are non-educator plans available, per the policies, students are connected to the service through a managed educator or school account.
Nearpod can be accessed through its website, and is available for download at the iOS App Store, and the Google Play Store. The Privacy Policy and Terms and Conditions used for this evaluation can be found on Nearpod’s website.This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.
Safety
Students connect to Nearpod lessons either through email or a join code provided by their teacher, and according to the Terms and Conditions, students are only able to see what their teachers share with them and are not able to interact with other users. The Terms indicate that adult users do have the option to participate in social features on the site, and they may voluntarily or inadvertently expose their personal information. Personal information teachers post to Nearpod's chat rooms, for instance, will be public according to the Privacy Policy, but such social features are not available to students. The Company reserves the right to pre-screen user-created content but has no obligation to do so, as stated in the Terms.
Privacy
According to the Privacy Policy, Nearpod collects personally identifying information from adult users when they set up an account. If teachers or institutions opt to create and roster student accounts, the Company collects information from students that includes first and last name, email Address, the name of the institution that the student belongs to, a reference account number, and an optional profile photo. The Company also collects all student-generated or created data and content, which may include audio recordings and photos, per the Policy. With regard to sharing of data, Nearpod shares the information it collects, including personal information, with its third-party sub-processors who are contractually bound to use the information only for purposes specified in the policies. The Terms and Conditions state that Nearpod may send marketing emails and employ targeted advertising on third party sites for teacher-users, but not for students. It is clear from both policies that Nearpod does not sell any user data or employ marketing tools on its student-facing platform, and the Company is a signatory of the Student Privacy Pledge.
Security
The Privacy Policy states that Nearpod and maintains information technology security measures designed to protect personally identifiable information from unauthorized disclosure to or access by a third-party. Educator accounts are required, per the Terms, and educators manage student accounts through individual or enterprise accounts. Additionally, the Privacy Policy states that all interactions with Nearpod’s application are encrypted in transit with TLS 1.2 grade encryption or better, and the company will notify uses in the event of a data breach.
Compliance
Nearpod's Terms specify that the product is intended for use by educators and their students in K-12 schools. Both the Privacy Policy and Terms and Conditions clearly state that the Company does not intend for students and/or minors to sign up to the Nearpod Materials on their own; rather, they intend for educators and license holders to create and manage student accounts. School officials and educators may access student account information, including presentations, reports, and any student information associated with the account according to the policies, and either account administrators or the Company can be contacted to delete student information. Finally, regarding applicable children's privacy protection laws, the Privacy Policy is clear that Nearpod relies on the institution’s consent in lieu of a parent in collecting verifiable consent of students under the age of 13.
Rating
- Personal information is not sold or rented to third parties.
- Personal information is not shared for third-party marketing.
- Personalised advertising is not displayed.
- Unclear whether data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
Data Collection
SCORE: 40%
What data does it collect?
- Personally identifiable information (PII) is collected.
- The categories of collected personally identifiable information are indicated.
- Collection or use of data is not limited to product requirements.
- Unclear whether this product collects geolocation data.
- Unclear whether this product collects biometric or health data.
- Unclear whether this product collects interactions, behaviors, or usage analytics data.
- Sensitive data are collected.
- Data is automatically collected.
- Opt-in consent is not requested from users at the time personal information is collected.
- Personal information of users is collected by a third party.
Data Sharing
SCORE: 55%
What data does it share?
- Collected information is shared with third parties.
- Unclear whether the categories of information shared with third parties are indicated.
- The purpose for sharing a user's personal information with third parties is indicated.
- Unclear whether the categories of third parties that receive data are indicated.
- Unclear whether data are shared for analytics.
- Data are shared for research and/or product improvement.
- Third-party services are used to support the product.
- The roles of third-party service providers are indicated.
- Unclear whether this product supports third-party login.
- Contractual limits are placed on third-party data use.
Data Security
SCORE: 75%
How does it secure data?
- A user's identity is verified with additional personal information.
- Account creation is required.
- Managed accounts are available.
- Unclear whether multi-factor account protection is available.
- Third-parties with access to information are required to provide the same security protections as the company.
- Reasonable security practices are used to protect data.
- Unclear whether this product limits employee or physical access to user information.
- All data in transit are encrypted.
- All data are stored in an encrypted format.
- Notice is provided in the event of a data breach.
Data Rights
SCORE: 95%
What rights do I have to the data?
- Users can create or upload content.
- Users retain ownership of their data.
- Processes to access or review user data are available.
- Processes to modify data are available for authorized users.
- A data-retention policy is available.
- Processes for authorized users to delete data are available.
- A user's data are deleted upon account cancellation or termination.
- Data are deleted when no longer necessary.
- Methods are available to restrict who has access to data.
- Processes to download user data are available.
Data Sold
SCORE: 80%
Is the data sold?
- Personal information is not sold or rented to third parties.
- Users can opt out from the disclosure or sale of their data to a third party.
- User information can be transferred to a third party in the event of a merge, acquisition, or bankruptcy.
- Users are notified if their information is transferred to a third party.
- User information can not be deleted prior to its transfer to a third party.
- Third-party transfer is not contractually required to use the same privacy practices.
- User information that is shared is not shared in an anonymous or de-identified format.
- The company describes their de-identification process of user information.
- Data are shared for research and/or product improvement.
- Contractual limits prohibit third parties from reidentifying or de-identified information.
Data Safety
SCORE: 45%
How safe is this product?
- Users can interact with trusted users.
- Unclear whether users can interact with untrusted users, including strangers and/or adults.
- Profile information must be shared for social interactions.
- Personal information can be displayed publicly.
- Users can control how their data are displayed to others.
- User-created content is reviewed, screened, or monitored by the company.
- User-created content is not filtered for personal information before being made publicly visible.
- Unclear whether social interactions between users are moderated.
- Unclear whether social interactions of users are logged.
- Unclear whether users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 40%
Are there advertisements or tracking?
- Personal information is not shared for third-party marketing.
- Unclear whether this product displays traditional or contextual advertisements.
- Personalised advertising is not displayed.
- Unclear whether data are collected by third-parties for their own purposes.
- User's information is used to track and target advertisements on other third-party websites or services.
- Unclear whether this product creates and uses data profiles for personalised advertisements.
- The company can send marketing messages.
- The company does not provide promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of contextual, or personalised advertising.
- Unclear whether users can opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 75%
Can I provide parental consent?
- Intended for children under 13.
- Personal information from children under 13 years of age is collected.
- Unclear whether intended for parents or guardians.
- Company does have actual knowledge that personal information from users under 13 years of age is collected.
- The company does provide a section, heading, or separate policy for children in their policies.
- Parental consent is required before personal information is collected or disclosed.
- Unclear whether this product limits parental consent with respect to third parties.
- Parents can withdraw consent for the further collection of their child's information.
- Children's personal information is deleted if collected without parental consent.
- Parental consent notice and method for submission are provided.
School Purpose
SCORE: 81%
Is the product intended for school?
- Intended for students.
- Personal information or education records are collected from preK-12 students.
- Intended for teachers.
- Product is primarily used by, designed for, and marketed toward students in grades preK–12.
- Processes to enter education records into the product are described.
- Additional rights or protections are not provided with an additional school contract.
- Company is designated as a school official.
- Parental consent obligations are transferred to the school or district.
Individual Control
SCORE: 25%
Can I control the use of my data?
- Unclear whether users can control the use of their information through privacy settings.
- Use of information is not limited to the purpose for which it was collected.
- The context or purpose for which data are collected is indicated.
- Unclear whether company may combine data with additional data from third-party sources.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Unclear whether notice is provided if the context in which data are collected changes.
- Unclear whether consent is obtained if the practices in which data are collected change.
- Unclear whether a grievance or remedy mechanism is available for users to file a complaint.
- Unclear whether users can request to know what personal information has been shared with third parties.
- Notice is provided in the event the company receives a government or legal request for a user's information.
Common Sense Standard Privacy Report (SPR)
The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.
About Privacy Evaluations
The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.
Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.