Privacy Evaluation for Nearpod
Disclaimer: Common Sense Education content is included in Nearpod.
Nearpod is a web-based and iPad compatible platform that allows K-12 teachers to present interactive lessons, quizzes, and virtual reality-based activities to their students. The terms of Nearpod state students do not need to create a Nearpod account or provide Nearpod with any personally identifiable information to access a Nearpod presentation--students just need the 5-digit PIN unique to their teacher's presentation. The terms of Nearpod state the service can be used by students with or without an account. The terms of Nearpod state they require encryption on login, and in all areas of the website. Lastly, Nearpod's terms state they do not intentionally collect personally identifiable information from children under 13 years of age.
The terms of Nearpod state students do not need to create a Nearpod account or provide Nearpod with any personally identifiable information to access a Nearpod presentation--students just need the 5-digit PIN unique to their teacher's presentation. In addition, the terms state teacher accounts can allow teachers to share lessons, including assessments, with students. Because the site is structured around teacher-directed activities, risks of inappropriate interactions are minimized.
In addition, the terms state Nearpod may provide various open communication tools, such as blog comments, blog posts, chat forums, and message boards. Lastly, the terms state users should exercise caution, because Nearpod does not monitor user content and therefore users may be exposed to content from other users that is inaccurate, offensive, obscene, indecent, or objectionable.
The terms of Nearpod state the service can be used by students with or without an account. The terms state this method of use minimizes the potential for sharing personal information. The service supports social or federated login with Google and Office 365, so users should be aware that using social login can provide access to additional personal information.
The terms also state Nearpod does not sell user personal information to third parties and will not advertise or market to students who use Nearpod, nor will any student information collected by Nearpod be shared with third parties for advertising or marketing purposes. However, Nearpod may use targeted advertising on third party sites. Lastly, the terms state the service does not collect any kind of personally identifiable information through the use of cookie technology or IP numbers for tracking purposes.
The terms of Nearpod state they require encryption on login, and in all areas of the website. However, the terms do not provide significant detail on security provisions in place, but given the level of student information stored in the site, and the various means provided by the site to minimize data collection, the general measures described seem appropriate. Schools and districts are encouraged to explore the ways to minimize sharing of personal information in this site, and to ask the vendor for more details about physical and procedural safeguards in place to protect student data. Lastly, in the event of a security breach, the terms state Nearpd will notify users by posting on Nearpod and notifying users by email.
Nearpod's terms state they do not intentionally collect personally identifiable information from children under 13 years of age and require parental consent. Nearpod also encourages users under 13 who want to use the service to review the terms with their parents. The terms disclose that if a parent or teacher believes that their child or student has provided Nearpod with personally identifiable information without their consent, they should notify Nearpod so that they may immediately delete the information.
Additionally, the terms say educators using the service designate NearPod as a school official as defined by FERPA and Nearpod bases their COPPA required verifiable consent from teachers. Educators should be aware that based on how they use some of the features created in the site, some activities could be defined as educational records under FERPA. Teachers should also be aware when using this tool (and any other tool that creates surveys) that certain categories of questions could be covered by the Protection of Pupil Rights Amendment (PPRA).
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 limited to product requirements.
- Geolocation data are not collected.
- Biometric or health data are not collected.
- Behavioral data are not collected.
- Sensitive data are not collected.
- Non-personally identifiable information is collected.
- Unclear whether this product treats combined information as personally identifiable information (PII).
- Personal information from children under 13 years of age is collected online.
What data does it share?
- Collected information is shared with third parties.
- The categories of information shared with third parties are indicated.
- The purpose for sharing a user's personal information with third parties is indicated.
- Use of information is limited to the purpose for which it was collected.
- Data are shared for analytics.
- Unclear whether data are shared for research and/or product improvement.
- Data are shared with third-party service providers.
- The roles of third-party service providers are indicated.
- Social or federated login is supported.
- Contractual limits are placed on third-party data use.
How does it secure data?
- A user's identity is not verified with additional personal information.
- Account creation is required.
- Parental controls or managed accounts are available.
- Unclear whether two-factor account protection is available.
- Unclear whether third-party contractual security protections are required.
- Industry best practices are used to protect data.
- Employee or physical access to user information is limited.
- All data in transit are encrypted.
- All data at rest are encrypted.
- Notice is provided in the event of a data breach.
What rights do I have to the data?
- Opt-in consent is requested from users at the time personal information is collected.
- Users can control their information through privacy settings.
- Users can create or upload content.
- Users retain ownership of their data.
- Processes to access and review user data are available.
- Processes to modify inaccurate data are available.
- A data-retention policy is available.
- Processes for the school, parents, or students to delete data are available.
- Processes to delete user data are available.
- Processes to download user data are available.
Is the data sold?
- Data are not sold or rented to third parties.
- Unclear whether 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.
- Users are notified if their information is transferred to a third party.
- User information can be deleted prior to its transfer to a third party.
- Third-party transfer is contractually required to use the same privacy practices.
- User information is shared in an anonymous or deidentified format.
- Unclear whether the vendor describes their deidentification process of user information.
- Unclear whether data are shared for research and/or product improvement.
- Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
How safe is this product?
- Users can interact with trusted users and/or students.
- Users can interact with untrusted users, including strangers and/or adults.
- Profile information is shared for social interactions.
- Personal information is not displayed publicly.
- Users can control how their data are displayed.
- User-created content is reviewed, screened, or monitored by the vendor.
- User-created content is 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
Are there advertisements or tracking?
- Data are not shared for third-party advertising and/or marketing.
- Traditional or contextual advertisements are not displayed.
- Behavioral or targeted advertising is displayed.
- Unclear whether this product allows data collection by third-party advertising or tracking services.
- Data are not used to track and target advertisements on other third-party websites or services.
- Data profiles are not created and used for data enhancement, and/or targeted advertisements.
- The vendor can send marketing messages.
- The vendor does provide promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Users can opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Unclear whether intended for parents or guardians.
- Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
- Children's privacy is applicable.
- Unclear whether this product indicates COPPA parental consent exceptions.
- Parental consent is required.
- Unclear whether this product limits parental consent with respect to third parties.
- Unclear whether this product allows parents to 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.
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.
- Product does create education records.
- Notification of a contract or additional rights is provided.
- Vendor is designated as a school official.
- Parental consent obligations are transferred to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Directory information is not disclosed.