Privacy Evaluation for Pear Deck
Pear Deck is a presentation platform that allows teachers to collect and save student responses in a live session in order to gauge student comprehension. Pear Deck requires both student and teacher accounts to use social login via Google. Pear Deck's terms state it does not intentionally collect any personally identifiable information ("PII") from users identified as students, but depending on how users use the services, they may be required to provide certain personally identifiable information through their Google or Microsoft Account. The terms state Pear Deck is committed to the highest standards of protection for student data and personally identifiable information (“PII”) at all times. Lastly, the terms specify that a district, school, or teacher acting on behalf of their organization should obtain the appropriate verifiable parental consent in order to comply with COPPA.
Pear Deck requires both student and teacher accounts to use social login via Google. Students can also access the service via teacher-shared access codes. Students with a Google Account and unique code can join a teacher's class. An individual with a teacher's account can then communicate with a student by uploading any kind of web or personal content including images, videos, and text to their presentations and activities (e.g., quizzes). Social interactions appear to be teacher-directed around specific class work. Pear Deck warns users that any information they choose to provide should reflect how much they want others to know about them. For example, users should consider carefully what information they disclose in their profile page and their desired level of anonymity.
The terms state Pear Deck is committed to the highest standards of protection for student data and personally identifiable information (“PII”) at all times. Pear Deck's terms state they take reasonable steps to help protect Information against loss, misuse, unauthorized access or disclosure. In addition, Pear Deck encrypts personal information in transit and will provide notification to users in the event of data breach.
The terms specify that a district, school, or teacher acting on behalf of their organization should obtain the appropriate verifiable parental consent in order to comply with COPPA. Pear Deck's terms state parents have choices regarding the personal information submitted by their children and parents should make any permitted requests to access, modify, or delete personal information with the School and have the School, as the parent’s agent, pass on those requests to Pear Deck. For example, if a representative from the child’s School contacts Pear Deck and provides the account information, Pear Deck may assume that the person calling is acting on behalf of the child’s parent. Lastly, teachers should also be aware when using this tool (and any other tool that creates surveys) that certain categories of questions could fall under what is 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.
- Unclear whether this product collects biometric or health data.
- Unclear whether this product collects behavioral data.
- Unclear whether this product collects sensitive data.
- 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?
- Unclear whether a user's identity is 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.
- Unclear whether this product limits employee or physical access to user information.
- All data in transit are encrypted.
- Unclear whether this product encrypts all data at rest.
- 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.
- Unclear whether the product provides a data-retention policy.
- 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.
- 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.
- Unclear whether third-party transfers are 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 displayed publicly.
- Users can control how their data are displayed.
- User-created content is reviewed, screened, or monitored by the vendor.
- Unclear whether 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 displayed.
- Behavioral or targeted advertising is not displayed.
- Data are not collected 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.
- Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
- Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
- Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Can I provide parental consent?
- Intended for children under 13.
- Unclear whether intended for parents or guardians.
- Vendor does have 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.
- Parental consent is limited with respect to third parties.
- Parents can withdraw consent for the further collection of their child's information.
- Unclear whether this product deletes children's personal information 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.
- Unclear whether this product provides notification of a contract or additional rights.
- Unclear whether this product designates the vendor as a school official.
- Parental consent obligations are transferred to the school or district.
- Unclear whether the vendor indicates FERPA parental consent exceptions.
- Unclear whether this product discloses directory information.