NDPA and State Data Privacy Addenda
Many districts and states require a service provider to sign a data privacy agreement before it processes student data. This page explains the agreements Pearl Education will sign and how they fit together.
Pearl’s Bilateral DPA
Pearl offers a Student Data Privacy Exhibit (“DPA”) that attaches to its Master Service Agreement. The DPA is structured to align clause-for-clause with the Student Data Privacy Consortium (SDPC) National Data Privacy Agreement (NDPA) version 2.2, so that a district or state NDPA can replace it with minimal change (DPA Art. I). It addresses data ownership, parent and eligible-student requests, subprocessors, prohibited uses, de-identified data, security, security incidents, and data return and deletion.
State and National NDPAs
Pearl is willing to execute state and national NDPAs — including the SDPC NDPA and state-specific exhibits — in place of or alongside its bilateral DPA. Because Pearl’s DPA already tracks the NDPA v2.2 structure, adopting a district’s NDPA is typically a low-friction change.
Which Agreement Controls
When Pearl and a customer (or the relevant education agency) execute a state or national NDPA, that NDPA replaces Pearl’s bilateral DPA and controls over the MSA with respect to Student Data (MSA §5.1; DPA Art. I). Pearl’s order of precedence states the same rule: for Student Data, the DPA — or an executed NDPA — controls (MSA §18.7). Where applicable state law or an executed state DPA imposes different disposition timelines, those timelines control for the affected Student Data (DPA §8.4).
Executed NDPAs and SDPC Adherence
Pearl adheres to the Student Data Privacy Consortium (SDPC) National Data Privacy Agreement (NDPA) framework. Pearl is not a member of the Access 4 Learning (A4L) Community or SDPC; membership is not required to adopt or sign the NDPA. Pearl has executed NDPAs with school districts and a multi-state consortium, including an 11-state consortium NDPA. Pearl provides executed copies on request, typically under NDA or after contracting, and does not post signed agreements publicly.
How to Request or Submit an Agreement
Districts and agencies can ask Pearl to sign their required NDPA or state addendum, or request Pearl’s bilateral DPA, through their Pearl account contact, or privacy@poweredbypearl.com. On request, Pearl will also provide its subprocessor list and, under NDA, its security documentation (MSA §4.4; DPA §2.5, §6.1). For related guidance, see State Privacy Law Posture and the Pearl Compliance Overview.
