This page explains how parental rights and consent work when a school uses Pearl Education. The short version: the school — not Pearl Education — is the authority that controls student data and decides how consent is handled. Pearl provides the service on the school’s behalf.

The School Is the Consent Authority

When a district, school, or state education agency uses Pearl, the school directs how student data is used, and Pearl acts as a “school official” with a legitimate educational interest under the Family Educational Rights and Privacy Act (FERPA), 34 C.F.R. §99.31(a)(1) (MSA §5.3; DPA Art. I, §1.1). The school retains ownership and control of student data (DPA §2.1).

Because of this structure:

• Consent decisions sit with the school, consistent with FERPA, PPRA, COPPA, and applicable state student-privacy laws (MSA §5.4). Pearl does not independently obtain parental consent on its own behalf.
• Where direct parental consent is required, or the school elects not to facilitate consent itself, Pearl can, at the school’s request, make available in-product mechanisms to obtain and record verifiable parental consent before a student accesses the Products (MSA §5.5).

COPPA in a School Context (Under 13)

The Children’s Online Privacy Protection Act (COPPA) applies to children under 13. In a school setting, consistent with FTC guidance, a school may provide consent on behalf of parents for educational use of a service like Pearl, where the school has authorized Pearl to collect that information solely for the educational purposes in the agreement (MSA §5.4). The school determines, and discloses to families, how it relies on this arrangement.

How Parents Exercise Their Rights

Parents and eligible students exercise access, correction, and deletion rights through their school, which holds the relationship and the authority over the student’s records:

• The school establishes the procedures for parents and eligible students to review, correct, or request deletion of student data (DPA §2.2).
• If a parent contacts Pearl directly, Pearl refers them back to their school (DPA §2.2).
• When the school asks Pearl for a student’s data, Pearl responds within a reasonably timely manner and no later than 45 days (DPA §2.2).

Pearl also maintains bright-line limits on student data: no sale of student data, no targeted or behavioral advertising to students, and no commercial student profiles except as needed to provide the Services (MSA §5.7; DPA §4.2).

Sample Explanation Districts Can Reuse

Districts may adapt the plain-language paragraph below for parent-facing notices. Districts should review and tailor it with their own counsel; bracketed items are district-specific.

Our school uses Pearl ([district program name]) to support student learning. Under FERPA, Pearl acts as a “school official” providing a service on our behalf, and we remain in control of your child’s information. We decide how your child’s data is used for this program, and Pearl does not sell student data or use it for advertising. If you want to review, correct, or delete your child’s information, please contact [school/district office and contact], not Pearl — we manage these requests for our families.

Related Pages

See FAQ: Student Data Protection, Educational Resources, and the Privacy pages for more detail on what data is processed and how it is protected.