Pearson UK

https://www.pearson.com/uk · 36/92 checks passed · publishers

Compliance report (framework 0.8)

Gate passed (every Core check must pass) · not counted towards the gate: paused 35, draft 48, ready for review 54.

Site level: 0 (no scored checks yet).

By level

LevelResult
Level 1 — Basic 21/37 (12 failed)
Level 2 — Enhanced 6/27 (13 failed)
Level 3 — Advanced 0/10 (4 failed)

By category

CategoryResult
Accessibility 9/13
Accountability 0/5
AI & Automation 3/8
Interoperability 0/3
Privacy 9/16
Provenance 0/2
Security 5/11
Transparency 1/13
Responsibility to the Future 0/3

Level 1 — Basic

Accessibility

FAIL No auto-playing media without controls
  • autoplay without controls: {'tag': 'video', 'src': 'https://www.pearson.com/content/dam/global/shared/brand/evolution/video/waves-fucsia-3-pearsonpurple-slow-16x9-l2r/waves-fucsia-3-pearsonpurple-slow-16x9-l2r-hires-v01.mp4', 'autoplay': True, 'controls': False}
FAIL Media elements have controls
  • without controls: {'tag': 'video', 'src': 'https://www.pearson.com/content/dam/global/shared/brand/evolution/video/waves-fucsia-3-pearsonpurple-slow-16x9-l2r/waves-fucsia-3-pearsonpurple-slow-16x9-l2r-hires-v01.mp4', 'autoplay': True, 'controls': False}

AI & Automation

Privacy

Security

Transparency

Level 2 — Enhanced

Accessibility

Accountability

FAIL Published response timeframes
  • response_timeframe: The terms page does not publish any response timeframes for inquiries, complaints, or feedback.
    Fix: Add a section specifying how long users can expect to wait for a response to inquiries or complaints.
  • specific: Since no timeframes are published at all, there are no specific day-based commitments on the page.
    Fix: Include concrete timeframes (e.g., 'within 14 days') for acknowledging and resolving user requests.
FAIL Documented complaints process
  • process_exists: The page contains no documented complaints or feedback process; it only covers terms of use, user conduct, and liability.
    Fix: Add a dedicated complaints/feedback section or link to a complaints policy explaining how users can raise concerns.
  • steps_clear: Because no complaints process is documented, there are no clear steps for users to follow.
    Fix: Provide a numbered step-by-step procedure (contact channel, information required, escalation path) for submitting complaints.
FAIL Clear appeals process
  • appeals_exists: The terms allow Pearson to suspend, terminate, or delete accounts at any time but do not document any appeals process for users to contest such actions.
    Fix: Add a clearly documented appeals process describing how users can contest account suspension, termination, or content removal decisions.
  • independent: No appeals mechanism is described, so there is no independent review or escalation path other than non-exclusive court jurisdiction.
    Fix: Establish and publish an independent or escalated review step (e.g., an internal ombudsperson or third-party reviewer) for disputed enforcement decisions.

AI & Automation

FAIL AI-assisted content clearly marked
  • marking_policy: The terms of use page does not mention any policy for marking or labeling AI-assisted content.
    Fix: Add a section to the terms that explains how AI-assisted or AI-generated content on the Site will be identified or labeled for users.
  • consistent: Without a marking policy stated on the page, there is no evidence that AI content marking is applied consistently.
    Fix: Document a consistent AI-content labeling standard and reference it in the terms so users can expect uniform marking across the Site.
FAIL Human oversight of AI documented
  • oversight_exists: The page contains no statement that AI outputs are subject to human oversight, only a general AI/text-and-data-mining rights reservation in the footer.
    Fix: Add a clause describing how Pearson maintains human oversight of any AI-generated outputs published on the Site.
  • review_process: No review or approval process for AI-generated content is described anywhere on the terms page.
    Fix: Describe the editorial or quality-assurance review steps applied to AI-generated material before it is published.
  • accountability: The terms do not identify any role, team, or entity accountable for AI-generated content.
    Fix: Name a responsible party (e.g., an editorial team or contact) who is accountable for AI-generated content and include their contact point in the terms.

Interoperability

Privacy

FAIL Data collection limited to necessity
  • necessity: The summary does not explicitly state that data collection is limited to what is necessary; it only mentions retention being 'only for as long as necessary'.
    Fix: Add an explicit statement on the summary page that Pearson limits data collection to what is necessary for the stated purposes (data minimisation principle).
  • proportionate: While purposes are listed, the page does not explicitly affirm that the data collected is proportionate to the Services provided.
    Fix: Include a clear statement that the data collected is proportionate to and relevant for the specific Service being provided.
FAIL Published data retention periods
  • specific: Retention is described vaguely ('as long as necessary', 'long periods of time') without specific timeframes on this page.
    Fix: Provide specific retention periods or ranges (e.g., qualifications retained for X years) directly on the summary page instead of only referring to the full notice.
FAIL No dark patterns in consent flows
  • equal_choices: The page only references a Cookie Notice link and does not display visible accept/reject buttons of equal prominence on this page content.
    Fix: Display both 'Accept' and 'Reject' cookie buttons with equal visual prominence (same size, color, and placement) in the cookie consent banner.
FAIL Cookie banner partner disclosure
  • banner_present: The page content shows no visible cookie or consent banner; only a 'Cookies' link appears in the footer.
    Fix: Implement a visible cookie consent banner on initial page load that allows users to accept, reject, or customize cookie preferences.
  • partner_sharing_mentioned: No on-page consent copy or banner discloses data sharing with third-party partners.
    Fix: Add clear disclosure in the consent banner explaining that data may be shared with third-party advertising and analytics partners.
  • partner_count_specific: Since no partner sharing is disclosed, no specific numeric count of partners is stated.
    Fix: Include a specific number of third-party partners (e.g., 'We share data with X partners') with a link to the full partner list.

Provenance

Security

Transparency

FAIL Algorithm explanation if applicable
  • algorithm_explained: The terms of use page contains no mention of algorithms or their purpose on the Pearson site.
    Fix: Add a section disclosing any algorithms used (e.g., for recommendations, assessments, or moderation) and explain their purpose.
  • impact_clear: There is no description of how algorithmic decisions might affect users such as learners or account holders.
    Fix: Include clear statements describing how algorithmic decisions impact users (e.g., content shown, account actions, assessment outcomes).

Level 3 — Advanced

Accessibility

FAIL Published accessibility statement
  • known_issues: The statement asserts products meet WCAG 2.2 AA but never acknowledges any known accessibility issues, limitations, or non-conformant areas.
    Fix: Add a section listing known accessibility limitations or areas of partial conformance so users understand what may not yet be fully accessible.
  • remediation_timeline: The page mentions reviewing and updating products 'often' but provides no timeline or commitment for fixing specific known issues.
    Fix: State a target timeframe or process for remediating identified accessibility issues (e.g., resolution targets after a report is filed).

Accountability

FAIL Published moderation policies
  • criteria_clear: Moderation criteria are vague, referring to content being 'vulgar, offensive or otherwise inappropriate, as determined by us in our sole discretion' without specific standards.
    Fix: Publish specific, objective moderation criteria (e.g., examples of prohibited content categories) either inline or via a linked Acceptable Use Policy with clear definitions.
  • enforcement: While the page states Pearson may delete, modify, suspend or terminate accounts, it does not explain the enforcement process, notice, or appeal mechanism.
    Fix: Describe the enforcement workflow including how violations are detected, whether users receive notice, and how they can appeal moderation decisions.

Interoperability

Security

Transparency

FAIL Algorithmic decision criteria published
  • criteria_published: The page does not publish any specific criteria used in algorithmic decision-making.
    Fix: Publish the specific input criteria (e.g., user data, behavior signals) used by any algorithms operating on the site.
  • weighting: No weighting or prioritization of decision criteria is disclosed anywhere on the page.
    Fix: Document how each criterion is weighted or prioritized in algorithmic decisions so users understand relative importance.
  • auditable: The page provides no technical detail, methodology, or audit information that would enable external review.
    Fix: Provide a public algorithmic transparency report or methodology documentation sufficient for independent audit.

Responsibility to the Future