A data protection impact assessment for a school that uses lite-type Educator with its students, in the seven steps of the UK regulator's template. Our answers are filled in. Fill in the boxes for your school, then ask your data protection officer to review it.
Step 1: Why a DPIA is needed
Educator processes data about students, who may be children, for a school. No names are kept, but a school may still decide to assess it.
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Step 2: The processing
Nature: the educator makes a class of numbered seats, gives each student a code and sets lessons. Students practise typing in a browser. lite-type records their typing and shows the educator their progress.
How the data flows: the educator enters seats, and emails if they choose, in the Educator Panel. A student signs in with their code. Their typing goes to lite-type's servers in Ireland. The educator reads the results in the panel. Sign-in emails go out through Amazon's email service.
Scope: a seat number, a seat password if used, an optional email address, typing runs, lesson progress and results, sign-in times, and server logs of IP address and browser. No names and no special category data. Up to 50 students a class and 10 classes an educator, kept as set out on Privacy for schools.
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Context: the students are the school's own. They do not choose to use lite-type; the school does. They see no ads, no leaderboards and no other students' results.
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Purposes: to let students practise typing and to let the educator follow their progress.
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Step 3: Consultation
We answer questions about the processing by email.
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Step 4: Necessity and proportionality
The data is kept to a minimum: no names, emails only if the educator chooses, no tracking and no ads for students. Each item is used only to run the class.
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Step 5: Risks and how they are reduced
| Risk | How it is reduced | Remaining risk |
|---|---|---|
| A student is identified from their data. | No names are kept, and class names must not hold them. Only the educator can link a seat to a student. | Low |
| Someone signs in as a student. | Seat or class passwords, a lock after ten wrong passwords, 12-hour sessions. The educator can change passwords or remove a seat. | Low |
| Stored data is lost or exposed. | Encryption in transit and at rest, access for the operator only, backups for 35 days, and notice of a breach within 48 hours. | Low |
| Data is kept longer than needed. | Removing a seat deletes the student's data. Everything is deleted three months after the subscription ends. | Low |
| Students are tracked or shown ads. | No ads, no analytics and no third-party scripts for students. | Low |
| Data leaves the UK and the EU. | All data is stored in Ireland. Error reports sent to the United States hold no students' data. | Low |
Step 6: Your school's own measures
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Step 7: Sign-off
Measures approved by
Residual risks approved by
Data protection officer's advice