The pattern is always the same. A teacher finds a tool, it works, word spreads, and by half term four classes are using it and nobody has asked where the data lives.

What a DPIA actually is

It is a structured set of questions about what data a system will process, why, and what could go wrong. For most classroom tools it is a twenty-minute exercise, not a project.

The questions worth asking first

  • What personal data does it collect, and does it need all of it?
  • Where is that data stored, and is it outside the UK?
  • Who at the supplier can see it?
  • What happens to it when we stop using the tool?

If the answer to any of those is "we do not know", that is the finding — and it is a much cheaper finding now than after a breach.