EdTech and GDPR Compliance: What Schools Need to Know
As schools increasingly rely on educational technology (EdTech)—from learning management systems to classroom apps—they also take on significant responsibilities under the General Data Protection Regulation (GDPR). Since GDPR applies whenever personal data of children is processed, schools must ensure any EdTech tool they adopt protects student privacy, uses data lawfully, and meets strict security standards.
Below is what schools need to know to use EdTech safely and compliantly.
📌 1. Schools Are the “Data Controller”
Under GDPR, the school (not the EdTech company) is legally responsible for:
determining why and how student data is processed
choosing compliant service providers
ensuring security is in place
informing parents and students about data use
EdTech companies act as data processors, operating on behalf of the school.
This means schools must actively evaluate and govern the tools they use.
📋 2. Legal Basis for Processing Student Data
Schools must document the legal basis for using each EdTech tool.
Typical bases include:
✔️ Public Task
Most learning tools used to deliver education fall under this category.
✔️ Consent
Used sparingly and usually only for non-essential or optional apps.
Important: Children’s consent cannot be used as a blanket workaround.
✔️ Legal Obligation
Certain systems (attendance, safeguarding) may fall under this.
Schools must clearly state which basis applies in each case.
🔐 3. Conduct a Data Protection Impact Assessment (DPIA)
A DPIA is required when processing may pose high risk to children’s rights—common with EdTech.
A DPIA identifies:
what data the app collects
how the data flows
potential risks
how risks will be mitigated
DPIAs must be completed before adopting new EdTech tools.
📨 4. Transparency With Students and Parents
GDPR requires schools to be open about how technology uses personal data.
Schools must provide:
clear privacy notices
explanations of what each EdTech tool does
what data is collected and why
how long data is kept
who it is shared with
Language should be age-appropriate for students.
🤝 5. Contracts and Data Processing Agreements (DPAs)
Every EdTech vendor must sign a Data Processing Agreement that includes:
only processing data on the school’s instructions
strong security measures
no hidden data sharing
clear deletion/retention terms
rules about subcontractors (sub-processors)
adherence to GDPR standards
Schools should never use EdTech that lacks proper contractual protections.
🌍 6. International Data Transfers
If an EdTech tool stores or processes data outside the EU/EEA:
transfers must have an adequacy decision, or
use Standard Contractual Clauses (SCCs), and
include a Transfer Impact Assessment (TIA)
Schools must ensure data sent to non-EU countries remains equally protected.
🛡️ 7. Security and Technical Controls
Schools must verify that EdTech services implement strong security, such as:
encryption
multi-factor authentication for staff dashboards
access controls and role separation
regular security updates
data minimization
IT teams play a major role here.
🧒 8. Special Attention to Children’s Data
Children’s data is “high-risk” under GDPR, meaning:
only essential data should be collected
profiling or behavioral analytics must be carefully scrutinized
marketing and data monetization are strictly limited
Schools should avoid tools that:
track students for advertising
collect unnecessary behavioral data
require excessive personal information
🗃️ 9. Data Retention and Deletion
Schools must know how long each tool keeps data.
Best practice:
define retention periods (e.g., delete 30–90 days after account closure)
ensure vendors actually delete data when requested
remove student accounts no longer in use
Long-term data hoarding increases compliance and security risks.
🧯 10. Incident Response and Breach Reporting
Schools must ensure that:
EdTech vendors notify them immediately of any breach
they can notify authorities (within 72 hours if required)
students and parents are informed when necessary
logs and audit trails are available
An incident response plan is essential.
🎓 Summary
To use EdTech safely and legally under GDPR, schools must:
✔️ understand their role as data controllers
✔️ choose tools with strong privacy protections
✔️ conduct DPIAs before adoption
✔️ maintain transparent communication with families
✔️ secure proper contracts and data protections
✔️ ensure data minimization, security, and timely deletion
✔️ monitor ongoing vendor compliance
When done right, GDPR-compliant EdTech strengthens both learning and student safety.
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