Data protection impact assessment - template
Wise Ed, module Accommodations (exam and study adjustments for students). For the school's data protection officer, to complete, decide on and keep. Prepared by Wise Technologies as a starting point; it is not legal advice.
The module is off by default; a school switches it on. An accommodation is given because of a student's health or disability, so even a record that names only the adjustment ("+50 % time", "separate room") can reveal data concerning health (GDPR Article 9). A DPIA (Article 35) is therefore recommended before the module is switched on. This page describes what the software does; the grey fields are the school's.
1. The assessment
| Controller (the school) | |
|---|---|
| Data protection officer | |
| Assessment made by, on | |
| Processor | Wise Technologies d.o.o., Ljubljana, Slovenia (hosting and operation of Wise Ed) - under the existing data processing agreement: |
| Review due | (and whenever the settings below change) |
2. What the processing is
Purposes
- The student office records what the school does for a student at exams and in studies - more exam time, a separate exam room, step-free rooms, another form of exam, an assistant or interpreter, an adjusted attendance requirement, extended deadlines, priority in choosing electives - each for a period, granted on a decided request or added by hand with a reason.
- The exam record shows the office, for one exam date, how many students need how much extra time, a separate room or step-free access, and the rooms the timetable has free, so the exam can be organised.
- The examiner and the lecturer see, for their own exam date or subject only, the words of the adjustment beside the student's name (for example "+50 % time"), and the attendance report shows "adjusted" instead of a shortfall.
- The student sees their own adjustments on the student portal, with the decision, and can ask for a renewal before one ends.
Data subjects
Students who have, or ask for, an adjustment.
Data
| The adjustment | the kind (from the school's list), its value (per cent, days or a few words), valid from and to, the decision number, the request it was granted on, a note for the office, the reason when it was added by hand or ended; who added and changed it, and when. |
|---|---|
| Type of impairment (optional) | ONE short line, only when the school switches the setting on (it is off by default). Seen only by staff with the right "Supporting documents"; never shown to lecturers, examiners, the student portal or third parties, and never written to the log. |
| Supporting documents | stay with the student's request in the Requests module (they are not copied). Opening them needs the separate right "Supporting documents"; every opening, and every refused attempt, is recorded (who, which request, when - not the content). |
| Never recorded by the module | a diagnosis. Every word the module shows names what the school does, never why. |
| Shown to whom | office staff whose roles open the module's screens: all adjustments; examiners: the words, for the students of their own exam date, on screen and on the printed list; lecturers: the words beside the student in their own subject's grade list, "adjusted" in their attendance report; the student: their own. Guardians, payers and sponsors: never (the Third-party access module has no scope for them). |
| The examiner's e-mail | carries only a mark that a student has an adjustment, not its words; the words stay behind the examiner's sign-in. |
| Logs | adding, changing and ending an adjustment; the documents' openings and refusals; that an examiner's list showed adjustments (per exam date and day, the persons only); the renewal reminders. |
Recipients
The school's staff as above; the student through the student portal of the school's web; Wise Technologies as processor.
3. Lawful basis
| Processing | Basis the school relies on (to confirm) |
|---|---|
| Recording and applying adjustments | The school's legal obligation or public task to make reasonable adjustments for students with disabilities (Article 6(1)(c) or (e)), and for health data Article 9(2)(b), (g) or (h) under national law: . Or the student's explicit consent (Article 9(2)(a)), given with the request: . |
| Showing the words to examiners and lecturers | Necessary to apply the adjustment at that exam or in that subject; limited to their own exam date or subject: |
| The optional "type of impairment" | Only if the school has a specific need for it: . Otherwise leave the setting off. |
4. Necessity and proportionality
- The adjustment, never the diagnosis: the module's words name what is done; the reason and the documents stay with the request.
- Need to know: an examiner sees only the students of their own exam date; a lecturer only their own subject; nobody outside the school.
- Defaults: the module off; the "type of impairment" field off.
- Separate right for documents: seeing that a student has an adjustment does not open the documents.
- Transparency: the student sees their adjustments and the decision; the renewal reminder tells them before one ends.
- Retention: an ended adjustment, and the log of who opened its documents, is erased after the period set in the module's settings - 3 years by default, set in years on the settings screen ( years at this school); 0 keeps everything until erased by hand.
5. Risks and measures
| Risk | Measures in the software | Likelihood / severity after them (school) |
|---|---|---|
| A diagnosis is written where many can read it | No field for a diagnosis; the only optional field is off by default, restricted to the documents right and never logged or shown outside the office; the screens say "the adjustment, never the diagnosis". | |
| Staff without a need read adjustments or documents | Role-based screens; documents behind a separate right; every opening and refused attempt recorded. | |
| An examiner's list travels further than the exam | The e-mail carries only a mark; the words are on the screen and the printed list behind a sign-in; that a list showed them is logged. | |
| Fellow students notice an adjustment | The words appear only on the examiner's and lecturer's own pages, never on public timetables or student lists. | |
| An adjustment outlives its need | Every adjustment has a period; a reminder before its end; ending it is one step with a reason. | |
| Ended adjustments are kept too long | Retention is a setting in years (default 3); a nightly job erases what is older. | |
| Data reaches parents, payers or sponsors | Adjustments are never a scope of Third-party access. |
Further risks the school sees and its measures:
6. Settings the school decides before switching the module on
- Record the type of impairment (off by default):
- Days before the end when the office and the student are reminded (30 by default):
- Years ended adjustments are kept (3 by default):
- The request type students use to ask for an adjustment:
- Who in the office may open the module's screens, and who has the right "Supporting documents" (roles):
- How students are informed (Article 13):
7. Outcome
| Residual risk | |
|---|---|
| Prior consultation with the supervisory authority needed (Article 36)? | |
| Data protection officer's opinion | |
| Decision, by, on |