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Data protection impact assessment - template

Wise Ed, module Third-party access (guardians, payers, sponsors). 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. Before it is switched on, the school decides whether a DPIA is required (GDPR Article 35) - processing data about students under 18, sharing study results and invoices with third parties, and keeping a record of views usually points that way. 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
ProcessorWise 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

Data subjects

Students (including students of 16 and 17 where the school enrols them); the third parties themselves (guardians, the contact persons of payers and sponsors).

Data

About the third partyname, e-mail address (how they sign in), phone, language, the kind of link (guardian, payer, sponsor), the relation, the payer in Finance it pays as, sign-in devices and one-time codes.
About the student, shown per part ("scope")timetable; exam dates and registrations; grades and progress toward the degree; attendance and absences; the school's announcements; invoices and payment slips; for a minor's guardian only, conversations with the class teacher.
Never shown to a third partyadjustments (accommodations) and anything about health; requests and their documents; the student's own messages; for a payer or sponsor, conversations.
Grantswhich scope the student granted to whom, when, and when it was withdrawn.
View logone row per link, scope and day on which the third party opened that part (not per click). The student sees it for the last 12 months; the third party is told on their page that their views are recorded and the student can see them.

Recipients

The third parties, through the parent portal (/a/parent) of the school's web; the school's staff with the roles that open the module's screens; Wise Technologies as processor.

3. Lawful basis

Who seesBasis the school relies on (to confirm)
Guardian of a minorThe school's statutory task or legitimate interest under national law: . Parental care ends at 18 in Slovenia, Croatia, Serbia and Bosnia and Herzegovina, and no law there gives a parent a 16- or 17-year-old's higher-education data - so the module shows a minor's guardians nothing until the school ticks what to show.
Anybody, for an adult studentThe student's consent (Articles 6(1)(a) and 7), per person and per scope, withdrawable at once. A guardian the school links with a written legal reason (a court-appointed guardian) is the exception; the reason is logged.
Payer, for invoices addressed to itContract or legitimate interest of the payer and the school (Article 6(1)(b) or (f)): . Anything beyond those invoices needs the student's consent.
SponsorThe student's consent only. The student's screen says the choice is theirs and the school does not require it - consent is not a condition of study (Article 7(4)).

4. Necessity and proportionality

5. Risks and measures

RiskMeasures in the softwareLikelihood / severity after them (school)
Somebody reads another family's dataSign-in by a one-time e-mail code or the school's invitation code; revocable device credentials; every read goes through one check that answers "not found" for anybody else's link.
A third party sees more than the student wantsPer-scope grants, effective at once; nothing shared until the student shares it; the student can end a link.
Pressure on a student to share (a sponsor, an employer)The grant screen states the choice is the student's and not required by the school; withdrawal is one tap and is not shown to the sponsor as a reason.
Special-category data reaches a third partyAdjustments, health entries, requests and documents are never a scope; status-revealing reductions are anonymised on payer invoices.
A parent keeps access after the student comes of ageThe link sees nothing from the day of majority until the student answers; the student is told.
Wrong person linked by the officeThe office is asked before a link waits for an adult's consent and before a payer link names a payer that is not on the student's account; every change is logged.
The view log is kept too longRetention is a setting; older rows are deleted.

Further risks the school sees and its measures:

6. Settings the school decides before switching the module on

7. Outcome

Residual risk
Prior consultation with the supervisory authority needed (Article 36)?
Data protection officer's opinion
Decision, by, on