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Data Protection Impact Assessment (DPIA)

EduGPT

Organisation:

CivAI B.V. (EduGPT)

Version:

2.1

Date:

14 October 2026

Status:

Final, updated after the pilot phase

Next review:

Q4 2026

Contact:

privacy@edugpt.nl

Management Summary

EduGPT offers European educational institutions a GDPR-compliant alternative to ChatGPT. Following the completed pilot phase (October 2025 – January 2026), EduGPT is available for implementations, with new educational implementations from school year 2026-2027. The platform runs on Scaleway within the EU (data centres in France and the Netherlands), outside the scope of the US CLOUD Act, and only processes personal data that is necessary for delivering AI services. Azure OpenAI in the Sweden Central region in Sweden, exclusively Data Zone Standard within the EU Data Zone (EU member states, Norway and Switzerland), is available exclusively at the institution's request. Scaleway is the default and is recommended.

Key Characteristics

  • Users: Teachers, educational support staff, researchers and (optionally, at the institution's initiative) students
  • Location: Data remains within the EEA (Scaleway, France/Netherlands)
  • Training: No use of data for AI training
  • Logging: Full audit logging
  • Control: The institution centrally determines which AI models are available

Risk Classification

Risk Level Description Measures
HIGH Unintended processing of special categories of personal data Technical and organisational measures
MEDIUM Possible data breaches, AI hallucinations Encryption, training, disclaimers
LOW Unauthorised access by third parties Access control, MFA

1. Description of the Data Processing

1.1 Context and Problem

More than 70% of teachers and students use ChatGPT or similar tools through private accounts for study and work purposes. This creates substantial risks:

  • • GDPR violations due to data processing outside the EU
  • • Shadow IT via WhatsApp and private tools
  • • No control over educational data
  • • Training of AI models on sensitive data (e.g. pupil reports)

1.2 EduGPT Solution

EduGPT offers a secure alternative that:

  • • Offers the same ChatGPT functionality
  • • Keeps data within the EEA (Scaleway data centres in France and the Netherlands)
  • • Performs no training on user data
  • • Provides audit trails for accountability
  • • Delivers European support

1.3 From Pilot to Implementation

  • Pilot phase: October 2025 – January 2026, completed (max. 10 educational institutions, max. 20 users per institution)
  • Outcome: go decision for implementations; findings incorporated in this DPIA version 2.0
  • Implementations: new educational implementations from school year 2026-2027 (September 2026)
  • Safeguarding: for each implementation, this DPIA is reviewed together with the institution for its specific context

2. Personal Data

2.1 Overview of Personal Data

Category of data subjects Type Personal data Source
Users (teachers, students, staff) Regular Name, email address, job title, institution Registration by user
Users Regular IP address, browser info, timestamps System logging
Users Regular Prompts, chat history User interaction
Third parties (in documents) Unknown Potentially all categories, incl. special categories Documents uploaded by users

2.2 Critical Risks

Warning: Users may upload documents containing personal data of pupils or students, such as:

  • • Medical data (dyslexia, ADHD)
  • • Study progress, grades, guidance reports
  • • Behavioural or care information
  • • Financial data (student finance, payment arrears)

3. Processing Activities

3.1 Overview of Processing Operations

Processing Personal data Purpose
Registration Name, email, institution Create account
Authentication Email, password Grant access
Storage All user data Deliver service
AI-processing Prompts, documents Generate answers
Logging All actions + metadata Audit trail, security
Backup All data Continuity
Deletion All data At user's request

3.2 Excluded Processing

No processing for:

  • ❌ Marketing
  • ❌ Product development
  • ❌ Sale to third parties
  • ❌ Profiling

4. Parties Involved

Party Role Functions Access to
CivAI B.V. (EduGPT) Processor Platform management, support All data (encrypted)
Scaleway S.A.S. Sub-processor Hosting and AI inference (default, EU) Encrypted data, no keys
Microsoft Ireland Sub-processor (optional) Azure OpenAI (AI, exclusively on request; Scaleway is the default and is recommended) Encrypted data, no keys
Educational institutions Controller Determine use Data of own users
Users Data subject/inputter Use of platform Own data

5. Technical and Organisational Measures

5.1 Processing Locations

  • Primary hosting: Scaleway (EU, France/Netherlands)
  • Backup: Within the EEA (Scaleway)
  • Support: CivAI office (Netherlands)
  • ❌ No transfer outside the EEA (default Scaleway route)

5.2 Technical Specifications

  • AI processing: Scaleway AI inference by default (EU); optionally and exclusively on request Azure OpenAI Service in the Sweden Central region (Sweden), exclusively Data Zone Standard within the EU Data Zone (EU member states, Norway and Switzerland). Scaleway is the default and is recommended.
  • Security: TLS 1.3, AES-256 encryption, bcrypt hashing, JWT sessions
  • No use of: profiling, automated decision-making with legal effects

6. Legal Bases

Processing Legal basis (Art. 6 GDPR) Rationale
Platform use 6.1.b (contract) Service delivery
Educational data 6.1.e (public interest task) Educational purposes
Security logging 6.1.f (legitimate interest) Security
Statutory retention 6.1.c (legal obligation) Compliance

7. Retention Periods

Data Retention period Rationale Action
Chat history Default 90 days, customisable in consultation with the customer User control Automatically deleted; user can delete earlier
Uploaded documents Linked to chat Part of conversation Deleted with chat
Account data Active + 90 days Administration Automatically deleted
Security logs Default 90 days, customisable in consultation with the customer Incident response Automatic rollover
Audit logs Default 90 days, customisable in consultation with the customer Accountability and incident investigation Automatic rollover
Backup 30 days rolling Disaster recovery Overwritten

8. Rights of Data Subjects

Right Implementation Lead time
Access Export function 5 working days
Rectification Account settings Immediate
Deletion Delete function 5 working days
Portability JSON/CSV export 5 working days
Objection Assessment by privacy officer 5 working days

9. Risk Assessment

9.1 Identified Risks

Personal data breach HIGH

Hack/leak of pupil or student data. Likelihood: Low, Impact: Very high

Special categories of data HIGH

Upload of medical/care data. Likelihood: High, Impact: High

AI hallucinations MEDIUM

Incorrect output in a teaching context. Likelihood: Medium, Impact: Medium

Unauthorised access MEDIUM

Account compromise. Likelihood: Low, Impact: High

Vendor lock-in LOW

Cloud provider dependency. Likelihood: High, Impact: Low

9.2 Risk Mitigation

Risk Technical measures Organisational measures Residual risk
Data breach Encryption, TLS, access control Incident response, training Low
Special categories of data Encryption, audit logs Warnings, onboarding Medium
AI hallucinations Model settings Training, disclaimers in UI Medium
Unauthorised access MFA, session timeout Awareness training Low
Vendor lock-in Container architecture Exit strategy 2026 Low

10. Special Categories of Personal Data (Article 9 GDPR)

10.1 Risk Identification

High risk: Users may upload special categories of data such as:

  • • Care records
  • • Medical certificates
  • • Study guidance

10.2 Mitigation Measures

  • Technical: Encryption of all data
  • Interface: Warnings in the UI
  • Training: Instruction of teachers/researchers
  • Policy: No substantive analysis by EduGPT

11. Purpose Limitation and Proportionality

11.1 Permitted Purposes

✅ Only for education-related AI services

11.2 Excluded Purposes

  • ❌ No product development using data
  • ❌ No sale/sharing with third parties
  • ❌ No marketing

11.3 Necessity and Proportionality

  • Necessity: Use of AI is a reality, a secure alternative is the only option
  • Proportionality: Minimal data collection, user remains in control
  • Subsidiarity: Banning does not work, commercial tools are not GDPR-compliant

12. Recommendations and Implementation

12.1 Points of Attention for Educational Institutions

  • Conclude a data processing agreement
  • Instruct users on responsible use
  • Align data breach procedures and retention periods
  • Adjust internal procedures

12.2 Decision-making by the Educational Institution

  • Approval of implementation
  • Data processing agreement signed
  • Users instructed
  • Internal procedures adjusted

13. Planning and Milestones

Milestone Date Status
DPIA finalised September 2025 ✅
Pilot start October 2025 ✅
Interim evaluation November 2025 ✅
Pilot evaluation December 2025 ✅
Go/No-go production January 2026 ✅
DPIA update (version 2.0) July 2026 ✅
Correction of Azure region to Sweden Central (version 2.1) October 2026 ✅
Independent DPIA by external DPO September 2026 ⏳
New educational implementations (school year 2026-2027) September 2026 ⏳
DPIA review Q4 2026 ⏳

14. Legal Framework

  • AVG/GDPR: Fully applicable
  • Education legislation (WVO, WHW): Indirectly relevant, institutions remain ultimately responsible
  • BIO 2.0: Baseline for government/education, designed in accordance, not certified
  • EU AI Act: Prepared (low risk)

Annexes

  • Annex A: Technical specifications (Kubernetes on Scaleway, PostgreSQL, object storage, secrets management)
  • Annex B: Incident Response Plan
  • Annex C: Data Processing Agreement
  • Annex D: Contact details CivAI/EduGPT

Document Approval

Position Name Date Signature
Privacy Officer
CISO
Management

This document has been prepared in accordance with the requirements of the General Data Protection Regulation (AVG/GDPR) and contains a thorough analysis of the privacy impact of EduGPT.