How to do a DPIA for edtech in education
A DPIA guide and template approach for education: when colleges and training providers need a DPIA for edtech such as learner support software, and what to cover.
Guide · Data, AI and technology
A vendor-neutral guide to choosing learner support software for FE colleges and apprenticeship providers: questions on data, permissions, AI and contracts.
Guide at a glance
Checked against official guidance. Updated 9 October 2026.
Choose learner support software by testing how well it fits your support process, then ask every vendor the same questions about data location, permissions, accessibility, exports, AI use and contract terms. Run a data protection impact assessment, insist on evidence in writing and plan how you would leave.
Buying software that holds learners’ support needs is a different decision from buying a general business tool. The records are sensitive, the users range from learners to employers, and the consequences of a poor choice fall on people who are already facing barriers.
This guide helps you choose well. It is vendor-neutral. It tells you how to define what you need, what to ask every supplier, how to compare fairly, and how to avoid common buying mistakes. Near the end we are honest about where Inclusion Studio stands, since you should apply the same questions to us.
Decide what problem you are solving and who will use the system. Software cannot fix a process you have not defined.
Write down, in plain terms:
Bring in your data protection officer, IT lead, safeguarding lead and, importantly, learners and tutors. A short demo with real scenarios will tell you more than a feature list.
Ask every vendor the same questions in writing and compare the answers. The seven areas below cover most of the risk.
The W3C’s WCAG 2.2 is the reference. See WCAG 2.2 for education software for how to test claims.
The ICO’s AI and data protection guidance is currently under review, so check its latest status. See our guide on using AI safely in learner support.
For our own position on price, see pricing.
Run a data protection impact assessment during selection. Learner support records contain health information, which is special category data (see the ICO explanation), and some learners are children or adults at risk. The ICO’s DPIA guidance says a DPIA is needed where processing is likely to result in high risk. Your DPO should decide, and early involvement is cheaper than finding problems after signing.
See DPIA for learner support software, the DPIA screening checklist and special category data in education. None of this is legal advice.
Use a weighted scorecard and the same scenarios for each.
| Criterion | Weight (example) | Evidence to ask for |
|---|---|---|
| Fit with your support journey | 25% | Scenario demo using your own cases |
| Permissions and data controls | 20% | Role matrix; test with real roles |
| Data protection and security | 20% | Data processing agreement, sub-processor list, assurance reports |
| Accessibility | 15% | Conformance report; your own testing |
| Exports and exit | 10% | Sample export; written exit terms |
| Total cost and contract | 10% | Full cost over term |
The weights are an illustration; set your own. Run two or three scenarios with each vendor, for example “a learner declines part of a plan”, “support is missed twice in a month” and “an employer needs to see only workplace adjustments”. Watch what the product does, not what the slide says.
Honestly, it is early. Inclusion Studio is pre-pilot. A clickable prototype with fictional learners exists. The production application is in development and uses synthetic data only. There are no customers yet and no certifications yet. Launch prices are on our pricing page.
What we can tell you today: the design is built around the Understand, Agree, Deliver, Review journey for England FE colleges and apprenticeship providers. The primary application database is hosted in London (Neon, AWS eu-west-2), and some supporting services such as sign-in, hosting and file storage may process data elsewhere; each will be documented and assessed before real learner data is used. Permissions are designed to be enforced on the server by organisation, relationship and field. AI is optional, labelled and human-reviewed. Gemini on Google Cloud Vertex AI is the selected AI provider, tested with synthetic data only; the location for real learner data is not decided, and no real learner data has been sent to any AI provider. Read the detail on our trust pages, the subprocessors page, the assurance roadmap, the roadmap and the pilot page. Please put these same questions to us. If you want to take part in the pilot, get in touch. Our comparison pages look at spreadsheets, paper plans and general case management fairly, and the FAQ answers common questions about Inclusion Studio.
Probably, because the software will process special category data about people who may be children or vulnerable adults, and the ICO expects a DPIA where processing is likely to result in high risk. Your data protection officer should decide. Start the DPIA during selection, not after you have signed.
Not automatically. The UK GDPR has rules for restricted transfers, and your supplier should tell you where data is processed, who the sub-processors are and what safeguards apply. Ask for a current list and a commitment to notify you of changes.
Not necessarily, but you should know exactly what the AI does, which provider and model it uses, whether data is used for training, whether it can be turned off, and how a person reviews its output. A product should work fully without AI.
Many providers do, and that can work for a small caseload with careful controls. The question is whether it supports your whole process, controls access by role, records delivery and review, and produces evidence without manual rework. Compare honestly against your actual workflow.
Agree in writing how you can export all your data in an open, usable format, how long it takes, what it costs, and when the supplier deletes your data afterwards, with confirmation.
Official guidance changes. Check the source before relying on any detail, and take professional advice for individual cases.
We are working with a small number of England FE colleges and apprenticeship providers first. Tell us about your learner support and we will be in touch.