Data protection impact assessment (DPIA): draft

Tool: AI Photo Editor (aiphotoreditor.com) Supplier: not stated - independent operator, not named on the site; no street address published
School: [School to complete: school name] Prepared by: [School to complete: name and role] Date: [School to complete: date]

Draft generated by AI Prefect from the supplier’s published documents (checked 2026-11-03). A starting point only; not legal advice. Verify every fact before relying on it.

1. What the tool will be used for

Type of tool	image generation / AI photo editing
Purpose in our school	[School to complete: what you will use it for, which year groups or staff, and why]
Who will use it	Supplier says pupil-facing: not stated - general consumer photo editor, not aimed at schools; 13+ [School to complete: number and roles of users]
Personal data involved	[School to complete: e.g. staff names and emails; any pupil data; any special category data (health, SEND, safeguarding)? Avoid where possible]

2. How the supplier handles data

Processor or controller	Not stated by the supplier. [School to complete: confirm with the supplier]
Where data is stored	may be processed outside your country (cloud infrastructure, Cloudflare hosting); storage region and transfer protections not stated
Trains AI on inputs	not stated - says it does not sell prompts or photos; nothing on training
How long inputs are kept	drafts kept about 24 hours (free) or about 7 days (paid pack) in My works, then deleted; guest previews about 24 hours in the browser; credit records and support emails kept longer
Data processing agreement	Not stated by the supplier. [School to complete: DPA reference or date signed] Signs individual DPAs: Not stated by the supplier. [School to complete: ask the supplier]
Supplier DPO / UK representative	Not stated by the supplier. [School to complete: contact details]
Minimum age	13
Other safety notes	prompts and uploaded photos go to third-party model providers (GPT, Nano Banana and Seedream named as options; providers not identified); Google sign-in needed after one free try a day; Microsoft Clarity records clicks, scrolls and mouse movement; Tawk.to live chat; terms ban uploading photos of people without their agreement and deepfakes
Lawful basis	[School to complete: e.g. public task (Article 6(1)(e)) or legitimate interests; Article 9 condition if special category data]

3. Risks and how we will reduce them

AI Prefect rating: staff Amber, pupils Amber.

Risk	Suggested measure	Likelihood / severity	Residual risk
Unclear whether inputs are used for AI training	Ask the supplier in writing; check plan settings.	[School to complete: low / medium / high]	[School to complete: accepted?]
Data may be stored outside the UK/EU (Other / unclear)	Confirm the transfer safeguards (UK IDTA, standard contractual clauses or adequacy).	[School to complete: low / medium / high]	[School to complete: accepted?]
No data processing agreement published	Request a DPA before use, or limit use to non-personal data.	[School to complete: low / medium / high]	[School to complete: accepted?]
Minimum age: 13	Check this against the age of any pupils who will use it.	[School to complete: low / medium / high]	[School to complete: accepted?]
Supplier not confirmed as a processor acting on school instructions	Clarify roles in the contract.	[School to complete: low / medium / high]	[School to complete: accepted?]
AI output may be inaccurate or biased	Staff review all output before it is used; do not rely on it for decisions about individuals.	[School to complete: low / medium / high]	[School to complete: accepted?]
[School to complete: any other risks]	[School to complete: measure]

4. Sign-off

DPO advice	[School to complete: DPO comments and date]
Decision	[School to complete: approved / approved with conditions / not approved]
Approved by	[School to complete: name, role, date]
Review date	[School to complete: usually within 12 months, or when the supplier changes its terms]

Sources

https://aiphotoreditor.com/privacy/
https://aiphotoreditor.com/terms/
https://aiphotoreditor.com/about
https://aiphotoreditor.com/contact