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This is a starting point, not legal advice. It is pre-filled from what Atom Learning publishes and what we found on 2026-10-23. The highlighted gaps are for your school to complete. Your data protection officer (DPO) should review the finished DPIA.

Data protection impact assessment (DPIA): draft

Tool: Atom Learning   Supplier: Atom Learning
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 2026-10-23). A starting point only; not legal advice. Verify every fact before relying on it.

1. What the tool will be used for

Type of tooladaptive learning (11+)
Purpose in our school[School to complete: what you will use it for, which year groups or staff, and why]
Who will use itSupplier says pupil-facing: yes
[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 controllerprocessor for school-uploaded data; controller for parent accounts
Where data is storedEEA
Trains AI on inputsNot stated by the supplier. [School to complete: confirm and record the setting you will use]
How long inputs are keptNot stated by the supplier. [School to complete: retention period]
Data processing agreementhttps://space-1.atomlearning.com/docs/school/AS.3%20-%20Atom%20School%20-%20Data%20Processing%20Agreement.pdf
Signs individual DPAs: Not stated by the supplier. [School to complete: ask the supplier]
Supplier DPO / UK representativeNot stated by the supplier. [School to complete: contact details]
Minimum ageNot stated by the supplier. [School to complete: minimum age]
Other safety notesadaptive (non-generative) AI; pupil data sanitised before internal ML analysis
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.

RiskSuggested measureLikelihood / severityResidual risk
Unclear whether inputs are used for AI trainingAsk the supplier in writing; check plan settings.[School to complete: low / medium / high][School to complete: accepted?]
Minimum age: not statedCheck this against the age of any pupils who will use it.[School to complete: low / medium / high][School to complete: accepted?]
AI output may be inaccurate or biasedStaff 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://www.atomlearning.com/gdpr
  • https://www.atomlearning.com/privacy
  • https://www.atomlearning.com/blog/what-is-adaptive-learning