Data protection impact assessment (DPIA): draft

Tool: CPOMS (AI features) Supplier: CPOMS Systems Ltd
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 tool	safeguarding
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: no [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	processor for school data
Where data is stored	Not stated by the supplier. [School to complete: confirm location and transfer safeguards]
Trains AI on inputs	Not stated by the supplier. [School to complete: confirm and record the setting you will use]
How long inputs are kept	Not stated by the supplier. [School to complete: retention period]
Data processing agreement	https://www.cpoms.co.uk/wp-content/uploads/CPOMS-Systems-Terms-and-Conditions.pdf (DPA within T&Cs) Signs individual DPAs: Not stated by the supplier. [School to complete: ask the supplier]
Supplier DPO / UK representative	DPO: dpo@cpoms.co.uk
Minimum age	Not stated by the supplier. [School to complete: minimum age]
Other safety notes	T&Cs: AI output is draft, human review required, no sole-basis safeguarding decisions. Privacy notice: may use third-party AI service providers (not named); transfers abroad rely on UK adequacy or contractual protections
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 Grey, pupils Grey.

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 (Not stated)	Confirm the transfer safeguards (UK IDTA, standard contractual clauses or adequacy).	[School to complete: low / medium / high]	[School to complete: accepted?]
Minimum age: not stated	Check 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 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://www.cpoms.co.uk/privacy/
https://www.cpoms.co.uk/wp-content/uploads/CPOMS-Systems-Terms-and-Conditions.pdf