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This is a starting point, not legal advice. It is pre-filled from what Dr Frost Learning (charity 1194954) 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: Dr Frost Learning   Supplier: Dr Frost Learning (charity 1194954)
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 toolmaths practice
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 (school is controller)
Where data is storedUK (Google Cloud UK data centre)
Trains AI on inputsno - PII not used for machine learning or AI
How long inputs are keptco-terminous with services agreement
Data processing agreementhttps://www.drfrost.org/data-processing-agreement
Signs individual DPAs: DPA accepted by checkbox for every customer
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 notesUK-hosted charity; sub-processors include Google Cloud, Sentry, Cloudflare, Zendesk, PostHog, Slack
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 Green, pupils Amber.

RiskSuggested measureLikelihood / severityResidual risk
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.drfrost.org/data-processing-agreement
  • https://www.drfrost.org/data-processor