Data protection impact assessment (DPIA): draft

Tool: English Dictation Supplier: not stated (no company name published; contact hi@englishdictation.org)
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 2026-11-07). 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	English listening dictation and shadowing practice (type what you hear, check word by word, review book, AI assistant, pronunciation scoring)
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: yes - learner accounts, but terms require the legal age to enter contracts [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 (privacy policy written as the service deciding how data is used; no school processor terms)
Where data is stored	United States (primary data storage; Cloudflare infrastructure in several countries; international transfers covered by standard contractual clauses and the international data transfer agreement via its providers); Google Analytics and Microsoft Clarity analytics
Trains AI on inputs	no - inputs and outputs not used to train their or third-party AI models (privacy policy and terms 8.3)
How long inputs are kept	AI prompts and output 90 days; account data for the life of the account, deleted or anonymised within 30 days of account deletion; logs 90 days; security logs 180 days; support records 2 years; transactions 7 years
Data processing agreement	Not stated by the supplier. [School to complete: DPA reference or date signed] Signs individual DPAs: not stated (says it uses DPAs with its own processors; no school DPA offered)
Supplier DPO / UK representative	not stated (single contact hi@englishdictation.org; no DPO or UK representative named)
Minimum age	18+ in the UK (legal age to enter binding contracts; not intended for minors)
Other safety notes	free tier with paid plans in USD; no named company behind the site; not intended for under-18s, so not for school pupils; pronunciation scoring and speaking features use your voice but the privacy policy does not mention voice recordings; AI prompts are sent to unnamed AI model providers; Google Analytics and Microsoft Clarity on the site
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 Red.

Risk	Suggested measure	Likelihood / severity	Residual risk
Data may be stored outside the UK/EU (US)	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: 18+ in the UK (legal age to enter binding contracts; not intended for minors)	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://englishdictation.org/
https://englishdictation.org/privacy-policy
https://englishdictation.org/terms-of-service
https://englishdictation.org/pricing