Data protection impact assessment (DPIA): draft

Tool: Kahoot! (AI features) Supplier: Kahoot! ASA
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	quiz
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 [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 customer data (DPA)
Where data is stored	EU/EEA and UK; outside these under SCCs / UK IDTA or addendum where no adequacy (DPA s.9)
Trains AI on inputs	no - platform data not used to train models; vendors not allowed
How long inputs are kept	Not stated by the supplier. [School to complete: retention period]
Data processing agreement	https://trust.kahoot.com/dpa/ Signs individual DPAs: yes - standard DPA applies where Kahoot! is a processor
Supplier DPO / UK representative	Not stated by the supplier. [School to complete: contact details]
Minimum age	children = under 13 US / under 16 elsewhere; limited data collected
Other safety notes	Kahoot! did NOT opt out of Azure abuse monitoring (prompts may be retained by Microsoft for review); users told not to enter personal data
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.

Risk	Suggested measure	Likelihood / severity	Residual risk
Minimum age: children = under 13 US / under 16 elsewhere; limited data collected	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://trust.kahoot.com/privacy-policy/
https://trust.kahoot.com/ai-powered-features-in-kahoot/
https://trust.kahoot.com/dpa/