Data protection impact assessment (DPIA): draft

Tool: No More Marking (AI marking / Double Marker) Supplier: No More Marking 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	marking / comparative judgement
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: indirect - pupils' scanned writing is processed [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 (school is controller)
Where data is stored	pupil data stored in Ireland; Google Vision in EU; OpenAI processing may be in the US
Trains AI on inputs	no - not used to train models
How long inputs are kept	AI inputs/outputs may be kept up to 30 days for abuse monitoring
Data processing agreement	https://d180ur4pf89izg.cloudfront.net/uploads/asset/attachment/5756/GDPR%2Bagreement.pdf Signs individual DPAs: yes - standard GDPR agreement with each school
Supplier DPO / UK representative	Not stated by the supplier. [School to complete: contact details]
Minimum age	Not stated by the supplier. [School to complete: minimum age]
Other safety notes	AI features are optional and off by default; schools must accept a separate AI GDPR agreement
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.

Risk	Suggested measure	Likelihood / severity	Residual risk
Data may be stored outside the UK/EU (Mixed)	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://help.nomoremarking.com/en/article/gdpr-for-ai-projects-gg0kkn/
https://help.nomoremarking.com/en/article/sub-processors-1vsujet/
https://help.nomoremarking.com/en/article/accept-the-ai-gdpr-iapsjv/