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This is a starting point, not legal advice. It is pre-filled from what Google 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: NotebookLM (Workspace for Education)   Supplier: Google
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 toolresearch/teacher tool
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: Not stated by the supplier. [School to complete: staff only, or pupils too?]
[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 (Workspace core service, Cloud Data Processing Addendum applies)
Where data is storedGoogle infrastructure; org data region settings do NOT apply to NotebookLM (now Gemini Notebook) data; transfers under the SCCs in Google's Cloud Data Processing Addendum
Trains AI on inputsno; not human reviewed
How long inputs are keptNot stated by the supplier. [School to complete: retention period]
Data processing agreementhttps://cloud.google.com/terms/data-processing-addendum
Signs individual DPAs: yes - Cloud Data Processing Addendum is part of the Workspace agreement
Supplier DPO / UK representativeNot stated by the supplier. [School to complete: contact details]
Minimum age18+
Other safety notesNot stated by the supplier. [School to complete: admin controls, content filtering]
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 Red.

RiskSuggested measureLikelihood / severityResidual risk
Data may be stored outside the UK/EU (Other / unclear)Confirm the transfer safeguards (UK IDTA, standard contractual clauses or adequacy).[School to complete: low / medium / high][School to complete: accepted?]
Minimum age: 18+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 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://support.google.com/a/answer/15706919?hl=en
  • https://workspaceupdates.googleblog.com/2025/04/notebookLM-and-gemini-app-core-services-for-education-customers.html
  • https://cloud.google.com/terms/data-processing-addendum
  • https://support.google.com/a/answer/15706919
  • https://workspace.google.com/terms/dpa_terms.html