Data protection impact assessment (DPIA): draft

Tool: Novastart Supplier: Marketplace Distributors LLC (Manhattan Beach, California, US)
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 2026-11-01). 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	AI agent / assistant
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: student- and teacher-facing; offered free to students and teachers at partner universities with a .edu email; site and software not directed at children under 16 [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 by the supplier. [School to complete: confirm with the supplier]
Where data is stored	canvas contents stay on the user's own machine and shared canvases stream peer to peer; AI agent screenshots and instructions are sent to OpenAI; other personal data may be processed in the US under safeguards such as standard contractual clauses
Trains AI on inputs	Not stated by the supplier. [School to complete: confirm and record the setting you will use]
How long inputs are kept	AI agent run logs (steps, clicks, screenshots) kept on the user's machine; account and billing records kept while the account is open and as tax rules require; support correspondence kept for a reasonable period
Data processing agreement	Not stated by the supplier. [School to complete: DPA reference or date signed] Signs individual DPAs: Not stated by the supplier. [School to complete: ask the supplier]
Supplier DPO / UK representative	not stated (contact support@novastart.com)
Minimum age	16+ (not directed at children under 16)
Other safety notes	replaces the computer desktop with an operating system; AI agents get their own mouse and keyboard and send screenshots of the window they work in to OpenAI; privacy policy allows analytics, advertising and retargeting cookies and email tracking pixels; no certification or audit claimed
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
Unclear whether inputs are used for AI training	Ask the supplier in writing; check plan settings.	[School to complete: low / medium / high]	[School to complete: accepted?]
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: 16+ (not directed at children under 16)	Check this against the age of any pupils who will use it.	[School to complete: low / medium / high]	[School to complete: accepted?]
Supplier not confirmed as a processor acting on school instructions	Clarify roles in the contract.	[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://novastart.com/privacy/
https://novastart.com/security/
https://novastart.com/education/