Data protection impact assessment (DPIA): draft

Tool: Proctorio Supplier: Proctorio Inc
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	online exam proctoring
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 - records students [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 (institution is controller)
Where data is stored	region chosen by institution (Europe, US, Canada and others)
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	set by institution; up to 30 days after contract end; e.g. Wolverhampton keeps recordings 2 years
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 by the supplier. [School to complete: contact details]
Minimum age	Not stated by the supplier. [School to complete: minimum age]
Other safety notes	webcam/screen/audio recording of students with automated behaviour flags; recordings end-to-end encrypted
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 (Mixed)	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: 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://proctorio.com/privacy
https://proctorio.com/privacy/data-security
https://www.wlv.ac.uk/about-us/governance/legal-information/data-protection/wepe-privacy-notice/