Data protection impact assessment (DPIA): draft

Tool: Running Paper Supplier: Running Paper Limited (UK, company 14874659; ICO ZB706592)
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 marking of handwritten work
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: teacher-facing; pupils sit printed papers by hand; teachers send reviewed feedback to pupils or parents [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, college or trust is controller; privacy policy and FAQ)
Where data is stored	core infrastructure and stored student work in the United Kingdom; some processing in the EEA under UK adequacy regulations; limited marking data processed in the US by AI providers under the UK-US Data Bridge or EU SCCs with the UK Addendum (FAQ)
Trains AI on inputs	no - "We don't train any large language models on student data" (FAQ)
How long inputs are kept	not stated publicly - set by the school's DPA (available on request)
Data processing agreement	Not stated by the supplier. [School to complete: DPA reference or date signed] Signs individual DPAs: yes - Data Processing Agreement forms part of each customer agreement; DPA, sub-processor list and security policy available on request before signing
Supplier DPO / UK representative	not stated (contact info@runningpaper.co.uk)
Minimum age	Not stated by the supplier. [School to complete: minimum age]
Other safety notes	teacher reviews every mark before release; Cyber Essentials; not linked to any exam board, so not for real GCSE/A level grades
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
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://www.runningpaper.co.uk/faq
https://www.runningpaper.co.uk/privacy
https://www.runningpaper.co.uk/terms