Data protection impact assessment (DPIA): draft

Tool: Top Marks AI Supplier: Top Marks AI Ltd (UK, company 11580241; ICO ZB903015)
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 2026-11-02). 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 GCSE/A-level scripts
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: no - teacher-facing; teachers upload pupils' scanned scripts [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	student and staff data stored and processed in the UK and EEA; only anonymised assessment content sent to US AI model providers
Trains AI on inputs	no - will not use customer data, including student data, to train or fine-tune any AI model without the school's prior written permission (terms 5.2)
How long inputs are kept	held for the licence period; deleted within 90 days of contract end (or 30 days of instruction) after a 60-day export window
Data processing agreement	https://www.topmarks.ai/terms (Schedule 1 Data Processing Agreement) Signs individual DPAs: yes - DPA is Schedule 1 of the platform terms
Supplier DPO / UK representative	data protection lead (COO), info@topmarks.ai
Minimum age	not applicable (teacher accounts)
Other safety notes	teacher reviews marks; Cyber Essentials; MIS link via Wonde can be switched off; DPIA support pack offered
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 Red.

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 applicable (teacher accounts)	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.topmarks.ai/privacy
https://www.topmarks.ai/terms