Data protection impact assessment (DPIA): draft

Tool: Whisper AI Transcribe Supplier: not stated (no company name published; site signs itself Whisper AI Transcribe, contact support@whisperaitranscribe.com)
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 2026-11-09). 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	audio and video transcription (upload recordings or public links of meetings, lectures and interviews, or record in the browser; speaker labels, AI summaries; export DOCX, PDF, TXT, CSV or SRT/VTT subtitles)
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: not stated (individual accounts; about page lists students capturing lectures among users; no school or pupil accounts described) [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 (privacy policy written as the service deciding how data is used; no school processor terms)
Where data is stored	not stated (storage location not given); transcription via OpenAI, L.L.C. (United States); Firebase, Mixpanel and Google Analytics analytics
Trains AI on inputs	no - recordings, audio and transcripts not used to train, fine-tune, evaluate or improve its own or third-party AI models, and providers not permitted to (privacy policy section 3)
How long inputs are kept	original uploaded audio or video deleted after processing; transcripts and associated audio kept in the account until you delete them; extracted MP3 files 30 days; no backups
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 (single contact support@whisperaitranscribe.com; no DPO or UK representative named)
Minimum age	13+ (not intended for under-13s)
Other safety notes	no named company behind the site; a separate site and account from WhisperTranscript (whispertranscript.ai) with its own prices, but its privacy policy and terms are word for word the same text (same Anguilla court clause), so it looks like the same unnamed operator; privacy policy says the service is for personal, non-commercial use only; recording lessons or meetings needs the consent of everyone recorded; audio is processed by OpenAI in the US; advertising cookies plus Firebase, Mixpanel and Google Analytics on the site; says 'Powered by OpenAI' but does not say it is run by OpenAI; paid plans in USD and all purchases non-refundable
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
Data may be stored outside the UK/EU (Not stated)	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: 13+ (not intended for under-13s)	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://whisperaitranscribe.com/
https://whisperaitranscribe.com/privacy
https://whisperaitranscribe.com/terms
https://whisperaitranscribe.com/pricing
https://whisperaitranscribe.com/subscription-terms
https://whisperaitranscribe.com/about-us