DPIA Support Information (for Schools)
LEARN-CO.DE LTD ("learn-co.de", "we", "us", "our")
Version 1.0 — Effective 22 June 2026
Before adopting a new EdTech service that processes children's data, a school (as controller) should normally carry out a Data Protection Impact Assessment (DPIA). This page gives schools the supplier-side information they need to complete one. It is provided for convenience and does not replace the school's own assessment.
Roles
- Controller: the School.
- Processor: LEARN-CO.DE LTD.
- Governed by our Data Processing Agreement.
What the Service does
Provides a computer science teaching and learning platform: class and assignment management, automatically marked questions and coding tasks, progress tracking, revision, and live in-class activities.
Personal data processed
- Teachers/staff: name, school email/username, role, classes.
- Pupils: name, school email/username, year group, class membership, answers/attempts, marks/grades, revision sessions, topic progress, saved code and free-text entries.
- Administrator: contact and billing data.
- Technical: limited security/operational logs.
- No special category data is requested or required.
Purpose and lawful basis
- Purpose: to deliver the teaching/learning service the school has chosen.
- Lawful basis: determined by the school as controller (commonly public task for state-funded schools).
- We process only on the school's documented instructions.
Data sharing and sub-processors
- No sale or sharing of personal data for others' purposes; no advertising; no profiling of children.
- Sub-processors are listed at /legal/sub-processors (Google Firebase/Firestore/Auth, Fly.io, Stripe, etc.).
Storage, location and security
- Stored in Firebase/Firestore in the United Kingdom (Google Cloud London,
europe-west2); hosted on Fly.io (London); Firebase Authentication is operated by Google and may process sign-in data outside the UK under appropriate safeguards. - Security measures: tenant isolation by school, role-based access, encryption in transit and at rest, least-privilege staff access, logging, backups and recovery. See our Security Statement.
Children's Code
We have regard to the ICO Age Appropriate Design Code: best interests of the child, data minimisation, high-privacy defaults, no marketing profiling. See our Safeguarding & Children's Code Statement.
Individuals' rights
Requests are handled by the school as controller; we assist. Schools can export and delete data using the admin tools.
Retention
Active for the subscription term; on cancellation, 90-day grace period then permanent deletion within a further 30 days. Billing records retained as legally required.
Risks and mitigations (starter list for schools)
| Risk | Mitigation |
|---|---|
| Unauthorised access to pupil data | Tenant isolation, role-based access, server-side rules, encryption |
| Inappropriate pupil-entered content | Teacher monitoring; our right to remove content / restrict accounts |
| Data loss | Backups and documented recovery |
| Accidental deletion on payment issue | 90-day grace period before deletion |
| Account sharing undermining accountability | Terms require one account per user |
Contact for DPIA queries
dpo@learn-co.de