There’s a certain kind of email that arrives in a school inbox that immediately raises eyebrows. It starts with something like:
“Exciting news! We’re trialling new biometric scanners in the canteen to speed up lunch queues!”
It’s followed by promises of efficiency, reduced lunch line chaos, and fewer forgotten PINs. On the surface, it sounds brilliant. Who wouldn’t want a futuristic solution to an age-old problem?
But here’s the thing: before you ask a group of eleven-year-olds to hand over their fingerprints for a chicken nugget, you need to stop and ask a bigger question… Have we done a Data Protection Impact Assessment (DPIA)?
You may wonder why it is so important. A DPIA isn’t just some bureaucratic hoop to jump through. It’s a vital safeguard designed to help schools understand how a new system or process might affect people’s privacy, especially when you’re dealing with sensitive or high-risk data.
In schools, we hold data about children who are arguably some of the most vulnerable individuals in society. Introducing new tech that collects biometric data (like fingerprints or facial recognition) raises serious privacy concerns. Biometric data is classed as “special category data” under the UK GDPR, which means it requires extra care and justification.
A DPIA helps you figure out: What data is being collected, why you need it, what risks it poses to individuals and, how to mitigate those risks. Even more crucially, it helps you decide whether the shiny new system is really necessary in the first place.
Let’s return to that canteen scanner idea. The supplier promises that fingerprinting pupils will slash queue times and reduce cash handling. Sounds efficient, right?
But have we asked:
- Do we really need biometric data for this?
- Could a swipe card or QR code achieve the same result with less risk?
- What happens if a student refuses to give their fingerprint?
- How securely will this data be stored and, who can access it?
Without a DPIA, these questions may never even surface.
Or take another example: your school is rolling out a new online safeguarding tool that uses artificial intelligence to flag potential risks based on student writing. Impressive? Maybe. Intrusive? Potentially. A DPIA would help you assess whether the tool’s benefits outweigh the privacy implications, and what safeguards should be in place.
Remember… behind every “data point” is a real child. Their birthday. Their behaviour record. Their image. Their fingerprint.
A DPIA isn’t about red tape. It’s about respecting the trust families place in us. It’s about making thoughtful, informed choices, not just because it’s the law, but because it’s the right thing to do.
And honestly, it’s also about protecting your school. If things go wrong, if a data breach happens, or parents push back, a completed DPIA shows you took privacy seriously. It shows you were proactive, not reactive.
A Culture Shift, Not a Paper Exercise
The best schools aren’t just doing DPIAs to tick a box. They’re building a culture where people ask early on:
“Could this new system affect how we handle personal data?”
“Do we need to speak to the Data Protection Officer before we go ahead?”
“Have we thought this through, not just for us, but for our students?”
That’s where real digital responsibility begins. Not in a policy document, but in everyday conversations.
So next time someone suggests a new app, platform, or process… pause. Before you roll it out, before the training sessions and the excited emails, check whether a DPIA is needed.
Because in a world where data is power, doing a DPIA is how we wield that power wisely. Not to impress with tech, not to dazzle with dashboards but, to protect, to consider, and to educate with integrity.
