FairCall Data Protection Impact Assessment (DPIA) Template
Last updated: February 18, 2026

Instructions
- This template is for school-level adaptation.
- Replace bracketed placeholders with school-specific details.
- Keep this document with your data protection records.

1. Product Description
- What: Cold call equity tracker for teachers.
- Who: Individual teachers in UK schools.
- Why: Improve classroom participation equity and support reflection.

2. Data Collected
- Teacher data: email, password hash.
- Student data: names, optional student ID, optional photo URL.
- Event data: timestamps and optional outcomes (correct, partial, incorrect).

3. Risk Assessment
Risk: Unauthorized access
Impact: Exposure of teacher or student records.
Mitigation: Encryption, authentication controls, tenant isolation.

Risk: Data loss
Impact: Loss of lesson reflection history.
Mitigation: Backup strategy, offline queue, sync recovery.

Risk: Surveillance perception
Impact: Reduced trust and adoption.
Mitigation: Teacher-only framing, reflection-first guidance.

Risk: Student anxiety
Impact: Classroom wellbeing concerns.
Mitigation: Clear positioning, guidance, optional logging behavior.

4. Safeguards
- No free-text notes on students (by design).
- No student-facing features.
- Reflection tool, not grading platform.
- No demographic data collection in MVP.

5. Data Retention and Deletion
- Default retention target: current academic year plus one.
- Teachers can delete class/account data through app controls.
- Account closure follows product retention/deletion controls.

6. Subprocessor List
- Vercel (frontend hosting, USA/EU).
- Railway (backend/database hosting, UK/EU preferred).
- Cloudflare R2 (future option, EU target region).

7. School Customization
- Controller identity: [School/Trust legal entity]
- Lawful basis: [Contract/Public task/Legitimate interests]
- Retention schedule: [School policy]
- DPO review date: [DD Month YYYY]
- Residual risk decision: [Accepted/Mitigated/Not accepted]
- Approval sign-off: [Name/Role/Date]

8. Decision Record
- DPIA outcome: [Proceed/Proceed with actions/Do not proceed]
- Required actions before rollout:
  1) [Action]
  2) [Action]
  3) [Action]

9. Review Cadence
- First review date: [DD Month YYYY]
- Trigger events: security incident, major feature change, legal/policy update.

10. Data Flow Map Artifacts (Pilot-ready)
- Narrative data flow map template: /templates/data-flow-map.txt
- Structured data flow register: /templates/data-flow-map-register.csv
- Ensure both artifacts are attached to your school DPIA record and reviewed with IT/DPO.