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AVT – exit report

Next steps

In this sandbox project on “”, we have explored the legal basis for processing, transparency and protection of pupil privacy through a data protection impact assessment.

The most intense debate has been focused on legal basis, where the participants have differing views. The Data Protection Authority has not concluded on what would be the most appropriate legal basis for those implementing the learning analytics system. That is neither our mandate for the sandbox, nor a goal in and of itself. The most important focus has been to explore challenges and opportunities within the regulatory framework, as well as to highlight relevant aspects to take into account when considering the use of artificial intelligence in education. The many good discussions have enhanced the competence on all those involved in this sandbox project. The fact that the legal basis for processing is such a controversial topic, in the NAV and Secure Practice projects as well as this one, is a finding in and of itself. Considerations of legal basis can be difficult, especially when artificial intelligence is involved.

The Ministry of Education is currently working on a new education act, which will not be ready until 2023, at the earliest. The education sector, therefore, currently has a unique opportunity to clarify how schools can contribute to the development of educational AI tools.

We have also documented the benefit of involving various stakeholders in assessments of risks and impacts to the pupils’ privacy. The pupils contributed with scenarios the adults had not necessarily considered. Parents, data protection officers and others helped emphasise the need for information that artificial intelligence brings. We have identified several challenges inherent in this use, including in exploring how information can be adapted to different user groups. Needs vary considerably, even within groups. Younger children’s needs differ from the needs of older children, and teachers’ needs differ from the needs of parents. Discussions on transparency also highlighted resource issues. The preparation of information comes at a cost, and resources are not infinite. Going forward, the AVT project will have to find a happy medium between what the law requires and what the stakeholders need to know.

The sandbox project is completed, but the exploration of artificial intelligence in schools has only just begun. The AVT project is blazing the trail in a field that will only become more important in the future. The project’s contributions in the sandbox has shed light on an area the Data Protection Authority does not have much experience with. The opportunities are endless, and the importance of a sober, ethical approach could not be more clear. The AVT project has taken its responsibilities seriously and is likely building the foundation for a better education for our children in the time to come.