Provided by CimotaTech Ltd for schools deploying Handwriting Horizons

This template is provided by CimotaTech to assist the contracting School/Multi-Academy Trust (the Data Controller) in completing their mandatory DPIA under UK GDPR. Sections marked [Pre-filled] reflect CimotaTech’s technical architecture. Sections marked [School Action] must be completed by the school’s DPO or Data Lead.

Step 1: Need for a DPIA

[Pre-filled] A DPIA is required because the School is adopting handwriting intervention software (Handwriting Horizons) that systematically processes the personal data of vulnerable data subjects (primary-aged children), including Special Category Data (Special Educational Needs and Disabilities - SEND indicators). The platform utilizes automated API synchronization from the school’s Management Information System (MIS).

Step 2: Describe the Processing

[Pre-filled]

• Nature of Processing: The platform generates pedagogical handwriting interventions synced to the school's phonics scheme and tailors the biomechanical/accessibility UI to the specific SEND profile of the learner.
• Data Sources: Read-only data is pulled directly from the school’s MIS via the Wonde API.
• Data Processed: First name, last initial, Year Group, Class Name, UPN (solely for matching), and specific Special Category Data (SEND indicators such as dyspraxia, dyslexia, visual impairment, or motor-skill flags).
• Data Excluded: Full medical files, safeguarding notes, and unrelated behavioral records are never requested or ingested.
• Sub-processors:
  
  • Hosting/Database: Google Cloud (UK London/Cardiff).
  • MIS API: Wonde Ltd (UK).
  • Identity/SSO: Zitadel (UK Hosted).
• Retention: Data is actively synced. When a pupil is removed from the school’s MIS, the Wonde integration automatically flags the pupil’s entire record (including SEND history) for permanent deletion from CimotaTech’s databases.

Step 3: Consultation Process

[School Action]

• Detail any consultation undertaken with staff, parents, or governors regarding the rollout of this software.
  
  • Response: _________________________________________________

Step 4: Assess Necessity and Proportionality

[Pre-filled - Lawful Basis]

• Standard Personal Data: Processing is based on Article 6(1)(e) Public Task, as it is necessary for the school to perform its official educational functions.
• Special Category Data (SEND): Processing is based on Article 9(2)(g) Substantial Public Interest, supported by the Data Protection Act 2018 (Schedule 1, Part 2, Paragraph 6: Statutory and Government Purposes), as tailoring the software to accommodate disabilities is necessary for inclusive educational provision and Equality Act 2010 compliance.
• Proportionality: Processing is strictly limited to the minimum fields required (Data Minimization). No passwords are created. No unmonitored communication features exist.

Step 5 & 6: Identify Risks and Mitigating Measures

[Pre-filled]

TODO

• Source of Risk: Unauthorized Access (Hacking)
  • Potential Impact: Data breach / exposure of pupil names
  • Mitigating Measures (CimotaTech): All databases hosted in enterprise Google Cloud UK environments. Data is encrypted in transit (TLS 1.3) and at rest (AES-256).
  • Residual Risk: Low
• Source of Risk: Exposure of Special Category (SEND) Data
  • Potential Impact: Privacy violation / Discrimination
  • Mitigating Measures (CimotaTech): Strict data minimization (only specific SEND flags ingested via Wonde). Pupil-facing interfaces never display SEND labels to peers. Strict engineering RBAC.
  • Residual Risk: Low
• Source of Risk: Compromised User Passwords
  • Potential Impact: Unauthorized access to profiles
  • Mitigating Measures (CimotaTech): Passwords are not used. Access is entirely federated via the school’s secure SSO (Google Workspace, Microsoft Entra ID, or Hwb).
  • Residual Risk: Low
• Source of Risk: Inappropriate Communication
  • Potential Impact: Safeguarding / Grooming risk
  • Mitigating Measures (CimotaTech): Platform architecture is entirely closed. Zero peer-to-peer messaging, chat features, or public profiles.
  • Residual Risk: Low

[School Action]

• Identify any localized risks specific to your school’s network or device deployment.
  
  • Localized Risk: _______________________________________
  • Mitigation: _______________________________________

Step 7: Sign-off and Record Outcomes

[School Action]

• DPO / Data Lead Name: ________________________
• Signature: ________________________
• Date: ________________________