ChatGPT and privacy: what it means for your school

What happens to what you type

A general-purpose assistant processes a prompt on the provider’s infrastructure, usually outside the school’s control and sometimes outside the EEA. Depending on the account type and the settings in force on the day, conversations may be retained, reviewed by humans for quality, or used to improve the service.

Consumer and business tiers differ, settings change between releases, and the terms are revised. That variability is the problem for a school: a control that depends on a toggle a teacher might flip, in an account the school does not administer, is not a control the school can evidence.

Which uses are a problem, and which are not

Not all of it is risky, and treating it as though it were is what drives the whole thing underground.

• Low risk — rewording a generic letter, generating practice questions on a topic, explaining a concept, drafting a scheme of work with no pupil named in it.
• High risk — anything containing a pupil’s name, class, SEN or IEP detail, medical or behavioural information, family circumstances, or text from a child-protection record.
• High risk and easy to miss — detail specific enough to identify a child without naming one, and uploading a document whose contents nobody re-read before attaching it.

Why this lands on the school

Under the GDPR the school — or, for an ETB school, the board — is the controller for pupil personal data. That responsibility does not transfer because a member of staff chose a tool themselves.

So the obligations stay where they were: lawful basis, data minimisation, transparency with parents about how their child’s data is processed, and the ability to answer a question about where it went. A free account opened on a laptop satisfies none of them, and nobody in the building knows it was opened.

What to do instead of banning it

Bans fail in both directions: staff lose a tool that genuinely helps with workload, and the usage continues on personal devices where the school has no visibility at all.

What works is narrower. Name the categories that may never be entered anywhere. Give staff a tool that is safe for the rest. Require a human to read anything before it reaches a pupil, a parent or a record. Then write it down in a policy the Board has adopted, so it is a rule rather than a preference.