Privacy and data

Trust pack · current as at 26 September 2026

Outleap DPIA Starter (School Template)

A starter for the school’s data protection impact assessment: Outleap’s processing set out, the school’s answers left to fill in.

These documents describe the new Outleap, which reaches schools on 2 November 2026. Schools using Outleap today can ask for their current copies at hello@outleap.io.

Download (.docx) Download (.md)

Status: Approved baseline template for school completion. This starter document does not replace legal or DPO advice.

1. Project Summary

  • Project: Outleap rollout for first-school destinations workflow
  • School: To fill in: School name
  • School owner: To fill in: Name + role
  • Outleap supplier entity: Outleap Limited (Company No. 14277395), 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE
  • ICO registration: ZB393894
  • Supplier contact: Jesse Merrigan (Director and named data protection contact, supported by Outleap's documented governance and review process). General/supplier, privacy and data-rights contact: hello@outleap.io
  • Start date: To fill in: YYYY-MM-DD
  • Review date: To fill in: YYYY-MM-DD

2. Processing Description

2.1 What is being processed

  • Student profile and school account data (name, email, role, school linkage)
  • Evidence entries and UCAS three-question statement drafts/submissions
  • Feedback drafts, published feedback, and status history
  • CV/application records where enabled for the school's rollout, including suggested wording stored with feedback on a cover letter or an application answer
  • Cohort visibility, at-risk flags, and progress/workflow metadata (milestones, submission state)
  • Administrative audit events and school setup metadata

2.2 Why this is processed

  • Give students a structured way to write their own drafts and get feedback on them in the school's active Outleap workflows
  • Enable staff oversight for progress and intervention
  • Support consistent, advisory statement feedback that staff can see through normal product views while safeguarding escalation remains owned by the school's usual route

2.3 Who can access data

  • Student role: own records
  • Teacher and school admin roles: scoped records according to assignment and school scope
  • Outleap admins: platform operations under contractual controls

3. Lawful Basis (School to complete)

  • Primary lawful basis: To fill in: Public task / Legitimate interests / Contract
  • Special category condition (if applicable): To fill in: Article 9 condition
  • Notes/justification: To fill in: School-specific rationale

4. Necessity and Proportionality

Document why this processing is required and proportionate.

  • Why these data fields are required for stated outcomes: To fill in: text
  • Why less intrusive alternatives are insufficient: To fill in: text
  • How role scoping/minimisation is enforced in school practice: To fill in: text

5. Data Flow Snapshot

StageData inProcessor/systemData out
AuthenticationEmail + auth tokenFirebase AuthRole-scoped session
Evidence captureEvidence entry text + metadataOutleap API + FirestoreSaved evidence records
Draft workflowStatement text + metadataOutleap API + FirestoreSaved draft/submission state
AI feedbackThe student's own writing + minimum workflow contextApproved AI service provider in the UK/EUStructured feedback returned to the Outleap API
Feedback deliveryGenerated feedback + workflow metadataOutleap API + FirestoreAdvisory feedback published to the student; statement feedback visible to staff through normal product views; feedback on a cover letter or an application answer can include suggested wording, stored with the feedback and not shown in the product views; no automated safeguarding alert delivery, staff routing or review hold in the service
AI drafting support, on the student's request (where enabled)The student's own evidence, or the CV point they choose + minimum workflow contextApproved AI service provider in the UK/EUA first CV built from the student's own evidence (where the school's CV setting allows it), stored when made; or a reworded CV point, returned to the student and stored only if they choose it
Evidence structuringA note about something the student has doneApproved AI service provider in the UK/EUA piece of evidence, returned to the student and stored only if they keep it
Page reading (where enabled)A course page the student keeps, or an advert or link they pasteApproved AI service provider in the UK/EUWhat it asks for: a course page's reading is stored when made; an advert's reading is stored only if the student keeps it
CV/application workspaces (where enabled)Evidence + CV/application text/contextOutleap API + FirestoreStudent-owned CV/application drafts, support and review states
ReportingProgress + status dataAdmin insights endpointsSchool admin views

6. Risk Assessment

Rate likelihood and impact for your school context.

RiskLikelihoodImpactControlsResidual risk
Unauthorised access to student recordsTo fill in: L/M/HTo fill in: L/M/HRBAC, school scoping, auth controlsTo fill in: L/M/H
Cross-school data visibilityTo fill in: L/M/HTo fill in: L/M/HSchoolId scoping checks, role middlewareTo fill in: L/M/H
Inappropriate handling of sensitive statement contentTo fill in: L/M/HTo fill in: L/M/HStaff visibility of feedback, school safeguarding process, Outleap operational support handoff if requiredTo fill in: L/M/H
Unnecessary disclosure or retention by an external AI serviceTo fill in: L/M/HTo fill in: L/M/HMinimum relevant workflow context; UK/EU provider routing; raw AI-output logging disabled; least-privilege runtime credentials; documented provider retention and contract termsTo fill in: L/M/H
Retention beyond educational needTo fill in: L/M/HTo fill in: L/M/HRetention schedule + deletion workflowTo fill in: L/M/H
Overreliance on AI feedbackTo fill in: L/M/HTo fill in: L/M/HFeedback labelled as advisory, staff visibility, human judgement retainedTo fill in: L/M/H

7. Mitigation Actions

  • Confirm school role model and access governance.
  • Agree retention windows by dataset and cycle.
  • Confirm safeguarding escalation route for concerning content.
  • Review and accept the current subprocessor list and data-flow description.
  • Confirm approved AI subprocessors, UK/EU processing arrangements and provider retention terms.
  • Document DSAR and breach communication contacts.
  • Complete contract pack (DPA + policy references).

8. Data Residency and Transfers

  • School confirms acceptance of documented residency statement in the supplier trust pack.
  • School confirms that relevant processing can occur in supported EU regions and records the applicable UK adequacy basis or other appropriate safeguard.
  • School confirms transfer safeguards are documented where any other non-UK processing occurs.
  • School records any local policy constraints here: To fill in: text.

9. Decision and Sign-Off

  • Residual risk level: To fill in: Low / Medium / High
  • DPO consultation required: To fill in: Yes / No
  • Approved by: To fill in: Name + role
  • Date: To fill in: YYYY-MM-DD

10. Review Cycle

  • Reassess at least annually, or sooner if processing scope materially changes.
  • Reassess after significant incidents, safeguarding events, or supplier architecture changes.

This is a template document. School-specific fields require completion and legal review before use.

For questions, and for privacy and data-rights requests, email hello@outleap.io.