ICEQC-R-2021-07 — Data Protection and Human Oversight in Emerging Educational Technologies cover

Informe de Investigación Temática

ICEQC-R-2021-07 — Data Protection and Human Oversight in Emerging Educational Technologies

A global standards interpretive study of necessity, learner data, accountable decisions and safe institutional use

Fecha de publicación
Categoría de investigación
Interpretación de normas
Informe arquetipo
Estudio interpretativo de estándares
Ámbito geográfico
Global
Fecha límite para la presentación de pruebas
Organismo responsable
Dirección de Investigación y Políticas de ICEQC
ICEQC-R-2021-07 — Data Protection and Human Oversight in Emerging Educational Technologies cover

Publication record

This is the controlled English edition. Evidence and institutional status are stated as at the evidence cut-off date.

Executive summary

An emerging education tool should not collect personal information or influence decisions merely because it can. Institutions should begin with a defined learner-facing purpose, lawful authority, necessity and less intrusive alternatives. Children’s best interests, evolving capacity and established education and privacy rights remain the governing baseline.

Data protection applies from collection and inference through access, sharing, retention, correction and deletion. Behavioural traces and derived labels can be as consequential as records supplied directly by learners. Institutions should minimize fields, provide understandable notice, restrict access and external use, separate temporary traces from authoritative records and verify deletion.

Human oversight is meaningful only when a competent person understands the purpose and limitations, can consider direct learner evidence, has authority to depart from the output and remains accountable for reasons. Nominal confirmation of a pre-determined result is not oversight. Learners need an understandable explanation, correction and independent review.

Instructional recommendation, participation monitoring, assessment, accessibility and online communication have different risks. Each use requires separate validation and safeguards. Behavioural traces should not be equated with motivation; accessibility must not depend on unnecessary sensitive inference; and commercial influence should remain subordinate to learning and child wellbeing.

Protection and oversight should appear in procurement, contract terms, limited introduction, incident response and exit. Suppliers should provide verifiable evidence and public authorities should retain scrutiny, correction and termination rights. Safe exit includes data return, verified deletion, record continuity and uninterrupted education.

Key findings

  • Educational purpose and necessity should precede collection or acquisition.
  • Derived labels and behavioural traces require the same rights discipline as supplied records.
  • Notice should be understandable to learners and explain purpose, recipients and consequence.
  • Human review requires competence, evidence access, real discretion and accountable reasons.
  • Each educational use needs distinct validity, equity, accessibility and remedy evidence.
  • External provision should not remove public scrutiny or learner correction rights.
  • Incidents require rapid containment, learner-facing correction and education continuity.
  • Termination should include data return, deletion evidence and usable replacement service.

Scope and method

This global standards interpretive study examines data protection and human oversight in emerging educational technologies as at 10 September 2021. It covers necessity, the data lifecycle, educational decisions, child protection, procurement, incidents and exit. Later 2021 recommendations, future reports and retrospective outcomes are excluded.

Evidence is confined to official international and European institutional material available by the cutoff, including education and rights instruments, statistical and equity guidance, pandemic education evidence, European data and communications law, public purchasing guidance and the United Nations child-rights interpretation for digital environments.

Part I

Necessity, purpose and accountable authority

1

A defined learner-facing purpose

A defined learner-facing purpose defines a material issue within the purpose definition. For a defined learner-facing purpose, the affected learners or institutions are learners and educators affected by a proposed tool, and the immediate evidence concerns educational need and intended decision. In governing a defined learner-facing purpose, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on a defined learner-facing purpose, technical capability and supplier availability do not establish necessity or public value.[REF-01] [REF-24] [REF-54] [REF-60]

The principal risk is that capability or vendor offer determines institutional use. In governing a defined learner-facing purpose, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on a defined learner-facing purpose, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning a defined learner-facing purpose, each stage needs an identified owner, evidence and correction route.[REF-01] [REF-24] [REF-54]

The recommended response is to state the learner benefit and bounded function. Within evidence on a defined learner-facing purpose, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning a defined learner-facing purpose, evidence requirements should rise with consequence. In reviewing a defined learner-facing purpose, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-24] [REF-54] [REF-60]

Validity for a defined learner-facing purpose should be demonstrated for the stated educational population and decision. For decisions concerning a defined learner-facing purpose, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing a defined learner-facing purpose, coverage, missingness and group error should be tested. For learner protection in a defined learner-facing purpose, outputs should not circulate beyond the construct and setting supported by evidence.[REF-01] [REF-60]

Data protection for a defined learner-facing purpose should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing a defined learner-facing purpose, learners need understandable information and practical correction. For learner protection in a defined learner-facing purpose, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-24] [REF-54] [REF-60]

Human oversight for a defined learner-facing purpose should be assigned to a competent person with real authority. For learner protection in a defined learner-facing purpose, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For a defined learner-facing purpose, the learner should receive a decision-level reason and independent review while current education continues.[REF-01] [REF-24] [REF-54] [REF-60]

Equity and child-rights review for a defined learner-facing purpose should examine disability, language, location, income, migration and age where they affect coverage or consequence. For a defined learner-facing purpose, equal application of an invalid measure is not substantive equality. In governing a defined learner-facing purpose, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-24] [REF-54] [REF-60]

Institutional accountability for a defined learner-facing purpose should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing a defined learner-facing purpose, continued use depends on verified educational benefit and acceptable distribution. Within evidence on a defined learner-facing purpose, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-01] [REF-24] [REF-54] [REF-60]

2

Necessity and less intrusive alternatives

Necessity and less intrusive alternatives defines a material issue within the necessity test. For necessity and less intrusive alternatives, the affected learners or institutions are institutions selecting a technology-enabled arrangement, and the immediate evidence concerns need, alternative and data burden. In governing necessity and less intrusive alternatives, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on necessity and less intrusive alternatives, technical capability and supplier availability do not establish necessity or public value.[REF-10] [REF-21] [REF-60] [REF-62]

The principal risk is that administrative convenience justifies excessive personal data. In governing necessity and less intrusive alternatives, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on necessity and less intrusive alternatives, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning necessity and less intrusive alternatives, each stage needs an identified owner, evidence and correction route.[REF-10] [REF-21] [REF-60]

The recommended response is to compare feasible lower-intrusion means. Within evidence on necessity and less intrusive alternatives, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning necessity and less intrusive alternatives, evidence requirements should rise with consequence. In reviewing necessity and less intrusive alternatives, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-21] [REF-60] [REF-62]

Validity for necessity and less intrusive alternatives should be demonstrated for the stated educational population and decision. For decisions concerning necessity and less intrusive alternatives, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing necessity and less intrusive alternatives, coverage, missingness and group error should be tested. For learner protection in necessity and less intrusive alternatives, outputs should not circulate beyond the construct and setting supported by evidence.[REF-10] [REF-62]

Data protection for necessity and less intrusive alternatives should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing necessity and less intrusive alternatives, learners need understandable information and practical correction. For learner protection in necessity and less intrusive alternatives, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-21] [REF-60] [REF-62]

Human oversight for necessity and less intrusive alternatives should be assigned to a competent person with real authority. For learner protection in necessity and less intrusive alternatives, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For necessity and less intrusive alternatives, the learner should receive a decision-level reason and independent review while current education continues.[REF-10] [REF-21] [REF-60] [REF-62]

Equity and child-rights review for necessity and less intrusive alternatives should examine disability, language, location, income, migration and age where they affect coverage or consequence. For necessity and less intrusive alternatives, equal application of an invalid measure is not substantive equality. In governing necessity and less intrusive alternatives, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-21] [REF-60] [REF-62]

Institutional accountability for necessity and less intrusive alternatives should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing necessity and less intrusive alternatives, continued use depends on verified educational benefit and acceptable distribution. Within evidence on necessity and less intrusive alternatives, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-10] [REF-21] [REF-60] [REF-62]

3

Lawful and competent authority

Lawful and competent authority defines a material issue within the decision authority. For lawful and competent authority, the affected learners or institutions are schools, ministries and external providers sharing functions, and the immediate evidence concerns legal basis, mandate and responsibility. In governing lawful and competent authority, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on lawful and competent authority, technical capability and supplier availability do not establish necessity or public value.[REF-18] [REF-27] [REF-58] [REF-60]

The principal risk is that no body owns the decision or provider terms define public authority. In governing lawful and competent authority, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on lawful and competent authority, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning lawful and competent authority, each stage needs an identified owner, evidence and correction route.[REF-18] [REF-27] [REF-58]

The recommended response is to publish competence and retained public duty. Within evidence on lawful and competent authority, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning lawful and competent authority, evidence requirements should rise with consequence. In reviewing lawful and competent authority, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-27] [REF-58] [REF-60]

Validity for lawful and competent authority should be demonstrated for the stated educational population and decision. For decisions concerning lawful and competent authority, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing lawful and competent authority, coverage, missingness and group error should be tested. For learner protection in lawful and competent authority, outputs should not circulate beyond the construct and setting supported by evidence.[REF-18] [REF-60]

Data protection for lawful and competent authority should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing lawful and competent authority, learners need understandable information and practical correction. For learner protection in lawful and competent authority, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-27] [REF-58] [REF-60]

Human oversight for lawful and competent authority should be assigned to a competent person with real authority. For learner protection in lawful and competent authority, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For lawful and competent authority, the learner should receive a decision-level reason and independent review while current education continues.[REF-18] [REF-27] [REF-58] [REF-60]

Equity and child-rights review for lawful and competent authority should examine disability, language, location, income, migration and age where they affect coverage or consequence. For lawful and competent authority, equal application of an invalid measure is not substantive equality. In governing lawful and competent authority, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-27] [REF-58] [REF-60]

Institutional accountability for lawful and competent authority should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing lawful and competent authority, continued use depends on verified educational benefit and acceptable distribution. Within evidence on lawful and competent authority, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-18] [REF-27] [REF-58] [REF-60]

4

Children’s best interests and evolving capacity

Children’s best interests and evolving capacity defines a material issue within the child-centred use. For children’s best interests and evolving capacity, the affected learners or institutions are children of different ages and circumstances, and the immediate evidence concerns benefit, autonomy and development. In governing children’s best interests and evolving capacity, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on children’s best interests and evolving capacity, technical capability and supplier availability do not establish necessity or public value.[REF-14] [REF-22] [REF-60] [REF-62]

The principal risk is that institutional or commercial interest displaces the child’s interest. In governing children’s best interests and evolving capacity, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on children’s best interests and evolving capacity, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning children’s best interests and evolving capacity, each stage needs an identified owner, evidence and correction route.[REF-14] [REF-22] [REF-60]

The recommended response is to assess best interests and age-appropriate participation. Within evidence on children’s best interests and evolving capacity, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning children’s best interests and evolving capacity, evidence requirements should rise with consequence. In reviewing children’s best interests and evolving capacity, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-22] [REF-60] [REF-62]

Validity for children’s best interests and evolving capacity should be demonstrated for the stated educational population and decision. For decisions concerning children’s best interests and evolving capacity, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing children’s best interests and evolving capacity, coverage, missingness and group error should be tested. For learner protection in children’s best interests and evolving capacity, outputs should not circulate beyond the construct and setting supported by evidence.[REF-14] [REF-62]

Data protection for children’s best interests and evolving capacity should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing children’s best interests and evolving capacity, learners need understandable information and practical correction. For learner protection in children’s best interests and evolving capacity, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-22] [REF-60] [REF-62]

Human oversight for children’s best interests and evolving capacity should be assigned to a competent person with real authority. For learner protection in children’s best interests and evolving capacity, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For children’s best interests and evolving capacity, the learner should receive a decision-level reason and independent review while current education continues.[REF-14] [REF-22] [REF-60] [REF-62]

Equity and child-rights review for children’s best interests and evolving capacity should examine disability, language, location, income, migration and age where they affect coverage or consequence. For children’s best interests and evolving capacity, equal application of an invalid measure is not substantive equality. In governing children’s best interests and evolving capacity, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-22] [REF-60] [REF-62]

Institutional accountability for children’s best interests and evolving capacity should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing children’s best interests and evolving capacity, continued use depends on verified educational benefit and acceptable distribution. Within evidence on children’s best interests and evolving capacity, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-14] [REF-22] [REF-60] [REF-62]

5

Risk proportionate to educational consequence

Risk proportionate to educational consequence defines a material issue within the risk classification. For risk proportionate to educational consequence, the affected learners or institutions are learners affected by support, prediction or high-consequence decision, and the immediate evidence concerns access, assessment, progression and remedy. In governing risk proportionate to educational consequence, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on risk proportionate to educational consequence, technical capability and supplier availability do not establish necessity or public value.[REF-09] [REF-21] [REF-38] [REF-60]

The principal risk is that all uses receive the same scrutiny or serious effects are understated. In governing risk proportionate to educational consequence, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on risk proportionate to educational consequence, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning risk proportionate to educational consequence, each stage needs an identified owner, evidence and correction route.[REF-09] [REF-21] [REF-38]

The recommended response is to raise evidence and oversight with consequence. Within evidence on risk proportionate to educational consequence, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning risk proportionate to educational consequence, evidence requirements should rise with consequence. In reviewing risk proportionate to educational consequence, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-21] [REF-38] [REF-60]

Validity for risk proportionate to educational consequence should be demonstrated for the stated educational population and decision. For decisions concerning risk proportionate to educational consequence, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing risk proportionate to educational consequence, coverage, missingness and group error should be tested. For learner protection in risk proportionate to educational consequence, outputs should not circulate beyond the construct and setting supported by evidence.[REF-09] [REF-60]

Data protection for risk proportionate to educational consequence should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing risk proportionate to educational consequence, learners need understandable information and practical correction. For learner protection in risk proportionate to educational consequence, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-21] [REF-38] [REF-60]

Human oversight for risk proportionate to educational consequence should be assigned to a competent person with real authority. For learner protection in risk proportionate to educational consequence, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For risk proportionate to educational consequence, the learner should receive a decision-level reason and independent review while current education continues.[REF-09] [REF-21] [REF-38] [REF-60]

Equity and child-rights review for risk proportionate to educational consequence should examine disability, language, location, income, migration and age where they affect coverage or consequence. For risk proportionate to educational consequence, equal application of an invalid measure is not substantive equality. In governing risk proportionate to educational consequence, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-21] [REF-38] [REF-60]

Institutional accountability for risk proportionate to educational consequence should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing risk proportionate to educational consequence, continued use depends on verified educational benefit and acceptable distribution. Within evidence on risk proportionate to educational consequence, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-09] [REF-21] [REF-38] [REF-60]

6

Time-limited authority and review

Time-limited authority and review defines a material issue within the review boundary. For time-limited authority and review, the affected learners or institutions are institutions using tools during changing recovery conditions, and the immediate evidence concerns duration, trigger and stopping condition. In governing time-limited authority and review, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on time-limited authority and review, technical capability and supplier availability do not establish necessity or public value.[REF-19] [REF-52] [REF-54] [REF-60]

The principal risk is that temporary use becomes permanent without renewed justification. In governing time-limited authority and review, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on time-limited authority and review, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning time-limited authority and review, each stage needs an identified owner, evidence and correction route.[REF-19] [REF-52] [REF-54]

The recommended response is to set expiry, review and termination conditions. Within evidence on time-limited authority and review, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning time-limited authority and review, evidence requirements should rise with consequence. In reviewing time-limited authority and review, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-52] [REF-54] [REF-60]

Validity for time-limited authority and review should be demonstrated for the stated educational population and decision. For decisions concerning time-limited authority and review, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing time-limited authority and review, coverage, missingness and group error should be tested. For learner protection in time-limited authority and review, outputs should not circulate beyond the construct and setting supported by evidence.[REF-19] [REF-60]

Data protection for time-limited authority and review should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing time-limited authority and review, learners need understandable information and practical correction. For learner protection in time-limited authority and review, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-52] [REF-54] [REF-60]

Human oversight for time-limited authority and review should be assigned to a competent person with real authority. For learner protection in time-limited authority and review, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For time-limited authority and review, the learner should receive a decision-level reason and independent review while current education continues.[REF-19] [REF-52] [REF-54] [REF-60]

Equity and child-rights review for time-limited authority and review should examine disability, language, location, income, migration and age where they affect coverage or consequence. For time-limited authority and review, equal application of an invalid measure is not substantive equality. In governing time-limited authority and review, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-52] [REF-54] [REF-60]

Institutional accountability for time-limited authority and review should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing time-limited authority and review, continued use depends on verified educational benefit and acceptable distribution. Within evidence on time-limited authority and review, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-19] [REF-52] [REF-54] [REF-60]

Part II

Data throughout the educational lifecycle

7

Data minimisation at collection

Data minimisation at collection defines a material issue within the collection restraint. For data minimisation at collection, the affected learners or institutions are learners asked to provide identity, activity or education information, and the immediate evidence concerns minimum fields and educational necessity. In governing data minimisation at collection, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on data minimisation at collection, technical capability and supplier availability do not establish necessity or public value.[REF-09] [REF-20] [REF-60] [REF-62]

The principal risk is that available data are gathered for possible future use. In governing data minimisation at collection, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on data minimisation at collection, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning data minimisation at collection, each stage needs an identified owner, evidence and correction route.[REF-09] [REF-20] [REF-60]

The recommended response is to collect only what the stated purpose requires. Within evidence on data minimisation at collection, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning data minimisation at collection, evidence requirements should rise with consequence. In reviewing data minimisation at collection, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-20] [REF-60] [REF-62]

Validity for data minimisation at collection should be demonstrated for the stated educational population and decision. For decisions concerning data minimisation at collection, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing data minimisation at collection, coverage, missingness and group error should be tested. For learner protection in data minimisation at collection, outputs should not circulate beyond the construct and setting supported by evidence.[REF-09] [REF-62]

Data protection for data minimisation at collection should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing data minimisation at collection, learners need understandable information and practical correction. For learner protection in data minimisation at collection, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-20] [REF-60] [REF-62]

Human oversight for data minimisation at collection should be assigned to a competent person with real authority. For learner protection in data minimisation at collection, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For data minimisation at collection, the learner should receive a decision-level reason and independent review while current education continues.[REF-09] [REF-20] [REF-60] [REF-62]

Equity and child-rights review for data minimisation at collection should examine disability, language, location, income, migration and age where they affect coverage or consequence. For data minimisation at collection, equal application of an invalid measure is not substantive equality. In governing data minimisation at collection, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-20] [REF-60] [REF-62]

Institutional accountability for data minimisation at collection should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing data minimisation at collection, continued use depends on verified educational benefit and acceptable distribution. Within evidence on data minimisation at collection, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-09] [REF-20] [REF-60] [REF-62]

8

Notice that learners can understand

Notice that learners can understand defines a material issue within the information transparency. For notice that learners can understand, the affected learners or institutions are learners and families providing or generating data, and the immediate evidence concerns purpose, recipient, consequence and right. In governing notice that learners can understand, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on notice that learners can understand, technical capability and supplier availability do not establish necessity or public value.[REF-14] [REF-21] [REF-60] [REF-62]

The principal risk is that dense terms replace meaningful notice. In governing notice that learners can understand, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on notice that learners can understand, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning notice that learners can understand, each stage needs an identified owner, evidence and correction route.[REF-14] [REF-21] [REF-60]

The recommended response is to provide concise age-appropriate layered information. Within evidence on notice that learners can understand, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning notice that learners can understand, evidence requirements should rise with consequence. In reviewing notice that learners can understand, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-21] [REF-60] [REF-62]

Validity for notice that learners can understand should be demonstrated for the stated educational population and decision. For decisions concerning notice that learners can understand, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing notice that learners can understand, coverage, missingness and group error should be tested. For learner protection in notice that learners can understand, outputs should not circulate beyond the construct and setting supported by evidence.[REF-14] [REF-62]

Data protection for notice that learners can understand should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing notice that learners can understand, learners need understandable information and practical correction. For learner protection in notice that learners can understand, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-21] [REF-60] [REF-62]

Human oversight for notice that learners can understand should be assigned to a competent person with real authority. For learner protection in notice that learners can understand, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For notice that learners can understand, the learner should receive a decision-level reason and independent review while current education continues.[REF-14] [REF-21] [REF-60] [REF-62]

Equity and child-rights review for notice that learners can understand should examine disability, language, location, income, migration and age where they affect coverage or consequence. For notice that learners can understand, equal application of an invalid measure is not substantive equality. In governing notice that learners can understand, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-21] [REF-60] [REF-62]

Institutional accountability for notice that learners can understand should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing notice that learners can understand, continued use depends on verified educational benefit and acceptable distribution. Within evidence on notice that learners can understand, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-14] [REF-21] [REF-60] [REF-62]

9

Access control and staff responsibilities

Access control and staff responsibilities defines a material issue within the data access. For access control and staff responsibilities, the affected learners or institutions are teachers, administrators and providers using learner records, and the immediate evidence concerns role, permission and traceable access. In governing access control and staff responsibilities, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on access control and staff responsibilities, technical capability and supplier availability do not establish necessity or public value.[REF-20] [REF-27] [REF-60] [REF-61]

The principal risk is that broad accounts or shared credentials expose sensitive information. In governing access control and staff responsibilities, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on access control and staff responsibilities, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning access control and staff responsibilities, each stage needs an identified owner, evidence and correction route.[REF-20] [REF-27] [REF-60]

The recommended response is to apply role-based access and accountable authorization. Within evidence on access control and staff responsibilities, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning access control and staff responsibilities, evidence requirements should rise with consequence. In reviewing access control and staff responsibilities, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-27] [REF-60] [REF-61]

Validity for access control and staff responsibilities should be demonstrated for the stated educational population and decision. For decisions concerning access control and staff responsibilities, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing access control and staff responsibilities, coverage, missingness and group error should be tested. For learner protection in access control and staff responsibilities, outputs should not circulate beyond the construct and setting supported by evidence.[REF-20] [REF-61]

Data protection for access control and staff responsibilities should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing access control and staff responsibilities, learners need understandable information and practical correction. For learner protection in access control and staff responsibilities, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-27] [REF-60] [REF-61]

Human oversight for access control and staff responsibilities should be assigned to a competent person with real authority. For learner protection in access control and staff responsibilities, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For access control and staff responsibilities, the learner should receive a decision-level reason and independent review while current education continues.[REF-20] [REF-27] [REF-60] [REF-61]

Equity and child-rights review for access control and staff responsibilities should examine disability, language, location, income, migration and age where they affect coverage or consequence. For access control and staff responsibilities, equal application of an invalid measure is not substantive equality. In governing access control and staff responsibilities, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-27] [REF-60] [REF-61]

Institutional accountability for access control and staff responsibilities should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing access control and staff responsibilities, continued use depends on verified educational benefit and acceptable distribution. Within evidence on access control and staff responsibilities, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-20] [REF-27] [REF-60] [REF-61]

10

Sharing and external provider limits

Sharing and external provider limits defines a material issue within the data disclosure. For sharing and external provider limits, the affected learners or institutions are institutions transferring records to contracted services, and the immediate evidence concerns recipient, purpose, location and onward use. In governing sharing and external provider limits, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on sharing and external provider limits, technical capability and supplier availability do not establish necessity or public value.[REF-57] [REF-58] [REF-60] [REF-62]

The principal risk is that contract terms permit unrelated use or indefinite onward sharing. In governing sharing and external provider limits, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on sharing and external provider limits, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning sharing and external provider limits, each stage needs an identified owner, evidence and correction route.[REF-57] [REF-58] [REF-60]

The recommended response is to restrict recipients, purposes and sub-contracting. Within evidence on sharing and external provider limits, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning sharing and external provider limits, evidence requirements should rise with consequence. In reviewing sharing and external provider limits, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-58] [REF-60] [REF-62]

Validity for sharing and external provider limits should be demonstrated for the stated educational population and decision. For decisions concerning sharing and external provider limits, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing sharing and external provider limits, coverage, missingness and group error should be tested. For learner protection in sharing and external provider limits, outputs should not circulate beyond the construct and setting supported by evidence.[REF-57] [REF-62]

Data protection for sharing and external provider limits should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing sharing and external provider limits, learners need understandable information and practical correction. For learner protection in sharing and external provider limits, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-58] [REF-60] [REF-62]

Human oversight for sharing and external provider limits should be assigned to a competent person with real authority. For learner protection in sharing and external provider limits, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For sharing and external provider limits, the learner should receive a decision-level reason and independent review while current education continues.[REF-57] [REF-58] [REF-60] [REF-62]

Equity and child-rights review for sharing and external provider limits should examine disability, language, location, income, migration and age where they affect coverage or consequence. For sharing and external provider limits, equal application of an invalid measure is not substantive equality. In governing sharing and external provider limits, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-58] [REF-60] [REF-62]

Institutional accountability for sharing and external provider limits should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing sharing and external provider limits, continued use depends on verified educational benefit and acceptable distribution. Within evidence on sharing and external provider limits, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-57] [REF-58] [REF-60] [REF-62]

11

Retention, deletion and education records

Retention, deletion and education records defines a material issue within the record duration. For retention, deletion and education records, the affected learners or institutions are learners whose authoritative and temporary records coexist, and the immediate evidence concerns retention need, expiry and deletion evidence. In governing retention, deletion and education records, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on retention, deletion and education records, technical capability and supplier availability do not establish necessity or public value.[REF-09] [REF-20] [REF-60] [REF-62]

The principal risk is that temporary activity traces persist as permanent learner profiles. In governing retention, deletion and education records, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on retention, deletion and education records, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning retention, deletion and education records, each stage needs an identified owner, evidence and correction route.[REF-09] [REF-20] [REF-60]

The recommended response is to separate authoritative records and delete unnecessary data. Within evidence on retention, deletion and education records, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning retention, deletion and education records, evidence requirements should rise with consequence. In reviewing retention, deletion and education records, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-20] [REF-60] [REF-62]

Validity for retention, deletion and education records should be demonstrated for the stated educational population and decision. For decisions concerning retention, deletion and education records, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing retention, deletion and education records, coverage, missingness and group error should be tested. For learner protection in retention, deletion and education records, outputs should not circulate beyond the construct and setting supported by evidence.[REF-09] [REF-62]

Data protection for retention, deletion and education records should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing retention, deletion and education records, learners need understandable information and practical correction. For learner protection in retention, deletion and education records, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-20] [REF-60] [REF-62]

Human oversight for retention, deletion and education records should be assigned to a competent person with real authority. For learner protection in retention, deletion and education records, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For retention, deletion and education records, the learner should receive a decision-level reason and independent review while current education continues.[REF-09] [REF-20] [REF-60] [REF-62]

Equity and child-rights review for retention, deletion and education records should examine disability, language, location, income, migration and age where they affect coverage or consequence. For retention, deletion and education records, equal application of an invalid measure is not substantive equality. In governing retention, deletion and education records, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-20] [REF-60] [REF-62]

Institutional accountability for retention, deletion and education records should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing retention, deletion and education records, continued use depends on verified educational benefit and acceptable distribution. Within evidence on retention, deletion and education records, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-09] [REF-20] [REF-60] [REF-62]

12

Correction, portability and continuity

Correction, portability and continuity defines a material issue within the learner record rights. For correction, portability and continuity, the affected learners or institutions are learners identifying error or moving institutions, and the immediate evidence concerns access, correction and minimum continuity record. In governing correction, portability and continuity, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on correction, portability and continuity, technical capability and supplier availability do not establish necessity or public value.[REF-14] [REF-20] [REF-31] [REF-60]

The principal risk is that errors propagate or provider exit removes needed education records. In governing correction, portability and continuity, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on correction, portability and continuity, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning correction, portability and continuity, each stage needs an identified owner, evidence and correction route.[REF-14] [REF-20] [REF-31]

The recommended response is to provide correction and protected record continuity. Within evidence on correction, portability and continuity, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning correction, portability and continuity, evidence requirements should rise with consequence. In reviewing correction, portability and continuity, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-20] [REF-31] [REF-60]

Validity for correction, portability and continuity should be demonstrated for the stated educational population and decision. For decisions concerning correction, portability and continuity, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing correction, portability and continuity, coverage, missingness and group error should be tested. For learner protection in correction, portability and continuity, outputs should not circulate beyond the construct and setting supported by evidence.[REF-14] [REF-60]

Data protection for correction, portability and continuity should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing correction, portability and continuity, learners need understandable information and practical correction. For learner protection in correction, portability and continuity, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-20] [REF-31] [REF-60]

Human oversight for correction, portability and continuity should be assigned to a competent person with real authority. For learner protection in correction, portability and continuity, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For correction, portability and continuity, the learner should receive a decision-level reason and independent review while current education continues.[REF-14] [REF-20] [REF-31] [REF-60]

Equity and child-rights review for correction, portability and continuity should examine disability, language, location, income, migration and age where they affect coverage or consequence. For correction, portability and continuity, equal application of an invalid measure is not substantive equality. In governing correction, portability and continuity, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-20] [REF-31] [REF-60]

Institutional accountability for correction, portability and continuity should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing correction, portability and continuity, continued use depends on verified educational benefit and acceptable distribution. Within evidence on correction, portability and continuity, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-14] [REF-20] [REF-31] [REF-60]

Part III

Meaningful human oversight of educational decisions

13

A competent named decision maker

A competent named decision maker defines a material issue within the human authority. For a competent named decision maker, the affected learners or institutions are learners affected by technology-assisted decisions, and the immediate evidence concerns identity, competence and final authority. In governing a competent named decision maker, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on a competent named decision maker, technical capability and supplier availability do not establish necessity or public value.[REF-21] [REF-27] [REF-58] [REF-60]

The principal risk is that responsibility is attributed to a system or diffuse team. In governing a competent named decision maker, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on a competent named decision maker, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning a competent named decision maker, each stage needs an identified owner, evidence and correction route.[REF-21] [REF-27] [REF-58]

The recommended response is to name the person or body accountable for the decision. Within evidence on a competent named decision maker, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning a competent named decision maker, evidence requirements should rise with consequence. In reviewing a competent named decision maker, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-27] [REF-58] [REF-60]

Validity for a competent named decision maker should be demonstrated for the stated educational population and decision. For decisions concerning a competent named decision maker, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing a competent named decision maker, coverage, missingness and group error should be tested. For learner protection in a competent named decision maker, outputs should not circulate beyond the construct and setting supported by evidence.[REF-21] [REF-60]

Data protection for a competent named decision maker should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing a competent named decision maker, learners need understandable information and practical correction. For learner protection in a competent named decision maker, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-27] [REF-58] [REF-60]

Human oversight for a competent named decision maker should be assigned to a competent person with real authority. For learner protection in a competent named decision maker, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For a competent named decision maker, the learner should receive a decision-level reason and independent review while current education continues.[REF-21] [REF-27] [REF-58] [REF-60]

Equity and child-rights review for a competent named decision maker should examine disability, language, location, income, migration and age where they affect coverage or consequence. For a competent named decision maker, equal application of an invalid measure is not substantive equality. In governing a competent named decision maker, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-27] [REF-58] [REF-60]

Institutional accountability for a competent named decision maker should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing a competent named decision maker, continued use depends on verified educational benefit and acceptable distribution. Within evidence on a competent named decision maker, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-21] [REF-27] [REF-58] [REF-60]

14

Ability to understand material limitations

Ability to understand material limitations defines a material issue within the oversight competence. For ability to understand material limitations, the affected learners or institutions are staff interpreting classifications or recommendations, and the immediate evidence concerns construct, data coverage and uncertainty. In governing ability to understand material limitations, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on ability to understand material limitations, technical capability and supplier availability do not establish necessity or public value.[REF-05] [REF-09] [REF-17] [REF-60]

The principal risk is that reviewers see only a score without evidence or limitation. In governing ability to understand material limitations, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on ability to understand material limitations, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning ability to understand material limitations, each stage needs an identified owner, evidence and correction route.[REF-05] [REF-09] [REF-17]

The recommended response is to provide decision-level evidence and training. Within evidence on ability to understand material limitations, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning ability to understand material limitations, evidence requirements should rise with consequence. In reviewing ability to understand material limitations, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-09] [REF-17] [REF-60]

Validity for ability to understand material limitations should be demonstrated for the stated educational population and decision. For decisions concerning ability to understand material limitations, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing ability to understand material limitations, coverage, missingness and group error should be tested. For learner protection in ability to understand material limitations, outputs should not circulate beyond the construct and setting supported by evidence.[REF-05] [REF-60]

Data protection for ability to understand material limitations should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing ability to understand material limitations, learners need understandable information and practical correction. For learner protection in ability to understand material limitations, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-09] [REF-17] [REF-60]

Human oversight for ability to understand material limitations should be assigned to a competent person with real authority. For learner protection in ability to understand material limitations, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For ability to understand material limitations, the learner should receive a decision-level reason and independent review while current education continues.[REF-05] [REF-09] [REF-17] [REF-60]

Equity and child-rights review for ability to understand material limitations should examine disability, language, location, income, migration and age where they affect coverage or consequence. For ability to understand material limitations, equal application of an invalid measure is not substantive equality. In governing ability to understand material limitations, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-09] [REF-17] [REF-60]

Institutional accountability for ability to understand material limitations should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing ability to understand material limitations, continued use depends on verified educational benefit and acceptable distribution. Within evidence on ability to understand material limitations, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-05] [REF-09] [REF-17] [REF-60]

15

Authority to depart from the output

Authority to depart from the output defines a material issue within the meaningful discretion. For authority to depart from the output, the affected learners or institutions are teachers and administrators reviewing system suggestions, and the immediate evidence concerns alternative evidence and ability to override. In governing authority to depart from the output, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on authority to depart from the output, technical capability and supplier availability do not establish necessity or public value.[REF-01] [REF-21] [REF-24] [REF-60]

The principal risk is that human review merely confirms a pre-determined outcome. In governing authority to depart from the output, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on authority to depart from the output, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning authority to depart from the output, each stage needs an identified owner, evidence and correction route.[REF-01] [REF-21] [REF-24]

The recommended response is to permit documented departure and prohibit retaliation. Within evidence on authority to depart from the output, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning authority to depart from the output, evidence requirements should rise with consequence. In reviewing authority to depart from the output, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-21] [REF-24] [REF-60]

Validity for authority to depart from the output should be demonstrated for the stated educational population and decision. For decisions concerning authority to depart from the output, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing authority to depart from the output, coverage, missingness and group error should be tested. For learner protection in authority to depart from the output, outputs should not circulate beyond the construct and setting supported by evidence.[REF-01] [REF-60]

Data protection for authority to depart from the output should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing authority to depart from the output, learners need understandable information and practical correction. For learner protection in authority to depart from the output, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-21] [REF-24] [REF-60]

Human oversight for authority to depart from the output should be assigned to a competent person with real authority. For learner protection in authority to depart from the output, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For authority to depart from the output, the learner should receive a decision-level reason and independent review while current education continues.[REF-01] [REF-21] [REF-24] [REF-60]

Equity and child-rights review for authority to depart from the output should examine disability, language, location, income, migration and age where they affect coverage or consequence. For authority to depart from the output, equal application of an invalid measure is not substantive equality. In governing authority to depart from the output, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-21] [REF-24] [REF-60]

Institutional accountability for authority to depart from the output should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing authority to depart from the output, continued use depends on verified educational benefit and acceptable distribution. Within evidence on authority to depart from the output, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-01] [REF-21] [REF-24] [REF-60]

16

Direct learner evidence and context

Direct learner evidence and context defines a material issue within the contextual judgement. For direct learner evidence and context, the affected learners or institutions are learners whose records omit material opportunity or circumstance, and the immediate evidence concerns current work, exposure and support conditions. In governing direct learner evidence and context, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on direct learner evidence and context, technical capability and supplier availability do not establish necessity or public value.[REF-10] [REF-29] [REF-38] [REF-53]

The principal risk is that historical traces replace direct educational evidence. In governing direct learner evidence and context, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on direct learner evidence and context, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning direct learner evidence and context, each stage needs an identified owner, evidence and correction route.[REF-10] [REF-29] [REF-38]

The recommended response is to combine output with current learner evidence. Within evidence on direct learner evidence and context, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning direct learner evidence and context, evidence requirements should rise with consequence. In reviewing direct learner evidence and context, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-29] [REF-38] [REF-53]

Validity for direct learner evidence and context should be demonstrated for the stated educational population and decision. For decisions concerning direct learner evidence and context, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing direct learner evidence and context, coverage, missingness and group error should be tested. For learner protection in direct learner evidence and context, outputs should not circulate beyond the construct and setting supported by evidence.[REF-10] [REF-53]

Data protection for direct learner evidence and context should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing direct learner evidence and context, learners need understandable information and practical correction. For learner protection in direct learner evidence and context, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-29] [REF-38] [REF-53]

Human oversight for direct learner evidence and context should be assigned to a competent person with real authority. For learner protection in direct learner evidence and context, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For direct learner evidence and context, the learner should receive a decision-level reason and independent review while current education continues.[REF-10] [REF-29] [REF-38] [REF-53]

Equity and child-rights review for direct learner evidence and context should examine disability, language, location, income, migration and age where they affect coverage or consequence. For direct learner evidence and context, equal application of an invalid measure is not substantive equality. In governing direct learner evidence and context, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-29] [REF-38] [REF-53]

Institutional accountability for direct learner evidence and context should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing direct learner evidence and context, continued use depends on verified educational benefit and acceptable distribution. Within evidence on direct learner evidence and context, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-10] [REF-29] [REF-38] [REF-53]

17

Reasons, response and contestability

Reasons, response and contestability defines a material issue within the decision fairness. For reasons, response and contestability, the affected learners or institutions are learners receiving a consequential result, and the immediate evidence concerns understandable reason and opportunity to respond. In governing reasons, response and contestability, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on reasons, response and contestability, technical capability and supplier availability do not establish necessity or public value.[REF-21] [REF-22] [REF-60] [REF-62]

The principal risk is that technical complexity excuses no explanation. In governing reasons, response and contestability, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on reasons, response and contestability, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning reasons, response and contestability, each stage needs an identified owner, evidence and correction route.[REF-21] [REF-22] [REF-60]

The recommended response is to state material reasons and accept counter-evidence. Within evidence on reasons, response and contestability, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning reasons, response and contestability, evidence requirements should rise with consequence. In reviewing reasons, response and contestability, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-22] [REF-60] [REF-62]

Validity for reasons, response and contestability should be demonstrated for the stated educational population and decision. For decisions concerning reasons, response and contestability, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing reasons, response and contestability, coverage, missingness and group error should be tested. For learner protection in reasons, response and contestability, outputs should not circulate beyond the construct and setting supported by evidence.[REF-21] [REF-62]

Data protection for reasons, response and contestability should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing reasons, response and contestability, learners need understandable information and practical correction. For learner protection in reasons, response and contestability, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-22] [REF-60] [REF-62]

Human oversight for reasons, response and contestability should be assigned to a competent person with real authority. For learner protection in reasons, response and contestability, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For reasons, response and contestability, the learner should receive a decision-level reason and independent review while current education continues.[REF-21] [REF-22] [REF-60] [REF-62]

Equity and child-rights review for reasons, response and contestability should examine disability, language, location, income, migration and age where they affect coverage or consequence. For reasons, response and contestability, equal application of an invalid measure is not substantive equality. In governing reasons, response and contestability, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-22] [REF-60] [REF-62]

Institutional accountability for reasons, response and contestability should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing reasons, response and contestability, continued use depends on verified educational benefit and acceptable distribution. Within evidence on reasons, response and contestability, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-21] [REF-22] [REF-60] [REF-62]

18

Independent review and continuing education

Independent review and continuing education defines a material issue within the effective remedy. For independent review and continuing education, the affected learners or institutions are learners challenging data or decision error, and the immediate evidence concerns review authority, timing and interim protection. In governing independent review and continuing education, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on independent review and continuing education, technical capability and supplier availability do not establish necessity or public value.[REF-10] [REF-14] [REF-21] [REF-60]

The principal risk is that appeal repeats the same output or interrupts education. In governing independent review and continuing education, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on independent review and continuing education, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning independent review and continuing education, each stage needs an identified owner, evidence and correction route.[REF-10] [REF-14] [REF-21]

The recommended response is to provide independent review and continuity. Within evidence on independent review and continuing education, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning independent review and continuing education, evidence requirements should rise with consequence. In reviewing independent review and continuing education, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-14] [REF-21] [REF-60]

Validity for independent review and continuing education should be demonstrated for the stated educational population and decision. For decisions concerning independent review and continuing education, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing independent review and continuing education, coverage, missingness and group error should be tested. For learner protection in independent review and continuing education, outputs should not circulate beyond the construct and setting supported by evidence.[REF-10] [REF-60]

Data protection for independent review and continuing education should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing independent review and continuing education, learners need understandable information and practical correction. For learner protection in independent review and continuing education, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-14] [REF-21] [REF-60]

Human oversight for independent review and continuing education should be assigned to a competent person with real authority. For learner protection in independent review and continuing education, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For independent review and continuing education, the learner should receive a decision-level reason and independent review while current education continues.[REF-10] [REF-14] [REF-21] [REF-60]

Equity and child-rights review for independent review and continuing education should examine disability, language, location, income, migration and age where they affect coverage or consequence. For independent review and continuing education, equal application of an invalid measure is not substantive equality. In governing independent review and continuing education, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-14] [REF-21] [REF-60]

Institutional accountability for independent review and continuing education should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing independent review and continuing education, continued use depends on verified educational benefit and acceptable distribution. Within evidence on independent review and continuing education, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-10] [REF-14] [REF-21] [REF-60]

Part IV

Education uses, equity and child protection

19

Learning resources and personalization

Learning resources and personalization defines a material issue within the instructional use. For learning resources and personalization, the affected learners or institutions are learners receiving recommended tasks or content, and the immediate evidence concerns curriculum fit, accessibility and teacher adjustment. In governing learning resources and personalization, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on learning resources and personalization, technical capability and supplier availability do not establish necessity or public value.[REF-01] [REF-24] [REF-29] [REF-54]

The principal risk is that recommendations narrow curriculum or reinforce past labels. In governing learning resources and personalization, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on learning resources and personalization, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning learning resources and personalization, each stage needs an identified owner, evidence and correction route.[REF-01] [REF-24] [REF-29]

The recommended response is to preserve curriculum breadth and teacher judgement. Within evidence on learning resources and personalization, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning learning resources and personalization, evidence requirements should rise with consequence. In reviewing learning resources and personalization, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-24] [REF-29] [REF-54]

Validity for learning resources and personalization should be demonstrated for the stated educational population and decision. For decisions concerning learning resources and personalization, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing learning resources and personalization, coverage, missingness and group error should be tested. For learner protection in learning resources and personalization, outputs should not circulate beyond the construct and setting supported by evidence.[REF-01] [REF-54]

Data protection for learning resources and personalization should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing learning resources and personalization, learners need understandable information and practical correction. For learner protection in learning resources and personalization, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-24] [REF-29] [REF-54]

Human oversight for learning resources and personalization should be assigned to a competent person with real authority. For learner protection in learning resources and personalization, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For learning resources and personalization, the learner should receive a decision-level reason and independent review while current education continues.[REF-01] [REF-24] [REF-29] [REF-54]

Equity and child-rights review for learning resources and personalization should examine disability, language, location, income, migration and age where they affect coverage or consequence. For learning resources and personalization, equal application of an invalid measure is not substantive equality. In governing learning resources and personalization, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-24] [REF-29] [REF-54]

Institutional accountability for learning resources and personalization should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing learning resources and personalization, continued use depends on verified educational benefit and acceptable distribution. Within evidence on learning resources and personalization, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-01] [REF-24] [REF-29] [REF-54]

20

Remote participation monitoring

Remote participation monitoring defines a material issue within the engagement evidence. For remote participation monitoring, the affected learners or institutions are learners studying through varied media and household conditions, and the immediate evidence concerns contact, participation and barrier. In governing remote participation monitoring, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on remote participation monitoring, technical capability and supplier availability do not establish necessity or public value.[REF-05] [REF-49] [REF-55] [REF-56]

The principal risk is that behavioural traces are treated as motivation or attendance. In governing remote participation monitoring, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on remote participation monitoring, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning remote participation monitoring, each stage needs an identified owner, evidence and correction route.[REF-05] [REF-49] [REF-55]

The recommended response is to investigate access and use proportionate evidence. Within evidence on remote participation monitoring, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning remote participation monitoring, evidence requirements should rise with consequence. In reviewing remote participation monitoring, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-49] [REF-55] [REF-56]

Validity for remote participation monitoring should be demonstrated for the stated educational population and decision. For decisions concerning remote participation monitoring, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing remote participation monitoring, coverage, missingness and group error should be tested. For learner protection in remote participation monitoring, outputs should not circulate beyond the construct and setting supported by evidence.[REF-05] [REF-56]

Data protection for remote participation monitoring should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing remote participation monitoring, learners need understandable information and practical correction. For learner protection in remote participation monitoring, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-49] [REF-55] [REF-56]

Human oversight for remote participation monitoring should be assigned to a competent person with real authority. For learner protection in remote participation monitoring, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For remote participation monitoring, the learner should receive a decision-level reason and independent review while current education continues.[REF-05] [REF-49] [REF-55] [REF-56]

Equity and child-rights review for remote participation monitoring should examine disability, language, location, income, migration and age where they affect coverage or consequence. For remote participation monitoring, equal application of an invalid measure is not substantive equality. In governing remote participation monitoring, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-49] [REF-55] [REF-56]

Institutional accountability for remote participation monitoring should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing remote participation monitoring, continued use depends on verified educational benefit and acceptable distribution. Within evidence on remote participation monitoring, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-05] [REF-49] [REF-55] [REF-56]

21

Assessment and progression

Assessment and progression defines a material issue within the high-consequence use. For assessment and progression, the affected learners or institutions are learners receiving marks, certification or progression decisions, and the immediate evidence concerns construct validity, evidence and review. In governing assessment and progression, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on assessment and progression, technical capability and supplier availability do not establish necessity or public value.[REF-09] [REF-17] [REF-38] [REF-60]

The principal risk is that a technology score is treated as objective across groups. In governing assessment and progression, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on assessment and progression, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning assessment and progression, each stage needs an identified owner, evidence and correction route.[REF-09] [REF-17] [REF-38]

The recommended response is to validate by population and require human reasons. Within evidence on assessment and progression, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning assessment and progression, evidence requirements should rise with consequence. In reviewing assessment and progression, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-17] [REF-38] [REF-60]

Validity for assessment and progression should be demonstrated for the stated educational population and decision. For decisions concerning assessment and progression, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing assessment and progression, coverage, missingness and group error should be tested. For learner protection in assessment and progression, outputs should not circulate beyond the construct and setting supported by evidence.[REF-09] [REF-60]

Data protection for assessment and progression should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing assessment and progression, learners need understandable information and practical correction. For learner protection in assessment and progression, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-17] [REF-38] [REF-60]

Human oversight for assessment and progression should be assigned to a competent person with real authority. For learner protection in assessment and progression, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For assessment and progression, the learner should receive a decision-level reason and independent review while current education continues.[REF-09] [REF-17] [REF-38] [REF-60]

Equity and child-rights review for assessment and progression should examine disability, language, location, income, migration and age where they affect coverage or consequence. For assessment and progression, equal application of an invalid measure is not substantive equality. In governing assessment and progression, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-17] [REF-38] [REF-60]

Institutional accountability for assessment and progression should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing assessment and progression, continued use depends on verified educational benefit and acceptable distribution. Within evidence on assessment and progression, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-09] [REF-17] [REF-38] [REF-60]

22

Disability accessibility and sensitive inference

Disability accessibility and sensitive inference defines a material issue within the inclusive use. For disability accessibility and sensitive inference, the affected learners or institutions are learners with different functional and communication needs, and the immediate evidence concerns accessible participation and limited disability data. In governing disability accessibility and sensitive inference, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on disability accessibility and sensitive inference, technical capability and supplier availability do not establish necessity or public value.[REF-10] [REF-11] [REF-15] [REF-62]

The principal risk is that accessibility is ignored or sensitive status is inferred unnecessarily. In governing disability accessibility and sensitive inference, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on disability accessibility and sensitive inference, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning disability accessibility and sensitive inference, each stage needs an identified owner, evidence and correction route.[REF-10] [REF-11] [REF-15]

The recommended response is to co-design access and minimize sensitive fields. Within evidence on disability accessibility and sensitive inference, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning disability accessibility and sensitive inference, evidence requirements should rise with consequence. In reviewing disability accessibility and sensitive inference, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-11] [REF-15] [REF-62]

Validity for disability accessibility and sensitive inference should be demonstrated for the stated educational population and decision. For decisions concerning disability accessibility and sensitive inference, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing disability accessibility and sensitive inference, coverage, missingness and group error should be tested. For learner protection in disability accessibility and sensitive inference, outputs should not circulate beyond the construct and setting supported by evidence.[REF-10] [REF-62]

Data protection for disability accessibility and sensitive inference should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing disability accessibility and sensitive inference, learners need understandable information and practical correction. For learner protection in disability accessibility and sensitive inference, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-11] [REF-15] [REF-62]

Human oversight for disability accessibility and sensitive inference should be assigned to a competent person with real authority. For learner protection in disability accessibility and sensitive inference, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For disability accessibility and sensitive inference, the learner should receive a decision-level reason and independent review while current education continues.[REF-10] [REF-11] [REF-15] [REF-62]

Equity and child-rights review for disability accessibility and sensitive inference should examine disability, language, location, income, migration and age where they affect coverage or consequence. For disability accessibility and sensitive inference, equal application of an invalid measure is not substantive equality. In governing disability accessibility and sensitive inference, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-11] [REF-15] [REF-62]

Institutional accountability for disability accessibility and sensitive inference should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing disability accessibility and sensitive inference, continued use depends on verified educational benefit and acceptable distribution. Within evidence on disability accessibility and sensitive inference, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-10] [REF-11] [REF-15] [REF-62]

23

Commercial influence and persuasive design

Commercial influence and persuasive design defines a material issue within the child protection. For commercial influence and persuasive design, the affected learners or institutions are children interacting with external education services, and the immediate evidence concerns advertising, inducement and educational purpose. In governing commercial influence and persuasive design, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on commercial influence and persuasive design, technical capability and supplier availability do not establish necessity or public value.[REF-14] [REF-58] [REF-60] [REF-62]

The principal risk is that commercial attention or profiling displaces learning and wellbeing. In governing commercial influence and persuasive design, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on commercial influence and persuasive design, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning commercial influence and persuasive design, each stage needs an identified owner, evidence and correction route.[REF-14] [REF-58] [REF-60]

The recommended response is to prohibit exploitative use and separate commercial interests. Within evidence on commercial influence and persuasive design, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning commercial influence and persuasive design, evidence requirements should rise with consequence. In reviewing commercial influence and persuasive design, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-58] [REF-60] [REF-62]

Validity for commercial influence and persuasive design should be demonstrated for the stated educational population and decision. For decisions concerning commercial influence and persuasive design, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing commercial influence and persuasive design, coverage, missingness and group error should be tested. For learner protection in commercial influence and persuasive design, outputs should not circulate beyond the construct and setting supported by evidence.[REF-14] [REF-62]

Data protection for commercial influence and persuasive design should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing commercial influence and persuasive design, learners need understandable information and practical correction. For learner protection in commercial influence and persuasive design, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-58] [REF-60] [REF-62]

Human oversight for commercial influence and persuasive design should be assigned to a competent person with real authority. For learner protection in commercial influence and persuasive design, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For commercial influence and persuasive design, the learner should receive a decision-level reason and independent review while current education continues.[REF-14] [REF-58] [REF-60] [REF-62]

Equity and child-rights review for commercial influence and persuasive design should examine disability, language, location, income, migration and age where they affect coverage or consequence. For commercial influence and persuasive design, equal application of an invalid measure is not substantive equality. In governing commercial influence and persuasive design, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-58] [REF-60] [REF-62]

Institutional accountability for commercial influence and persuasive design should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing commercial influence and persuasive design, continued use depends on verified educational benefit and acceptable distribution. Within evidence on commercial influence and persuasive design, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-14] [REF-58] [REF-60] [REF-62]

24

Safety, communications and reporting

Safety, communications and reporting defines a material issue within the online safeguarding. For safety, communications and reporting, the affected learners or institutions are learners communicating through education tools, and the immediate evidence concerns safe contact, reporting and response. In governing safety, communications and reporting, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on safety, communications and reporting, technical capability and supplier availability do not establish necessity or public value.[REF-12] [REF-14] [REF-61] [REF-62]

The principal risk is that informal or unmoderated channels expose learners to harm. In governing safety, communications and reporting, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on safety, communications and reporting, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning safety, communications and reporting, each stage needs an identified owner, evidence and correction route.[REF-12] [REF-14] [REF-61]

The recommended response is to set boundaries, confidential routes and rapid response. Within evidence on safety, communications and reporting, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning safety, communications and reporting, evidence requirements should rise with consequence. In reviewing safety, communications and reporting, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-14] [REF-61] [REF-62]

Validity for safety, communications and reporting should be demonstrated for the stated educational population and decision. For decisions concerning safety, communications and reporting, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing safety, communications and reporting, coverage, missingness and group error should be tested. For learner protection in safety, communications and reporting, outputs should not circulate beyond the construct and setting supported by evidence.[REF-12] [REF-62]

Data protection for safety, communications and reporting should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing safety, communications and reporting, learners need understandable information and practical correction. For learner protection in safety, communications and reporting, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-14] [REF-61] [REF-62]

Human oversight for safety, communications and reporting should be assigned to a competent person with real authority. For learner protection in safety, communications and reporting, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For safety, communications and reporting, the learner should receive a decision-level reason and independent review while current education continues.[REF-12] [REF-14] [REF-61] [REF-62]

Equity and child-rights review for safety, communications and reporting should examine disability, language, location, income, migration and age where they affect coverage or consequence. For safety, communications and reporting, equal application of an invalid measure is not substantive equality. In governing safety, communications and reporting, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-14] [REF-61] [REF-62]

Institutional accountability for safety, communications and reporting should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing safety, communications and reporting, continued use depends on verified educational benefit and acceptable distribution. Within evidence on safety, communications and reporting, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-12] [REF-14] [REF-61] [REF-62]

Part V

Procurement, assurance, incidents and exit

25

Pre-use rights and educational assessment

Pre-use rights and educational assessment defines a material issue within the prior assessment. For pre-use rights and educational assessment, the affected learners or institutions are authorities considering a new education tool, and the immediate evidence concerns purpose, necessity, data, risk and alternative. In governing pre-use rights and educational assessment, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on pre-use rights and educational assessment, technical capability and supplier availability do not establish necessity or public value.[REF-10] [REF-27] [REF-59] [REF-60]

The principal risk is that purchase precedes examination of learner consequences. In governing pre-use rights and educational assessment, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on pre-use rights and educational assessment, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning pre-use rights and educational assessment, each stage needs an identified owner, evidence and correction route.[REF-10] [REF-27] [REF-59]

The recommended response is to complete a documented assessment before commitment. Within evidence on pre-use rights and educational assessment, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning pre-use rights and educational assessment, evidence requirements should rise with consequence. In reviewing pre-use rights and educational assessment, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-27] [REF-59] [REF-60]

Validity for pre-use rights and educational assessment should be demonstrated for the stated educational population and decision. For decisions concerning pre-use rights and educational assessment, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing pre-use rights and educational assessment, coverage, missingness and group error should be tested. For learner protection in pre-use rights and educational assessment, outputs should not circulate beyond the construct and setting supported by evidence.[REF-10] [REF-60]

Data protection for pre-use rights and educational assessment should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing pre-use rights and educational assessment, learners need understandable information and practical correction. For learner protection in pre-use rights and educational assessment, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-27] [REF-59] [REF-60]

Human oversight for pre-use rights and educational assessment should be assigned to a competent person with real authority. For learner protection in pre-use rights and educational assessment, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For pre-use rights and educational assessment, the learner should receive a decision-level reason and independent review while current education continues.[REF-10] [REF-27] [REF-59] [REF-60]

Equity and child-rights review for pre-use rights and educational assessment should examine disability, language, location, income, migration and age where they affect coverage or consequence. For pre-use rights and educational assessment, equal application of an invalid measure is not substantive equality. In governing pre-use rights and educational assessment, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-27] [REF-59] [REF-60]

Institutional accountability for pre-use rights and educational assessment should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing pre-use rights and educational assessment, continued use depends on verified educational benefit and acceptable distribution. Within evidence on pre-use rights and educational assessment, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-10] [REF-27] [REF-59] [REF-60]

26

Supplier evidence and public scrutiny

Supplier evidence and public scrutiny defines a material issue within the procurement assurance. For supplier evidence and public scrutiny, the affected learners or institutions are authorities evaluating product claims, and the immediate evidence concerns validation, population, security and limitations. In governing supplier evidence and public scrutiny, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on supplier evidence and public scrutiny, technical capability and supplier availability do not establish necessity or public value.[REF-09] [REF-57] [REF-59] [REF-60]

The principal risk is that marketing or secrecy replaces independent evidence. In governing supplier evidence and public scrutiny, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on supplier evidence and public scrutiny, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning supplier evidence and public scrutiny, each stage needs an identified owner, evidence and correction route.[REF-09] [REF-57] [REF-59]

The recommended response is to require verifiable claims and inspection rights. Within evidence on supplier evidence and public scrutiny, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning supplier evidence and public scrutiny, evidence requirements should rise with consequence. In reviewing supplier evidence and public scrutiny, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-57] [REF-59] [REF-60]

Validity for supplier evidence and public scrutiny should be demonstrated for the stated educational population and decision. For decisions concerning supplier evidence and public scrutiny, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing supplier evidence and public scrutiny, coverage, missingness and group error should be tested. For learner protection in supplier evidence and public scrutiny, outputs should not circulate beyond the construct and setting supported by evidence.[REF-09] [REF-60]

Data protection for supplier evidence and public scrutiny should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing supplier evidence and public scrutiny, learners need understandable information and practical correction. For learner protection in supplier evidence and public scrutiny, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-57] [REF-59] [REF-60]

Human oversight for supplier evidence and public scrutiny should be assigned to a competent person with real authority. For learner protection in supplier evidence and public scrutiny, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For supplier evidence and public scrutiny, the learner should receive a decision-level reason and independent review while current education continues.[REF-09] [REF-57] [REF-59] [REF-60]

Equity and child-rights review for supplier evidence and public scrutiny should examine disability, language, location, income, migration and age where they affect coverage or consequence. For supplier evidence and public scrutiny, equal application of an invalid measure is not substantive equality. In governing supplier evidence and public scrutiny, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-57] [REF-59] [REF-60]

Institutional accountability for supplier evidence and public scrutiny should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing supplier evidence and public scrutiny, continued use depends on verified educational benefit and acceptable distribution. Within evidence on supplier evidence and public scrutiny, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-09] [REF-57] [REF-59] [REF-60]

27

Contract clauses for data and oversight

Contract clauses for data and oversight defines a material issue within the contract control. For contract clauses for data and oversight, the affected learners or institutions are institutions and external providers sharing functions, and the immediate evidence concerns purpose, access, auditability, correction and exit. In governing contract clauses for data and oversight, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on contract clauses for data and oversight, technical capability and supplier availability do not establish necessity or public value.[REF-20] [REF-57] [REF-58] [REF-60]

The principal risk is that standard provider terms remove public control. In governing contract clauses for data and oversight, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on contract clauses for data and oversight, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning contract clauses for data and oversight, each stage needs an identified owner, evidence and correction route.[REF-20] [REF-57] [REF-58]

The recommended response is to specify data limits, evidence access and termination duties. Within evidence on contract clauses for data and oversight, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning contract clauses for data and oversight, evidence requirements should rise with consequence. In reviewing contract clauses for data and oversight, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-57] [REF-58] [REF-60]

Validity for contract clauses for data and oversight should be demonstrated for the stated educational population and decision. For decisions concerning contract clauses for data and oversight, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing contract clauses for data and oversight, coverage, missingness and group error should be tested. For learner protection in contract clauses for data and oversight, outputs should not circulate beyond the construct and setting supported by evidence.[REF-20] [REF-60]

Data protection for contract clauses for data and oversight should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing contract clauses for data and oversight, learners need understandable information and practical correction. For learner protection in contract clauses for data and oversight, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-57] [REF-58] [REF-60]

Human oversight for contract clauses for data and oversight should be assigned to a competent person with real authority. For learner protection in contract clauses for data and oversight, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For contract clauses for data and oversight, the learner should receive a decision-level reason and independent review while current education continues.[REF-20] [REF-57] [REF-58] [REF-60]

Equity and child-rights review for contract clauses for data and oversight should examine disability, language, location, income, migration and age where they affect coverage or consequence. For contract clauses for data and oversight, equal application of an invalid measure is not substantive equality. In governing contract clauses for data and oversight, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-57] [REF-58] [REF-60]

Institutional accountability for contract clauses for data and oversight should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing contract clauses for data and oversight, continued use depends on verified educational benefit and acceptable distribution. Within evidence on contract clauses for data and oversight, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-20] [REF-57] [REF-58] [REF-60]

28

Limited introduction and stopping conditions

Limited introduction and stopping conditions defines a material issue within the staged adoption. For limited introduction and stopping conditions, the affected learners or institutions are learners exposed during early use, and the immediate evidence concerns reach, validity, group effect and incident. In governing limited introduction and stopping conditions, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on limited introduction and stopping conditions, technical capability and supplier availability do not establish necessity or public value.[REF-09] [REF-24] [REF-52] [REF-60]

The principal risk is that wide use begins before evidence under ordinary conditions. In governing limited introduction and stopping conditions, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on limited introduction and stopping conditions, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning limited introduction and stopping conditions, each stage needs an identified owner, evidence and correction route.[REF-09] [REF-24] [REF-52]

The recommended response is to start narrowly and declare stopping rules. Within evidence on limited introduction and stopping conditions, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning limited introduction and stopping conditions, evidence requirements should rise with consequence. In reviewing limited introduction and stopping conditions, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-24] [REF-52] [REF-60]

Validity for limited introduction and stopping conditions should be demonstrated for the stated educational population and decision. For decisions concerning limited introduction and stopping conditions, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing limited introduction and stopping conditions, coverage, missingness and group error should be tested. For learner protection in limited introduction and stopping conditions, outputs should not circulate beyond the construct and setting supported by evidence.[REF-09] [REF-60]

Data protection for limited introduction and stopping conditions should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing limited introduction and stopping conditions, learners need understandable information and practical correction. For learner protection in limited introduction and stopping conditions, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-24] [REF-52] [REF-60]

Human oversight for limited introduction and stopping conditions should be assigned to a competent person with real authority. For learner protection in limited introduction and stopping conditions, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For limited introduction and stopping conditions, the learner should receive a decision-level reason and independent review while current education continues.[REF-09] [REF-24] [REF-52] [REF-60]

Equity and child-rights review for limited introduction and stopping conditions should examine disability, language, location, income, migration and age where they affect coverage or consequence. For limited introduction and stopping conditions, equal application of an invalid measure is not substantive equality. In governing limited introduction and stopping conditions, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-24] [REF-52] [REF-60]

Institutional accountability for limited introduction and stopping conditions should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing limited introduction and stopping conditions, continued use depends on verified educational benefit and acceptable distribution. Within evidence on limited introduction and stopping conditions, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-09] [REF-24] [REF-52] [REF-60]

29

Incident reporting and rapid correction

Incident reporting and rapid correction defines a material issue within the harm response. For incident reporting and rapid correction, the affected learners or institutions are learners and staff experiencing breach or decision error, and the immediate evidence concerns report, containment, correction and continuity. In governing incident reporting and rapid correction, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on incident reporting and rapid correction, technical capability and supplier availability do not establish necessity or public value.[REF-14] [REF-21] [REF-60] [REF-62]

The principal risk is that incidents remain with the provider or learner harm continues. In governing incident reporting and rapid correction, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on incident reporting and rapid correction, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning incident reporting and rapid correction, each stage needs an identified owner, evidence and correction route.[REF-14] [REF-21] [REF-60]

The recommended response is to require prompt authority notice and learner-facing remedy. Within evidence on incident reporting and rapid correction, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning incident reporting and rapid correction, evidence requirements should rise with consequence. In reviewing incident reporting and rapid correction, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-21] [REF-60] [REF-62]

Validity for incident reporting and rapid correction should be demonstrated for the stated educational population and decision. For decisions concerning incident reporting and rapid correction, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing incident reporting and rapid correction, coverage, missingness and group error should be tested. For learner protection in incident reporting and rapid correction, outputs should not circulate beyond the construct and setting supported by evidence.[REF-14] [REF-62]

Data protection for incident reporting and rapid correction should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing incident reporting and rapid correction, learners need understandable information and practical correction. For learner protection in incident reporting and rapid correction, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-21] [REF-60] [REF-62]

Human oversight for incident reporting and rapid correction should be assigned to a competent person with real authority. For learner protection in incident reporting and rapid correction, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For incident reporting and rapid correction, the learner should receive a decision-level reason and independent review while current education continues.[REF-14] [REF-21] [REF-60] [REF-62]

Equity and child-rights review for incident reporting and rapid correction should examine disability, language, location, income, migration and age where they affect coverage or consequence. For incident reporting and rapid correction, equal application of an invalid measure is not substantive equality. In governing incident reporting and rapid correction, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-21] [REF-60] [REF-62]

Institutional accountability for incident reporting and rapid correction should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing incident reporting and rapid correction, continued use depends on verified educational benefit and acceptable distribution. Within evidence on incident reporting and rapid correction, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-14] [REF-21] [REF-60] [REF-62]

30

Exit, deletion and service continuity

Exit, deletion and service continuity defines a material issue within the safe termination. For exit, deletion and service continuity, the affected learners or institutions are institutions withdrawing a tool or changing provider, and the immediate evidence concerns data return, deletion, record continuity and substitute service. In governing exit, deletion and service continuity, governance should begin with the education purpose, lawful authority and consequence for the learner. Within evidence on exit, deletion and service continuity, technical capability and supplier availability do not establish necessity or public value.[REF-20] [REF-31] [REF-57] [REF-60]

The principal risk is that dependency or data lock-in prevents exit. In governing exit, deletion and service continuity, this can expose personal information, distort an educational decision or make harm difficult to understand and challenge. Within evidence on exit, deletion and service continuity, review should separate collection, inference, system output, human interpretation and final consequence. For decisions concerning exit, deletion and service continuity, each stage needs an identified owner, evidence and correction route.[REF-20] [REF-31] [REF-57]

The recommended response is to plan termination and verify deletion and continuity. Within evidence on exit, deletion and service continuity, the institution should document purpose, minimum data, access, retention, human decision right, learner notice, remedy and review date. For decisions concerning exit, deletion and service continuity, evidence requirements should rise with consequence. In reviewing exit, deletion and service continuity, under uncertainty, a limited reversible arrangement is preferable to broad dependence or an irreversible high-consequence use.[REF-31] [REF-57] [REF-60]

Validity for exit, deletion and service continuity should be demonstrated for the stated educational population and decision. For decisions concerning exit, deletion and service continuity, administrative fields and behavioural traces may be proxies rather than direct evidence of learning, motivation or need. In reviewing exit, deletion and service continuity, coverage, missingness and group error should be tested. For learner protection in exit, deletion and service continuity, outputs should not circulate beyond the construct and setting supported by evidence.[REF-20] [REF-60]

Data protection for exit, deletion and service continuity should minimize collection, restrict authorized access and define sharing, retention and deletion. In reviewing exit, deletion and service continuity, learners need understandable information and practical correction. For learner protection in exit, deletion and service continuity, external providers should not reuse records for unrelated purposes, and contract expiry should trigger controlled return or deletion without losing authoritative education records.[REF-31] [REF-57] [REF-60]

Human oversight for exit, deletion and service continuity should be assigned to a competent person with real authority. For learner protection in exit, deletion and service continuity, the reviewer should see material limitations and direct learner evidence and should be able to depart from the output. For exit, deletion and service continuity, the learner should receive a decision-level reason and independent review while current education continues.[REF-20] [REF-31] [REF-57] [REF-60]

Equity and child-rights review for exit, deletion and service continuity should examine disability, language, location, income, migration and age where they affect coverage or consequence. For exit, deletion and service continuity, equal application of an invalid measure is not substantive equality. In governing exit, deletion and service continuity, children’s best interests, participation, protection and development should remain visible beside institutional efficiency.[REF-31] [REF-57] [REF-60]

Institutional accountability for exit, deletion and service continuity should appear in a public use description, procurement evidence, contract controls, incident routes and stopping conditions. In governing exit, deletion and service continuity, continued use depends on verified educational benefit and acceptable distribution. Within evidence on exit, deletion and service continuity, exit should protect service continuity, correct residual labels and verify that unnecessary data and access have ended.[REF-20] [REF-31] [REF-57] [REF-60]

A protection-and-oversight record for a defined learner-facing purpose should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning a defined learner-facing purpose, it should be revised when the use, provider, population or evidence changes. In reviewing a defined learner-facing purpose, this makes responsibility traceable from institutional decision to learner remedy.[REF-01] [REF-24] [REF-54] [REF-60]

A protection-and-oversight record for necessity and less intrusive alternatives should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning necessity and less intrusive alternatives, it should be revised when the use, provider, population or evidence changes. In reviewing necessity and less intrusive alternatives, this makes responsibility traceable from institutional decision to learner remedy.[REF-10] [REF-21] [REF-60] [REF-62]

A protection-and-oversight record for lawful and competent authority should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning lawful and competent authority, it should be revised when the use, provider, population or evidence changes. In reviewing lawful and competent authority, this makes responsibility traceable from institutional decision to learner remedy.[REF-18] [REF-27] [REF-58] [REF-60]

A protection-and-oversight record for children’s best interests and evolving capacity should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning children’s best interests and evolving capacity, it should be revised when the use, provider, population or evidence changes. In reviewing children’s best interests and evolving capacity, this makes responsibility traceable from institutional decision to learner remedy.[REF-14] [REF-22] [REF-60] [REF-62]

A protection-and-oversight record for risk proportionate to educational consequence should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning risk proportionate to educational consequence, it should be revised when the use, provider, population or evidence changes. In reviewing risk proportionate to educational consequence, this makes responsibility traceable from institutional decision to learner remedy.[REF-09] [REF-21] [REF-38] [REF-60]

A protection-and-oversight record for time-limited authority and review should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning time-limited authority and review, it should be revised when the use, provider, population or evidence changes. In reviewing time-limited authority and review, this makes responsibility traceable from institutional decision to learner remedy.[REF-19] [REF-52] [REF-54] [REF-60]

A protection-and-oversight record for data minimisation at collection should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning data minimisation at collection, it should be revised when the use, provider, population or evidence changes. In reviewing data minimisation at collection, this makes responsibility traceable from institutional decision to learner remedy.[REF-09] [REF-20] [REF-60] [REF-62]

A protection-and-oversight record for notice that learners can understand should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning notice that learners can understand, it should be revised when the use, provider, population or evidence changes. In reviewing notice that learners can understand, this makes responsibility traceable from institutional decision to learner remedy.[REF-14] [REF-21] [REF-60] [REF-62]

A protection-and-oversight record for access control and staff responsibilities should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning access control and staff responsibilities, it should be revised when the use, provider, population or evidence changes. In reviewing access control and staff responsibilities, this makes responsibility traceable from institutional decision to learner remedy.[REF-20] [REF-27] [REF-60] [REF-61]

A protection-and-oversight record for sharing and external provider limits should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning sharing and external provider limits, it should be revised when the use, provider, population or evidence changes. In reviewing sharing and external provider limits, this makes responsibility traceable from institutional decision to learner remedy.[REF-57] [REF-58] [REF-60] [REF-62]

A protection-and-oversight record for retention, deletion and education records should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning retention, deletion and education records, it should be revised when the use, provider, population or evidence changes. In reviewing retention, deletion and education records, this makes responsibility traceable from institutional decision to learner remedy.[REF-09] [REF-20] [REF-60] [REF-62]

A protection-and-oversight record for correction, portability and continuity should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning correction, portability and continuity, it should be revised when the use, provider, population or evidence changes. In reviewing correction, portability and continuity, this makes responsibility traceable from institutional decision to learner remedy.[REF-14] [REF-20] [REF-31] [REF-60]

A protection-and-oversight record for a competent named decision maker should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning a competent named decision maker, it should be revised when the use, provider, population or evidence changes. In reviewing a competent named decision maker, this makes responsibility traceable from institutional decision to learner remedy.[REF-21] [REF-27] [REF-58] [REF-60]

A protection-and-oversight record for ability to understand material limitations should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning ability to understand material limitations, it should be revised when the use, provider, population or evidence changes. In reviewing ability to understand material limitations, this makes responsibility traceable from institutional decision to learner remedy.[REF-05] [REF-09] [REF-17] [REF-60]

A protection-and-oversight record for authority to depart from the output should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning authority to depart from the output, it should be revised when the use, provider, population or evidence changes. In reviewing authority to depart from the output, this makes responsibility traceable from institutional decision to learner remedy.[REF-01] [REF-21] [REF-24] [REF-60]

A protection-and-oversight record for direct learner evidence and context should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning direct learner evidence and context, it should be revised when the use, provider, population or evidence changes. In reviewing direct learner evidence and context, this makes responsibility traceable from institutional decision to learner remedy.[REF-10] [REF-29] [REF-38] [REF-53]

A protection-and-oversight record for reasons, response and contestability should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning reasons, response and contestability, it should be revised when the use, provider, population or evidence changes. In reviewing reasons, response and contestability, this makes responsibility traceable from institutional decision to learner remedy.[REF-21] [REF-22] [REF-60] [REF-62]

A protection-and-oversight record for independent review and continuing education should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning independent review and continuing education, it should be revised when the use, provider, population or evidence changes. In reviewing independent review and continuing education, this makes responsibility traceable from institutional decision to learner remedy.[REF-10] [REF-14] [REF-21] [REF-60]

A protection-and-oversight record for learning resources and personalization should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning learning resources and personalization, it should be revised when the use, provider, population or evidence changes. In reviewing learning resources and personalization, this makes responsibility traceable from institutional decision to learner remedy.[REF-01] [REF-24] [REF-29] [REF-54]

A protection-and-oversight record for remote participation monitoring should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning remote participation monitoring, it should be revised when the use, provider, population or evidence changes. In reviewing remote participation monitoring, this makes responsibility traceable from institutional decision to learner remedy.[REF-05] [REF-49] [REF-55] [REF-56]

A protection-and-oversight record for assessment and progression should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning assessment and progression, it should be revised when the use, provider, population or evidence changes. In reviewing assessment and progression, this makes responsibility traceable from institutional decision to learner remedy.[REF-09] [REF-17] [REF-38] [REF-60]

A protection-and-oversight record for disability accessibility and sensitive inference should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning disability accessibility and sensitive inference, it should be revised when the use, provider, population or evidence changes. In reviewing disability accessibility and sensitive inference, this makes responsibility traceable from institutional decision to learner remedy.[REF-10] [REF-11] [REF-15] [REF-62]

A protection-and-oversight record for commercial influence and persuasive design should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning commercial influence and persuasive design, it should be revised when the use, provider, population or evidence changes. In reviewing commercial influence and persuasive design, this makes responsibility traceable from institutional decision to learner remedy.[REF-14] [REF-58] [REF-60] [REF-62]

A protection-and-oversight record for safety, communications and reporting should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning safety, communications and reporting, it should be revised when the use, provider, population or evidence changes. In reviewing safety, communications and reporting, this makes responsibility traceable from institutional decision to learner remedy.[REF-12] [REF-14] [REF-61] [REF-62]

A protection-and-oversight record for pre-use rights and educational assessment should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning pre-use rights and educational assessment, it should be revised when the use, provider, population or evidence changes. In reviewing pre-use rights and educational assessment, this makes responsibility traceable from institutional decision to learner remedy.[REF-10] [REF-27] [REF-59] [REF-60]

A protection-and-oversight record for supplier evidence and public scrutiny should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning supplier evidence and public scrutiny, it should be revised when the use, provider, population or evidence changes. In reviewing supplier evidence and public scrutiny, this makes responsibility traceable from institutional decision to learner remedy.[REF-09] [REF-57] [REF-59] [REF-60]

A protection-and-oversight record for contract clauses for data and oversight should preserve the purpose, authority, data, validity evidence, affected population, human reviewer, learner notice, complaint route and termination condition. For decisions concerning contract clauses for data and oversight, it should be revised when the use, provider, population or evidence changes. In reviewing contract clauses for data and oversight, this makes responsibility traceable from institutional decision to learner remedy.[REF-20] [REF-57] [REF-58] [REF-60]

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    https://undocs.org/A/RES/73/195
  41. REF-41

    United Nations General Assembly. Office of the United Nations High Commissioner for Refugees — Resolution 73/151, Affirming the Global Compact on Refugees. 2018.

    Contemporaneous affirmation of the Global Compact on Refugees and shared responsibility including education.

    https://undocs.org/A/RES/73/151
  42. REF-42

    European Commission, Education, Audiovisual and Culture Executive Agency, Eurydice. Integrating Students from Migrant Backgrounds into Schools in Europe: National Policies and Measures. 2019.

    European comparative evidence on language, learning, psychosocial and whole-school support for migrant-background students.

    https://op.europa.eu/en/publication-detail/-/publication/39c05fd6-2446-11e9-8d04-01aa75ed71a1
  43. REF-43

    UNESCO Institute for Statistics and Global Education Monitoring Report. Meeting Commitments: Are Countries on Track to Achieve SDG 4?. 2019.

    Contemporaneous evidence on national education benchmarks, feasible progress and comparative monitoring.

    https://unesdoc.unesco.org/ark:/48223/pf0000369009
  44. REF-44

    United Nations. The Sustainable Development Goals Report 2019. 2019.

    Global account of Sustainable Development Goal progress and data limitations available by cutoff.

    https://unstats.un.org/sdgs/report/2019/
  45. REF-45

    European Commission. Education and Training Monitor 2019. 2019.

    European comparative evidence on education benchmarks, equity, investment and national conditions.

    https://op.europa.eu/en/publication-detail/-/publication/15d70dc3-e00e-11e9-9c4e-01aa75ed71a1
  46. REF-46

    UNESCO Institute for Statistics. SDG 4 Data Digest 2018: Data to Nurture Learning. 2018.

    Guidance on learning data, reporting architecture, coverage and use for Goal 4 monitoring.

    https://uis.unesco.org/sites/default/files/documents/sdg4-data-digest-data-nurture-learning-2018-en.pdf
  47. REF-47

    UNESCO General Conference. Global Convention on the Recognition of Qualifications concerning Higher Education. 2019.

    Adopted global normative basis for fair, transparent and non-discriminatory recognition of higher-education qualifications and partial studies.

    https://unesdoc.unesco.org/ark:/48223/pf0000373602
  48. REF-48

    UNESCO. COVID-19 Educational Disruption and Response. 2020.

    Contemporaneous institutional evidence on worldwide education disruption and response.

    https://www.unesco.org/en/covid-19/education-response
  49. REF-49

    UNESCO. Distance Learning Strategies in Response to COVID-19 School Closures — UNESCO COVID-19 Education Response Education Sector Issue Note No. 2.1. 2020.

    Contemporaneous guidance on technology choices, planning, teacher support, inclusion and monitoring for distance education.

    https://unesdoc.unesco.org/ark:/48223/pf0000373305
  50. REF-50

    UNESCO, UNICEF, World Bank and World Food Programme. Framework for Reopening Schools. 2020.

    Contemporaneous framework connecting continuity, equity, safety, learning and preparation for reopening.

    https://unesdoc.unesco.org/ark:/48223/pf0000373348
  51. REF-51

    European Commission. Online Learning Resources for Schools during the Coronavirus Outbreak. 2020.

    European institutional guidance on remote learning resources and educator support available by cutoff.

    https://education.ec.europa.eu/resources-and-tools/coronavirus-online-learning-resources
  52. REF-52

    United Nations. Policy Brief: Education during COVID-19 and Beyond. 2020.

    Contemporaneous account of disruption, unequal access, continuity, recovery and education-system resilience.

    https://unsdg.un.org/resources/policy-brief-education-during-covid-19-and-beyond
  53. REF-53

    UNESCO. Inclusion and Education: All Means All — Global Education Monitoring Report 2020. 2020.

    Evidence on inclusive education, exclusion, governance, finance, data and system conditions.

    https://unesdoc.unesco.org/ark:/48223/pf0000373718
  54. REF-54

    European Commission. Digital Education Action Plan 2021–2027: Resetting Education and Training for the Digital Age — COM(2020) 624 final. 2020.

    European policy direction on accessible, inclusive and effective digital education and institutional capacity available by cutoff.

    https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020DC0624
  55. REF-55

    UNICEF. COVID-19: Are Children Able to Continue Learning during School Closures?. 2020.

    Contemporaneous estimates and cautions concerning household reach of remote learning policies.

    https://data.unicef.org/resources/remote-learning-reachability-factsheet/
  56. REF-56

    UNESCO, UNICEF and World Bank. What Have We Learnt? Overview of Findings from a Survey of Ministries of Education on National Responses to COVID-19. 2020.

    Contemporaneous comparative evidence on national education responses, remote provision, support and reopening.

    https://unesdoc.unesco.org/ark:/48223/pf0000374702
  57. REF-57

    European Parliament and Council of the European Union. Directive 2014/24/EU on Public Procurement. 2014.

    European legal framework on transparent public purchasing, award criteria, contract conditions and oversight.

    https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0024
  58. REF-58

    United Nations Human Rights Council. Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework. 2011.

    Authoritative framework on State duty, organizational responsibility, due diligence and remedy.

    https://undocs.org/A/HRC/17/31
  59. REF-59

    European Commission. Buying Social: A Guide to Taking Account of Social Considerations in Public Procurement — Second Edition. 2021.

    Pre-cutoff European guidance on social objectives, accessibility, contract conditions, monitoring and public value in purchasing.

    https://ec.europa.eu/docsroom/documents/45767
  60. REF-60

    European Parliament and Council of the European Union. Regulation (EU) 2016/679 on the Protection of Natural Persons with Regard to the Processing of Personal Data and on the Free Movement of Such Data. 2016.

    European legal principles on lawful purpose, minimisation, transparency, rights, security, impact assessment and accountable automated decisions.

    https://eur-lex.europa.eu/eli/reg/2016/679/oj
  61. REF-61

    European Parliament and Council of the European Union. Directive 2002/58/EC concerning Privacy and Electronic Communications. 2002.

    European protections for confidentiality and information associated with electronic communications.

    https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32002L0058
  62. REF-62

    United Nations Committee on the Rights of the Child. General Comment No. 25 on Children’s Rights in Relation to the Digital Environment. 2021.

    Pre-cutoff interpretation of child rights concerning access, privacy, safety, participation, commercial interests and remedy in digital environments.

    https://undocs.org/CRC/C/GC/25