GDPR and enrolling students to edu platforms

[nickjelly]

I've been posed a question that I'm not sure the answer to. We are about to enrol hundreds of students to Thisislangauage.com via a bulk CSV upload using their school email addresses as usernames. In terms of GDPR do we need to obtain consent from the student/student's guardians before we do this? If we ask students to sign up themselves (which will be a headache) does this negate the need for us to obtain consent? Edited November 21, 2019 by nickjelly

[crc-ict]

It depends - our advice was that if the sites are used as part of the 'public task' of education, and you reference them on your privacy notice, then no specific consent is required - actually, having something like this relying on consent would be undesirable as you don't want some students not having access to a curriculum tool. This assumes that you have completed the relevant due diligence on the service to ensure they have appropriate data protection policies etc etc.

 

However, we have also found that a lot of the terms and conditions of these sort of services place a requirement on the schools to have documented parental consent before uploading data. So it may not be directly a GDPR issue, but more one of compliance with the terms and conditions of the specific services.

[bobsmith]

what personal data are you providing to this company?

[nickjelly]

what personal data are you providing to this company?

 

Name, school email and possibly class

[IrritableTech]

Name, school email and possibly class

Information is minimal. What you are doing here is a Data Protection Impact Assessment. It's best to formalize this - what info, why, what benefit, who with and how do they protect, and finally what legal basis you are concluding. I'd be inclined to agree with @crc-ict this is a normal thing for a school to do under public task and shouldn't require consent.

[mavhc]

Assuming that site has a privacy policy that doesn't conflict with GDPR.

[nickjelly]

Thanks everyone. That's given me some useful pointers.