Compliance

GDPR: which student data can a teacher collect?

The question comes up in every digital project and usually gets two equally wrong answers: "we are not allowed to do anything any more" or "nobody checks anyway". The reality is simpler. The GDPR does not ban digital tools in class: it requires you to collect only what is necessary, to know why, and to be able to explain it. This article is decision support, not legal advice.

📅 Published on 03/09/2026 ⏱ 9 min read ✍️ Équipe EduTools

Who is responsible for what

This is the least understood point, and everything else follows from it.

The practical consequence: a teacher adopting a tool alone commits their institution without its knowledge. It is not a moral failing, it is a common blind spot — and exactly what the approach below prevents.

On what basis can this data be processed?

Every processing operation needs a legal basis. In education, the most common one is not the one people assume.

Consent remains relevant for anything outside the teaching frame: publishing a photograph, sharing work beyond the class, using an optional service.

What is defensible, and what is not

The minimisation principle is tested by one simple question: would the activity work without this data? If yes, do not collect it.

The useful reflex is the opposite of habit: do not ask "am I allowed to collect this?", ask "what can I avoid collecting?". An activity that works with a first name typed on the spot is far easier to justify than a filled-in student account.

How long to keep it, and how to delete it

Retention is the most frequently forgotten obligation. Data is not meant to stay indefinitely because it might be useful one day.

Check that the tool genuinely deletes rather than merely hides. An "archive" that keeps everything forever does not meet the obligation.

Data subjects have rights you must be able to honour: access their data, correct it, request erasure. A family that writes in should get an answer within one month.

Seven questions to ask before adopting a tool

This list fits on one page and can be put to any vendor. An evasive answer is itself an answer.

Keep the answers in writing: they form most of the file your data protection officer will ask for.

This article describes general principles and does not constitute legal advice. For a specific case, consult your organisation's data protection officer.

Frequently asked questions

Do I need parental consent to use a digital tool in class?
Not systematically. If the use falls within the teaching mission, the legal basis is not consent but the public interest task: you must inform, not ask permission. Agreement becomes necessary for anything beyond that frame, such as publishing a photograph.
Can a learner refuse to use the tool?
They can ask for an alternative, and planning one is good practice — pair work, answering aloud. It avoids excluding anyone and settles the equipment question at the same time.
Do pseudonyms take you outside the GDPR?
No. A pseudonym that can be traced back to a person is still personal data: that is pseudonymisation, not anonymisation. It reduces risk; it does not remove obligations.
What if a tool is already in use without approval?
Do not pull it mid-unit: report it to the data protection officer and document what is collected. Regularisation is almost always possible; it is prolonged silence that causes problems.

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