1. Describe the processing
- Purpose: sharing approved classroom photos/videos with each child's own family; documentation; optional public use with separate consent.
- Data: images and short videos of children; names; class; guardian contact details; consent status.
- Data subjects: children (a vulnerable group), guardians, staff.
- Flows: teacher device → vendor → guardian app; admin approval; retention; deletion; export.
2. Necessity and proportionality
- Lawful basis per purpose (consent for sharing; public task/legitimate interests for documentation as applicable).
- Data minimisation: short captions, no open chat, no personal-gallery storage, no biometrics.
- Retention period and deletion mechanism.
- Rights: access, export, erasure, withdrawal — how each is honoured.
3. Risks to consider
- ✓An opted-out child appears in a group photo shared to other families
- ✓A photo is published publicly without public-tier consent
- ✓Images stored on a staff member's personal phone
- ✓Unauthorised access to the vendor's systems
- ✓Separated parents — one guardian seeing the other's details
- ✓Retention beyond the stated period
- ✓Vendor change of ownership or sub-processor
4. Mitigations
- Per-child tiered consent enforced by the software
- Manager approval before any parent sees a post; second approval for public use
- Capture straight into the setting's account; nothing in personal galleries
- Encryption in transit and at rest; role-based access; audit logs
- Multiple guardians per child without mutual visibility
- Article 28 DPA with sub-processor list and breach notification
- Automatic deletion at end of retention; family export
5. Sign-off
DPO or nominated lead, date, review date (annually or on material change). Attach the vendor's DPA and trust documentation — for Oyku, our Trust Center.
See it live
Want this for your classrooms?
Book a 20-minute call. We'll show the parent feed, teacher capture and approvals — then set up a free pilot classroom. Under $10 per child, per month.
