Admissions and proctoring are high-risk, and the affected people are often minors.
Exam proctoring and admissions are Annex III point 3. Emotion inference in education is prohibited outright under Article 5, and many of the affected people are children.
- Annex
- Annex III · 3 — education and vocational training
- Provisions
- Art. 5(1)(f) · Annex III 3 · Art. 26 · UNCRC
- Pack
- €149/month add-on · 3 duties · 1 notice templates
Why this sector is different
Education combines a prohibited-practice trap (emotion and attention inference), a high-risk category, and a vulnerable population. The practical risk is that proctoring products are bought as productivity tools and arrive with emotion or attention scoring enabled by default.
Audit every proctoring and attention tool for prohibited inference
Emotion and attention inference in education is banned with no conditions route. Vendor defaults are the usual source.
Art. 5(1)(f) · due within 14 days of activation
Add the minor-specific safeguards and parental information
Assessments about children need a higher bar on oversight, explanation and data minimisation.
Art. 26 · GDPR Art. 8 · due within 30 days of activation
Give every student an appeal route against an automated assessment
A grade or a disqualification is a consequential decision and needs a human review path.
Art. 86 · Art. 14 · due within 45 days of activation
The notices you owe
Unlocked with the pack, rendered with your own facts, blanks kept where you must decide.
Students and, where relevant, guardians
Student and guardian notice — AI in assessment
{company} uses an AI system to support {purpose}. The system does not make the final decision: {reviewer} reviews its output first. The system does not infer your emotions or attention. You or your guardian …
What your buyers will ask
The questions that stall a deal or trigger an audit. Each one is a control in the matrix.
- ?Does the proctoring tool do any emotion or attention inference?
- ?How are minors' assessments reviewed?
- ?What is the appeal route for an automated decision?
Straight answers
Is exam proctoring high-risk?
Yes, Annex III point 3 covers AI intended to be used to determine access to education or to evaluate learning outcomes, including proctoring. That brings Article 26 deployer duties.
Is attention tracking prohibited?
Inferring emotions is prohibited in education under Article 5(1)(f). Attention or engagement scoring is not always emotion inference, but many products implement it that way. Assume it is prohibited until the vendor shows exactly what the model predicts.
Know where you stand before the questions arrive.
Four minutes, no card. You get your exposure score and the exact articles that apply to a education organisation.