Optional module

Pupil use of AI

Off by default. Switched on only when two conditions are genuinely met, because enabling it carelessly is the most common way a sound policy becomes indefensible.

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Pupils aren’t covered by the staff policy. Bringing them into scope is a deliberate, carefully guarded decision. It shouldn’t happen by default, and it shouldn’t be allowed to creep in.

What it is

An optional module that extends the policy to pupil use of AI, but only once both conditions are in place: first, a DPIA completed for the specific tools and processing; and second, age-appropriate teaching about AI within your curriculum and online safety provision, covering AI literacy, misinformation, deepfakes and responsible use, in line with the whole-school approach to online safety in KCSIE 2026. If pupil use isn’t permitted, you should delete the module, and pupils stay out of scope.

Why it’s important

Two things are easy to confuse, and mustn’t be. A tool’s terms may require parent or guardian agreement for younger users; a named person obtains and records that. Separately, your UK GDPR lawful basis for processing pupils’ data comes from the DPIA, and will rarely be consent. Where a pupil-facing tool processes children’s data, the ICO Children’s Code applies: the child’s best interests come first, settings default to high privacy, and profiling is off by default. Using a tool below its stated minimum age, or without the agreement it requires, is likely to breach both the tool’s terms and data protection law.

Pupils are taught what AI can and can’t do: how to recognise deepfakes, misinformation and impersonation, and how to avoid over-reliance, including on tools that simulate conversation or companionship. Web-enabled or recording-capable devices, including smart glasses and earpieces, must not be taken into examinations or controlled assessments, in line with JCQ regulations. Declining pupil use, where meeting these conditions isn’t practical, is a perfectly reasonable and defensible choice.

Mark always starts with pedagogy!

Emma Ledger · Headteacher, Ranches Primary School, Dubai

A non-negotiable

Don’t bring pupils into scope until a DPIA is complete and age-appropriate teaching about AI is embedded in your curriculum. Enabling pupil use without them is the most common way a sound policy becomes indefensible.

He isn’t just an advocate of tech for tech’s sake. It always has to fit the pedagogy, and that makes him a respected source of knowledge that schools can trust.

Al Kingsley MBE · Multi-academy trust chair and author

Working on your AI policy?

Support with writing or refining it, and with training your staff, is exactly the work I do. And if the template or the screening tool has helped in your school or trust, I’d love to hear about it.