GDPR in Plain English – Key Definitions for Educators

When Emma Davies, a middle school science teacher in Manchester, decided to use a new online quiz platform with her students, she didn’t think twice about entering their names and email addresses. Two weeks later, she found herself in the headmaster’s office, facing questions about GDPR compliance and data protection impact assessments.

“I just wanted to make learning more interactive,” she recalls. “I had no idea I was potentially violating privacy regulations.”

Emma’s experience is increasingly common in educational settings across Europe and beyond. The General Data Protection Regulation (GDPR)—the comprehensive privacy law that went into effect in 2018—has profound implications for educators, yet many find its legal terminology bewildering and its requirements daunting.

Let’s demystify the essential GDPR concepts every educator should understand:

Personal Data: Much More Than Just Names

When the IT coordinator mentions “personal data,” many teachers immediately think of obvious identifiers like names and addresses. However, GDPR defines personal data much more broadly.

“Personal data encompasses any information relating to an identified or identifiable person,” explains Maria Gonzalez, a data protection officer for a Barcelona school district. “This includes photos, audio recordings, behavioral observations, and even seemingly anonymous information that could be combined with other data to identify someone.”

For teachers, this means virtually any digital tool that collects student information—from learning management systems to attendance apps—involves personal data processing. Those innocent-looking classroom photos posted to the school website? They’re personal data too.

Data Subject: Your Students and Their Rights

Under GDPR, a “data subject” is any individual whose personal data is being processed. In educational contexts, students and their parents are your primary data subjects, and they possess specific rights that schools must honor.

These include the right to:

• Access their data
• Correct inaccurate information
• Request deletion in certain circumstances
• Object to certain types of processing
• Obtain their data in a portable format

“Most educators are surprised when they learn that a parent can request copies of all digital records relating to their child,” notes Julian Weber, who conducts GDPR training for schools in Germany. “This includes teacher comments in digital gradebooks, emails mentioning the student, and even metadata about when the student logged into school systems.”

Data Controller vs. Data Processor: Who’s Responsible?

One of GDPR’s most important distinctions involves who determines how and why personal data is processed (the controller) versus who actually processes that data on the controller’s behalf (the processor).

“Schools almost always function as data controllers,” explains Phillip Richards, privacy attorney specializing in education. “They decide what student information to collect and how to use it. Meanwhile, companies providing educational software or cloud storage services typically serve as data processors.”

This distinction matters because controllers bear primary responsibility for GDPR compliance. When teachers select educational apps without their school’s approval, they may inadvertently create unauthorized data controller relationships—potentially exposing their institution to significant compliance risks.

Lawful Basis: Your Permission Slip for Using Data

Perhaps the most critical concept for educators to grasp is “lawful basis”—the legal justification required for processing personal data.

GDPR specifies six lawful bases, but schools typically rely on three:

Consent: Freely given, specific, informed, and unambiguous agreement to data processing. While parental consent forms are common in schools, consent can be problematic because it must be truly optional and easily withdrawn.

Legal Obligation: Processing necessary to comply with a law. Records required by education authorities typically fall here.

Public Task: Processing necessary to perform a task in the public interest or official function. Much of a school’s core educational data processing falls under this basis.

“Many schools mistakenly believe they need consent for everything,” says Catherine Durand, who advises French educational institutions on data protection. “But for essential educational functions, ‘public task’ is often more appropriate. You don’t need parental permission to grade homework or take attendance—these are inherent to your educational mission.”

Data Protection Impact Assessment: Think Before You Collect

When considering new technologies that might pose significant privacy risks—like biometric systems, comprehensive learning analytics platforms, or AI-powered educational tools—GDPR requires schools to conduct a Data Protection Impact Assessment (DPIA).

“A DPIA isn’t just bureaucratic paperwork,” insists Klaus Müller, data protection specialist at Austria’s Ministry of Education. “It’s a practical exercise that helps educators think critically about data collection. Do we really need this information? What are the risks? How can we minimize them?”

For classroom teachers, this means consulting with administration before implementing new digital tools that collect sensitive or extensive student data. That facial recognition attendance system might seem efficient, but have you considered less invasive alternatives?

Data Minimization: Less is More

This principle requires that personal data be limited to what’s necessary for your stated purpose—no extra information “just in case” it might be useful later.

“When teachers understand data minimization, they start asking better questions,” notes Elena Popescu, who leads teacher training on digital citizenship in Romania. “Instead of collecting twenty data points for a science project, they realize they can accomplish the same educational goal with five, or with anonymized data.”

Practical application might mean using student ID numbers instead of full names for online activities, collecting age ranges rather than birth dates, or gathering anonymous feedback rather than identified responses when personal identification isn’t necessary for the educational purpose.

Navigating GDPR in Your Classroom

While GDPR compliance ultimately requires institutional commitment, individual educators can take meaningful steps toward better data protection:

• Audit your digital tools: What student data are they collecting? Is this necessary? Has your school approved these tools?
• Default to privacy: Consider whether activities requiring personal data could be accomplished with anonymized information instead.
• Be transparent with students and parents about data practices.
• Document your data processing activities, particularly for special projects.
• Consult with administration before implementing new technologies that process student data extensively.

As education becomes increasingly digital, understanding these fundamental GDPR concepts isn’t just about regulatory compliance—it’s about modeling ethical digital citizenship for your students.

“Teachers who engage thoughtfully with data protection concepts help prepare students for a world where privacy literacy is as essential as traditional literacy,” concludes Weber. “That might be the most important lesson of all.”