DPAI-01

Does your service use AI for the processing of institutional data?

Explanation

This question is asking whether your service incorporates artificial intelligence (AI) technologies to process data that belongs to the institution conducting the assessment. 'Processing' in this context refers to any operation performed on data, such as collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, or any other form of handling. This question is being asked in a security assessment because AI processing introduces specific privacy, security, and ethical concerns that traditional data processing may not. These include: 1. Transparency issues: AI systems can be 'black boxes' where the decision-making process isn't clear 2. Data retention concerns: AI models may incorporate training data in ways that create privacy risks 3. Algorithmic bias: AI systems may produce biased or discriminatory outcomes 4. Data amplification: AI may generate new insights about individuals beyond what was explicitly shared 5. Regulatory compliance: Many jurisdictions have specific requirements for automated decision-making The best way to answer this question is to be transparent about any AI usage in your service. If you do use AI, specify what type of AI is used (machine learning, natural language processing, computer vision, etc.), what institutional data it processes, and for what purposes. Also mention any safeguards you have in place to address AI-specific risks. If you don't use AI to process institutional data, simply state that clearly.

Example Responses

Example Response 1

Yes, our service uses AI for processing institutional data We employ machine learning algorithms to analyze student performance data to identify at-risk students and provide early intervention recommendations The AI processes anonymized grade data, course participation metrics, and assignment completion rates We have implemented several safeguards including: regular bias testing of our algorithms, human review of all AI-generated recommendations before they're acted upon, clear documentation of how the AI makes its determinations, and strict access controls that prevent the AI system from accessing sensitive personal identifiers beyond what's necessary for its function All AI processing complies with FERPA requirements and our institutional data governance policies.

Example Response 2

No, our service does not currently use AI for processing institutional data While we do employ some automated processes for data validation and report generation, these use traditional rule-based algorithms rather than AI or machine learning techniques All data processing logic is deterministic and fully documented in our technical specifications Should we implement AI-based processing in the future, we would notify all clients and update our security and privacy documentation accordingly.

Example Response 3

Partially Our core service functionality does not use AI for processing institutional data However, our optional analytics module does incorporate machine learning to identify patterns in anonymized usage data This feature is disabled by default and requires explicit opt-in from the institution We currently cannot meet full compliance requirements for AI processing in all jurisdictions because our model training and validation procedures are still being formalized, and we have not yet completed third-party bias audits of our algorithms Institutions that enable this feature should be aware that the AI processing occurs in our US-based data centers and may be subject to different regulatory frameworks than their primary data.

Context

Tab
Privacy
Category
Privacy and AI

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Neil Cameron