EU School Readiness Gate
Status: Not ready for general EU school sale. Phase: Phase 1 - legal, privacy, AI-risk, safety, and accessibility foundation. Last updated: [LAST_UPDATED_DATE]
Not legal advice. This document is an operating readiness pack for Lumi Tutor. It must be reviewed by qualified counsel before any school pilot, school sale, or public claim that Lumi is ready for all EU schools.
Current position
Lumi Tutor may be used only as a controlled family beta or controlled school pilot until this gate is complete. Lumi must not claim that it is ready for every child, every school, every EU country, every religious/private school, or university learners.
The safe current claim is:
- Lumi is a child-focused tutoring product for parent-supervised use.
- Child profiles currently cover ages 3-19; ages 18-19 remain a separate secondary-age lane and do not imply adult or university approval.
- The strongest current product fit is school-age tutoring in core subjects.
- School use is pilot-only until the DPA, DPIA, AI Act classification, minor-consent model, accessibility review, and tenant controls are complete.
- Lumi is not a grading, admissions, placement, discipline, proctoring, certification, psychotherapy, or child-protection decision system.
Legal sources to anchor Phase 1
| Area | Why it matters | Source |
|---|---|---|
| EU AI Act education risk | AI systems used for admission, assignment, summative learning evaluation, level assessment, or prohibited-behaviour monitoring in education can be high-risk. Lumi should stay formative-only unless high-risk compliance is built. | https://ai-act-service-desk.ec.europa.eu/en/education-and-vocational-training |
| GDPR Article 8 | Child consent rules for information-society services use age 16 by default, while Member States may lower the age to no less than 13. Lumi therefore needs country review and a conservative parent/school authority model. | https://gdpr-info.eu/art-8-gdpr/ |
| GDPR Article 9 | Religious and philosophical beliefs are special-category data. Religious/private-school support must avoid child profiling and unnecessary collection. | https://gdpr-info.eu/art-9-gdpr/ |
| DSA minors guidance | Online platforms accessible to minors need appropriate child-safety measures, including privacy defaults, recommender controls, reporting, parental controls, and age assurance where appropriate. | https://digital-strategy.ec.europa.eu/en/library/commission-publishes-guidelines-protection-minors |
| European Accessibility Act | EU accessibility rules create a shared baseline for accessible digital products and services, with e-commerce and digital services in scope. Lumi needs an EAA/WCAG audit before broad EU launch. | https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/disability/european-accessibility-act-eaa_en |
| Ethical AI in education | Schools need practical, ethical, and pedagogical controls for AI and data in teaching and learning. | https://education.ec.europa.eu/focus-topics/digital-education/actions/plan/ethical-guidelines-for-educators-on-using-artificial-intelligence |
Hard red lines
Lumi must not be used for these purposes unless a separate high-risk compliance program is completed:
- Deciding school admission, access, assignment, or scholarship eligibility.
- Producing official grades or final learning evaluations.
- Determining a student's level, track, placement, or progression for school purposes.
- Monitoring, proctoring, or detecting prohibited student behaviour.
- Disciplinary decisions.
- Special-education classification or diagnosis.
- Religious profiling, belief inference, or child belief records.
- Mental-health diagnosis, therapy, or emergency safeguarding decisions without human escalation.
Phase 1 gate checklist
| Gate | Owner | Evidence required | Blocks |
|---|---|---|---|
| Legal identity | Legal | lib/legal/tokens.ts filled with real company details, addresses, and real privacy/legal/safety/security inboxes. | Any real-user launch |
| Counsel review | Legal | Counsel signoff for family use, school use, first pilot countries, private schools, and religious schools. | School pilot and sale |
| DPIA pack | Legal | Completed school DPIA, data-flow map, retention map, ROPA inputs, and school-controller instructions. | School pilot and sale |
| DPA/subprocessors | Legal | School DPA, SCC/transfer assessment, and live subprocessor list matching production. | School pilot and sale |
| Minor consent | Legal | Country-by-country local-law matrix plus parent/school authority workflow for each pilot. | School pilot and sale |
| AI Act classification | Legal/Product | Feature-by-feature risk register and written classification. | School pilot and sale |
| Summative decision ban | Product | Contracts, UI, teacher copy, prompts, and school onboarding say "formative tutoring only." | School pilot |
| DSA minors safety | Product/Safety | Age-appropriate defaults, reporting, escalation, recommender limits, chatbot safeguards, and age-assurance rationale. | School pilot |
| Accessibility | Product | WCAG 2.2 AA/EAA audit plan and remediation tracker. | School pilot |
| Special-category data | Legal/Product | Religious/private-school policy approved; no child religious profiling by default. | School pilot |
| Tenant controls | Engineering | Tenant isolation, roles, rosters, audit logs, parent opt-outs, export/deletion flows. | School pilot |
| Incident response | Security | Tabletop exercise for breach, safety incident, harmful AI output, and school escalation. | Evidence before expansion |
Launch levels
| Level | Allowed use | Required gate state |
|---|---|---|
| Family beta | Parent-created child profiles, parent consent, no school contract. | Existing child-processing and safety gates; legal identity before real public launch. |
| Controlled school pilot | Named school, signed pilot terms, DPA, DPIA support, no official grading or placement. | All launch-blocker and pilot-blocker gates complete. |
| General school sale | Repeatable onboarding across EU schools, production school tenant controls, support, incident response, accessibility, and country legal matrix. | All gates complete. |
| High-risk education use | Official grading, admission, placement, progression, proctoring, or behaviour monitoring. | Separate AI Act high-risk compliance program complete. |
Immediate Phase 1 actions
- Fill or explicitly defer each legal identity token.
- Complete the School DPIA Template.
- Complete the AI Act Education Risk Register.
- Complete the Minor Consent Matrix for the first three pilot countries.
- Approve the Religious and Private School Policy.
- Remove broad school claims from pricing, teacher pages, and sales copy.
- Run a child-data incident tabletop before any school pilot.