EU AI Actclassroom analyticsprivacy-firsteducation complianceschool leadersEdTechCLMPnon-surveillancelow-risk AIAnnex IIIArticle 5DPIAGDPRAI literacy14-day pilot

Insight, not surveillance: A school leader’s guide to EU AI Act-Ready classroom analytics

By Cristian

Who this is for: EU school leaders who want the benefits of classroom analytics while staying well inside the boundaries of the EU AI Act.

What the EU AI Act means for schools (in plain language)

The EU AI Act is a risk-based law. Some AI uses are banned (unacceptable risk). Others are high-risk and come with strict duties. Most day-to-day tools are limited/minimal risk and only need light measures (mainly transparency and good practice). The Act entered into force 1 Aug 2024; the first binding obligations (including bans) start 2 Feb 2025 and other layers follow later. (Artificial Intelligence Act EU)

Your goal with CLMP (Classroom Learning Monitoring Platform) is simple: get visibility, not surveillance—and avoid any use that would be banned or “high-risk.”

CLMP logo with a magnifying glass highlighting the words “TERMS AND CONDITIONS” on a document—symbolizing compliance and policy review.

What’s banned outright (Article 5) — and how CLMP avoids it

Under Article 5, schools and vendors must not use AI to:

  • Infer emotions in schools (e.g., reading feelings from faces/voices),
  • Scrape facial images from the internet/CCTV to build biometric databases,
  • Social-score people or use manipulative/exploitative techniques. (Artificial Intelligence Act EU)

CLMP fit: Use CLMP with no cameras/mics and no emotion inference. Stick to teacher-logged events and student self-reports (polls). That keeps you out of prohibited territory. (If any optional module tries to do emotion detection or biometric ID, do not enable it.) (Artificial Intelligence Act EU)

Keep CLMP out of high-risk (Annex III for education)

Annex III treats some education uses as high-risk, which would trigger heavy duties (risk management system, documentation, oversight, possible conformity tasks). Avoid these four triggers:

  1. Admissions / access decisions (who gets in).
  2. Grading / evaluating learning outcomes (AI scores work/exams).
  3. Level/placement decisions (tracking, streaming).
  4. Test proctoring (AI monitoring for cheating). (Artificial Intelligence Act EU)

CLMP fit: Use CLMP strictly as decision-support for teachers (visibility and early support). Do not use it to admit, grade, place, or proctor. That keeps it in limited/minimal risk territory, with lighter obligations. (Artificial Intelligence Act EU)

A practical 7-step adoption plan (you can copy)

1) Define the purpose in writing. State: “We use CLMP to improve classroom visibility and early support. We do not use it for admissions, grading, placement, or exam proctoring.” This single sentence keeps you out of high-risk. (Artificial Intelligence Act EU)

2) Do a DPIA-lite (privacy check). Map data (class lists, teacher-logged events, student self-reports). Confirm no biometrics. Sign/update your DPA with the vendor. Note data minimisation and retention. (The AI Act complements GDPR; keep both in mind.) (EUR-Lex)

3) Check for prohibited features. Verify there is no emotion inference and no biometric scraping/ID. If the vendor offers optional webcam analytics, keep them disabled. Record this decision. (Artificial Intelligence Act EU)

4) Classify risk internally. Document that CLMP is not used for Annex III education decisions; therefore, you treat it as limited/minimal risk with basic transparency and oversight. Keep a short entry in your internal AI register. (Artificial Intelligence Act EU)

5) Train staff on “AI literacy.” The AI Act expects providers/deployers to ensure a sufficient level of AI literacy for people operating/using AI. Give teachers a short briefing: what CLMP does, what it doesn’t do, and how to interpret alerts with professional judgment. Keep a record of the session. (Artificial Intelligence Act EU)

6) Run a 14-day pilot with guardrails.

  • Scope: 1–2 classes, low-stakes use only.
  • Baseline: gather a week of normal activity.
  • Check-ins: quick coaching for teachers mid-pilot.
  • Decision pack: summarise benefits (visibility, quieter students surfaced, time saved), confirm no banned/high-risk use occurred, and list any tweaks. This aligns with the staged timeline and shows due diligence early (as bans and literacy start applying from Feb 2025). (Artificial Intelligence Act EU)

7) Close the loop with policy + logs. Add one page to your IT/AI policy: scope, prohibited uses, contacts for concerns, review cadence (e.g., annual). Keep simple usage notes (e.g., issues, false positives) to show oversight. The AI Act stresses human control and traceability—good practice even for low-risk tools. (Digital Strategy)

Ready-to-use procurement lines (paste into your RFP/contract)

  • “The solution must not use AI to infer emotions in education settings, nor conduct any biometric identification or scraping.” (AI Act, Article 5.) (Artificial Intelligence Act EU)
  • “The solution will not be used for admissions, grading, placement, or exam proctoring (Annex III education triggers).” (Artificial Intelligence Act EU)
  • “Provider will support AI literacy for staff with short, role-appropriate materials.” (Article 4.) (Artificial Intelligence Act EU)

Quick FAQ for SLT & DPOs

Does “mood” tracking break the rules? Not if it’s self-reported by students or teacher-logged (observations). What’s banned is AI inferring emotions from biometrics (faces, voices). Keep it manual; don’t enable automated emotion detection. (Artificial Intelligence Act EU)

Do we need a full conformity assessment? No—if you keep CLMP out of the four Annex III triggers. Use it as a teacher aid, not a decision engine. (Artificial Intelligence Act EU)

When do we need to act? Bans and AI-literacy expectations start 2 Feb 2025; more layers phase in afterwards. Start with the pilot + policy now. (Goodwin Law)

Bottom line

Use CLMP for insight, not surveillance. Avoid banned features, keep away from high-risk use cases, train your staff, and document a short pilot. You’ll gain classroom clarity and stay aligned with the EU AI Act.

Sources (official & reputable)

  1. EU AI Act – Official text (EUR-Lex): Regulation (EU) 2024/1689. Key basis for all rules and definitions. https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng (EUR-Lex)

  2. Article 5 (Prohibited practices): Plain-English summary (emotion inference in schools; biometric scraping; manipulation/social scoring). https://artificialintelligenceact.eu/article/5/ (Artificial Intelligence Act EU)

  3. Annex III (Education high-risk use cases): Admissions/access, grading, placement, exam proctoring. https://artificialintelligenceact.eu/annex/3/ (Artificial Intelligence Act EU)

  4. Article 4 (AI literacy duty for providers/deployers): https://artificialintelligenceact.eu/article/4/ and Commission FAQ on AI literacy: https://digital-strategy.ec.europa.eu/en/faqs/ai-literacy-questions-answers (Artificial Intelligence Act EU)

  5. Implementation timeline (entry into force and phased dates, incl. bans effective from Feb 2025): https://artificialintelligenceact.eu/implementation-timeline/ and Goodwin summary: https://www.goodwinlaw.com/en/insights/publications/2024/10/insights-technology-aiml-eu-ai-act-implementation-timeline (Artificial Intelligence Act EU)

  6. Commission overview of the AI Act (context, risk-based approach): https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai (Digital Strategy)

Note: The Article 5 prohibitions apply from 2 Feb 2025, and further obligations phase in afterward. Staying out of Annex III use keeps CLMP in low-risk territory with light duties. (Goodwin Law)