GDPR and AI Act: what it means for today's apps

GDPR

  • The school is the controller; Dify and the model provider are processors, outside the EU
  • No data processing agreement (sandbox) = no personal data goes in
  • Personal data after all: a student's message to the teacher (Study coach). Then: legal basis, impact assessment, retention period for the logs

EU AI Act

  • Art. 4: AI literacy mandatory for whoever uses AI (since Feb 2025). This workshop is such a measure
  • Prohibited: emotion recognition in education
  • High risk: admission, assessing learning outcomes, proctoring. Our apps decide nothing about people; a coach that assesses students would
  • Art. 50: a chatbot says it is AI

Rule of thumb: as soon as an app decides or records something about a person, the question changes from "does it work?" to "is it allowed, and who is responsible?" State of play September 2026; check your national assessment framework for the current picture.

Workshop AI Agents with Dify · LeX Consultancy · CC BY-SA 4.0

LeX Consultancy