A head of year at a secondary school gets two questions within an hour one Wednesday. A teacher of Dutch wants to know whether her class can practise writing an argumentative essay with a chatbot. A colleague in the office asks whether he can have Copilot rewrite a letter to parents. The school's AI protocol is about cheating in assessments and says nothing about either.
An AI policy for a school answers two kinds of question, and they are not the ones a company faces. For staff: which tools can you use, on which account and which pupil data never goes in? For pupils: what can you do with AI on an assignment, how do you show it and what happens if you do not? Two strands, joined at one point: the teacher who explains the rules in class also uses AI and faces the same questions.
Why two strands rather than one?
Because the risks differ. For a pupil the question is about learning and assessment: what still counts as their own work, and what anyone learns when the chatbot writes the essay. That is a question of teaching and examinations, and schools have their own instruments for it. For staff the question is about data: a report comment, a pupil support note, the notes from a parents' meeting. That is data about minors, often about health or home circumstances, and it turns up in precisely the texts someone wants rewritten at the end of a long working day.
A single document that tries to cover both usually turns into a cheating protocol with a paragraph on privacy attached. The teacher finishing a letter at four o'clock finds no answer in it.
What do you agree on with staff?
The same questions as in any AI policy, answered for a school.
| Question | What a usable answer looks like for a school |
|---|---|
| Which tools are allowed? | A list of names, each with its account: Copilot on the school account yes, ChatGPT on a personal account no |
| Which data never goes in? | A pupil's name and class combined with a concern, a diagnosis, a home situation or a grade; a citizen service number in any case |
| What is fine? | Lesson materials, rewriting an assignment, a letter to parents without names, feedback on an anonymised essay |
| What do you do with a tool that has no decision? | Public information only, and here is where you report it |
| Who assesses a new tool? | A role and a deadline, with the data protection officer involved whenever pupil data goes in |
| How do you hear about a change? | Not just in the newsletter; the decision appears where the tool is opened |
Two points are specific to education. First, the data processing agreement: Dutch schools sign processing agreements under the Privacyconvenant, the education sector's privacy agreement with suppliers, and a free AI account has none. A tool without a processing agreement can be on the list, but only for use without pupil data. Second, the account: a teacher who logs in at home on a personal account falls outside every agreement the school has with a vendor. That is not bad faith; the school laptop was simply already shut. The policy has to deal with it, and "use the school account, at home too" works better than a ban. In education, the difference between a free and a business account is the difference between having an agreement and not having one.
What do you agree on with pupils?
Here the policy answers different questions: is AI allowed on this assignment, to what extent and how do you show what you did? Kennisnet, the Dutch public organisation for ICT in education, advises schools to set clear rules on how pupils and staff use generative AI, and for assessment there are frameworks that set a level for each assignment, from no AI to writing together with AI.
What is usually missing is the data side. A pupil who asks a chatbot for feedback on a personal story sometimes shares more than they realise: a name, a school, something from home. Pupils are minors, and the terms of most free tools were not written for them. So the rules for pupils also say which tool the school has set up for use in class, and what you do not put into a chatbot about yourself or your classmates.
Where do the two strands meet?
At the teacher. The teacher explains the rules in class, judges whether a pupil has kept to them and uses AI to prepare lessons. A school where staff can use any tool and pupils none cannot keep that up. A school with clear-cut rules on data for staff and clear rules on assignments for pupils can stand in front of a class with one consistent story.
There is a second meeting point: the tools themselves. A learning tool the school has used for years gains an AI feature, which then affects pupils and teachers alike. That belongs in the AI register, not in the cheating protocol.
What does the school not need to do?
More than you might think. The school does not have to predict every tool; a status of "No decision yet" with an instruction attached covers the tools you do not know about yet. The school does not have to write its own risk assessment of every model; the question is which data goes in and under which agreement, not how the model works. And the school does not have to obtain a certificate in AI literacy. Article 4 of the AI Act requires organisations that use AI systems to take measures towards a sufficient level of AI literacy among their staff, and what is sufficient varies by role. How to meet that without a compulsory course is explained in our overview of AI literacy in 2026.
What the school does have to show is that it decided something about each tool, with a date and a reason, and that staff knew about it. The accountability principle in the GDPR does not ask for a thick document. It asks for a decision you can find again.
How does the decision reach the teacher?
A board with seven schools decides that Copilot on the school account is allowed, and ChatGPT only without pupil data. Six months later, an inventory finds Gamma, MagicSchool, a transcription tool for parents' meetings and two lesson materials tools in use across the schools as well. Three of them are not recorded anywhere. Nobody did anything wrong; nothing had been decided about those tools. But it does show that six months on, a policy set once a year covers different tools from the ones actually in use.
The decision works when it appears where the tool is opened, not just in the document on SharePoint. BeeSensible records the board's decision on each AI tool and shows it when someone opens that tool in the browser, with the approved alternative as the first button. The extension does not block anything on its own initiative: whether someone can carry on to a tool that is not allowed after seeing the notice is a setting the board chooses. No user ID is recorded. This is what the overview looks like, with each tool next to its status:
