ⒾMachine translations by Deepl
The digital learner
Now that the summer holidays are over, many schools have been preparing for a new school year. Once again this year, digital learning resources will play a central role in this – from digital teaching methods and adaptive exercise programmes to online collaboration platforms. Technology offers pupils and teachers undeniable benefits. At the same time, concerns about pupils’ privacy are growing. Recent indications from both the Dutch Data Protection Authority (AP) and Privacy First show that these concerns are not unfounded.
However, the debate on digital learning resources is still too often presented as a choice between innovation and privacy. That is a false dichotomy. Good education and effective privacy protection should go hand in hand.
Pupils are not a data source
Earlier this year, the AP once again warned of the privacy risks posed by digital learning resources in the classroom.[1] Schools process large amounts of pupils’ personal data, ranging from names and contact details to academic performance, behavioural data and, in some cases, even data that provides insight into a child’s development. When this data is collected, combined or used for purposes other than those necessary for educational purposes, serious risks arise.
This is particularly problematic because pupils are a vulnerable group. Unlike adults, they often have little understanding of the scale and consequences of data processing. Furthermore, they cannot simply decide not to use a digital learning resource when it forms part of the curriculum.
More than just a legal obligation
The debate is often framed in terms of the GDPR and contractual agreements between schools and suppliers. Whilst this is important, it is not enough. Ultimately, it comes down to a broader societal question: what sort of digital environment do we want to create for children?
Privacy protection should not be viewed as an administrative hurdle that must be overcome before an application can be deployed. It should be a fundamental design principle.[2] Anyone who develops technology for children has a responsibility to minimise data processing as much as possible, to be transparent, and never to prioritise commercial interests over the interests of pupils.
The responsibility does not lie solely with schools
Schools are expected to take a critical look at the digital resources they use. In practice, however, many educational institutions lack the expertise, capacity or bargaining power to effectively scrutinise large technology companies and software suppliers.
Responsibility should therefore not rest solely with schools. Suppliers must be able to demonstrate that privacy protection has been incorporated into the design from the outset. In addition, the government and regulators have an important role to play in setting clear standards and enforcing them where necessary.
In a recent letter to the House of Representatives, the State Secretary for Education, Culture and Science acknowledges the need to draw up a coordination plan regarding digitalisation and AI in primary and secondary education.[3] The government, schools and public sector partners are working together on this plan to regain control over digitalisation in education. The guiding principle is that technology should support high-quality education and that public values should be protected. The joint management plan is expected in the autumn of 2026.
The introduction of new European legislation, such as the AI Regulation (AI Act), only serves to make this debate all the more relevant. When digital learning resources use AI to analyse learning performance, profile pupils or make personalised recommendations, the importance of transparency and oversight increases further.
Digital literacy starts with privacy
Schools are, quite rightly, paying increasing attention to digital literacy. The focus is often on media literacy, online safety and recognising disinformation. Privacy deserves a prominent place within this education.
Pupils must not only learn how to use digital tools, but also understand what data is collected, why this is done and what rights they have. Precisely because digital technology is playing an ever-greater role in their daily lives, knowledge of privacy has become an essential skill. Digital literacy helps pupils become critical and informed adults who can avoid the pitfalls of a digital society and make the most of its opportunities.
From discussion to action
The concerns highlighted by the AP and Privacy First are no reason to slow down digital innovation in education. On the contrary, they are a call to shape innovation in a responsible manner.
This calls for greater transparency from suppliers, more support for schools, stricter scrutiny of digital learning resources and a stronger position for pupils and parents. Ultimately, the guiding principle must be simple: digital technology should support the learning process, but must never be at the expense of children’s fundamental rights.
Because good education is not just about what pupils learn. It is also about the society in which we raise them. And in that society, privacy should not be a luxury, but a fundamental right.
[1] Data Protection Authority, Privacy risks for pupils arising from digital learning resources in the classroom, 30 March 2026.
[2] The Code on the Rights of the Child consists of ten principles, accompanied by practical examples, to help designers and developers safeguard children’s fundamental rights in digital services.
[3] Letter from the State Secretary for Education, Culture and Science Digital learning resources | House of Representatives of the States General.
