Privacy impact assessment
From 1 January 2027, institutions subject to Ontario’s Municipal Freedom of Information and Protection of Privacy Act are required to carry out a privacy impact assessment before collecting personal information. Boards in other provinces have their own assessment requirements. The material below applies to either.
The board completes the assessment as the institution collecting personal information. Litly provides the technical and operational information about the service.
Available assessment material#
The following material is available as a single package:
- The technical schedule. What Litly holds, where it is, who touches it, how long it stays and how it is destroyed.
- The sub-processor list, with AWS documentation on model training and data retention.
- The access-control model describing who can access student records.
- The retention and deletion design, including exactly what survives a deletion request.
- The safeguarding design, including collection, disclosure, escalation and retention.
- The current accessibility assessment.
Assessment considerations#
The board determines the following within its own legal, policy and risk framework:
- Cross-border processing. Stored records never leave Canada; AI inference may be processed in the United States and therefore falls within US jurisdiction. MFIPPA does not impose a residency requirement; some other provinces do. See data residency. An all-Canada configuration is available.
- Safeguarding disclosure. Litly reads student writing for signs of risk, and relevant writing may be disclosed to authorized school staff. The assessment should document this collection, use and disclosure.
- Retention periods. The board sets its retention periods. Until a safeguarding period is set, those records are retained indefinitely.
- The AI’s role in assessment. The writing coach supports drafting but does not grade. A teacher writes the assessment. Litly does not make automated grading decisions.
Contact#
privacy@litly.ai. Include the board’s assessment template to request completed technical sections.