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Data Protection Impact Assessment

ChildSafe AI — Compliance Assessment Platform

Controller: Privacomply Ltd DPO: David Anderson, CIPP/E, CIPM (Data Protection Officer) Version 2.1 · August 2026 Review: August 2027 ✅ APPROVED — pending ICO Sandbox review

This DPIA was prepared in accordance with ICO DPIA guidance (2018, updated 2024) and UK GDPR Article 35. It will be reviewed annually or upon any material change to the processing.


STEP 1 Need for DPIA

Does this processing require a DPIA?

ChildSafe AI processes documents submitted by users. Those documents may contain descriptions of data practices affecting children. The ICO's list of processing operations likely to result in high risk (Article 35(3) UK GDPR) is assessed below:

CriterionApplicable?Notes
Systematic and extensive evaluation / profilingNoDocuments are assessed, not individuals
Processing of special category data at scalePossibleSubmitted documents may describe processing of children's data, but ChildSafe AI does not itself process children's data directly
Systematic monitoring of publicly accessible areasNoN/A
Novel technologyYesAI/LLM used for compliance assessment — novel application
Prevents access to service / contractNoN/A
Processes children's dataIndirectDocuments assessed may relate to children's data practices

Decision: DPIA required — novel AI technology; potential for documents containing personal data; indirect processing of information about children's data environments.


STEP 2 Describe the Processing

2.1 What is ChildSafe AI?

ChildSafe AI is a web-based SaaS compliance assessment tool that enables organisations to upload policy documents (privacy notices, product specifications, terms of service, compliance reports) and receive an AI-generated assessment of compliance with:

The tool generates: a compliance score (0–100), framework-by-framework findings, a DPIA document, a prioritised remediation roadmap, and a compliance certificate (requiring human expert sign-off).

2.2 Data Flows

USER BROWSER │ ├── Document text (pasted or uploaded) → stored in memory only (state object) │ ⚠️ NEVER written to disk, cookie, localStorage or database │ ├── Document name → stored in browser localStorage (History feature) │ ⚠️ Name only — no document content stored in localStorage │ ├── Anonymised audit log → browser localStorage (childsafe_audit_log) │ Timestamp, framework IDs, document type, risk band — NO content │ ├── [IF SIGNED IN] Google Sign-In → 🇬🇧 FIREBASE AUTHENTICATION │ ├── Email address + Firebase UID stored │ ├── Region: europe-west2 (London, UK) ← DATA NEVER LEAVES UK │ └── Governed by Google Cloud DPA (UK sovereignty maintained) │ ├── [IF SIGNED IN] Compliance report results → 🇬🇧 GOOGLE CLOUD FIRESTORE │ ├── Scores, findings, framework breakdowns — NO document content │ ├── Region: europe-west2 (London, UK) ← DATA NEVER LEAVES UK │ └── Governed by Google Cloud DPA (UK sovereignty maintained) │ ├── [IF SAVED TO MY LIBRARY] Document content → 🇬🇧 GOOGLE CLOUD FIRESTORE │ ├── Full document content stored per user UID │ ├── Region: europe-west2 (London, UK) ← DATA NEVER LEAVES UK │ └── User can delete at any time from My Documents tab │ └── HTTPS POST → NETLIFY FUNCTION (/.netlify/functions/gemini) │ First 4,000 chars of document + AI prompt + model config │ Encrypted in transit (TLS 1.3) │ ⚠️ Netlify access logs: IP address, timestamp, request size (30 days) │ └── HTTPS POST → 🇬🇧 PRIVACOMPLY / GOOGLE CLOUD VERTEX AI Region: europe-west2 (London, UK) ← DATA NEVER LEAVES UK Structured prompt with document content — processed in UK only Governed by Google Cloud DPA (SCCs not required — UK processing)

🇬🇧 UK Data Sovereignty Statement: All personal data processed by ChildSafe AI — including user accounts, saved reports, and AI inference — is stored and processed exclusively within the United Kingdom (London, europe-west2). No personal data crosses UK borders at any point in the processing chain. This is enforced at the infrastructure level through Google Cloud region locking, not merely stated as policy.

2.3 Personal Data Involved

Data ElementSourceLegal BasisLocationRetention
Document content submitted by userUserLegitimate interests (Art. 6(1)(f))Memory only — never persistedSession only — zero server retention
Document nameUserLegitimate interestsBrowser localStorageUser-controlled
IP address / request metadataAutomatic (Netlify)Legitimate interestsNetlify logs30 days (Netlify standard)
Anonymised audit log entriesGeneratedLegitimate interestsBrowser localStorageMax 50 entries FIFO — localStorage only
Email address [if signed in]User (Google Sign-In)Contract (Art. 6(1)(b))🇬🇧 Firebase Auth, London UK (europe-west2)Until account deleted
Firebase UID [if signed in]Generated by FirebaseContract (Art. 6(1)(b))🇬🇧 Firebase Auth, London UK (europe-west2)Until account deleted
Saved compliance reports [if signed in]Generated (no document content)Contract (Art. 6(1)(b))🇬🇧 Firestore, London UK (europe-west2)Until report or account deleted
Documents saved to My Library [if signed in]User (explicitly saved)Contract (Art. 6(1)(b))🇬🇧 Firestore, London UK (europe-west2)Until document or account deleted

2.4 Processors

ProcessorLocationRoleSafeguard
Google Cloud / Firebase Authentication🇬🇧 London, UK (europe-west2)User accounts — Google Sign-In, authenticationUK-region enforced at infrastructure level. Google Cloud DPA. No international transfer.
Google Cloud / Firestore🇬🇧 London, UK (europe-west2)Cloud database — compliance report persistenceUK-region database. Google Cloud DPA. Data never leaves UK. Firestore security rules restrict access to authenticated user only.
Google Gemini API🇬🇧 London, UK (europe-west2)AI inference — compliance analysis of submitted document content (not stored post-analysis)Document content processed in-session only; not retained after response. Google AI API Terms apply. UK GDPR Data Processing Addendum in place.
Netlify Inc.UK/EU CDN edgeHosting, serverless function proxyTransit only — no content storage. Netlify DPA.

🇬🇧 UK Data Sovereignty — Infrastructure Statement: All three Google Cloud services used by ChildSafe AI (Vertex AI, Firebase Auth, Firestore) are configured to the europe-west2 (London) region. This is enforced at infrastructure level, not policy level. No personal data — including user accounts, compliance reports, or document content — leaves the United Kingdom at any point.

2.5 Special Category Data

Submitted documents are not themselves special category data. Documents may describe the processing of special category data. ChildSafe AI does not extract, store or further process any special category data found within submitted documents.


STEP 3 Consultation

StakeholderConsultedNotes
DPO / AssessorDavid Anderson, CIPP/E, CIPM (Data Protection Officer)Independent Data Protection Officer
ICO Regulatory SandboxPendingApplication in progress
End users (pilot)InformalPre-launch pilot feedback incorporated
ProcessorsNetlify, GoogleStandard vendor DPAs reviewed

⏳ Peer review pending: A second IAPP-certified privacy professional has been invited to review 5 sample outputs and countersign this DPIA before ICO submission.


STEP 4 Necessity and Proportionality

QuestionAssessment
Could the purpose be achieved without AI processing?No — manual assessment requires a qualified lawyer at prohibitive cost for SMEs
Is document content the minimum needed?Yes — only first 4,000 characters are transmitted for AI processing; document content submitted for analysis is never stored server-side. Documents the user explicitly saves to My Library are retained in Firestore (London, UK) under the user’s full control
Is account/report data retention proportionate?Yes — compliance reports store scores and findings only (no submitted document content). My Library documents are stored only when the user explicitly saves them; user retains full control with self-service deletion of both reports and documents; all data remains in UK
Is the AI model appropriate?Yes — Google Gemini with structured prompting and temperature=0 for deterministic outputs
Is the cloud storage location appropriate?Yes — Firestore and Firebase Auth both configured to europe-west2 (London, UK); UK data sovereignty is maintained at infrastructure level

Lawful Basis

Article 6(1)(f) UK GDPR — Legitimate Interests applies to document analysis processing. Article 6(1)(b) — Contract applies to account creation and report storage (processing is necessary to deliver the account-based service the user has signed up for). Balancing test for legitimate interests: purpose is clear and beneficial; minimum data is used; document content is a business document, not personal correspondence; document content submitted for analysis is never stored server-side. Documents explicitly saved to My Library by the user are stored under Art. 6(1)(b) with the user’s full knowledge and control, restricted by Firestore security rules to the authenticated owner only.


STEP 5 Identify and Assess Risks

RiskLikelihoodSeverityOverall
R1 Document contains personal data inadvertentlyMediumMediumMedium
R2 AI processing via UK London endpoint — no international transferLowLowLow
R3 AI generates incorrect compliance adviceMediumHighHigh
R4 Netlify access logs expose user IP addressesLowLowLow
R5 localStorage accessed on shared deviceLowMediumMedium
R6 Firestore account/report data breach or unauthorised accessLowMediumMedium
R7 UK data sovereignty compromised via infrastructure misconfigurationVery LowHighLow-Medium
R8 Documents saved to My Library contain sensitive business dataLowMediumMedium

STEP 6 Measures to Reduce Risk

RiskMitigationStatus
R1Warning advising users not to include personal data in submitted documents; document content submitted for analysis is session-only and never stored server-side; My Library document storage is clearly disclosed in the privacy notice and restricted to the authenticated owner by Firestore security rules✅ Implemented
R2All Google Cloud services (Vertex AI, Firebase Auth, Firestore) locked to europe-west2 (London, UK); UK sovereignty enforced at infrastructure level✅ Implemented
R3"Not legal advice" disclaimer on all outputs; HITL certification requirement; temperature=0; criteria reviewed by CIPP/E CIPM✅ Implemented
R4HTTPS enforced; no additional logging beyond Netlify defaults✅ Implemented
R5Browser localStorage data disclosed in privacy notice; users advised to use private browsing on shared devices✅ Documented
R6Firestore security rules restrict read/write to authenticated owner UID only; Google Cloud DPA in place; reports contain no document content; user can delete at any time✅ Implemented
R7All three Google Cloud services explicitly region-locked to europe-west2 (London) in Firebase project configuration; Google Cloud DPA confirms UK processing; no cross-border transfer mechanism needed or triggered✅ Implemented — verified at project level
R8My Library documents stored in Firestore restricted by security rules to authenticated owner UID only; users can delete documents at any time; privacy notice clearly discloses My Library storage; users advised not to save documents containing personal data✅ Implemented

Residual Risk

RiskResidual LevelAcceptable?
R1LowYes
R2LowYes — UK sovereignty enforced at infrastructure level
R3MediumYes — mitigated by HITL and disclaimers
R4LowYes
R5LowYes
R6LowYes — Firestore rules + user-controlled deletion
R7LowYes — region lock verified at project configuration level
R8LowYes — Firestore rules + user-controlled deletion + clear disclosure

Overall residual risk: MEDIUM — ACCEPTABLE. Mitigations are proportionate and in place.


STEP 7 Sign-off and Record Outcomes

This DPIA concludes that ChildSafe AI can proceed with the described processing. Residual risks are acceptable given the mitigations in place. The processing is necessary, proportionate, and serves a legitimate public benefit in supporting compliance with children's data protection law.

⏳ Outstanding Actions Before ICO Submission

DPO Sign-off

NameDavid Anderson, CIPP/E, CIPM (Data Protection Officer)
QualificationsIAPP CIPP/E, IAPP CIPM
DateAugust 2026
Signature

ChildSafe AI DPIA v2.1 · August 2026 · Privacomply Ltd · David Anderson, CIPP/E, CIPM (Data Protection Officer) · Review date: August 2027 · Material change: My Library document storage added; Google Gemini API processor reference updated