School documents · Pack 2026-08-29

AI processing notice

When staff text is sent to Google Gemini, and how to keep it proportionate.

Who it is for: DPOs, SENCOs, curriculum leads
How to access it: Public. Disable AI planner and do not use SEND generate actions if the school cannot accept this sub-processor.

This pack describes how Five Wells Education designs and operates the platform so schools can complete their own due diligence. It is not legal advice. The school remains the data controller for pupil and staff data it places in the product. A solicitor or DPO should review processing before go-live.

AI is optional and staff-initiated

Five Wells does not continuously train a model on your live database. Staff generate actions run when a signed-in staff member asks for a draft (lesson plan, worksheet, EHCP extract, IEP goals, successor goal, or group plan). If the school enables the pupil Well helper, a pupil (or staff preview) can send a short, labelled question. Distress wording never reaches Gemini — the app returns a fixed “tell a trusted adult” message.

What leaves the school tenant

The prompt constructed by the product, which can include pupil first name, year group, goal text, and EHCP excerpts the staff member supplied or uploaded.
PDF EHCP uploads may be sent to Gemini as a document for extraction (size-capped).
Google returns a draft. Staff must review it before it is relied on in an IEP or lesson.

What is not sent

The whole school database is not dumped to the model.
Safeguarding case-management systems are not connected.
The pupil Well helper is not a consumer chatbot account. It is optional, school-flagged, rate-limited, and labelled as a computer helper. Prompts are not stored as a pupil chat history.

School controls

AI lesson planner is a per-school flag (platform operator).
The pupil Well helper is a separate school-admin Security toggle (off by default).
SEND Tracker generate actions only exist if SEND Tracker is enabled for the school.
Staff should paste the minimum EHCP text needed (typically Section F/G), not historic appendices.

Vendor terms

Processing follows Google’s Gemini API terms in force at the time of the request. Five Wells does not claim that Google will never change those terms. If the school’s DPO requires “no pupil data outside the UK”, do not enable these features.

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