Privacy Protection and Law 25 Compliance

Scolaro is a platform designed specifically for the Quebec educational environment. We have built our service to comply with the applicable requirements of Law 25 (Act modernizing legislative provisions as regards the protection of personal information) as well as the principal Quebec and Canadian privacy laws.

Scolaro never replaces the teacher: AI serves as a pedagogical support tool. Final decisions remain in human hands.

1. Our Commitment

• Protect the personal information of students, teachers, and administrators.
• Use only data necessary for the pedagogical functioning of the platform.
• Be transparent about the use of AI and the technological providers we use (e.g., Google/Firebase, OpenAI).
• Offer simple mechanisms to access, correct, export, or delete data.
• Collaborate with schools and school service centres to meet their legal obligations.

2. Roles of Scolaro and Educational Establishments

• The educational establishment (school, school service centre, private school board) remains responsible for students' academic records and the choice of digital tools used in class.
• Scolaro acts as a service provider ("subcontractor") and processes personal information only to provide the agreed pedagogical features (test generation, AI-assisted grading, progress tracking, etc.).
• A written agreement can be established with each establishment to specify confidentiality, security, and data retention obligations.

3. How We Apply Law 25

3.1 Data Minimization and Purpose

• We collect only necessary information: for example, name, email, and role (teacher/student), classes, results, and submitted assignments.
• Data is used only to:
  • provide the Scolaro platform;
  • generate, grade, and analyze evaluations;
  • improve service quality (aggregated and anonymized usage statistics where possible).
• We do not resell data and we do not use it for advertising purposes.

3.2 Consent and Minor Students

• For students under 14 years of age, the use of Scolaro must be authorized by a parent/guardian or by the educational establishment in accordance with Law 25.
• Scolaro provides letter/notice templates to help schools inform parents and obtain necessary consents.
• When creating an account, a clear notice explains what data is collected, for what purposes, and with which providers it may be shared.

3.3 Hosting, Security, and Restricted Access

• Data is hosted on a secure infrastructure (Google Cloud / Firebase), with encryption in transit (HTTPS/TLS) and encryption at rest.
• Access to data is restricted by role:
  • students see only their own assignments and results;
  • teachers see only their own groups and students;
  • administrators have limited access, strictly necessary for support and maintenance.
• Access logs and technical controls are in place to limit and trace access to personal information.

3.4 Data Retention and Deletion

• Data is retained for a limited and reasonable duration, based on pedagogical needs and the establishment's administrative obligations.
• Upon request from the establishment, teacher, or user (when allowed by law), we can:
  • delete an account;
  • delete or anonymize certain datasets;
  • provide a copy of data in a structured format.

3.5 Data Transfer Outside Quebec and AI Providers

• Certain features (e.g., AI-assisted grading) may require sending content to technological providers, notably OpenAI.
• We limit these transmissions to the strict minimum (e.g., anonymized response text, without student name or direct identifier) and use encrypted connections.
• Before any data transfer outside Quebec, Scolaro performs a privacy impact assessment and implements the contractual and technical guarantees required by Law 25.
• Whenever possible, we disable the use of data by these providers for the purposes of general model training or improvement.

4. Use of AI and Automated Decisions

4.1 Role of AI in Scolaro

AI can:

• suggest exam questions;
• propose feedback on student responses;
• assign an initial suggested grade according to a rubric;
• help identify recurring difficulties within a group.

These features are decision aids: they do not replace the professional judgment of the teacher.

4.2 Transparency and the Right to Human Review

• When a result or feedback comes from automated processing, this is indicated to the teacher, and may be indicated to the student depending on configuration.
• Teachers can modify, validate, or reject AI suggestions at any time.
• In accordance with Law 25, any person subject to a decision based exclusively on automated processing has the right to:
  • be informed of this situation;
  • request explanations on the factors that led to this decision (to the extent possible);
  • request a review by a human being.
• Scolaro allows and encourages this human review by always leaving final control with the teacher and the establishment.

5. Your Rights

In accordance with Quebec and Canadian personal information protection laws, users (and parents of minor students) notably have the following rights:

• right to information (knowing what data is collected and why);
• right of access to their personal information;
• right to rectification in case of error or incompleteness;
• right to portability of certain data, where applicable;
• right to withdraw their consent to the extent permitted by law and the establishment's obligations;
• right to file a complaint with the establishment, Scolaro, and if necessary, the Commission d'accès à l'information du Québec.

To exercise your rights, you can communicate with Scolaro's Privacy Officer:

6. Important Notice

We designed Scolaro to comply with the applicable requirements of Law 25 and major Quebec and Canadian personal information protection laws in the school context.

However:

• each establishment remains responsible for its use of the platform and its own legal obligations;
• this text is an informative summary and does not replace legal advice;
• Scolaro continually adapts its practices to follow evolving laws, guidelines from the Commission d'accès à l'information du Québec, and privacy protection best practices.

For any specific legal question, we recommend our school partners consult their legal department or a advisor specialized in personal information protection.

For more information on Law 25 and your rights, visit the Commission d'accès à l'information du Québec (CAI) website.