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P1-S6 School planning: staff data-handling guide — what may and may not be put into an AI tool

  • StageP1-S6
  • SubjectSchool planning
  • Learning strandreflection on the application of AI
  • Official documentsGuide to Using AI in Teaching in Primary and Secondary Schools · AI Literacy Learning Framework for Primary and Secondary Schools (Examples of Application Scenarios) · Music Curriculum Guide (Primary 1 - Secondary 6)
  • Session time45-60 minutes (fits inside one staff meeting)

Turns what may and may not be put into an AI tool into a seven-item negative list a school can check line by line, with the compliance requirements, the content that is safe to enter and how to anonymise it, and four school procedures left for the school to fill in.

Two simple faceless colleagues standing side by side in a plain bright office beside a pale filing cabinet, one holding a red folder and the other a blue folder.
  • EquipmentEditable Word guide; projector or print; the school-procedure fields are best filled in with the colleague responsible for personal data
  • Version1.2
  • Last updated2026-10-16

One line to remember: a pupil’s name, a pupil’s number, and any piece of work or record that identifies which pupil it is, never go into an AI tool. Everything else goes in only after the identifying parts have been removed.

What this solves

Teachers now paste text into an AI tool all day: to draft a set of practice questions, to rewrite an explanation, to turn a record into a report. The accident is rarely the tool. It is the paragraph that went in. A pupil’s name, a pupil’s number, a mark, a parent’s contact details, a recording, a photograph — once any of it has left the school’s own systems, that is already a personal data breach, and uploading someone else’s article, music or video is already a copyright problem.

Nothing about this gives a warning. The tool is working, the teacher was not careless, and the school has simply never had one page that says what may be entered, what may not, and what has to happen first. This is not a preference: it sits inside the digital education part of a School Development Plan and applies to the teaching and learning of every subject.

This guide is that page: seven things that must never go in, the content that is safe to enter and how to anonymise it, four school procedures left blank for the school to fill in, and a one-page printable staff summary at the end that can be copied for the staff room, the photocopier or the computer room.

Purpose

Scope. This guide applies to every member of staff — teachers, teaching assistants, administrative colleagues, library and IT colleagues — and to anyone who uses an AI tool for school work or pupil data, including student teachers and supply teachers. It is to be applied together with the school’s own AI-use policy and its personal data rules: this guide says what may be entered; those two school documents say who approves it and who is responsible.

By the end of this guide, a school will be able to:

  1. Read the seven-item negative list out at a staff meeting, item by item, and name the one staff are most likely to touch in their own daily work.
  2. Say what is safe to enter, and what has to be done to it first.
  3. Put an owner and a review cycle against each of the four school procedures (the approved-tool list, the approval route and its owner, incident handling and reporting, and the review cycle for tools’ default privacy settings).
  4. Tell a colleague which part of a pupil’s work has to come out before it is uploaded.

The guide is built on the reflection on the application of AI strand of AI literacy and on the values of technology for good, critical discernment, human-AI collaboration and timely and appropriate use: handling data well is how a school shows that judgement, not convenience, decides what an AI tool is given.

How to use it

The file is one editable Word guide in four parts — scope, what may not be entered (the seven-item negative list), what may be entered and how to handle it, and the school procedures — with a one-page printable staff summary at the end. Work through it in one staff meeting, led by the curriculum coordinator or the colleague responsible for personal data: read the negative list out loud, then fill in the school procedures together.

Part 1: what may not be entered (the seven-item negative list)

The official documents are explicit about this layer:

  • “When using AI tools to collect and process students’ learning data, schools must comply with the Personal Data (Privacy) Ordinance, the Copyright Ordinance, the relevant guidelines of law enforcement agencies (such as the Hong Kong School Network Security Guidelines) and the school’s own rules.”
  • “Where a teacher needs to upload students’ work to an AI platform for marking, the parts that identify a student must be carefully removed first, in keeping with the Personal Data (Privacy) Ordinance.”

None of these seven may be entered:

  1. Anything that identifies a pupil — name, pupil number, class and seat number, photograph, voice, video, handwriting. If it lets someone work out which pupil it is, it does not go in.
  2. A pupil’s personal and family data — parents’ names and contact details, home address, identity document numbers, health records, special educational needs, counselling records and individual learning plans.
  3. A pupil’s learning data and assessment records — marks, grades, comments, report cards, examination questions and model answers, internal tracking records.
  4. Staff personnel data — personal files, appraisal records, pay, personnel correspondence, and any colleague’s personal data.
  5. Other people’s material, music or images — without permission, do not upload someone else’s article, photograph, recording, music or video, and do not hand it to a tool to rework. The copyright rule is: get permission before you upload.
  6. Content that endangers national security, disrupts social order or tramples on moral standards — for example material promoting pornography, violence or unlawful acts, or deliberately created and spread false information. This may neither be entered nor generated with a tool.
  7. Confidential and unpublished school material — unpublished examination questions, tenders and quotations, contracts, internal investigations and meeting records.

If the subject matter involves national security, sovereignty or territorial disputes, or incorrect values, it should be removed, and the school’s management should be consulted.

Part 2: what may be entered, and how to handle it

Once it has been anonymised, this content is safe to enter:

  • A topic, theme or learning objective with no name attached, for example “upper primary mathematics: percentages in use”.
  • Material that is already public: official curriculum documents, government statistics, published news reports.
  • Material the school owns the rights to, or that involves nobody else’s rights: a chart you made, a paragraph you wrote, a photograph you took that shows no one else.
  • Subject-level teaching ideas: the flow of an activity, a set of questions, a first draft of marking criteria.
  • A pupil’s work or record after it has been anonymised, as below.

How to anonymise

  1. Replace names and pupil numbers with codes. Use “S07” instead of a pupil’s name, and a class code (such as “4A” or “P4A-G2”) instead of the class and seat number.
  2. Check the other identifying parts one by one. Faces, voices, handwriting, school uniform and classroom background in a photograph, recording or video can all identify a pupil. The PE scenario in the AI Literacy Learning Framework (Examples of Application Scenarios) asks pupils to keep the camera on the specific target of the movement and not to film other pupils’ faces, so that no more data is collected than is needed.
  3. Enter only the smallest version that has been processed. Do not upload the whole document and then delete the names inside the tool.
  4. Keep the code key at school. The list matching codes to real identities stays in the school’s own system or on paper. It is never entered or uploaded with the material.
  5. Deal with it when you have finished. Export what has to be kept to the school’s own storage, and delete the conversation and file records as the school’s rules require.

The same document also asks that, when pupils enter a prompt or upload material, they provide only anonymised data and never enter, upload or store real names, pupil numbers or other personally identifying information.

Part 3: school procedures (left blank for the school to fill in)

These four fields are left blank in the file, for the school to fill in and keep up to date:

  1. The approved-tool list — the tools the school allows, what each is for, and who manages the accounts. This guide names no tool; the list is the school’s to write and update.
  2. The approval route and its owner — if a teacher wants to use a tool that is not on the list, who they ask, how long a reply takes, and who approves it.
  3. Incident handling and reporting — if identifying pupil data is found to have been entered into a tool, what the first step is, who is told, and how it is recorded.
  4. The review cycle for tools’ default privacy settings — who checks each tool’s default privacy settings every term (or every quarter), and where the review date is recorded. The official documents also ask schools to keep reviewing and adjusting the default privacy settings of AI tools as needed.

Part 4: the one-page printable staff summary

The last page of the file condenses all of the above onto one page: the seven things that may not be entered, the three steps that must happen before anything is, and who to go to when something has gone wrong. It can be copied on its own for the staff room, the photocopier or the computer room.

Review checklist

Before the guide goes back, check each item:

  • The seven-item negative list was read out item by item at a staff meeting, and someone can explain each one.
  • Every member of staff has the guide, on paper or electronically, including teaching assistants and administrative and library colleagues.
  • All four school procedures name an owner and a review cycle; none is left blank.
  • The approved-tool list has been written, and says who updates it.
  • The incident-handling field says what the first step is and who is told.
  • Anonymisation was demonstrated once on a real piece of pupil work (codes and a class code replacing the name and pupil number) and checked on the spot.
  • Nothing in the guide conflicts with the school’s own AI-use policy or its personal information collection statement.
  • The next review date is written on the document.

Files

Staff data-handling guide (editable Word document)

Scope, the seven-item negative list of what may not be entered, what may be entered and how to handle it, four blank school-procedure fields, and a one-page printable staff summary at the end. A school can adapt and reuse the whole document.

Official documents

Every resource in this library is written to the AI Literacy Learning Framework for Primary and Secondary Schools and falls within the policy scope of the Blueprint for Digital Education Development in Primary and Secondary Schools.

This resource maps to:

  • Supplement II: Guide to Using AI in Teaching in Primary and Secondary Schools (pp.2-4 and 2-7, and p.2-9): sets out the principle of compliance and safe learning, requiring that the use of AI tools to collect and process students’ learning data comply with the Personal Data (Privacy) Ordinance, the Copyright Ordinance and the relevant guidelines of law enforcement agencies; it also requires the parts that identify a student to be carefully removed before a teacher uploads students’ work to an AI platform for marking, and asks schools to keep reviewing and adjusting tools’ default privacy settings.
  • AI Literacy Learning Framework for Primary and Secondary Schools (Examples of Application Scenarios) (pp.11 and 17): the PE scenarios ask pupils to provide only anonymised data when entering a prompt or uploading material, never to enter, upload or store a real name, pupil number or other personally identifying information, and to keep the camera on the target rather than filming other pupils’ faces.
  • Music Curriculum Guide (Primary 1 - Secondary 6) and Visual Arts Curriculum Guide (Primary 1 - Secondary 6): both curriculum guides set the same copyright requirement — permission must be obtained before other people’s material, music or images are uploaded.

Learning strand: reflection on the application of AI

Official documents page: https://www.edb.gov.hk/en/edu-system/primary-secondary/applicable-to-primary-secondary/it-in-edu/debp.html

This page is an independent Beets teaching resource, not an official EDB document.

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