The pilot phase ran the school's new tool approval workflow on three live tools: Google Workspace for Education (Gemini AI), Canva for Education (AI features), and Edmodo. This generated the first real evidence of the governance framework operating under real conditions and established the KPI baseline for Year 1 reporting.
Review Findings
- Google confirmed student data in Education Plus tier is not used to train Gemini models — DPA clause verified.
- Gemini features for students under 14 require admin restriction in Workspace console — completed Week 1 (emergency action).
- Smart Compose and Smart Reply: approved for all ages — no student data processed externally.
- Gemini in Google Docs/Slides: approved for Grades 8+ with teacher supervision; restricted for Grades 1–7.
- Gemini in Meet (transcription): approved for staff only.
Approval Conditions
Data Processing Agreement
Google Workspace for Education DPA signed. Data residency: US (Google Cloud). Ley 1581 cross-border transfer clause included. ✓
Review Findings
- Canva for Education tier confirmed: AI-generated content is not stored or used for model training.
- Magic Media (AI image generation): suitable for Grades 4+ with teacher oversight. Requires content guardrail review.
- Magic Write (AI text): suitable for Grades 6+ as a drafting aid; not for submission as final work without disclosure.
- DPA reviewed and signed — Colombian data transfer clause added.
Approval Conditions
Review Findings
- Edmodo's updated privacy policy (Jan 2026 revision) contains an ambiguous clause permitting "aggregate and de-identified data to improve AI recommendation systems."
- DPA template submitted to Edmodo — awaiting response as of report date.
- No evidence of active breach; precautionary suspension applied.
- Affected classes (3 teachers, ~90 students) migrated to Google Classroom.
Next Steps
These are the baseline values established at Day 60 of the program launch (February 2026). They form the reference point for all future governance reporting.
Each approved student-facing tool was assessed across 5 equity dimensions. No critical failures identified. Three areas flagged for monitoring.
Four refinements were made to the Living AI Policy based on pilot findings. Policy updated to v[X.X] on 13 February 2026.
- §3 Tool Registry: Added "Suspended — DPA Pending" status tier for Edmodo; added admin console review requirement for Google Workspace updates.
- §5 Prohibited Uses: Clarified that AI-generated images used in any student submission must be labelled, including in visual arts portfolios.
- §8 Tool Approval: Added content guardrail check as mandatory step in approval checklist for any AI tool that generates text or images for student consumption.
- §10 Incident Response: Added vendor suspension as a default P2 containment step when DPA compliance is uncertain.