At ONVU Learning, we are committed to supporting teachers through innovative, evidence-based tools that enhance professional growth and classroom practice. Our technology is designed to help educators reflect on their teaching and make meaningful improvements, always with privacy, security, and transparency at the forefront.
We also understand that using classroom video and audio recording technology raises important questions about data protection, consent, and privacy. As part of our commitment to openness, we want to make sure schools, teachers, and parents have clear and accessible information about how ONVU Learning operates and how we handle data responsibly.
An organisation called Defend Digital Me recently shared a list of questions about how educational technology companies manage data. Although these questions were not directed to ONVU Learning, we felt it was important to respond openly and directly, as many of the themes raised are relevant to how our system is used in schools.
This article brings together our responses to those questions. It aims to provide clarity on key topics such as lawful data processing, data security, consent, retention, and safeguarding. It also shows how ONVU Learning works in partnership with schools to ensure compliance with UK GDPR and data protection best practices.
We hope this resource helps you understand our approach and supports your confidence in using ONVU Learning as a safe, effective, and transparent professional development tool.
Addressing data protection questions
ONVU Learning is a pioneering tool designed to improve how teachers review and develop their classroom practice. ONVU Learning utilises cutting-edge technology developed by the Group (ONVU Technologies) to create and deliver our products and services. Innovation drives change and should happen carefully, achieving the intended aims without causing harm. We recognise the importance of ensuring that data, especially that of children, is well-managed, securely stored, and used responsibly. We acknowledge that third parties have a role in supporting society to adopt innovations. In schools, these third parties may include workforce unions, stakeholder groups such as parents and students, and separate third parties seeking to represent specific viewpoints.
Recently, we have decided to collate responses to a set of questions that have been posed by an organisation called ‘Defend Digital Me’. They have posed these questions not to us but rather generally on their website and specifically to a customer. Unfortunately, some of their questions indicate a lack of product knowledge and appear to suggest a general scepticism of our product. However, we have responded sincerely in the hope that you find them helpful.
This article sits alongside existing documentation, including our Data Protection Policy, your Terms and Conditions, and those linked in this article.
Thematic questions
-
Purpose and Justification: What is the main reason for installing ONVU systems in classrooms, and why is this the only (necessary and proportionate) method of achieving that aim (e.g., teacher training, safeguarding, behaviour monitoring)?
OVL response: ONVU Learning (OVL) is an innovative tool designed to enable effective and impactful self-reflection on teachers’ practice in classrooms. Evidence demonstrates that video self-reflection is effective at improving teachers’ performance, overcoming the evident shortfalls in traditional lesson observations.
-
Children and Company Privacy notice ONVUs privacy notice says, “Our products and services are aimed at those aged 16 and over.” Why are their products being used with our children under 16? (“Introduction” https://www.onvulearning.com/privacy-policy/)
OVL response: OVL is used by teachers and their immediate, permitted peers for the purposes defined. Children are not the intended users.
-
Voice recordings: Is voice also always recorded when the film is recorded, or are there measures to minimise capturing unnecessary biometric data? When is the voice recording switched on or off in comparison with when the camera recording is on? Is it like CCTV ‘always on’ but not always retained for a longer time period unlike the ‘clips’ that can be ‘saved’ by staff actively on demand?
OVL response: The system is designed to record video and audio simultaneously when it is set to record (by scheduling recordings). The system is ‘always on’ by virtue of being powered by Ethernet connection and being an IoT device, i.e. internet internet-connected to make it work. But it is not always recording. Original recordings are stored locally on the in-room device, encrypted and then self-deleted after 30 days. Clips are securely stored in the AWS cloud.
-
Consent: How are parents, pupils, visitors, and staff asked for consent before recording takes place?
OVL response: Data controllers basis for controller the data produced by OVL is typically for the performance of public task. In some cases and for specific reasons legitimate interest may be used.
-
Biometric data If you are not basing processing on consent (See Q4) how are you processing voice data? Schools can only lawfully process biometric data under the Protection of Freedoms Act 2012. How do you meet its requirements for pupil and parental consent?
OVL response: ONVU Learning does not use automated biometric recognition systems. The platform does not analyse or process facial or voice data for identification purposes. Therefore, the Protection of Freedoms Act 2012 does not apply to ONVU Learning’s standard operations.
-
Data Protection law and data security How is the video data stored, encrypted, and protected in line with UK GDPR and the Data Protection Act 2018 and where?
OVL response: Security Statement - ONVU Learning
-
Access: Who is allowed to view the recording ’clips’ that are saved (teachers, senior leaders, governors, external consultants, the ONVU staff), and under what circumstances?
OVL response: Our system is designed for in-platform self-reflection to enable and enhance teachers’ performance in their classrooms. The system is built to allow access to view any footage based on a permissions basis.
-
Watch live permissions. Tell us about the ‘watch live’ permissions option and how we will know who is accessing content granted using it?
OVL response: Permission to access and view video of any kind (live or recorded) is managed in the platform. Email notifications are sent if/when changes are made to viewing permissions.
-
Product development. According to the ONVU privacy notice, they may use recordings to further develop their products — what’s the lawful basis for that? https://www.onvulearning.com/privacy-policy/ “Within certain products, the function of those products is to record images/ video of the customers' working environment. This information is integral to the product offering, primarily being used by our customers and may be used by us to further improve the specification and performance of the products.”
OVL response: We have a legitimate interest in developing our product. We do not use video or audio footage to do so as a general rule. However, we may require discrete, time-bound and permitted access to footage in order to resolve specific technical queries. Such footage will not typically contain recordings involving people in the rooms unless absolutely unavoidable. All access is logged for auditing purposes.
-
Retention Period: How long are those recordings kept, and what happens to them after that period?
OVL response: see response to Q3.
-
Ownership: What research has the school done into the company ownership, owners, and their global partners and subsidiaries?
OVL response: ONVU learning is a brand of ONVU Technologies AG, trading in the UK as ONVU LTD. Company No. 11384360.
-
Foreign ownership and data transfers: ONVU Technologies AG, which owns the UK company, is based in Switzerland, and its subsidiaries and affiliates are around the world. Their Ts&Cs say they may share data with them. What audits will you do to know that our children’s recordings don’t leave the UK? https://www.onvutech.com/our-businesses/
OVL response: Security Statement - ONVU Learning and Onboarding – ONVU Learning Knowledge Hub
-
Safeguarding: How does the system support confidential child safeguarding without infringing on pupil privacy — sensitive disclosures or health information might be recorded visually or verbally for example?
OVL response: safeguarding training makes a point of making clear that during any disclosure by a child, the information given may be shared with the appropriate people in order to safeguard that child and/or others, e.g., the school’s designated safeguarding lead. In the unlikely event that a disclosure occurs in an OVL classroom while a recording is happening, then the footage can be used or deleted depending on the best interests of the child from a safeguarding perspective.
-
Pupil behavioural impact: How will you know if there is a chilling effect on some children’s participation or willingness to ask questions, for example, given that you have an obligation to tell them they are being recorded, not keep it covert?
OVL response: There is no evidence to support the premise of this question. However, we are aware that students forget that the device is in the room quickly, and teachers report gaining the desired benefits without any evident ‘chilling effect’ on students’ willingness to engage as normal. Some examples are collated here: Press & Media - ONVU Learning
-
Impact on Teaching and Learning: What independent evidence is there that ONVU systems improve teaching quality or student outcomes from sources other than the company?
OVL response: Please see the independent articles that we have collated here: Press & Media - ONVU Learning
-
Transparency: How are parents and students informed about when and how recording is happening, and what might have been recorded? What will you do with incidental recording findings, eg unintentionally recording behavioural incidents that went unseen in the live classroom in real time?
OVL response: how a school/trust deals with this will be informed by their relevant policies and practices.
-
Rights and Complaints: What rights do parents and pupils have if they object to being recorded, and how can they raise concerns or request the deletion of footage?
OVL response: We recommend that stakeholder engagement is actively sought and that parents and students are shared information about the deployment of ONVU Learning.
-
Visitor recording. If the school has visitors to assist in classroom activities, eg reading with pupils or other activities, will their participation be dependent on consent to recording? Will visitors who object have to give up their school involvement?
OVL response: There are a number of ways of dealing with this issue, including but not limited to scheduling recordings around such events, displaying appropriate signage, and informing those involved of the purpose and intent. Schools know their communities best and should manage this as they would any other operational matter.
-
Rights to Subject Access Depending on children’s age, parents and pupils have the right to request access to view the recording of their own child, regardless of purpose. How will you edit the recordings to hide the images and voices of other children or staff to whom they don’t have any right to view/listen?
OVL response: Please refer to Q7 below and this article https://www.vwv.co.uk/insights/articles/subject-access-requests-key-issues-for-schools-and-academy-trusts/ . Users are trained on how to use ONVU Learning. We will respond to subject access requests in accordance with data protection law. Where video footage includes other individuals, Data Controllers should take reasonable steps to protect others’ privacy, which may include editing or redacting the footage, either by clipping as appropriate or using third-party editing software on a downloaded (by Admin permission only) clip.
-
Parental notice. The notice to parents that many schools give shortly before processing begins says explicitly, “this is not a surveillance system”, which appears to be a marketing claim rather than a fact. Can the school describe its own due diligence process to independently assess this claim? Onvu is owned by Oncam. Oncam 360-degree camera technology is marketed to schools under the ONVU subsidiary brand. The ONCAM, website says, “At Oncam we are obsessed with 360-degree surveillance technology”. (See https://www.oncamgrandeye.com/) and “Oncam technology works best when part of a wider surveillance solution. We are continuously working to ensure our technology is integrated into market leading Video Management and Recording solutions.“ and it claims,”We’re also fully compliant with the USA’s National Defense Authorization Act (NDAA).” (See section ‘discover our technology partners’ https://www.oncamgrandeye.com/partners/). How does the school justify the parental statement “this is not a surveillance system” when it’s the same technology?
OVL response: Many tools have multiple uses, and many companies make use of the same or similar devices within their portfolio to achieve different outcomes. Without ONVU technologies choosing to leverage the benefits of their C-12 Oncam camera in ONVU Learning, OVL would not be as effective as it is in achieving its intended purpose as a discrete product.
Operational questions
-
Have ONVU created a child-friendly privacy notice?
OVL response: No, we do not sell to children and are not best placed in any case to do so. Every school cohort is subtly different and so if a discrete notice is required, then it is incumbent on the school to first decide that and then act on the decision.
-
Where is the data stored, and who has access to the controlled servers?
OVL response: Security Statement - ONVU Learning
-
What is the technical capability of the cameras?
OVL response: C-12 Indoor Camera - Oncam: Experts in 360-degree and 180-degree Video Technology Solutions
-
What systems does ONVU run against the data?
OVL response: By 'the data' we take this to be referring to recordings data. No third-party systems are used.
-
What do those systems do with the data?
OVL response: Not applicable.
-
Does ONVU use the data for product development?
OVL response: Yes, as per our Privacy Notice.
-
How does ONVU handle subject access requests?
OVL response: ONVU Learning, as a Data Processor, would not typically respond directly to Subject Access Requests from parents. Any such requests received will be referred to the appropriate Data Controller. ONVU Learning will provide reasonable assistance to the Controller to enable them to meet their obligations under UK GDPR
-
What is their approach to Article 12 (UK GDPR) – ensuring pupils have something to take home to discuss with parents?
OVL response: Suggested wording could be as follows:
"Your school uses ONVU Learning to help teachers learn and improve how they teach. Sometimes, this means recording lessons using cameras and microphones in the classroom.
Here’s what that means for you:
- 🎥 What is recorded?
The camera might record video and sound during lessons. This could include your voice or image if you're in the classroom. - 🔒 Who sees the recordings?
Only your teachers and school staff who are allowed to see the recordings can watch them. They use them to learn and get better at teaching. - 🧠 What is NOT done with the recordings?
ONVU Learning does not use your face or voice to identify you. We don’t use the recordings to make decisions about you, and we don’t share them with anyone outside your school. - 📁 Where is the data stored?
The recordings are kept safe and secure. Only people your school approves can access them. -
📝 Can you ask questions or see what’s recorded?
Yes! If you or your parents want to know more or ask to see what’s been recorded, you can speak to [insert]. They’ll help you."9. Are they processing special category data (e.g. biometric data like voice and face)?
OVL response: ONVU Learning does not process special category data as defined under UK GDPR. While our system enables the viewing of video recordings that include audio, we do not actively analyse, extract, or use biometric identifiers such as facial recognition or voice profiling. The recordings are used solely for observational and review purposes, and not for identifying individuals based on biometric characteristics.
10. What safeguards are in place for identifiable special category data?
OVL response: ONVU Learning’s video and audio recordings are not used to identify individuals via biometric analysis (e.g. facial recognition or voice matching), therefore they do not constitute special category data, even if individuals are visible or audible.