Project Overview
A UK EdTech company wanted to build an adaptive learning platform for UK primary school mathematics (Years 1–6...
Technology Stack
Compliance & Standards
The Challenge
A UK EdTech company wanted to build an adaptive learning platform for UK primary school mathematics (Years 1–6, National Curriculum aligned). The platform would use ML to identify knowledge gaps and adapt question difficulty per pupil. ICO Age Appropriate Design Code (AADC) — all users are under 18, UK GDPR Article 9 (SEND data), KCSIE, Teacher Standards framework alignment, and DfE Assessment frameworks (KS1/KS2 National Curriculum assessment) were mandatory. Budget: £90,000.
Our Approach
ICO AADC Privacy by Default Architecture
- Every design decision starts from the ICO AADC standard 2 (best interests of the child) and standard 5 (data minimisation).
- No behavioural advertising capability — by design.
- No social features — by design.
Profile data
only what the teacher and school explicitly provide.
All analytics
aggregated (class, year group) — no individual pupil behavioural tracking for commercial purposes.
Privacy by default settings
tightest possible settings enabled at creation.
KS1 and KS2 mathematics National Curriculum
all 56 statutory assessment points mapped to question bank.
Adaptive algorithm
Item Response Theory (IRT) model — estimates pupil ability from response patterns and selects next question at appropriate difficulty.
Knowledge Graph
prerequisite relationships between curriculum objectives (cannot answer Year 4 fractions without Year 3 fractions foundation).
Intervention flags
when ability estimate drops below year-group expectation.
KCSIE
no safeguarding data in the learning platform — pupil wellbeing concerns raised by teachers go to the school's CPOMS (Child Protection Online Management System) — not the learning platform.
SEND
SEN flag from MIS integration (Arbor/Sims) used only to flag to teacher that adaptive difficulty ceiling should be adjusted.
Article 9 special category
SEN medical detail never processed — only the flag that additional adaptation is needed.
Teacher dashboard
class progress heatmap against National Curriculum objectives, intervention pupil list, question-level analysis (which objectives the class is struggling with).
Parent portal
ICO AADC standard 15 (parental controls) — parents can view their child's progress summary and set time limits.
Parent privacy notice
separate, child-appropriate language.
The Results
Platform live at 16 weeks, £82,000 — under budget.
ICO AADC audit: zero findings.
Schools deployed: 84 primary schools, 6,200 pupils.
Adaptive algorithm accuracy: 91% correct difficulty calibration (pupil self-report: questions feel "right level of challenge").
KS2 SATs (pilot cohort Year 6): 8.4 percentage point improvement over control group in maths standardised score.
Teacher Net Promoter Score: 72 (excellent — professional SaaS benchmark: 30+).
“8.4 percentage point improvement in KS2 SATs versus the control group. That is the product justification. The ICO AADC audit found nothing — because we designed for children's best interests from Sprint 1, not as a compliance afterthought. The Teacher NPS of 72 is the best score we've seen in EdTech — teachers are our hardest customers." — CEO, UK Primary EdTech Company (name withheld)”
Project Details
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