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Founder of Euverify | EU & UKCA Compliance Expert
Ajay is an eCommerce expert with 17+ years of experience as an Amazon, eBay, and Etsy seller and a Shopify specialist. He excels in EU and UK compliance, including GPSR and UKCA, helping businesses expand into European and UK markets. Ajay is the founder of Sweans, a London-based eCommerce agency, and Euverify.com, a SaaS platform streamlining compliance for non-EU sellers.
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Why Online Learning and EdTech Platforms Must Appoint a GDPR Representative Under Article 27
The digital classroom never sleeps. From online tutoring platforms to global EdTech apps, virtual learning has made education more accessible than ever. But as these platforms grow, many are now handling personal data from students in the EU and the UK, including children and teenagers.
With that global reach comes serious responsibility.
Under the General Data Protection Regulation (GDPR), companies that process EU or UK student data must follow strict privacy rules. If a platform operates outside these regions but collects or processes such data, it’s legally required to appoint a GDPR representative under Article 27. This person acts as the local contact for regulators and students on all data protection matters.
In this post, we’ll explore why online learning platforms, tutoring apps, virtual classrooms, and EdTech companies need a GDPR representative, what risks they face without one, and how they can stay compliant.
Understanding GDPR Article 27 for EdTech
Article 27 of the GDPR might sound technical, but its purpose is straightforward. It requires any organisation that is not based in the EU or UK, but still processes the personal data of people living there, to appoint a GDPR representative within the EU or UK.
This representative acts as the official contact for both data protection authorities and individuals such as students or parents. Their role ensures:
- Clear and transparent communication
- Accountability in processing student data
- Quick and efficient handling of data requests or potential breaches
It is important to understand that this role is separate from an internal compliance team or automated privacy tools. Even smaller EdTech companies, like tutoring apps, online courses, or education marketplaces, must appoint a GDPR representative if they handle data from EU or UK students.
GDPR Representative for E-Learning Platforms: Why It Matters
Digital learning platforms collect a wide range of student data, including:
- Personal identifiers such as name, email, and date of birth
- Academic records and progress
- Usage data and learning analytics
- Payment information for course subscriptions
When these platforms serve students in the EU or UK, they must follow GDPR rules. This applies to:
- Online courses aimed at EU or UK students
- Tutoring apps that track user behavior
- Virtual classrooms that store or transfer student data internationally
Even if internal privacy policies are strong, without a GDPR representative, platforms risk non-compliance.
For instance, between July 2023 and December 2024, more than 9,000 cyber incidents affected nearly 5,000 K–12 schools, according to Education Curated. This shows how vulnerable online learning systems are to data breaches and unauthorised access. Even if not all cases fall under GDPR, they highlight the need for stronger safeguards in EdTech—especially when minors’ data is involved. Having a GDPR representative helps ensure that data protection, reporting, and communication with regulators are handled correctly.
Risks of Non-Compliance for EdTech Companies
Failing to appoint a GDPR representative carries legal, financial, and reputational risks:
- Fines: Up to €10 million or 2% of global turnover.
- Regulatory action: Investigations, audits, or temporary restrictions on service.
- Reputational damage: Loss of trust from students, parents, and partners.
For example, virtual classroom platform offering live tutoring to EU students without a GDPR representative could face fines and regulatory enforcement, disrupting operations and harming brand reputation.
In fact, recent enforcement data shows that education and public institutions are facing growing scrutiny over data protection failures. According to the EDPB’s 2024 Enforcement Tracker, the biggest fines in this sector came from cases involving large-scale collection of personal data, including student and citizen records. This clearly signals that online learning and EdTech platforms handling student data are now a key focus for regulators.
Role and Responsibilities of a GDPR Representative in EdTech
For e-learning and EdTech platforms, a GDPR representative plays a key role in making sure all data protection requirements are met. Their responsibilities typically include:
- Main point of contact: Acting as the link between your platform and EU or UK data protection authorities, as well as students.
- Handling data requests: Managing requests from students or parents who want to access, correct, or delete their personal data.
- Reporting data breaches: Making sure any breach is reported within the required 72-hour window under GDPR.
- Providing compliance guidance: Advising your team on privacy policies, consent management, and data transfers between regions.
- Supporting audits: Keeping accurate records of data processing activities to assist with internal reviews and regulatory audits.
Even if your platform already follows strong privacy practices, having a GDPR representative adds an extra layer of assurance. It helps maintain compliance, builds trust with users, and reduces the risk of regulatory issues down the line.
Steps to Appoint a GDPR Representative for EdTech Platforms
- Assess Data Processing Activities
Begin by evaluating whether your platform processes the personal data of EU or UK residents. This step helps determine if appointing a GDPR representative is necessary. - Select a Qualified Representative
Once required, choose a representative established within the EU or UK who has expertise in data protection laws. Their knowledge will be crucial in ensuring compliance. - Formalise the Appointment
Next, formalise the relationship through a written agreement that clearly outlines the representative’s responsibilities and the scope of their authority. - Update Privacy Notices
Make sure your privacy policies and notices are updated to include the representative’s contact information, ensuring transparency for data subjects. - Maintain Ongoing Communication
Finally, maintain regular communication with your GDPR representative. Keep them informed about your data processing activities and any significant changes.
Engaging specialised GDPR service providers can further simplify this process and help ensure your platform remains fully compliant.
Benefits of a GDPR Representative for Online Learning Platforms
- Enhanced Student Trust
Appointing a GDPR representative demonstrates a clear commitment to protecting both personal and academic data, which helps build trust with students and their families. - Operational Efficiency
A dedicated representative can handle regulatory queries and data requests, freeing internal teams to focus on core educational activities. - Investor & Partner Confidence
Showing strong data governance signals to potential investors and partners that your platform takes privacy seriously, enhancing credibility and collaboration opportunities.
These benefits are especially crucial for EdTech startups, virtual classrooms, and international online courses, where compliance can impact growth and reputation.
Moreover, beyond mere compliance, trust is a crucial driver of growth in EdTech. A 2024 survey found that 66% of parents are concerned about “unnecessary data harvesting” by digital education tools, highlighting widespread worries over student data handling. By appointing a GDPR representative, platforms can strengthen credibility and demonstrate a clear commitment to responsible data use. An essential factor in building lasting relationships with students, parents, and educational institutions.
Common Mistakes by EdTech and Online Learning Platforms
- Relying Solely on Internal Staff or Legal Counsel
Assuming that internal teams or legal advisors automatically fulfill Article 27 requirements can leave gaps in compliance. - Mistaking Platform Tools for a Representative
Believing that analytics platforms, KYC software, or other digital tools can replace the need for a GDPR representative is a common misconception. - Appointing a Representative in Only One EU Country
Serving multiple EU markets but appointing a representative in just one country can create compliance blind spots. - Neglecting Updates as Operations Grow
Failing to update the appointed representative when your services or operations expand may result in regulatory oversights.
Avoiding these mistakes helps reduce the risk of fines, regulatory delays, and reputational damage, ensuring smoother and more reliable compliance across your EdTech platform.
Final Takeaway
EdTech companies and online learning platforms that process EU or UK student data are required under Article 27 to appoint a GDPR representative. Doing so not only protects the platform from fines and regulatory scrutiny but also ensures that data subject requests are handled efficiently. Beyond compliance, a GDPR representative helps maintain student trust and strengthens the platform’s overall credibility.
Even with advanced compliance tools in place, a GDPR representative remains a legal necessity and a critical safeguard against operational and reputational risks. Assess your platform’s GDPR compliance today and appoint a qualified representative to protect your students’ data while maintaining your platform’s integrity and credibility.
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