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Privacy & Student Data

What's stored, who can see it, and how to answer your IT department.

Program & adoption6 min read6 sections

What gets stored when a student practices

It's worth knowing exactly what exists after a session, because this is the first thing anyone asks. A completed conversation produces a transcript, an audio recording where available, the generated feedback, and metadata about the session.

  • A transcript of the conversation
  • An audio recording of the session, where available
  • The generated feedback report and any proficiency estimate
  • Session metadata — timing, completion status, and which attempt was submitted

Lemon says: Students should know the transcripts and recordings they submit are visible to you. Say it in week one.

Who can see a student's work

Access is scoped to the section. Instructors assigned to a section can see the submitted work of students in that section, and no other instructors can.

  • You and your co-instructors can see submissions in the sections you teach
  • There's no view-only role: anyone you add to a section as an instructor can see and manage that section's work
  • Instructors of other classes cannot see your students' conversations
  • Each class is isolated from every other class

Lemon says: If you add a co-instructor to a section, they can see and manage everything in it. Worth knowing before you add someone.

AI processing

Conversations are processed by an AI model to run the roleplay and generate feedback. The relevant commitments for an institutional review are described in the privacy policy and the trust pages; the two points instructors are usually asked about are training use and third-party sharing.

  • Conversations are not used to train publicly available AI models, and the AI providers may not train on them
  • Conversations are not shared with third parties outside the described subprocessors
  • Connections are encrypted in transit, and audio recordings are stored encrypted
Note: The public trust pages cover the research approach, the AI feedback approach, student data privacy, the subprocessor list, and a security FAQ written for school adoption reviews. That's the material to forward.

Lemon says: For anything an IT reviewer needs in writing, point them at the trust pages rather than paraphrasing from memory.

FERPA and institutional use

For FERPA-covered institutional use, the privacy policy describes the service operating in the school official role with a legitimate educational interest. This is normally the specific framing your registrar or general counsel is looking for.

Watch out: Institutional agreements vary. If your institution requires its own data processing agreement or a completed vendor security review, start that conversation before a full-course rollout rather than mid-term.

Lemon says: "School official with a legitimate educational interest" is the phrase that answers the question they're actually asking.

Preparing for an IT review

If your institution runs a vendor review, gathering these in advance turns a multi-week process into a much shorter one.

  • The privacy policy and the student data privacy page
  • The subprocessor list — reviewers almost always ask where data goes
  • Where data is stored and processed
  • The security and school-adoption FAQ
  • The accessibility statement and conformance report (available on request), which the same review often requests

Lemon says: Send all of it at once. Reviews stall on round-trips more than on substance.

Good practice in your own course

A few habits keep your course on the right side of expectations regardless of what the institution requires.

  • Tell students in the syllabus that conversations are recorded and reviewed
  • Don't build activities that ask students to disclose sensitive personal information
  • Be careful with public share links — never create one for anything containing student detail
  • Keep an alternative available for students who decline on privacy grounds

Lemon says: Scenarios that ask about family, health, or immigration status feel natural to write and can put students in an awkward position. Keep the personal disclosure optional.