The Polish Data Protection Authority (UODO) has communicated its position regarding the initiative to create a free public digital school documentation system.

The president of the UODO supports this project but conditions its implementation on a thorough analysis, recalling that a law dated 31 July 2026 on this subject was subject to a presidential veto. The authority highlights that existing commercial solutions often present security flaws and doubts about their GDPR compliance, as confirmed by numerous citizen complaints and an audit revealing irregularities.

The UODO insists on the necessity to carry out a comprehensive and transparent data protection impact assessment (DPIA) beforehand. This assessment must evaluate the legal bases, cybersecurity guarantees, the principle of data protection by design, and precisely define the roles of the actors involved. Particular attention must be paid to the major systemic risk posed by the centralization of data in a single database, creating a "single point of failure." The authority has offered its technical support to the Ministry of National Education and the Chancellery of the President for this project.