Legal
DPIA Summary
Public summary of NEB RADAR's Data Protection Impact Assessment. Version 2026-06-16. The full DPIA is available to institutional partners on request.
Scope
This DPIA covers: (a) AI-generated narratives and recommendations from the RADAR Core engine; (b) youth-mode usage by minors; (c) free-text inputs to the Concierge and Explain & Improve tools; (d) public radar leaderboards.
Risks & mitigations
| Risk | Severity | Mitigation |
|---|---|---|
| AI-generated narratives could misrepresent a project or person | Medium | Every AI output is labelled as AI-generated, includes a 'flag' affordance, and the underlying signals (RADAR Core) are shown alongside. Users can edit or delete narratives at any time. |
| Free-text inputs may contain personal data of third parties | Medium | User-facing guidance discourages submitting third-party PII. Prompts to the LLM are scoped to assessment context. No training on user data. |
| Youth-mode users are minors (13–17) under Art. 8 GDPR | High | Strict system prompt: age-appropriate tone, refuses self-harm/violence content and routes to safeguarding task, no PII echo, no contact information generation. Parental consent flow required at sign-up for users under the local digital-consent age. |
| Scoring could be perceived as authoritative judgement | Low | Radar charts include 'evidence' citations per signal and a transparency panel explaining the framework. Scores are framed as self-assessment plus AI-assisted reflection, never as accreditation. |
| LLM provider outage or change of sub-processor | Low | AI provider abstraction (Phase C3) allows swapping providers without code changes downstream. Users notified 14 days in advance per the sub-processor list. |
Residual risk
After mitigations, residual risk is assessed as Low. The combination of self-assessment framing, AI transparency labels, safeguarding controls in youth mode, and EU-hosted infrastructure keeps processing proportionate to NEB RADAR's public-interest purpose.
Review cadence
This DPIA is reviewed at every minor release and at least every 12 months, or when a new sub-processor is added.