GRIO
Data Sovereignty & Privacy Framework
Protecting Student Data. Empowering National Education.
March 2026
1. Executive Overview
Grio is committed to full data sovereignty and privacy protection. This document outlines how student data is collected, stored, protected, and governed. Grio is designed from the ground up to support government oversight and comply with national data protection requirements. No student data is shared with third parties.
2. Data Sovereignty Principles
All student data stored on sovereign infrastructure
Phase 1: Hetzner Cloud servers (Germany/Finland—EU data protection standards)
Phase 2: Uganda-based edge servers for local caching and low-latency
Phase 3: Fully in-country infrastructure, ministry-controlled if required
No dependency on US-based cloud providers (no AWS, no Azure, no Google Cloud)
Infrastructure designed for complete data portability—no vendor lock-in
3. What Data Grio Collects
Data Collected
Student profiles: name, school, class, subjects
Learning activity: sessions, topics covered, time spent, mode usage
Performance data: assessment scores, practice results, topic completion
AI interaction logs: questions asked, responses given (for quality and audit)
Teacher data: class management actions, content uploads
System data: device info, connectivity status, error logs
What Grio Does NOT Collect
Biometric data
Financial information (payment handled by third-party processor)
Personal communications between students
Location tracking beyond school assignment
4. Data Protection Measures
Encryption
In transit: TLS 1.2+ on all connections
At rest: database-level encryption, storage encryption
Access Control
Role-Based Access Control (RBAC): Super Admin, School Admin, Teacher, Student
Multi-tenancy with Row-Level Security—school data is isolated from other schools
No cross-school data access without explicit authorization
Infrastructure Security
Firewall protection (UFW/iptables)
VPN-only administrative access
Container-level isolation (Docker + K3s)
Minimal attack surface by design
5. Audit & Transparency
Comprehensive audit logs: who accessed what, when, from where
All AI interactions logged with timestamp, session context, and user role
Logs retained for configurable period (default: 1 year)
Ministry can request audit reports at any time
System designed for external security audits
6. Government Access & Oversight
Ministry of Education can access national-level analytics dashboard
Aggregated data available by: subject, school, region, district
Individual student data accessible only by school staff and parents (with proper authorization)
Grio can provide data exports in standard formats on ministry request
Infrastructure can be transitioned to government-controlled servers
7. Student Privacy Rights
Students (and parents/guardians) have the right to:
Know what data is collected
Request access to their data
Request deletion of their data (right to erasure)
Opt out of non-essential data collection
Data deletion requests processed within 30 days
Student data never used for advertising or marketing
8. AI-Specific Privacy
AI responses are grounded in curriculum content only (no external data)
AI does not retain personal information between sessions beyond what is needed for continuity
Topic-locking prevents AI from engaging in inappropriate topics
AI outputs are age-appropriate and content-filtered
No student data is used to train external AI models
9. Third-Party Data Handling
LLM API calls (OpenAI, Phase 1) transmit only curriculum context and anonymized queries
No personally identifiable student information sent to LLM provider
Phase 2: self-hosted LLM eliminates all third-party AI data transmission
Payment processing handled by certified third-party (e.g., Stripe)—Grio does not store payment details
10. Compliance & Certification Roadmap
Current: HTTPS/TLS encryption, RBAC, audit logging, data isolation
Planned: Uganda Data Protection & Privacy Act compliance review
Future: SOC2-type certification, government security assessment, penetration testing
11. Commitment
Grio is built on the principle that student data belongs to students, schools, and the nation—not to technology providers. Our infrastructure, policies, and practices are designed to earn and maintain the trust of the Government of Uganda.