Executive Summary
Praxis is designed for course-governed learning and is not intended for sensitive personal data. The system minimizes data before external AI use and blocks messages that may contain national identity numbers or login credentials before they are stored or processed further.
- Data minimization and sanitization before AI processing.
- Hard-block + no-store for national identity numbers and credentials.
- GDPR flows per customer where information or consent can be configured per subscriber.
- EU/Sweden-resident AI routing: student data must be processed through reviewed EU/Sweden provider routes and fail closed if no safe route is available.
- DPA & SCC: data processing agreements and standard contractual clauses with all subprocessors.
Design Principle
Privacy by design and data minimization at every step.
Contact
Roles and Responsibilities (GDPR)
Controller
The education provider, such as the university, is the controller for student data in the educational context.
Processor
Praxis (Virtualis) processes data on behalf of the education provider according to agreement and instructions.
Subprocessor
AI processing that may contain personal data must be routed through reviewed EU/Sweden-resident provider routes according to customer and production configuration.
Praxis can be configured per subscriber, including whether information or consent flows should be used.
What Data Is Processed?
Identifiers
Email address, so messages can be received and answered.
Education-Related Content
Message subject and body connected to course learning activities.
Technical Metadata
Timestamps, delivery status, and limited logs for operations and security.
Consent/Information (Optional)
Tracking of whether an information notice has been sent and/or consent exists, depending on customer configuration.
Praxis is not intended for sensitive personal data. The system includes technical controls to stop certain types of especially protected information.
Technical Safeguards
Hard Block
Messages that may contain national identity numbers or credentials are blocked.
No Store
When blocked, message content is not stored and no AI processing takes place.
Sanitization
Data minimization and sanitization before external AI is used, when enabled.
Limited Logging
No raw text in logs; only metadata and safe indicators when needed.
Sharing and International Transfers
Email data is processed and stored within Sweden/EU according to the provider statement. A data processing agreement is available.
AI Processing (EU/Sweden)
AI processing that involves student data must use the reviewed EU/Sweden-resident provider chain. Praxis must not fall back to an unreviewed route for student data.
Praxis uses configurable AI routing. Student data must be processed through reviewed EU/Sweden-resident provider routes, and the current provider/model configuration must be verified before each pilot or customer deployment.
Additional safeguards: In addition to EU/Sweden-resident processing, we apply strict data minimization before AI processing, maintain data processing agreements (DPA) with relevant subprocessors, and use standard contractual clauses (SCC) as an additional legal safeguard even where no transfer takes place.
Data Flow (Overview)
The diagram shows the control points where processing is stopped, and when external AI may be used.
flowchart TD
A[Student sends message] --> B[Praxis receives the message]
B --> C{Sensitive information found}
C -->|Yes| D[Auto-reply with instructions]
D --> X[Stop no storage]
C -->|No| E[GDPR control]
E --> F{Consent required}
F -->|Yes| G[Send consent message]
G --> X
F -->|No| H{Information notice needed}
H -->|Yes| I[Send information notice]
H -->|No| J{Sanitization enabled}
I --> J
J -->|Yes| K[Data minimization]
K --> L[AI processing via EU/Sweden route]
J -->|No| L
L --> M[Queue response]
M --> N[Send response by email]
"Stop no storage" means that message content is not stored and is not processed further.