Prepared by Korva Academy's operator on 2026-10-07 under sections 10 and 11 of the exposure draft Privacy (Children's Online Privacy) Code 2026. The draft is not yet in force; Korva is working to meet it. This assessment has not been reviewed by a lawyer.
Purpose and method
Sections 10 and 11 of the draft Code say Korva may collect, use or disclose personal information about a child only where doing so is consistent with the child's best interests. For each kind of information Korva actually holds about a child, this document records the purpose, the assessment, the reasoning, and the date. A second table records each kind of information Korva deliberately does not collect.
The test applied to every row: does keeping this information help the child practise and learn, or protect them, in a way that outweighs any risk to them — and is there a less intrusive way to get the same benefit? A category that only helped Korva, and not the child, would fail.
Korva applies the draft Code to every user regardless of age (draft Code section 8(5)), and treats every child profile as belonging to a child aged 10 to 12.
Information Korva collects about children
| Information | Purpose | Assessment | Reasoning | Date |
|---|---|---|---|---|
| Nickname (two words the child picks from two fixed word lists on first sign-in) | So the child can find their own profile and Korva can greet them | Consistent with best interests | It identifies the profile without identifying the child. Because it can only be built from Korva's own word lists, it cannot carry a real name. It lets two siblings share one parent account safely. | 2026-10-07 |
| Optional 4-digit PIN (set by the parent, stored as a one-way hash) | Lets a parent stop a sibling using the wrong profile | Consistent with best interests | Optional, chosen by the parent, never shown, cannot be read back. It protects the child's practice record from mix-ups. | 2026-10-07 |
| Practice responses (question, answer, time, right/wrong, hints used, answer revealed; includes Weekly Mock and Challenge answers) | Mark the answer, choose the next question, and show progress | Consistent with best interests | Practice cannot be marked or adapted without the answer. Choosing the next question from past answers spares the child questions that are too hard or already mastered. Hint and reveal counts let the parent see where help was needed. | 2026-10-07 |
| Mistake Bank entries | Bring a wrongly answered question back the next day | Consistent with best interests | Revisiting mistakes is one of the most effective ways to learn. The entry is resolved once the child answers correctly. | 2026-10-07 |
| Writing submissions (text, score, word count, feedback) | Give the child written feedback on their writing | Consistent with best interests, with a short retention limit | Feedback on their own words is the whole value of writing practice. Writing is the child's most personal content, so the raw text is erased about 24 hours after it is written; only the score, word count and feedback are kept. The feedback may quote a short phrase. | 2026-10-07 |
| Masterclass progress and chalkboard / whiteboard history | Let the child resume a lesson where they left off | Consistent with best interests, with a short retention limit | Resuming saves the child repeating work. The board working is blanked about 24 hours after the lesson was last touched, because after that it has no use to the child. | 2026-10-07 |
| Session information (sign-in and finish times, duration, attempted and correct counts; an optional end-of-session note) | Show the parent when and how much the child practised; keep a practice sitting together | Consistent with best interests | Lets a parent support a healthy, steady routine. The end-of-session note is optional and can be left blank. | 2026-10-07 |
| Skill progress and daily totals (derived from practice responses) | Show strengths and weaknesses; the readiness estimate on the parent dashboard | Consistent with best interests | Derived from information already held; adds no new collection. It helps the parent direct practice to where it helps most. | 2026-10-07 |
Uses and disclosures of children's information
| Use or disclosure | Purpose | Assessment | Reasoning | Date |
|---|---|---|---|---|
| Showing a child's practice, scores and writing to their parent or guardian | Parental oversight and support | Consistent with best interests | A child of 10 to 12 benefits from an adult who can see how they are going. The child is told this on first sign-in and in the children's privacy policy (draft Code section 33). | 2026-10-07 |
| Sending answers (for hints and explanations) and writing text (for feedback) to Anthropic (United States) | AI hints, explanations and writing feedback | Consistent with best interests, subject to separate parent consent | The help is immediate and tailored to the child's own work. Only the question, the answer and the writing are sent — no name, contact detail or account identifier. Anthropic does not train its models on API data by default. The parent can withdraw the AI-processing consent at /settings/consent. | 2026-10-07 |
| Hosting all information with Railway (United States) | Run the service | Consistent with best interests | Korva cannot operate without hosting. No information is sent to Railway for any other purpose. | 2026-10-07 |
| Stripe and Postmark | Payment and the two account emails | Not a disclosure of children's information | Both receive parent information only. | 2026-10-07 |
| Direct marketing, advertising, sale, profiling for any purpose other than choosing practice | — | Not done | None of these is in a child's best interests. Korva does none of them. | 2026-10-07 |
Information Korva deliberately does not collect
Each of these is a minimisation decision (draft Code section 9): Korva can provide its full service without it, so it is not asked for and there is no field for it.
| Not collected | Why not |
|---|---|
| Real name or surname | A nickname does everything a name would. A real name would let information be linked to the child outside Korva. |
| Date of birth or age | Korva applies the draft Code to everyone (section 8(5)), so it needs no age check. Every profile uses the same Year 6 programme. |
| Year or grade level | The programme is fixed at Year 6 for everyone, so asking would collect information for no purpose. |
| School | Not needed for practice, and would identify the child's location and community. |
| Address, phone number or location | Korva never contacts a child, and practice does not depend on where the child is. |
| Photo, video or voice | No feature needs them. |
| Sensitive information (Privacy Act section 6: health, religion, ethnicity, biometrics and the rest) | No feature needs it, so draft Code section 10(2) and the assent duty in section 20(1)(b)(i) do not arise. |
| Contact details for the child | Children have no email address and are never sent anything. |
Review
This assessment is reviewed at least once a year with Korva's annual privacy review (draft Code section 25), and before any new kind of information about children is collected. Next review due: 2027-10-07.