01What Verifi is, and what it is not
Verifi lets a learner explain their own coursework, spoken, typed or in a faculty-led conversation, and gives the instructor an organised, sourced summary of that explanation to read before the instructor decides what happens next. Its purpose is to make a human conversation about understanding practical at scale.
- No software output is a mark, a verdict or a judgement about a learner. Every decision of record is a named member of faculty's, recorded with their reason, and it cannot be edited after it is recorded.
- There is no AI-content detection, no proctoring, no biometrics and no behaviour analysis. The system does not try to work out whether a learner used AI, and records no risk of any kind.
- Learners never see an AI signal. What a learner sees is what their instructor chose to publish.
- The AI's suggestions to faculty are recorded with what the person did with them: accepted, edited or rejected. That record is the human-oversight record an EU AI Act deployer needs.
We treat Verifi as a high-risk use in education under the EU AI Act and design for Article 14 human oversight and Article 26 deployer duties accordingly. The instructions for use and the technical file are listed under Documents.
02Where each claim stands
Three states only. In place means a DPO could verify it today. In progress means work exists and is not finished. Planned means nothing exists yet. Certification and conformance are words for an auditor to write, not for this page.
- EU AI ActIn progress
- Treated as a high-risk use in education. Human oversight is by design: every decision of record is a named person's, and the AI's suggestions are recorded with what that person did with them. Exportable oversight records and the Annex IV technical file are in progress.
- GDPR / UK GDPRIn progress
- Data processing agreement on Article 28 terms is in preparation for pilots. The privacy notice covers what is recorded, the lawful basis, retention and learner rights.
- Data residencyIn progress
- Single-region hosting today; the region and every subprocessor are named in the trust pack. Customer-selectable residency is not offered yet.
- DPIA supportIn progress
- A DPIA input pack (processing description, data flows, retention schedule, human-oversight design) is being assembled for pilot institutions.
- SubprocessorsIn progress
- The list of subprocessors (hosting, media storage, transcription and question generation) is published in the trust pack and changes are notified in advance.
- FERPA postureIn place
- Student-consented context only; nothing is scraped from the LMS beyond the assignment being verified.
- Data ownershipIn place
- The institution owns its data and can export or erase it.
- Model-training policyIn place
- Student data is never used to train models.
- Retention and deletionIn place
- Per-activity recording windows, a scheduled purge, per-learner export and audited erasure. The window is an institution setting.
- Audit and human controlIn place
- Faculty decisions cannot be edited after they are recorded; deletion happens only through audited institutional erasure. Full provenance for every AI suggestion, and an exportable per-session oversight record.
- EncryptionIn progress
- In transit everywhere. At rest: requested on every media object and backup; verification of the host volume is pending, so it is stated as in progress until it is.
- Accessibility conformance reportIn progress
- WCAG 2.2 AA is the target; typed, audio and faculty-led paths are equal. An accessibility conformance report is being prepared.
- LTI 1.3In progress
- Blackboard and Canvas launch, roster (NRPS) and completion passback (AGS) are built; a round-trip inside a customer LMS is still pending.
- Institutional SSO / SAMLPlanned
- Not built yet. OIDC federation (Entra, Okta, Google; Shibboleth via a bridge) is the next identity milestone and replaces the closed demonstration gate before any institutional rollout. No self-service accounts.
- Multi-factor authenticationPlanned
- Not built yet. TOTP on the demonstration gate is scheduled ahead of federation.
- SOC 2Planned
- Type II audit is planned and not yet certified.
03Hosting and infrastructure
These are the third parties that may process personal data on an institution's behalf. If a party is not on this list, it does not receive personal data from the product. The list is maintained with the deployment runbook and reviewed on the date shown above.
| Party | Role | Data | Region | Notes |
|---|---|---|---|---|
| Hetzner Online GmbH | Virtual machine hosting the application, the database and, in local-storage mode, media | All product data | Germany | One stateful host. The database is a SQLite file on the VM disk; disk-level encryption of that volume is not yet verified (see Encryption). |
| Cloudflare, Inc. | Tunnel and DNS in front of the application; TLS termination at the edge | Request metadata in transit | Global edge (EU and US points of presence) | No product data is stored at Cloudflare. |
| Backblaze, Inc. | Private object storage for raw recordings and nightly database backups (S3-compatible API) | Raw audio and video recordings; database backups | Set per deployment. An EU institution is provisioned an EU bucket and the region is stated in its DPA annex. | Private bucket; every object is written with server-side encryption requested; playback only through 90-second signed links issued to authenticated faculty. |
04Model and speech providers
Which provider is active is a deployment decision made through configuration, and the deployment's DPA annex records the choice. Every call is written to an AI-call ledger with its purpose, provider, model and prompt version, and the per-session oversight record exports it.
| Purpose | Provider | Data sent | Retention at provider |
|---|---|---|---|
| Claim mapping, question generation, evidence summaries, interview probes, question translation | Anthropic, PBC (Claude API) when configured for the deployment; otherwise a built-in deterministic stand-in with no network calls | Submission text, transcripts, the assignment prompt and rubric. No learner name or email is included in any prompt. | Per the provider's API data policy. The product does not opt into training and sends nothing for that purpose. |
| Transcription of recordings | OpenAI (speech-to-text API) when configured; otherwise the built-in stand-in | Raw audio, for transcription only | Per the provider's API data policy |
| The interviewer's voice (text-to-speech) | Self-hosted on the same VM. ElevenLabs or Fish Audio may be enabled as an optional voice vendor for a deployment; they are off unless configured. | Question text only, never learner speech | None on the host; per vendor policy if an optional vendor is enabled, and the deployment's DPA annex says so |
05Not subprocessors
- The institution's LMS (Canvas, Blackboard) is the institution's own system. Verifi is a tool the institution connects to it through LTI 1.3; nothing is read from the LMS beyond the assignment being verified and the roster the institution chooses to share.
- Eklipse Technologies staff may access the production host for operations under named operator roles. They are the processor, not a subprocessor, and their access is logged.
06Encryption, honestly
- In transit: TLS everywhere, terminated at the edge and carried to the host over a private tunnel.
- Object storage: server-side encryption is requested on every recording and backup written, and is expected to be the bucket default.
- Database and local media on the host: the runbook does not yet record an encrypted volume.
Until an operator has verified an encrypted volume under the database, the honest state for encryption at rest is In progress, and every questionnaire answer we give says so. We would rather a reviewer read that here than discover it later.
07Data residency
Single-region hosting today, in Germany, with recording storage in the bucket region recorded for the deployment. Customer-selectable residency is not offered yet. Transfers to model providers are covered by the provider's standard contractual terms and are listed in the DPA annex; an institution that requires no transfer outside its region can run the deployment on the built-in stand-in providers at the cost of question quality, and we will say so plainly rather than pretend otherwise.
08Security practices in plain terms
- Faculty sign-in is closed by default: an access code and a participant allowlist, both supplied out of band, and no self-service accounts. Institutional SSO is planned and not built; the sign-in page says the same.
- No passwords are collected anywhere in the product. Learners reach a verification from the LMS or a secure link, never an account.
- Failed sign-in attempts are throttled and locked out. Only a hash of a coarse requester hint is kept; no raw address or user agent is stored.
- The audit log is append-only at the database level: triggers refuse updates and deletes. Faculty decisions cannot be edited after they are recorded.
- Recordings are played back only through 90-second signed links issued to authenticated faculty, and every access is logged.
- Nightly backups are taken consistently, kept for 14 days on the host and copied off-host to private object storage.
- The incident response procedure names an incident lead, a data-protection contact and the institution's contact, and commits to notifying an affected institution within 24 hours of an incident being confirmed, with what is not yet known stated as such.
No third-party penetration test has been commissioned yet and no SOC 2 report exists. Both are planned. A reviewer who needs either before a pilot should say so; we will not describe internal testing as if it were an external one.
09Documents for a procurement review
| Document | Where | State |
|---|---|---|
| Privacy notice (the learner-facing text, adoptable by the institution) | /privacy | Published |
| Accessibility statement (self-assessment against WCAG 2.2 AA) | /accessibility | Published |
| Pilot terms | /terms | Published |
| Data processing agreement on Article 28 terms, with annexes for data categories, retention, subprocessors and transfer mechanisms, and technical and organisational measures | On request from [email protected] | Template ready for counsel |
| Incident response procedure | Shared with institutions under the DPA | In place |
| Instructions for use (EU AI Act Art. 13) and technical documentation on Annex IV headings | On request | In progress |
| DPIA input pack: processing description, data flows, retention schedule, human-oversight design | On request | In progress |
| HECVAT or an institution's own vendor questionnaire | Answered on request | Not yet published |
| Accessibility conformance report (VPAT or ACR) | With the independent audit | Planned |
10Change control
A new subprocessor is added to this page, the DPA annex and the privacy notice in the same change, before it receives any data. Institutions on a signed DPA are notified in advance under the notice period the DPA sets. The review date at the top of this page moves whenever any row changes.
11Contact
Security, privacy and procurement questions go to [email protected], the one mailbox in use today, read by a person. Put Security, Privacy or Procurement in the subject line. A responsible disclosure of a vulnerability is answered within two working days, and we will not act against anyone who reports one in good faith.