Provider and transfer evidence

Providers, storage and transfers

Working inventory of relevant external services. Roles, contracts and processing must match the municipality's actual feature scope; the list alone does not authorise sub-processors.

Review draft v0.12. Content revised: November 12, 2026.

Provider/service
Google / Firebase Authentication
Purpose
Authentication and account identity, including guest and Feide login.
Personal data
User/provider ID, available name/email, login metadata and password-related authentication data for password accounts. Provider security may use IP/device data.
Location and open points
Google documents US processing for Firebase Authentication. The Cloud DPA and transfer terms have been reviewed; Google states DPF applies to relevant EU/EEA–US transfers, with SCCs where applicable under the agreement.
Role and status
Technical sub-processor. The contracting party, customer registration and documented agreement acceptance are being reconciled with Google. This is an open documentation point, not a conclusion that existing agreement coverage is absent.
Provider/service
Google Cloud Firestore
Purpose
Database for accounts, rooms, tasks, work, feedback and administration.
Personal data
Profile/role data, Space membership, submissions, text/results, feedback, content/admin data, events and timestamps.
Location and open points
Database (default) in project skole-c09b8: europe-west1 (Belgium). Fjord Service checked the storage location in Firebase Console and Google Cloud Console on October 18, 2026.
Role and status
Technical sub-processor. Contract terms, other processing and support access are assessed separately from the confirmed storage location.
Provider/service
Firebase Storage / Google Cloud Storage
Purpose
Storage of student audio, podcast segments, images and attachments.
Personal data
File bytes, object metadata and user/room/activity/submission links. Historical references and access links require assessment.
Location and open points
Bucket skole-c09b8.firebasestorage.app in project skole-c09b8: regional storage in europe-west1 (Belgium). Fjord Service checked the storage location in Firebase Console and Google Cloud Console on October 18, 2026.
Role and status
Technical sub-processor for files. Private file handling is deployed. Old download tokens for the mapped audio set are revoked and checked. Daily copying of finalised stored files is active. Retention, other processing and support access are assessed separately from storage location.
Provider/service
Sikt / Feide
Purpose
School-controlled authentication and agreed identity attribute disclosure.
Personal data
Attributes listed in the Feide portal: userinfo-name includes givenName, sn, norEduPersonLegalName, displayName and cn; userid-feide includes eduPersonPrincipalNamePrior, eduPersonPrincipalName, uid, eduPersonTargetedID and eduPersonUniqueId; email includes mail. These are configured requested fields, not proof that every field is received or stored. Feide identifiers must be distinguished from the Firebase UID.
Location and open points
Norwegian identity service. Current Sikt agreement, locations and roles must be checked with the school owner.
Role and status
Identity service when used; its contract chain is not automatically Fjord Service's sub-processor chain.
Provider/service
Vercel
Purpose
Web hosting, delivery and server processing of application requests.
Personal data
IP, browser/request metadata and logs; server routes also process submitted text, file bytes and feedback for relevant features.
Location and open points
Production Vercel Functions run in Frankfurt (fra1), verified during deployment on 28 October 2026. The move does not automatically change processing locations for Firebase Authentication, OpenAI, Resend or other services, nor does it confine all logging, CDN, build and support processing to the EEA.
Role and status
The Pro DPA includes SCCs. Other processing countries and relevant subprocessors are recorded in the provider annex.
Provider/service
OpenAI
Purpose
Selected AI features: content, feedback, text/image and speech tools.
Personal data
Prompts, task/reading text, answers, results and relevant context. Image/audio data depends on the feature. Teacher-requested feedback may process student data.
Location and open points
Project Residency Global is confirmed in an account image. This specifies neither one country nor EU-only processing. Responses, files, cache and security logs have separate retention rules.
Role and status
321school uses OpenAI Platform/API. The owner reports a DPA signed on 23 October 2026. Account images show all three sharing options disabled, API call logging Enabled per call and Project Residency Global. OpenAI states API data is not used for training without opt-in. Global is neither an EU restriction nor a single processing country. Response storage, Files, prompt caching and security logs have different rules; no general zero-retention guarantee is given. Explicit store:false in the selected text calls was deployed on 28 October 2026. This does not change the other retention rules.
Provider/service
Resend
Purpose
Transactional email, invitations and account messages.
Personal data
Recipient address, message content, invitation/account context and delivery metadata. Answers must not be included as default email content.
Location and open points
The reviewed DPA states primary processing in the US, incorporates SCCs and states DPF participation. Account-specific periods for message and log categories are checked separately.
Role and status
The DPA was obtained from the account and reviewed. Its wording makes it binding through acceptance of the service agreement or execution; the customer’s exact acceptance date has not been checked. Relevant certification scope is checked when relying on DPF.
Provider/service
Stripe
Purpose
Payments, subscriptions and billing.
Personal data
Paying customer name/email, customer ID, subscription, payment/billing information. Not a general recipient of all student work.
Location and open points
Entities, contract, countries and onward payment processing must be checked for the payment setup.
Role and status
Provider for paid customer relationships; role and relevance are separate from student data.
Provider/service
Google Analytics
Purpose
Previous page/product analytics; disabled in the published code policy.
Personal data
When previously active: page/event and technical user/device data. Historical retention is assessed separately.
Location and open points
Google infrastructure; account-specific processing, transfers, contract and retention not fully documented.
Role and status
Google Analytics and application product analytics are disabled in the published service, regardless of role. Necessary operational/security logging and educational statistics are separate purposes and are not disabled by this measure. Aggregate statistics are not necessarily anonymous, especially in small groups.
Provider/service
YouTube / Google
Purpose
External instructional videos when opened or embedded.
Personal data
Technical viewing/connection data depending on playback/embed configuration.
Location and open points
External service locations, cookies and terms require assessment for the selected use.
Role and status
External content; not automatically a sub-processor under the school agreement.
Provider/service
Daily.co
Purpose
Optional video/course features if used.
Personal data
Participant/session identifiers, connection metadata and any media for the chosen feature.
Location and open points
School use, setup, countries, retention and contract must be confirmed before inclusion.
Role and status
Optional; not documented as part of the municipality's agreed scope.

About the provider overview

  • • The providers covered by school use and the terms of processing are specified in the data processing agreement and annex C.
  • • European storage does not necessarily mean that all processing takes place within the EEA. Processing countries and the basis for any transfers are clarified for each provider.