1. Purpose and Scope

This statement explains how SEN Tools, provided by The Anthill Group (ICO Registration: ZB945587), uses artificial intelligence to assist education professionals in analysing Education, Health and Care Plans (EHCPs) and related SEN documentation. It is intended to support Data Protection Officers, Information Governance leads, and senior leadership teams in understanding the technical architecture that protects pupil data.

2. How AI Is Used

SEN Tools uses generative AI, accessed via secure API connections, to process anonymised document text and produce structured outputs. The AI is used to:

Generate SMART plans from EHCP outcomes
Create Support Snapshots summarising behavioural, medical, and safety needs
Produce pupil profiles (About Me) from strengths and Section A content
Organise instructional and environmental strategies (Strategy Builder)
Summarise provision requirements (Provision Summary)

All outputs are advisory and intended as a starting point for professional review. They are not a substitute for professional judgement.

3. AI Providers

SEN Tools uses API-based AI services from providers such as OpenAI and Anthropic. These are commercial API services, not consumer-facing products like ChatGPT. Our architecture is model-agnostic — we can utilise the best available AI engine without any change to the data protection position, because the specific provider is irrelevant to the school's risk profile. This is explained in the next section.

4. The Anonymisation Bridge

The Anonymisation Bridge is a server-side middleware layer that sits between SEN Tools and any external AI provider. It ensures that no personally identifiable information (PII) ever leaves our UK infrastructure.

How It Works

Detection and Tokenisation: Before any text is sent to an AI provider, the Anonymisation Bridge scans the document and replaces all PII with neutral tokens. For example:
- “Jayden” becomes “[NAME_1]”
- “Mrs Thompson” becomes “[NAME_2]”
- “15/03/2018” becomes “[DOB_1]”
- “SW1A 1AA” becomes “[POSTCODE_1]”
- NHS numbers, UPNs, emails, and phone numbers are similarly tokenised
AI Processing: The AI provider receives only the tokenised text. It processes the request and returns a response that still contains only tokens — never real data.
Restoration: Our server restores real values from a temporary in-memory vault. This vault is never logged or persisted to disk and is destroyed immediately after de-anonymisation.

Why This Matters

Traditional AI tools rely on contractual guarantees — a Data Processing Agreement with the AI provider that promises not to misuse your data. SEN Tools takes a different approach: the AI provider physically cannot access personal data because it never receives it. This is an architectural constraint built into how the system works, not a policy promise.

5. Categories of PII Protected

The Anonymisation Bridge detects and tokenises the following categories:

Category	Examples	Token Format
Names	Children, staff, family members	[NAME_1], [NAME_2]
Dates of birth	DD/MM/YYYY, YYYY-MM-DD	[DOB_1]
UK Postcodes	SW1A 1AA, M1 1AA	[POSTCODE_1]
Phone numbers	07xxx xxxxxx, +44 7xxx	[PHONE_1]
Email addresses	user@example.co.uk	[EMAIL_1]
NHS numbers	3-3-4 digit pattern	[NHS_1]
Unique Pupil Numbers	Letter + 12 digits	[UPN_1]

6. No AI Training

SEN Tools uses API-based AI services that do not train on, or learn from, your submitted content. Your data is used solely to generate the output you have requested. Additionally, because of the Anonymisation Bridge, even the anonymised tokens sent to AI providers contain no real personal information.

7. Human Oversight

All AI-generated outputs from SEN Tools are advisory only. They are designed to save time and improve clarity, but they are not a substitute for professional expertise. Users must always review, verify, and adapt generated outputs for the individual child's needs before use. SEN Tools does not make decisions about children — professionals do.

8. Accuracy and Limitations

AI-generated content may:

Contain errors or omissions
Misinterpret ambiguous text in source documents
Produce outputs that require professional adjustment
Vary in quality depending on the clarity and completeness of the source document

Users are responsible for verifying all outputs against the original documentation and applying their professional judgement before relying on any AI-generated content.

9. Audit Logging

SEN Tools maintains audit logs that record tool usage for accountability purposes. These logs record which tool was used, when it was used, and the type of processing performed. Audit logs do not contain any personally identifiable information about the children whose documents are processed.

10. DfE Generative AI Product Safety Standards

SEN Tools is designed to align with the Department for Education's “Generative AI: Product Safety Standards” (updated January 2026). In particular:

The intended purpose and educational use cases are clearly stated
The platform complies with UK GDPR and the Data Protection Act 2018
Data processing, sub-processors, and data residency are fully transparent
Pupil data is never used to train AI models
Audit logging is maintained for accountability
The Anonymisation Bridge ensures the tool operates as a “closed” system with respect to personal data

11. Contact

For further information about our AI architecture or to request a detailed technical briefing, please contact:

The Anthill Group

ICO Registration: ZB945587

Email: privacy@theanthill.co.uk

Address: 13a Park Street, Minehead, Somerset, United Kingdom, TA24 5NQ

AI Transparency Statement