Classroom observation only works when everyone in the building knows what happens to the record afterwards. This note sets out what Learning Lens does with observation data, what it deliberately does not do, and the commitments that follow — written to be read by headteachers, local authority data protection officers, professional association representatives, and the teachers being observed.
It summarises the procedural commitments that follow from how the product is built. The architecture summary behind it, setting out the role-based visibility model in full, is available on request.
The standards this is built against
Classroom observation in a Scottish secondary school sits inside an established framework of agreements and professional standards: SNCT handbook guidance, local LNCT agreements, GTC Scotland's Professional Update framework, professional association policy, and the long-settled separation between developmental classroom observation and competence procedures.
Learning Lens was designed against that framework rather than adapted to it afterwards. What follows is the specific account — ten commitments, each a statement about what the product does and does not do with teacher data, including the one place where what we have built today stops short of what a local agreement might ask for.
The ten commitments
1. Observation is developmental, not disciplinary.
Learning Lens is designed as an evidence layer for professional dialogue, self-evaluation under HGIOS4, and collaborative enquiry. Records are not intended for, and the Terms of Use contractually prohibit use in, competence procedures or disciplinary processes. There is no integration with HR systems, no export format compatible with competence documentation, and no data structure that supports a progress-against-expectation tracking model for individual teachers.
2. Observation records are visible to the teacher simultaneously with leadership.
It is worth being precise about this one.
Learning Lens records are stored in a shared school database. When an observer saves a visit record, that record becomes visible at the same moment to the teacher, to the observer, to the teacher's middle leader (if same department), and to senior leadership. The product does not implement a "teacher sees the record first, and decides when leadership sees it" sequencing model.
What it does implement — described in Commitment 4 below — is that the teacher has full access to their own record from the moment it is created, and can attach a written reflection to it. That reflection is held separately from the observer's record and is readable by the teacher alone: not by the observer, not by leadership, and not by us. It is a private professional space, not an annotation that leadership reads over the teacher's shoulder. The teacher can read their record, respond to it privately in writing, and export it.
Teacher-first sequencing is on the roadmap for 2027. We are not claiming it for 2026–27, because it is not built. If a school's local agreement requires teacher-first sequencing as a precondition for any observation infrastructure, that is better established now than after a pilot has started.
3. Individual teachers are not ranked, graded, or algorithmically flagged.
The product does not produce a score, grade, rating, or ranked position for any individual teacher. The taxonomy of 59 teaching practices is descriptive throughout. Quality emerges from patterns across many observations — and those patterns are surfaced to leadership at department, stage, or school level only.
There are no automated alerts naming individual teachers. Where the analytics surface a concerning pattern, they surface it at department level; the individual-teacher view of the same data belongs to the teacher, on their own dashboard.
4. Teachers hold, annotate, and export their own records — at the database level.
Every teacher sees their own practice dashboard with their Bright Spots, their patterns of practice across the year, their Strengths Signature, their observation conversations, and a private reflection space visible only to them.
These privacy rights are worth describing precisely, because they are enforced in the database rather than promised by the interface — and that is a materially stronger commitment.
Private reflection. The teacher's long-form reflection — the "My notes" space on their dashboard — is stored separately from observation records, and access is restricted to the teacher who owns it. There is no administrator bypass, no SLT exception, and no vendor support exception. A senior leader, an administrator, or a Learning Lens support operator cannot read another user's reflections at any layer of the product: not because an interface hides them, but because the database refuses the query.
Per-visit teacher reflection. A teacher can write a reflection on any of their own visit records. These reflections are held separately from the observer's record, readable and writable only by the teacher they belong to, and the database rejects any attempt to attach a reflection to a visit naming someone else. The observer's record itself — prose, tags, events, dates — cannot be modified by the teacher, and the database rejects that too. So a teacher cannot change what an observer wrote about them, and nobody but the teacher — not the observer, not leadership, not the vendor — can read what the teacher wrote in response.
Export rights. Teachers can export their own Practice Profile as a PDF at any time. The export is logged server-side.
"Teachers hold their own records" is an easy claim to make and a harder one to enforce, which is why it is worth being specific about where the enforcement lives. In Learning Lens it sits at the layer that no client-side code can bypass.
5. Observation is bounded and negotiated, not continuous.
The product supports two formats: a short Quick Visit (typically under ten minutes, for gathering patterns across a department on one focus question) and a longer Learning Visit (typically around twenty to thirty minutes, for a fuller professional conversation). Both are initiated by a named observer in the context of an agreed local arrangement. Observations require an observer and a named teacher; there is no covert, unannounced, or continuous observation mode. The product has no real-time dashboard showing which classrooms are currently being observed.
6. Leadership sees patterns; leadership does not see rankings.
Senior leaders see departmental, stage-level, and whole-school patterns aligned to HGIOS4 Quality Indicators, supporting their responsibilities under QI 1.3 and QI 2.3. They do not see dashboards that rank their staff against each other. There is no league table, no performance heatmap of named teachers, no sorted list of teachers by any quality metric.
A teacher viewing their own dashboard sees a comparison of their own practice coverage against their department average — a self-reflective tool. That comparison appears on the teacher's own dashboard only. It is deliberately not rendered on the leadership view of a named teacher's profile, because individual comparative analysis visible to a line manager is a structural concern regardless of how it is framed.
7. The framework is Scottish.
Learning Lens maps primarily to HGIOS4. Ofsted EIF mapping exists for schools in England. The product does not import Ofsted's evaluative language into Scottish schools and does not present English frameworks as primary to Scottish users. When HMIE's post-2025 inspection framework is published, we will update the product to reflect it; our framework layer is designed to be rapidly updated for this kind of change.
8. Separation from Professional Review and Development.
Learning Lens records are not PRD / Professional Update evidence unless the teacher chooses to include them. GTC Scotland guidance is explicit that learning and teaching should not be judged during PRD/PU, and the product respects that line. Observation under Learning Lens is professional dialogue evidence; the teacher decides what, if anything, becomes review evidence.
9. Observer data is also bounded.
Observers themselves have a visibility envelope. The Observer Calibration view — which supports moderation conversations between observers looking at their own team's patterns — includes a coverage-gap prompt ("this observer has never recorded practices in categories X, Y, Z") as developmental data for collaborative professional conversation. What it deliberately does not include is any measure of how far a named observer's capture habits diverge from the team average: that is evaluative measurement of an individual surfaced to leadership, and Commitment 3 applies to observers just as it applies to teachers.
10. Data handling is built for Scottish council procurement.
Data is hosted in AWS EU (Frankfurt), under UK-EU adequacy. The school is the data controller under GDPR; Learning Lens is the data processor. A Data Protection Impact Assessment support pack — a screening assessment, a pre-populated DPIA in ICO format, a security architecture summary, and a sub-processor register — is provided to schools and councils before implementation. Teacher-identifiable observation records can be exported or deleted on request. The product has been designed anticipating review by council Data Protection Officers and is structured to pass that review without operational pauses.
One specific commitment: every data export — PDF, bulk report, staff-meeting text — is logged server-side with the generator, timestamp, and scope. During the pilot year, the teacher's own dashboard will gain a record of exports containing their own data, so that the log is visible to the person the data is about and not only to us.
Security
The visibility rules set out above are enforced in the database, not in the interface. The distinction matters: interface rules can be worked around, database rules cannot. Data is hosted in AWS EU (Frankfurt) under UK–EU adequacy.
The platform is audited against the full codebase and database schema, and that audit is repeated ahead of each pilot rather than treated as a one-off. Our published security overview is at /security; the underlying security and architecture documentation is available to a school's or council's data protection officer on request.
How to use this document
This is written to be useful inside a school's own governance process rather than read once and filed. Three uses in particular.
Briefing staff. The ten commitments answer "what happens to the record afterwards?" — the question teachers ask first about any observation programme.
Checking or negotiating a local agreement. Learning Lens is designed to sit inside, not replace or circumvent, any LNCT or JNCT agreement already in place. The commitments above map onto the procedural floors typical of those agreements: teacher-held notes, bounded frequency, non-disciplinary use, right to respond, developmental framing. Where a local agreement has provisions stricter than the product's defaults, the product's settings can be configured to match.
If your school does not yet have a local agreement covering classroom observation, we would recommend negotiating one before a pilot begins. We can share templates drawn from existing Scottish council agreements, though we have no preference as to their content — that is properly a matter for the school and the local association.
Completing a DPIA. Commitment 10 summarises the data protection position; the full support pack, including a pre-populated DPIA in ICO format and a sub-processor register, goes to the council's data protection officer before implementation rather than after a request.
Questions we welcome
We would rather test these commitments against a critical reading before a pilot than after one. In particular:
- If any commitment here is inadequate, we want to know where and why.
- If there is a procedural safeguard typical in Scottish local agreements that we have not addressed, we want to know what it is.
- If anything described here as on the roadmap ought to be in place before a pilot rather than after it, that is worth saying now.
Verifying this document
These commitments are meant to be checked rather than taken on trust. For a school or local association considering a pilot, we can provide:
- An architecture summary setting out the role-based visibility model and how it is enforced
- A security overview covering hosting, access control, and audit practice
- The Data Protection Impact Assessment support pack for your council's DPO
- A technical conversation to answer questions on any of the above
Contact
Jamie Scobie, founder, Learning Lens — jamie@mylearninglens.app
Learning Lens is Jamie Scobie, trading as Learning Lens. ICO registered (ZC200575). Working with schools in Scotland from academic year 2026–27.
This document may be shared freely. It does not require permission to forward — to colleagues, to a local association, to a data protection officer, or to anyone else weighing up how classroom observation data should be handled.