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L3-M2 / lesson 2 of 2

Document exceptions, profiling and registration

The buyer reviews a claimed high-risk exception.

10–15 min · 0/4 steps complete

Start here / A workplace decision

Document the exception analysis

The buyer reviews a claimed high-risk exception.

Performance data is used to evaluate individual learners.

Before you read / Think it through

In “Document the exception analysis”, what would you check or do first?

Pause and form your answer, then compare the reasoning. This reflection is not scored.

Compare the reasoning

Examine whether profiling is involved and its effect on the exception analysis.

The ideas below give you a method for this decision. Then work through the rest of this case and try the decisions yourself.

Part 1 of 4 Learn the ideas
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Profiling overrides the exception

An Annex III system profiling natural persons remains high-risk under Article 6(3).

Assess automated evaluation of personal aspects.

In the workplace

Course recommendations based on inferred performance may involve profiling. The mere presence of personal data is not the same as profiling.

Remember this

A human reviewer does not remove the profiling rule.

The workplace case
YOUR CASE / HIGH-RISK CLASSIFICATION IN DEPTH

A supplier offers three education features: sorting uploaded files, recommending a learner's next course from performance data and evaluating exam answers. It claims all are preparatory because teachers can override them. A public institution plans to use the evaluation feature.

Quick reference / five key ideas
Profiling overrides the exception
A human reviewer does not remove the profiling rule.
Provider documentation
Make the documentation available to authorities when required.
Registration routes
Annex III critical-infrastructure systems have a national route.
Product and sectoral routes
Check overlaps with Annex III and sectoral assessment routes.
Reviewable conclusions
Reassess changes in purpose, profiling or decision influence.