AI Impact Assessment

PROODOS EduAI is a doctoral research platform developed at the International Hellenic University (IHU), Thessaloniki, for the professional development of K-12 teachers in artificial intelligence literacy. The platform is structured around the UNESCO AI Competency Framework for Teachers, in 15 modules followed by a synthesis Epilogue, and uses AI-generated feedback as a core pedagogical mechanism.

PROODOS is the empirical instrument of John Dourvas's doctoral dissertation, under the supervision of Assoc. Prof. Georgios Kokkonis, Department of Information and Electronic Engineering.

Seven AI-driven features are active during a participant's journey:

• RAG-based reflection feedback: after each module's reflection submission, a retrieval-augmented generation pipeline (Google Gemini 2.5 Flash) produces a personalised feedback narrative grounded in pedagogy literature.
• Reflective Tension Mapper (RTM): from the participant's reflection text, the system extracts up to two pedagogical tensions and asks the participant to self-position on a 5-point scale between two contrasting poles.
• Developmental Trajectory Predictor (DTP): a narrative summary of the participant's reflection trajectory across modules. Available from Module 2 onwards.
• Peer synthesis: drawing on pseudonymised peer reflections, this produces a comparative view of how other participants engaged with the same content.
• AI Literacy Sandbox: an optional practice environment unlocked after Module 5. Participants construct prompts across 48 curriculum-anchored scenarios (8 subject clusters × 6 responsible-prompting strategies) and receive AI-generated responses from Google Gemini 2.5 Flash. Sandbox sessions are recorded as research data per the research participation consent.
• Aletheia help chat: an assistant available on every page while you are signed in (Google Gemini 2.5 Flash) that answers questions about the platform and its modules from the platform's own help material. The conversation is kept only in your session and is cleared when you log out.
• Practice Workshop facilitation (Module 10): when an annotated Module 10 workshop post has received no response, an AI facilitator, labelled "Aletheia · AI", may post a short response to it (Google Gemini 2.5 Flash).

After Module 15, the PROODOS Epilogue presents a Personal Evolution Dashboard synthesising the participant's developmental trajectory across the 15 modules. The Epilogue is a non-AI synthesis surface: it aggregates existing AI outputs (DTP themes, RTM tension trajectories) and existing platform telemetry into a single read-only view; no new AI inference runs during the Epilogue itself.

Under our assessment of Regulation (EU) 2024/1689 (the EU AI Act), as amended by Regulation (EU) 2026/1744, PROODOS is classified as a Limited Risk AI system falling under Article 50 transparency obligations.

The platform:

• Does not produce automated decisions about participants' professional, academic, or employment standing.
• Does not perform biometric identification, social scoring, or any practice listed as Prohibited (Article 5) or as High-Risk (Annex III).
• Generates content that the user reviews and may dispute (see Section 4).

The AI's role is assistive and pedagogical: it surfaces patterns, asks reflective questions, and offers commentary. Authority over interpretation remains with the educator.

Per Article 50 and the spirit of Article 14 (human oversight) of the EU AI Act:

• Explicit consent: use of AI assistance is disclosed, and must be acknowledged, before any AI feature is used, and is revocable at any time from the Privacy dashboard.
• Output dispute: the four reflection-analysis outputs (RAG feedback, RTM, DTP and peer synthesis) each carry a dispute submission button. Flagged outputs feed back into the research dataset for AI-alignment analysis.
• No automated decision-making: AILST self-assessment scores are computed deterministically from the participant's own responses; no AI inference is involved in score calculation, gating, or certification.
• Pedagogical framing: AI feedback is presented as one voice among many, not as authoritative pronouncement. Module copy reinforces this stance throughout the programme.
• Continuous evaluation: AI dispute submissions, RAG telemetry, and AILST trajectory data are part of an ongoing research programme to refine the AI's pedagogical alignment.

Lawful basis under the EU General Data Protection Regulation (GDPR, Regulation 2016/679) and Greek Law 4624/2019:

• Primary basis: Article 6(1)(a) — explicit informed consent, captured at onboarding Step 3.
• A small number of optional fields (for example, gender) could be considered a special category under GDPR Article 9. Where that applies, the same explicit consent covers it, together with the safeguards Article 9(2)(j) requires for scientific research.

This page explains, in plain language, how PROODOS works and what it does with your data. It is not legal advice, and it does not interpret the law on your behalf. For an authoritative reading, contact the IHU Data Protection Officer (dpo@ihu.gr) or the Hellenic Data Protection Authority.

Retention and identifiers:

• Research data is retained for three years after data collection for this research ends, then transformed as described in the Privacy Policy. Participants can request this transformation earlier via the Privacy dashboard's account anonymisation action.
• Within the platform, only the two research staff accounts (the Principal Investigator and the Academic Supervisor) can see analytics broken down by individual participant, identified there by your account username — not your full name or email. Data that leaves this internal use, for example for publication or for analysis outside these two accounts, is pseudonymised. Free-text fields that may contain identifiers are cleared on participant-initiated erasure.
• IP addresses are captured at consent time only, automatically redacted after 30 days, and immediately cleared on erasure.

Optional data sharing for secondary research: a separate consent allows pseudonymised data to be used in further analyses approved separately by the IHU Research Ethics Committee. Optional and revocable independently of primary research consent.

Guaranteed by GDPR Articles 7, 15, 17, and 21 and operationalised in the Privacy dashboard at /profile/privacy/:

• Withdraw any consent at any time (Article 7(3)): three independent revoke endpoints, one per consent type.
• Download a full copy of your personal data in JSON format (Article 15).
• Anonymise your account permanently (Article 17): identifying information is removed; pseudonymised research data remains attached to an anonymous account and is excluded from future analyses through the opt-out flag set at the same time.
• Object to processing or contact the research team for questions about your data (Article 21).

For questions about this platform's AI use or your data:

• Principal Investigator: John Dourvas, doctoral researcher - idourvas@ihu.gr.
• Academic Supervisor: Assoc. Prof. Georgios Kokkonis - IHU, Department of Information and Electronic Engineering.
• Institution: International Hellenic University (IHU, Διεθνές Πανεπιστήμιο της Ελλάδος), Thessaloniki.

This document is version v10_omnibus_cited (October 2026). It updates v9 so that §3 cites the EU AI Act as amended by Regulation (EU) 2026/1744. The approval note is unchanged: this platform's research protocol has been approved by the IHU/ΔΙΠΑΕ Research Ethics Committee (ΕΗΔΕ), Αρ. Πρωτ. 229/2026 (Session 35, 14 September 2026).