‘Scan First, Act Later’ The Pitfalls of Isolated AI Implementation in Education

COMPLIANCE

How to cite this learning scenario

Arantes, J. (2025). Scan First, Act Later. www.AI4education.org. Licensed under a Creative Commons Attribution 4.0 International License.
abstract
This scenario-based learning activity engages participants in critically analysing the governance, ethical, and operational challenges of implementing AI systems in education without adequate ecosystem scanning or stakeholder consultation. It centres on the real-world implications of siloed decision-making, particularly when digital tools designed to support student outcomes are adopted in haste. Learners are invited to reflect on the unintended consequences of such practices, including overlaps with existing technologies, staff resistance, and student disengagement. By unpacking this case, participants will explore practical strategies for embedding human oversight, ensuring transparency, and strengthening institutional readiness for AI deployment through participatory and consultative approaches to meet basic compliance mechanisms.

When systems are deployed without scanning the ecosystem they enter, failure isn’t a possibility—it’s a certainty in slow motion."

The Pitfalls of Isolated AI Implementation in Education

A mid-sized dual-sector university is under pressure to demonstrate improvements in student retention and timely completions. In response, the executive team fast-tracks the adoption of a commercial AI-driven Early Warning System (EWS) to monitor academic engagement and predict student dropout risks. The vendor claims the tool complies with international best practice and assures alignment with Australian data privacy regulations, though no internal compliance check is performed prior to deployment. Crucially, the implementation bypasses the University's Academic Board, digital learning committee, and legal department. Staff in student support, academic advising, and digital learning are unaware of the rollout, despite having developed a homegrown student engagement dashboard that aligns with pedagogy and known student contexts. The new AI tool duplicates some of its functionality, uses opaque algorithms, and performs sentiment analysis on student emails—without any explicit consent or privacy impact assessment. Once live, confusion spreads among staff about which system to use. Students begin receiving automated alerts from the EWS without context or follow-up, including those who are high-performing but flagged due to inconsistent attendance. An international student advocates group raises concerns that non-domestic students are disproportionately identified as “at-risk,” prompting fears of algorithmic bias. A compliance review reveals the system has not undergone a Privacy Impact Assessment (PIA), breaching internal policy and possibly the Privacy Act. Faculty unions and the Student Union call for an immediate suspension of the system, citing lack of transparency, potential discrimination, and misuse of personal data. The university is forced to publicly respond, review its procurement procedures, and engage external legal counsel. The case is escalated to the Office of the Australian Information Commissioner (OAIC) for possible investigation.
NB This Scenario is situated in Australia

Research Topics

Research Questions

Identify governance, compliance, privacy, and equity risks in AI tool implementation in education. Analyse how poor consultation and risk scanning undermine trust and institutional readiness. Apply ethical and legal frameworks (e.g., Australian Privacy Principles, GDPR, eSafety guidelines) to evaluate AI deployments. Develop strategies for transparent, compliant, and consultative AI adoption in educational institutions.
What compliance breaches occurred in this scenario, and how could they have been prevented? How did the lack of governance structures contribute to the system’s failure? What processes should be in place to ensure that AI tools align with legal and ethical standards? How might the situation have been different if students and staff were meaningfully consulted? What lessons does this scenario offer about the relationship between trust, data ethics, and educational technology?

Data Collection

Governance and Risk Mapping Workshop Groups examine the governance failures in the scenario, mapping where consultation, compliance, or human oversight was absent. They propose actionable strategies using existing frameworks (e.g., AI Ethics Principles, ISO/IEC 42001, GDPR). Crisis Role-Play Simulation Participants act as stakeholders (VC, student union rep, compliance officer, faculty member, vendor) to simulate a governance crisis meeting. Their task: negotiate a way forward, including next steps for internal review, public communication, and long-term governance reform. Institutional AI Readiness Audit Design Participants create a checklist or diagnostic tool to assess AI readiness at their institution. The audit must include sections on compliance (e.g., PIA), ethical risk, stakeholder engagement, transparency, and explainability.
Suggested article: https://journalsonline.academypublishing.org.sg/e-First/Singapore-Academy-of-Law-Journal/ctl/eFirstPDFPage/mid/568/ArticleId/2532/Citation/eFirstPDF

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Acknowledgement of Country We acknowledge the Ancestors, Elders and families of the Kulin Nation (who are the traditional owners of the land. where this work has bene predominantly completed. As we share our own knowledge practices, we pay respect to the deep knowledge embedded within the Aboriginal community and recognise their ownership of Country. We acknowledge that the land on which we meet, learn, and share knowledge is a place of age-old ceremonies of celebration, initiation and renewal, and that the Traditional Owners' living culture and practices have a unique role in the life of this region.