President of the Personal Data Protection Office supports the introduction of digital hygiene
The President of the Personal Data Protection Office presented comments on the draft core curriculum of pre-school education and general education for primary school.
In a letter to the Deputy Minister of Education Katarzyna Lubnauer Mirosław Wróblewski, President of the Personal Data Protection Office, positively assesses the Ministry’s of Education effort to increase students' digital awareness starting from kindergarten. Compared to the previous core curriculum, which only referred in general terms to the use of technology by students, the new project decided to introduce specific solutions concerning digital hygiene and data security.
In particular, the goal of building broad digital resilience and informed privacy management at every stage of education deserves approval. An important goal is to lay foundation in kindergartens such as digital hygiene and learning how to protect one’s personal data, including one’s image.
With regard to education in 1st -3rd grades, the drafter focused on security and a critical approach to online content to protect the youngest from manipulation and cyberthreats.
In turn, the project drafter set the goal that students in the older classes of primary school enter an advanced level, including the ethics of using artificial intelligence, the detection of disinformation and the practical application of fundamental rights.
Guided by the well-being of children with disabilities, the draft regulations emphasise the operation of assistive devices, communication, distinguishing reality from the virtual world and the ability to report threats online.
The Personal Data Protection Office has also been undertaking educational activities for years to raise the awareness of students and teachers regarding the protection of personal data and the right to privacy, including through the ‘Your data – Your concern’ programme. The initiative also supports the development of digital competences necessary for safe and responsible functioning in the world of new technologies.
According to Mirosław Wróblewski, President of the Personal Data Protection Office, it is crucial that public authorities cooperate on this matter and strive to prepare students for safe and ethical functioning in the dynamic world of technology.
However, the draft regulation also raises issues that raise doubts and need to be clarified.
• Firstly, it is questionable whether the regulation, i.e. the implementing act can serve as a legal basis for the introduction of a requirement not to use digital screen devices in pre-school activities. In accordance with constitutional provisions, the formation of rights and obligations in connection with the exercise of constitutional freedoms and rights may be established only by means of a statutory law and only if necessary in a democratic society for, inter alia security or public order purposes, the protection of the environment, public health and morals or the freedoms and rights of others.
• Secondly, it would be useful to clarify on what legal basis and which AI tools should be used by students during their studies, i.e. tools that are safe and do not rely on the use of personal data of students and teachers.
• Thirdly, the draft regulation states that 4th – 6th grade student: discusses the risks arising from the misuse of information and communication technologies, including cyberbullying, hate speech, the creation of cyber reality, pathostreaming, addiction to the Internet and computer games, and dangerous contacts online, including grooming; discusses the benefits and risks of AI and virtual reality’ (pp. 303-304 of the draft regulation). However, the President of the Personal Data Protection Office points out that the risks are not listed in the closed catalogue of adverse phenomena and threats – indicating that the deepfakes are not mentioned among the other risks. In the light of the ongoing public debate, it would be worth complementing the core curriculum adding deepfakes as well.
DPNT.401.23.2026
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