A leadership perspective on vendor vetting in international schools
Why Vendor Vetting Has Become a Leadership Issue

Many of us in school leadership recognise the pattern: A new digital platform appears, promising to make things easier, faster, or more insightful. A teacher discovers a tool that generates useful feedback. A department begins experimenting with a new analytics system. A colleague shares an AI tool that seems to save hours of work.
The possibilities are exciting and often genuinely helpful. At the same time, the pace of technological change now asks schools to make decisions about digital tools faster than ever before.
Not long ago, these decisions often felt largely technical. If a tool worked well and teachers found it useful, adoption was relatively straightforward. Today, the situation is different. Decisions about digital platforms increasingly carry legal, ethical, and financial implications that reach well beyond the classroom.
In many regions, regulatory frameworks such as the EU’s General Data Protection Regulation (GDPR) and the recently adopted EU Artificial Intelligence (AI) Act have made institutional responsibility more explicit. They clarify expectations around data privacy, transparency, and accountability when digital systems are used in education.
Yet regulation is not the real starting point. Regardless of jurisdiction and liability, schools have a duty of care toward the people they serve. Introducing digital systems means making decisions that affect the privacy, agency, learning and working environments of students, staff, and families.
The question has therefore shifted. The issue is no longer simply what digital tools can do. The more important question is what we should responsibly adopt in service of learning and institutional trust.
Technical expertise remains essential. IT teams and data protection officers bring the knowledge needed to properly evaluate systems. But decisions about which tools enter a school’s digital ecosystem ultimately involve broader considerations: pedagogical value, organisational risk, financial sustainability, and alignment with the school’s mission. In practice, these decisions are most effective when they emerge from cross-functional collaboration rather than from isolated departmental choices.
Seen in this light, vendor vetting cannot remain a purely technical task. It must be treated as a leadership responsibility. The challenge for school leaders today is not choosing the newest digital tools, but shaping the ecosystem in which they enable growth.
Thinking about digital systems in this way reveals how similar the work is to shaping a living ecosystem: preparing the conditions for growth, deciding what should take root, defining the boundaries within which they develop, and occasionally pruning so that the whole environment can flourish.
In practice, these decisions rarely unfold in such a tidy sequence. Schools often find themselves defining boundaries, revisiting earlier choices, and pruning existing systems simultaneously. However, thinking in these terms helps make the leadership work more visible.
Preparing the Soil: Risk, Responsibility, and Digital Stewardship

If we think about our digital environment in this way, the metaphor of a garden becomes helpful.
Schools are not marketplaces in which tools are simply purchased, used, and replaced. They are living ecosystems. Every digital system we introduce subtly reshapes the environment in which teaching, learning, and organisational work take place.
Platforms influence workflows, communication patterns, assessment practices, and even how teachers design learning experiences. Over time, these tools begin to shape the culture and rhythms of the school itself.
Healthy ecosystems require intentional care. They need clear boundaries, ongoing maintenance, thoughtful cultivation, and, at times, pruning. Seen this way, schools are not simply collecting digital tools. We are cultivating a digital landscape.
Educational researchers Fiona Aubrey-Smith and Peter Twining describe this shift as moving from EdTech to PedTech, emphasising that technology decisions should begin with clear educational purpose rather than technical possibility (Aubrey-Smith & Twining, 2023). When we look through that lens, every technology decision becomes a design decision. The systems we adopt influence not only classroom practice but also the wider infrastructure of schooling, shaping how learning is assessed and reported, how schools communicate with families, and how organisational processes such as admissions and recruitment are managed.
This perspective also changes how we think about risk and responsibility. Schools often evaluate digital tools first for their functionality. Only later do questions emerge about data protection, security, or compliance. When those concerns arise after a tool has already been adopted, institutions may be forced to withdraw systems that teachers and teams have already begun integrating into daily practice. Once a digital system becomes embedded in everyday work, these questions become far harder to revisit. Data begins flowing through the system. Processes reorganise themselves around the technology. Expectations and workflows shift in subtle but powerful ways. If responsibility structures were not clear from the beginning, no amount of functionality can compensate for the resulting risk.
Frameworks such as the EU’s GDPR and the EU AI Act help clarify institutional responsibilities, particularly around data protection, transparency, and oversight when automated systems influence educational processes. The deeper issue is not regulatory compliance alone. It is institutional stewardship.
Returning to the garden metaphor, healthy growth rarely happens by accident. It depends on careful preparation and ongoing attention to the conditions in which things grow. Seen in this light, vendor vetting is not primarily about choosing tools. It is about protecting the conditions in which meaningful teaching, learning, and organisational trust can take place.
In recent years, AI has brought many of these questions into sharper focus, forcing schools to confront issues of judgment, responsibility, and accountability that previously remained implicit. While AI has intensified many of the questions schools were already facing, it has not fundamentally changed the purpose of education: supporting the intellectual and human development of young people.
Schools exist to support human learning, development, and judgment, perhaps even more so in 2026 than before. Recent research summarised in the OECD’s Digital Education Outlook 2026 suggests that the future impact of generative AI in education will depend less on how efficiently it automates tasks and more on how effectively it supports teachers’ professional judgement and competence (OECD, 2026). Technology may change how we organise information, analyse data, or support teaching. But the responsibility for guiding learning, exercising professional judgement, and caring for students ultimately remains with educators.
As AI tools appear in classrooms and operational systems, we find ourselves asking questions that may previously have remained implicit. Where should human judgment remain central? Which decisions should never be automated? Who is accountable when technology influences outcomes for students, staff, or families? And how do we ensure that such systems remain transparent, fair, and open to challenge? These questions are not new. AI has simply made them impossible to ignore.
Regulatory frameworks such as the EU AI Act reflect this shift by emphasising the importance of human oversight, transparency, and accountability in systems that influence educational decisions.
Most educators would recognise the underlying principle instinctively. Technology can support professional practice, but it should not replace the responsibility educators carry for the decisions that shape students’ learning and wellbeing.
The Accountability Bridge

One of the most important implications for school leaders concerns accountability. When we adopt digital tools, it can be tempting to assume that responsibility sits primarily with the vendor providing the platform. After all, the vendor designs the system, hosts the infrastructure, writes the terms of service and makes assurances about data privacy.
In reality, the responsibility remains ours. When a school adopts a digital system, it also accepts responsibility for how that system is used within the school community. Under frameworks such as GDPR, schools typically act as data controllers. This means we are accountable for how personal data is processed, even when the infrastructure is managed by an external provider. Similarly, emerging regulations such as the EU AI Act recognise that institutions deploying AI systems carry responsibility for ensuring that those systems are used appropriately.
Vendor assurances and contractual clauses are an important part of responsible procurement. They help define obligations between the school and the vendor. But they do not remove the school’s accountability for the decision to use the system in the first place.
Some certification schemes exist under GDPR, but they do not make a tool “GDPR compliant” in the abstract (GDPR Art. 42). Compliance ultimately depends on how a system is configured and used in a specific context. As the data controller, the school is responsible for carrying out the necessary assessments and determining whether the use of a tool is lawful and appropriate (GDPR Art. 4(7); Art. 24).
This is why vendor vetting cannot rely on vendor claims alone. What matters is whether we understand how a tool operates within the context of our school: what data it processes, how decisions are supported, and where responsibility ultimately sits.
From a leadership perspective, vendor vetting therefore becomes an exercise in due diligence and risk management. Our role is to ensure that the conditions for safe, ethical, and educationally sound use are in place before new technologies enter the school environment.
The Picket Fence: Why Clear Boundaries Matter

Most educators adopt new digital tools with the best of intentions. Teachers experiment with platforms because they are trying to solve real problems, support students, and improve their practice. In complex digital environments, we naturally gravitate toward tools that are easy to access and appear immediately helpful.
When institutional boundaries are unclear, people often step outside formal systems, not out of resistance but simply out of necessity. This is where shadow IT begins to emerge.
Shadow IT, the use of unauthorised tools, is rarely the result of deliberate rule-breaking. More often, it reflects a mix of factors: unmet needs, slow approval processes, uncertainty about which tools are already available within the school, or simply familiarity with tools colleagues have used elsewhere.
The rapid spread of generative AI has intensified this dynamic. Powerful AI tools are now accessible within seconds. Teachers and students can experiment with them long before schools have had the opportunity to evaluate their implications. Recent international survey data suggest that more than one-third of teachers already use generative AI tools for work-related tasks such as lesson planning or summarising topics, often well before institutional guidance is in place (OECD, 2026). Trying to block every new tool is neither realistic nor desirable. What schools need instead are clear boundaries.
This is where the garden metaphor becomes helpful again. A picket fence does not enclose a garden completely, but it makes the boundaries visible. It creates a shared understanding of where things belong and how the space is cared for.
In digital ecosystems, clear boundaries serve the same purpose. They help everyone understand which tools are approved, what kinds of data may be shared, and where responsibility ultimately sits. When those expectations are visible, autonomy becomes possible. Teachers can explore new tools and approaches while still working within a shared framework that protects the school community.
Without that clarity, things begin to drift. Tools start operating outside institutional oversight, data flows become harder to track, and accountability gradually becomes blurred. Organisational risk rarely appears suddenly; it grows quietly in the background.
Seen in this light, shadow IT is rarely about staff wanting to bypass systems. It usually reflects a mix of practical factors. It becomes a governance problem when institutional boundaries are unclear. When those boundaries are visible and widely understood, leadership no longer needs to focus on control. The role shifts toward stewardship: shaping the digital ecosystem so that innovation and responsibility can coexist.
Pruning as Leadership: Why Not Everything Should Stay

Healthy gardens require pruning. Digital ecosystems are no different. Over time, most schools accumulate digital tools through pilots, departmental initiatives, and well-intentioned experimentation. A platform that once solved a specific problem may remain long after its original purpose has faded. Another tool appears, a new feature is introduced, and gradually the ecosystem becomes more complex than intended.
Low usage does not necessarily mean low risk. Every system introduced into a school carries ongoing responsibilities: compliance obligations, technical support, contractual commitments, and reputational exposure. Even those that don’t carry a financial cost are not truly free (though that’s a separate topic).
This is why ‘pruning’ becomes an important leadership task. Sometimes, pruning means retiring tools that no longer add meaningful value. Sometimes it means ending pilots that did not lead to sustainable practice. At other times it means consolidating overlapping platforms in order to restore clarity and coherence.
These decisions are rarely straightforward. Innovation requires experimentation, and educators understandably value the freedom to explore tools that support their work. Yet leadership involves balancing innovation with coherence. Saying no to certain tools can be just as important as adopting new ones.
Pruning is therefore not a failure of innovation. It is evidence of responsible stewardship.
Pruning is also about sustainability. Most digital platforms now operate through subscription-based software-as-a-service models. Individual tools may appear inexpensive at first, but over time subscription costs accumulate across departments and systems. Because schools typically do not own these systems, they remain dependent on vendor pricing, product decisions, and contractual terms. Vendors adjust pricing structures, merge with other companies, or shift their product strategies, sometimes in ways that schools cannot influence. What begins as a small pilot can quietly become a long-term financial commitment.
Every platform we maintain also carries an opportunity cost. Resources tied up in maintaining underused systems cannot be invested elsewhere. Digital stewardship therefore requires financial awareness. School leaders need to consider the total cost of ownership, the degree of vendor dependency created by a system, the possibility of exiting contracts, and the extent to which a tool supports the school’s long-term priorities. Digital environments that depend on ever-expanding subscriptions face similar vulnerabilities.
For school leaders, this means that digital ecosystems cannot be shaped through isolated decisions about individual tools. They require consistent institutional practices: clear criteria for adoption, proportionate review processes based on risk, time-limited pilots, and regular review cycles for existing systems.
This is not about creating additional bureaucracy. It is about creating clarity so that technology decisions remain aligned with the school’s purpose.
Digital stewardship recognises that every technology choice influences the conditions in which teaching, learning, and organisational life unfold.
So What Kind of Digital Garden Are We Cultivating?

Schools today face no shortage of digital tools. New platforms appear constantly, each promising new efficiencies, insights, or possibilities.
The real challenge for school leaders is not deciding what technology can do, but deciding what we should responsibly allow to take root in our learning environments.
Leadership in digital ecosystems is not about adopting more platforms or chasing every new innovation. It is about shaping environments in which technology genuinely supports learning, protects students and families, and sustains institutional trust.
The most future-ready schools will therefore be those that cultivate their digital ecosystems with intention and care. International research increasingly points in the same direction. The OECD argues that the long-term value of AI in education will depend on whether it strengthens teachers’ professional judgement and enriches the teaching and learning process, rather than simply automating tasks (OECD, 2026).
In the end, the real question is whether the technologies we invite into our schools help us focus more deeply on the work that matters most: thoughtful teaching, meaningful learning, and the growth of every student.
References
Aubrey-Smith, F., & Twining, P. (2023). From EdTech to PedTech: Changing the way we think about digital technology. Routledge. https://doi.org/10.4324/9781003267304
European Union. (2016). Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation). Official Journal of the European Union. https://eur-lex.europa.eu/eli/reg/2016/679/oj
European Union. (2024). Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (Artificial Intelligence Act). Official Journal of the European Union. https://eur-lex.europa.eu/eli/reg/2024/1689/oj
OECD. (2026). Digital Education Outlook 2026: Exploring Effective Uses of Generative AI in Education. OECD Publishing. https://www.oecd.org/en/publications/oecd-digital-education-outlook-2026_062a7394-en.html
Yi, X. (2026). AI Is Not Replacing Learning—It’s Exposing Where Learning Was Thin to Begin With. Inside Higher Ed. https://www.insidehighered.com/opinion/views/2026/03/10/ai-exposes-where-learning-was-thin-begin-opinion
Disclaimer: This article was written by the author. AI tools were used for general editing, such as flow, grammar and spelling.
Sibylle Harth
Director of Teaching, Learning & Technology — International School of Düsseldorf
Sibylle’s leadership is grounded in a belief that schools are places of hope, where we learn how to be human together. A passionate advocate for systems thinking and reflective practice, she has held leadership roles in international schools across the UK, Norway, the Netherlands, Vietnam, and Germany. She leads ISD’s work in teaching, learning, professional growth, and technology — from digital tools to the infrastructure that supports them. Her work focuses on designing coherent learning experiences, building professional capacity, and fostering a culture of curiosity, dignity, and shared purpose.
Sibylle holds a Master’s in School Leadership and a Master of Business Administration, reflecting her commitment to bridging pedagogical expertise with organisational leadership.
