Security, GDPR and remote proctoring

Your data is safe

Your framework is the GDPR, enforced by each country's data protection authority and applied consistently through the European Data Protection Board (EDPB). Evalmee, a European company with its data hosted in France, also applies by default the recommendation of the CNIL, France's data protection authority: one of the most detailed texts in Europe on the remote proctoring of exams.

Updated October 2, 2026

Where is Evalmee's data hosted?

Submissions, results and proctoring recordings are hosted in France, at Scaleway and in the AWS eu-west-3 (Paris) region. Nothing is replicated outside Europe, backups included, and no US or Asian region is used.

Any transfer is covered by the European Commission's standard contractual clauses, as articles 44 to 49 of the GDPR provide. Where the six other French platforms host their data: see the comparison of online exam platforms.

ProviderRoleLocation and safeguards
ScalewayExam dataFrench hosting provider; its data centers and processes are ISO/IEC 27001 certified, not the Evalmee software
AWS FranceExam dataeu-west-3 region (Paris), data at rest within the European Union
Cloudflare, Sentry, StripeNetwork protection, error reporting, paymentsEstablished in the EU, part of US groups: any transfer covered by standard contractual clauses

How is data encrypted?

In transit and at rest, backups included: encryption is one of the measures that article 32 of the GDPR names.

  • In transit

    HTTPS, TLS 1.2 or 1.3, across all traffic.

  • At rest

    AES-256 for sensitive data, hashing for passwords.

  • Backups

    Encrypted, in the same geographic zone as production.

How is the infrastructure protected?

Through defense in depth: it is the stacking of measures that shrinks the attack surface.

  • Cloudflare upstream

    DDoS protection and rate limiting in front of every service.

  • Private network (VPC)

    A firewall controls inbound and outbound traffic.

  • SSH key access

    Limited to authorized team members, no passwords.

  • Logged access

    Logging of access to dataAudit trailA timestamped log of every event in a session: sign-in, display of each question, successive answers, network incidents, proctor actions. It is what makes it possible to reconstruct a contested exam and to answer a complaint with something other than memory., in line with the CNIL recommendation on logging (délibération no. 2021-122 of October 14, 2021).

  • CVE monitoring

    Automated monitoring of vulnerabilities in software components.

  • OWASP Top 10

    Trained team, regular code and infrastructure audits.

What does the GDPR require for remote proctoring, and how does Evalmee answer?

The GDPR does not ban remote proctoring, but it rules out decisions based solely on automated processing (article 22), places strict limits on biometric data (article 9) and calls for an impact assessment where the risk is high (article 35).

The organizer is the data controller, Evalmee its processor under article 28 of the GDPR. Nothing is enabled by default: every mechanism is set exam by exam, so the organizer switches on only what it can justify.

Based in France, Evalmee applies by default the CNIL's délibération no. 2023-058 (June 8, 2023). It does not bind outside France, but it goes into the detail of each measure: proportionality is assessed “as a whole and not measure by measure” (§ 33), “in the light of the context and of what is at stake in the exam” (§ 34). The table sets out its paragraphs, with what Evalmee does.

The detail: what the French recommendation sets out, and how Evalmee complies.
Ref.CNIL recommendationWhat Evalmee does
§ 33-34Keep the system proportionate to what is at stake, do without it when the stakes are lowEvery mechanism is set exam by exam. Nothing is enabled by default, or on Evalmee's initiative.
§ 35Monitor activity through the platform: other tabs detected or blockedAll plans: mandatory full screen, an alert at every exit. Pro, Max and Organization plans: event-triggered screenshots (leaving full screen, another application, suspicious browser extension). Organization plan: screen sharing, continuous video streamed to the proctor and retained.
§ 36-37Rule out automated analysis of behavior: typing, gaze, emotionsMini, Pro and Max plans: none of these technologies. Organization plan: gaze direction and head orientation detection exists as an option, off by default and switched on exam by exam; the CNIL recommends not using it.
§ 38A human check before any decisionAn alert opens a passage to review, never a sanction: the proctor or the examining board decides, live (chat) or afterwards (the submission's timeline). On the Organization plan, AI analysis of the webcam and the sound (second person, absent face, phone, voice), off by default and run on Evalmee's servers, only alerts the proctor.
§ 43-47Favor document comparison, place strict limits on biometricsMini, Pro and Max plans: no webcam, hence no identity verification. Organization plan: visual comparison settled by the examiner, no biometric template; automated validation on quote, under the conditions of § 45.
§ 48-49Set and limit retention periods before going liveThree months by default for screenshots and recordings, the time needed to handle appeals.
§ 53-56Encrypt, restrict read access, keep logsTLS 1.2/1.3, AES-256. Recordings reserved for the client's examiners; Evalmee accesses them only where strictly necessary for technical reasons, under confidentiality controls.
§ 51Place safeguards around transfers outside the European UnionExam data in France; standard contractual clauses for peripheral tools.

What about a certification body accredited to ISO/IEC 17024?

The 2026 edition of ISO/IEC 17024 adds requirements on data protection, AI and technology-related security, which apply to the body, not the platform.

Details: ISO/IEC 17024 and certification bodies pages.

ClauseThe body demonstratesEvalmee supplies
7.3.2 Data protectionDedicated proceduresDPA, hosting in France, configurable retention (three months by default)
6.5 Use of AIValidation by expertsAI-assisted grading validated by a person; alerts from the optional AI analysis reviewed by a person; deterministic fraud risk score, no AI
7.4.2 Technology-related securityThreats addressedSuspicious browser extension: screenshot. Security measures set out in the DPA

Does Evalmee use facial recognition?

Not on the Mini, Pro and Max plans, which use no webcam: no video, no identity verification, no biometrics. Identity verification belongs to the Organization plan: a comparison of documents checked by eye by the examiner, the first arrangement the CNIL names in § 43, and, on quote, automated validation.

Mini, Pro and Max plans

  • No webcam: no video, no identity verification, no biometrics.
  • No automated analysis of behaviorAutomated proctoringSupervision carried out by algorithms that analyze the video feed, the sound and the activity on the device in order to flag atypical events: face absent, second person present, window switched. The flags produced are leads to be investigated, never proof of cheating in themselves. The automation lies in the analysis, never in the decision: drawing a consequence from a flag without a person having examined it would be a fully automated decision, governed by article 22 of the GDPR., as the CNIL recommends (§ 37): the only automated signals concern activity within the exam (§ 35).

Organization plan

  • The participant photographs their ID document or student card, and their face, through the webcam.
  • The examiner compares and decides: human validation from end to end.
  • No biometric template computed or stored, databases the CNIL rules out at remote proctoringRemote proctoringThe set of arrangements that make it possible to supervise a candidate sitting outside an exam center: video and audio capture, screen sharing, detection of atypical behavior. The level chosen must stay proportionate to the stakes of the exam and to the data it leads you to collect. providers (§ 46).
  • On quote, automated identity validationCandidate authenticationVerification that the person sitting the exam is the person enrolled: named credentials, sign-in through the institution's directory, checking an identity document, sometimes a biometric comparison. The level of verification is set by the stakes of the exam and by the data it makes it legitimate to process., limited to establishing the candidate's identity, before the exam or, as an option, afterwards.
  • Never used to monitor the candidate during the exam, never enabled without an explicit decision by the institution.
  • Only under one of the exceptions article 9 of the GDPR allows for biometric data; in France, under the cumulative conditions of § 45: a single verification, a very large number of candidates, an alternative always available, prior information.

How long are recordings kept?

Three months by default for screenshots and video proctoring recordings (Organization plan), the time needed to handle appeals. Everything else follows the period you set as the data controller: Evalmee keeps nothing on its own initiative.

Access restricted to examiners of the client organization, with optional logging of who consults what. Distribution or external reuse prohibited, save for a legal obligation or a formal request from the authorities; the client organization may download the recordings for its archiving and its accreditations.

DataRetention period
Video proctoring recordings (Organization plan): webcams, microphone, screen sharingThree months by default; a different period by contract
Screenshots (Pro, Max and Organization plans)Three months by default; a different period by contract on the Organization plan
Submissions, answers, grades, metadataSet by the examining institution
AI analysis alerts (Organization plan)That of the submissions, deleted along with them

What is Evalmee's AI policy?

Evalmee uses OpenAI models to speed up authoring and grading, under four conditions.

  • Open questions only

    AI-assisted gradingAI-assisted gradingPre-grading of written answers by a language model, which proposes a grade and a justification that the grader validates, amends or rejects. The decision stays human: what the AI saves is the first pass over the paper, never the responsibility for the grade. applies to open questions; MCQs are graded automatically, without AI.

  • No name or identifier

    The question, rubric and answer go to OpenAI, on its European endpoints, without the participant's name or identifier.

  • No training

    Your data never trains an AI model.

  • Validated grading

    A grader validates every AI suggestion: no grade is awarded automatically on a written answer.

Who are Evalmee's sub-processors?

The full list is public, dated and kept up to date: provider, purpose and country of establishment, as article 28 of the GDPR requires. Your data goes only to the partners strictly necessary.

For authoring and for grading open questions, OpenAI receives the question, the rubric and the answer, without the participant's name or identifier. The optional analysis of the webcam and microphone, on the Organization plan, runs on Evalmee's servers and adds no sub-processor.

Does Evalmee offer a Data Processing Agreement (DPA)?

Yes, compliant with article 28 of the GDPR: respective responsibilities, retention periods, security measures and sub-processors. It is signed before go-live, at no extra cost, whatever your plan.

For a signed copy, contact us.

Is Evalmee GDPR-compliant?

Evalmee is built so that your institution can process exam data in line with the GDPR; compliance is judged processing by processing, under your responsibility.

Our commitments as a processor

  • Process only the data strictly necessaryData minimizationThe GDPR principle under which, in the CNIL's wording, personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. Applied to remote proctoring, it requires collecting only what the stakes of the exam justify. to deliver the service
  • Guarantee the rights of access, rectification, portability and deletion
  • Keep exam data in France, peripheral transfers under standard contractual clauses
  • Notify any breach without delay, so that the 72-hour deadline of article 33 of the GDPR can be met
  • Guarantee the candidate access to the data from their remote proctoring, which the CNIL requires in all circumstances (§ 16)

To exercise your rights or for any question regarding your data, contact us.

Data protection questions have a single point of contact, monitored by our team: contact@evalmee.com.

What certifications does Evalmee hold?

None, to date, in its own name: the certifications cited on this page are those of our hosting providers.

What we do not hold

  • SOC 2

    Type I or Type II: Evalmee is not SOC 2 audited.

  • ISO/IEC 27001

    The one cited on this page is Scaleway's, our hosting provider.

  • HDS

    Evalmee is not certified as a French health data host and is not intended to process health data.

  • SecNumCloud

    Evalmee does not hold the ANSSI SecNumCloud qualification.

How available is the service?

As of August 14, 2026, Evalmee's public status page shows 100% observed availability over the last ninety days for its seven components, remote proctoring included: a figure over a rolling window, not a contractual commitment.

No SLA on self-service plans; an availability commitment can be negotiated on the Organization plan. The status page also publishes the incident history, updated automatically.

Sources and reference texts

  1. EUR-Lex

    Regulation (EU) 2016/679 (GDPR), in particular articles 9, 22, 28, 32, 33, 35 and 44 to 49

    Consulted on August 14, 2026

  2. European Data Protection Board (EDPB)

    About the European Data Protection Board: independent European body ensuring the consistent application of the GDPR

    Consulted on October 1, 2026

  3. CNIL

    Délibération n° 2023-058 du 8 juin 2023 portant adoption d'une recommandation relative aux modalités de mise en œuvre des dispositifs de télésurveillance pour les examens en ligne (CNIL recommendation no. 2023-058 of June 8, 2023 on remote proctoring arrangements for online exams)

    Consulted on August 14, 2026

  4. CNIL

    Remote proctoring of online exams: the CNIL publishes a recommendation

    Consulted on August 14, 2026

  5. Légifrance

    Délibération n° 2023-058, text published in Journal officiel no. 0203 of September 2, 2023, text no. 63

    Consulted on August 14, 2026

  6. Légifrance

    Article D. 611-12 of the code de l'éducation (the French Education Code): validation of coursework through examinations held remotely in digital form

    Consulted on August 14, 2026

  7. French Ministry of Higher Education and Research, DGESIP

    Fiche 6, Évaluer et surveiller à distance (Sheet 6, Assessing and proctoring remotely), teaching continuity plan

    Consulted on August 14, 2026

  8. Scaleway

    Scaleway infrastructure security and resilience

    Consulted on August 14, 2026

  9. Evalmee

    Evalmee privacy policy

    Consulted on September 5, 2026

  10. Evalmee

    List of Evalmee's sub-processors

    Consulted on August 14, 2026

  11. Evalmee

    Checking and verifying participants' identity, Evalmee help center

    Consulted on August 14, 2026

Frequently asked questions about security and GDPR

Yes, provided it stays proportionate. The GDPR applies in every EU country, enforced by each country's data protection authority, and the European Data Protection Board (EDPB) brings those authorities together so that it is applied consistently. It rules out decisions based solely on automated processing (article 22), places strict limits on biometric data (article 9) and calls for an impact assessment where the risk is high (article 35); the institution, as data controller, informs candidates in advance. Evalmee, a European company based in France, also applies by default délibération no. 2023-058 of June 8, 2023 of the CNIL, France's data protection authority, one of the most detailed texts in Europe on remote exam proctoring.

Not on the Mini, Pro and Max plans: they use no webcam, so no video, no identity verification and no biometrics. Identity verification belongs to the Organization plan: it rests on a comparison of documents, the participant holds their ID up to the webcam, the examiner compares the two visually and then decides, and no biometric template is computed or kept. On that plan, automated identity verification can also be deployed on a quote basis: it is limited to establishing the candidate's identity, before the exam or afterwards as an option, and is never used to monitor them during the exam. The conditions for such a deployment are set out on the security page. The AI analysis option for the webcam, on the same plan, detects an absent face as an object, without biometric processing.

In France, at Scaleway and in the AWS eu-west-3 (Paris) region, backups included: exam data does not leave French soil. A few peripheral tools (Cloudflare, Sentry, Stripe) may involve a transfer covered by the European Commission's standard contractual clauses.

Screenshots (Pro, Max and Organization plans) and video proctoring recordings, specific to the Organization plan (webcams, microphone and screen sharing), are deleted by default after three months, the time needed to handle appeals; on the Organization plan, a different period can be set contractually. AI analysis alerts are attached to the participant's submission: they follow the retention period of submissions, set by the examining institution, and are deleted along with it.

No. Evalmee holds no security certification in its own name today: no SOC 2, no ISO/IEC 27001, no HDS, no SecNumCloud. The ISO/IEC 27001 certification mentioned on our security page is Scaleway's, our hosting provider, and covers their data centers.

Yes, at no extra cost and whatever the plan. Our Data Processing Agreement complies with article 28 of the GDPR: it sets out the respective responsibilities, the retention periods, the security measures and the list of sub-processors, which is public in any case.

Not on the self-service plans: no service level commitment is attached to them. Evalmee does, however, publish a status page open to everyone, showing observed availability over the last ninety days along with the incident history. An SLA can be negotiated on the Organization plan.

A question about security?

Our team will get back to you quickly, including on data protection.