{'fraction_non_alphanumeric': 0.018633540372670808, 'fraction_numerical': 0.0, 'mean_word_length': 5.2684824902723735, 'pattern_counts': {'":': 0, '<': 0, '<?xml version=': 0, '>': 0, 'https://': 0, 'lorem ipsum': 0, 'www.': 0, 'xml': 0}, 'pii_count': 0, 'substrings_counts': 0, 'word_list_counts': {'cursed_substrings.json': 0, 'profanity_word_list.json': 0, 'sexual_word_list.json': 0, 'zh_pornsignals.json': 0}}
EDUCATIONAL INSTITUTION AS A DATA CONTROLLER: PROBLEMS AND CHALLENGES

The right to data portability applies only to personal data provided to the controller by the data subject himself, and only if the processing was initially based on the consent of the user or on the basis of a contract. Most cases when students or their parents submits their personal data to educational institution are cases covered by this right, moreover, in most cases, those are sensitive personal data. In the context of the right to data portability, data subjects directly transmit data from one data controller to another where technically possible. The regulation does not specify what is meant by “technically feasible”. The wording indicates that this should be addressed on a case-by-case basis and a dynamic interpretation of the term "technically feasible" should be ensured. This is limited because the Regulation does not oblige data controllers to accept or maintain compatible processing systems. In case with educational institutions and students’ opportunities to change the study place including mid-school year it’s important to identify problems with data portability and facilitate the transition process to get student into the new study environment and system faster and more effective. For this purpose, the author identifies main problems and challenges that educational institutions can face when they act as a data controllers. The subject of the research is the relationship between the data subject (students) and the data controller (educational institution), implementing the right to data portability.