Signals measures where your content loses people using behavioural telemetry alone. Deployable in EU workplaces and education institutions, where facial analysis is prohibited.
Since 2 February 2025, Article 5(1)(f) of the EU AI Act has prohibited AI systems that infer emotions from biometric data in workplaces and education institutions. No consent exception. Penalties to 7% of global turnover.
If your engagement tool infers emotional states from a camera feed, it cannot lawfully be deployed to EU employees or students — regardless of consent, contract wording or on-device processing.
The prohibition hangs on biometric data. Tab-switching, window focus and dwell time are browser events, not physiological characteristics, and they infer no emotional state.
The strongest single predictor of disengagement in the literature is behavioural, not facial. The camera was never where most of the signal lived.
All captured through native browser APIs. No hardware, no permissions prompt, no installation.
Signals produces content diagnostics, not personal dossiers. That is both the compliance position and the commercially useful output.
Every section scored. "Module 3, slide 14 loses 60% of learners" — a fix list, not a verdict on individuals.
Exactly where sessions end, and what the behavioural pattern looked like in the minutes beforehand.
Deviation from each person's own pattern rather than a population average, so habitual multitaskers are not permanently flagged.
Aggregate at the point of collection. No individual identifiable, no session linked to a person, no personal data processed at all.
Prove version B held attention better than version A on real behaviour rather than survey scores.
Flag at-risk sessions from behavioural pattern breaks while there is still time to intervene.
Signals is designed to sit outside the Article 5(1)(f) prohibition, and we will support your assessment with a written vendor position and a completed supplier section for your DPIA. That is not a substitute for your own legal advice on your specific deployment. Use the applicability checker to work through the test.
Under 50KB. Works with any LMS, SCORM package or xAPI platform. No migration, no server-side integration, no infrastructure change.
Canvas, Moodle, Docebo, Cornerstone, TalentLMS, Absorb, Blackboard, Open edX — anything browser-based.
Emits xAPI statements to your existing Learning Record Store, or runs standalone.
Zero external dependencies. Runs fully offline for government, defence and regulated environments.