Our Ref: FOI2020/105
Jen Persson
xxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx
Thursday, 09 July 2020
Dear Jen Persson,
Freedom of Information Act 2000 – Request for Information
Regarding your request for information received by the University of Westminster on 2nd
June 2020.
Our apologies for the slight delay in responding to your request.
The Request and the University’s Response
The University can confirm that it holds information relating to your request. Please see
below for details of your recent request in
bold and our response.
“Dear University of Westminster,
FOI request re: Student social media monitoring
Please provide the following information under the FOI Act 2000, regards processing of
students' social media accounts, whether routinely or based on an individual need case --
for example but not exclusively, Facebook, Twitter, Instagram, YouTube, TikTok,
WhatsApp, Tumblr, Pinterest, Flickr and Medium-- by or on behalf of the University in a
formal, systemic or other recognised process for investigations including for University PR
or management of reputational risk purposes. (This excludes for example, one Academic
looking at one student's posts for personal reasons.) Relevant time period: since January
2016.
1. Provide a copy of your University policy for your administrators or equivalent, on
the monitoring or use of social media in investigations, for the purposes of the
Prevent programme, including for reputational management. (please confirm if you
do not have one, and which do apply)
Information not held.
© University of Westminster
2. Does your University either conduct overt (ie students are informed) and/or
covert (students are not explicitly informed at the time of the surveillance) social
media intelligence gathering?
We do monitor publicly available social media content for references to the University of
Westminster for social media marketing analysis, without any specific individuals in mind.
a. If yes (2), please specify whether this includes profiling individuals, conducting
investigations, monitoring individuals, monitoring groups, monitoring locations,
gathering intelligence, for recruitment purposes, or purposes of reputational risk, or
state what it is if other.
For social media marketing analysis.
b. If your University does conduct social media intelligence/monitoring, please
specify which social media may be in scope.
Our social media marketing analysis can be conducted in; Facebook, Instagram, Twitter,
Linkedin, You Tube and Tik Tok.
c. Does your University conduct social media monitoring exclusively for the
purposes of the Prevent programme?
No.
d. If yes, to c. if the University has conducted covert social media monitoring, for
the purposes of the Prevent programme, please confirm the number of any warrants
obtained in the last two years for this purpose, or police or Home Office requests to
do so, if any or none.
Not applicable.
3. If you conduct social media intelligence relating to social media platforms, please
provide a copy of:
a. Relevant [sections of the] privacy policy; b. the data protection impact
assessment; c. privacy impact assessment; d. equality and human rights impact
assessment e. training materials for those conducting social media surveillance
Please state if you do not have any of the above.
No social media intelligence gathering takes place. Our social media marketing analysis
helps inform the University on social media content approach and general channel usage
with references to the University of Westminster.
Any usage of social media by current students will be subject to our Social Media
Guidelines, Student Charter, Student Code of Conduct, Acceptable Use of IT, Freedom of
Information Compliance Team University of Westminster
3rd Floor, 32-38 Wells Street
Fitzrovia, London W1T 3UW
T: +44 (0)20 7911 5000
E
: xxx@xxxxxxxxxxx.xx.xx
© University of Westminster
Speech Policy, Diversity and Dignity at Work and Study Policy and Unacceptable
Behaviour Policy.
More information can be found on our website at:
https://www.westminster.ac.uk/current-students/guides-and-policies/student-
matters/social-media-guidelines
The University will investigate potential breaches of these guidelines and policies by
following our internal policies and procedures.
4. Please confirm whether or not your University uses software and/or hardware to
conduct social network / social media monitoring and/or in relation to sentiment
analysis on social media.
In relation to our social media marketing analysis, yes.
a. If yes, please state the name of the company / provider.
Socialbakers and Planoly.
b. If no, please state whether the University has developed internal methods to
conduct automated analysis of social media / social network monitoring.
Not applicable.
5. Please confirm, if not stated already in the above, the policy on deletion of data
obtained from social networking sites.
The University’s social media marketing analysis does not require the retention of personal
data.
Where personal data may be held in relation to a potential or actual student breach of
University guidelines or policy, it is retained in line with University’s Student Records
Retention Policy.
Se
e https://www.westminster.ac.uk/about-us/our-university/corporate-
information/information-compliance-records-management-and-information-
security/records-management/records-retention-schedule
6. If not already set out in the guidance documents above, please explain:
a. In what areas of the University’s work social media monitoring is used (ie finance
department) b. What criteria must be satisfied in order for social media monitoring
to be carried out c. Who must authorise the request to conduct social media
monitoring d. What is the process for conducting social media monitoring e. How
long is data collected and retained?
Information Compliance Team University of Westminster
3rd Floor, 32-38 Wells Street
Fitzrovia, London W1T 3UW
T: +44 (0)20 7911 5000
E
: xxx@xxxxxxxxxxx.xx.xx
© University of Westminster
f. Is there any process for requesting deletion by the subject (person whose social
media is surveilled)?
a) Social media marketing analysis.
b) Social media references to the University of Westminster.
c) Information not held.
d) Use of software as described.
e) Non-personal data for analysis will be retained for as long as it is useful for
marketing purposes. Any personal student data will be retained with reference to
our Student Records Retention Schedule.
f) All data protection subject rights can be exercised by contacting the University. For
further details and informatio
n please see: https://www.westminster.ac.uk/about-
us/our-university/corporate-information/information-compliance-records-
management-and-information-security/personal-data-protection
7. Please state how regularly social media monitoring is used, on what volume of
individuals (ie targeted for individual situations or every students on the network)
Please provide the figures as available, preferably in excel, and by month or on the
available basis you have, since January 2016.
Social media marketing analysis is an ongoing process, as described above. No
information is held in the way you request.
8. Please provide the organisational name of any third party or authority to whom
such information gathered has been passed on, and which information types (e.g.
name, report of X) in the time period since the University has undertaken such
monitoring. (For example but not only: Since January 2016 -- X number of referals to
Student disciplinary boards, X to internal student loans administration, X to external
student loan administration (Student Loans Company or other), HESA, the OfS,
Other universities, Police, the Home Office.) etc.
The University holds some information that may be related to this question regarding
formal student disciplinary hearings and social media misuse:
2016/17 - no cases.
2017/18 - 2 cases
2018/19 - 2 cases
2019/20 - 1 case to date
Information Compliance Team University of Westminster
3rd Floor, 32-38 Wells Street
Fitzrovia, London W1T 3UW
T: +44 (0)20 7911 5000
E
: xxx@xxxxxxxxxxx.xx.xx
© University of Westminster
These cases do not necessarily directly correlate to any social media marketing analysis
we have undertaken. However, due to our current working from home conditions and an
inability to check all records held, they are disclosed for your information.
9. If the university does monitor students' social media, please cofirm if the same
policy has continued and been applied since March 23, 2020 (lockdown) in the
COVID-19 crisis?
The University’s social media marketing analysis has not changed in this period to date.
We hope this information may be of use to you.
All rights are reserved. This document is for personal use only and may not be copied, or
stored in any electronic form, or reproduced in any other way or used for any other
purpose, either in whole or in part, without the prior written consent of the University of
Westminster. All copies of this document must incorporate this Copyright Notice.
If you are dissatisfied with this response you may ask the University to conduct a review of
its decision.
By Post: Information Compliance Team
University of Westminster
3rd Floor 32-38 Wells Street
Fitzrovia, London, W1T 3UW
By Telephone:
0207 911 5000
By Email:
xxx@xxxxxxxxxxx.xx.xx
Please do so in writing (including by fax, letter or email) or in some other recorded form
(e.g. audio or video tape), describe the original request, explain your grounds for
dissatisfaction, and include an address for correspondence.
If after contacting the University of Westminster you are not happy with the outcome, you
also have a right of appeal to the Information Commissioner.
Please note that the Information Commissioner will not investigate the case until the
internal review process has been completed.
By Post:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
By Telephone:
01625 545 700
Web:
www.ico.org.uk
Information Compliance Team University of Westminster
3rd Floor, 32-38 Wells Street
Fitzrovia, London W1T 3UW
T: +44 (0)20 7911 5000
E
: xxx@xxxxxxxxxxx.xx.xx
© University of Westminster
Yours sincerely,
Information Compliance Team
xxx@xxxxxxxxxxx.xx.xx
Information Compliance Team University of Westminster
3rd Floor, 32-38 Wells Street
Fitzrovia, London W1T 3UW
T: +44 (0)20 7911 5000
E
: xxx@xxxxxxxxxxx.xx.xx
© University of Westminster