Higher Education data: social media monitoring

Jen Persson made this Freedom of Information request to University of Wales as part of a batch sent to 124 authorities

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Mae'r cais hwn wedi cael ei dynnu'n ôl gan y sawl a'i wnaeth. Efallai y bydd esboniad yn yr ohebiaeth isod.

Dear University of Wales,

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)

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?

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.

b. If your University does conduct social media intelligence/monitoring, please specify which social media may be in scope.

c. Does your University conduct social media monitoring exclusively for the purposes of the Prevent programme?

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.

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.

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.

a. If yes, please state the name of the company / provider.

b. If no, please state whether the University has developed internal methods to conduct automated analysis of social media / social network monitoring.

5. Please confirm, if not stated already in the above, the policy on deletion of data obtained from social networking sites.

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?
f. Is there any process for requesting deletion by the subject (person whose social media is surveilled)?

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.

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.

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?

Thank you for your consideration.
Sincerely,

Jen Persson

Paul Osborne,

Dear Jen,

 

Thank you for your freedom of information request below received by this
office today, 3rd June 2020. I can confirm that University of Wales is a
degree awarding/ accreditation body not a conventional university with
faculties and students thus I would respond to the questions in your
request with a nil return.

 

You may request a review of the information contained within this freedom
of information response from my colleague Lee Bartlett 
[1][email address]  If you remain dissatisfied following the
review you may appeal to the Information Commissioner at [2]ico.org.uk.
Alternatively, you may write to the ICO at:

 

Head Office

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a
national rate number

 

Yours sincerely

 

Paul Osborne   BSocSc(Hons) LLM,
Solicitor                                                                                                            

Swyddog Diogelu Data   /  Data Protection Officer

Campws Busnes Abertawe SA1 1NE Cymru DU/ Swansea Business Campus, SA1 1NE,
Wales, UK

Llinell Uniongyrchol / Direct Line: 01792
481180                                               

e-bost / e-mail: [3][email address]

 

 
Dear University of Wales,

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)

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?

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.

b. If your University does conduct social media intelligence/monitoring,
please specify which social media may be in scope.

c. Does your University conduct social media monitoring exclusively for
the purposes of the Prevent programme?

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.

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.

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.

a. If yes, please state the name of the company / provider.

b. If no, please state whether the University has developed internal
methods to conduct automated analysis of social media / social network
monitoring.

5. Please confirm, if not stated already in the above, the policy on
deletion of data obtained from social networking sites.

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?
f. Is there any process for requesting deletion by the subject (person
whose social media is surveilled)?

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.

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.

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?

Thank you for your consideration.
Sincerely,

Jen Persson

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Paul Osborne,

Dear Jen,

 

Thank you for your freedom of information request received by this office
on 3rd June and please accept my apologies for the delay in this response
as beneath in red narrative.

 

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)
There is not a specific policy, matters will be covered by the Student
Non-Academic Misconduct Policy
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 will conduct overt
monitoring but not covert monitoring

 

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. Primarily
conducting investigations where there may be a breach of the appropriate
University student codes of conduct

b. If your University does conduct social media intelligence/monitoring,
please specify which social media may be in scope. All social media

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. N/A

3. If you conduct social media intelligence relating to social media
platforms, please provide a copy of:  N/A

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.

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. No

a. If yes, please state the name of the company / provider. N/A

b. If no, please state whether the University has developed internal
methods to conduct automated analysis of social media / social network
monitoring. No

5. Please confirm, if not stated already in the above, the policy on
deletion of data obtained from social networking sites. If data is
obtained it will be subject to the University's Records Retention Policy

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)  Investigations and also  Marketing
b. What criteria must be satisfied in order for social media monitoring to
be carried out An investigation will have been approved as part of the
non-academic misconduct procedures as there has been an alleged breach of
the Student Code of Conduct (a complaint has been made)
c. Who must authorise the request to conduct social media monitoring If an
investigation is being carried out  it is subject to the Non-academic
misconduct Policy
d. What is the process for conducting social media monitoring It will be
carried out by the University's Case Officer as part of investigating the
complaint
e. How long is data collected and retained? In accordance with 5. above
f. Is there any process for requesting deletion by the subject (person
whose social media is surveilled)? A request would be passed to the
University's Data Protection Officer

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.  We do not have this level of data

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.as 7 above

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?  Yes

 

 

You may request a review of the information contained within this freedom
of information response from my colleague Lee Bartlett 
[1][email address]  If you remain dissatisfied following the
review you may appeal to the Information Commissioner at [2]ico.org.uk.
Alternatively, you may write to the ICO at:

 

Head Office

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a
national rate number

 

Yours sincerely

 

Paul Osborne   BSocSc(Hons) LLM,
Solicitor                                                                                                            

Swyddog Diogelu Data   /  Data Protection Officer

Campws Busnes Abertawe SA1 1NE Cymru DU/ Swansea Business Campus, SA1 1NE,
Wales, UK

Llinell Uniongyrchol / Direct Line: 01792
481180                                               

e-bost / e-mail: [3][email address]

 

 

References

Visible links
1. mailto:[email address]
2. Original URL: http://ico.org.uk. Click or tap if you trust this link.
https://eur01.safelinks.protection.outlo...
3. mailto:[email address]