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Higher Education data: social media monitoring

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Dear University of Reading,

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

IMPS, University of Reading

Dear Ms Persson,
This is to acknowledge receipt of your request for information.
COVID19 – Notice of possible impact on requests for information
The University is doing all it can to minimise disruption and meet statutory deadlines during these challenging times and your patience and understanding would be much appreciated.
Please be advised that many staff across the University are now working remotely. Staffing numbers and ease of access to some information may be affected during this time.
We will do all we can to respond to your request in 20 working days from receipt of your request, however delays in responding to your request may be unavoidable. We will notify you of any delay to your request if this is likely to exceed the 20 day timeframe.
We would like to ask you to help us at this time by:
• Consulting our publication scheme prior to making a request – the information may already be available. If you subsequently find the information you have requested is already available, please notify us and withdraw your request. http://www.reading.ac.uk/internal/imps/F...
• If you are seeking information relating to COVID19 measures taken by the University, please consult our dedicated pages here - https://www.reading.ac.uk/internal/staff...
• If you are looking for a staff contact please use or staff directory (please note that many staff are currently off site)
• If you are seeking information relating to IT security and/or polices, please consult our IT and IMPS pages here
http://www.reading.ac.uk/internal/imps/p...
• We may in some instances have readily available information but for differing timeframes, for example earlier years. Please consider whether this would be of use to you.
• Please be mindful that these are unprecedented and very challenging circumstances. Whilst the University will be doing everything it can to meet compliance obligations, priority is necessarily being given to the provision of teaching and learning, including remote working to support these functions. Please consider whether your request could be made at a later date.
Your request has been assigned a reference number in the subject line (IMPS#02787); please quote this on future correspondence, thank you.

Yours sincerely,
Sinead Latham
Information Management & Policy Services (IMPS), University of Reading, Whiteknights, Reading, RG6 6AH
www.reading.ac.uk/foia

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IMPS, University of Reading

Dear Jen Persson, 

 

We have completed the compilation of information in response to your
request.

 

We can confirm that we do hold some information of the description
specified in your request. Our responses are given below each limb of your
request.

 

************* FOI RESPONSE ************

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)

No information held, we do not hold a “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”

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?

No the University does not conduct “overt and/or covert social media
intelligence gathering” of students.

 

Please note: we do conduct media monitoring (social media listening) on
public platforms for keywords and search terms related to the University,
for example; tweets containing “University of Reading” “Reading Uni” “Uni
of Reading” or Instagram posts which check in at our physical locations.
We do not monitor students, and there is no past or current practice
around specifically following/tracking/surveilling students to monitor
their specific social media output.

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.

N/A by virtue of answer to Q2

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

N/A by virtue of answer to Q2

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 by virtue of answer to Q2c

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

N/A

Please state if you do not have any of the above.

N/A

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, for monitoring students. We do use tools for media monitoring (social
media listening) on public platforms for keywords and search terms related
to the University, the details for these are given below.

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

Hootsuite (lowest tier) and Tweetdeck

These are used to monitor for keywords, phrases, and locations, not
students

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

N/A

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

No information held, we do not hold a policy on deletion of data
specifically obtained from social networking sites.

Any information that forms part of a formal student disciplinary matter,
which could include information taken from social networking sites, for
example, if the matter related to student harassment of another student
via those channels, would be retained as per the policy for student
misconduct matters which is typically retained for 6 years after the
ceasing of their relationship with the University.

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)

The University doesn’t use “social media monitoring” however social media
listening as described above is used by Corporate Functions.

b. What criteria must be satisfied in order for social media monitoring to
be carried out

No information held. The University doesn’t use “social media monitoring”
for the purposes of monitoring student accounts, however in respect of
social media listening we may become aware of posts if they match criteria
for our general keyword and phrase-based social listening, and we may be
directed to specific posts as the result of a complaint raised by other
social media users inside or outside the university.

c. Who must authorise the request to conduct social media monitoring

No information held. The University doesn’t use “social media monitoring”
for the purposes of monitoring student accounts, and so requests are not
submitted for authorisation.

d. What is the process for conducting social media monitoring

N/A the University doesn’t use “social media monitoring” for the purposes
of monitoring student accounts.

e. How long is data collected and retained?

N/A the University doesn’t use “social media monitoring” for the purposes
of monitoring student accounts.

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

N/A

The University doesn’t use “social media monitoring” for the purposes of
monitoring student accounts, and so does not collect information on
individuals for those purposes. We do not monitor the social media output
of individual students.

We may become aware of posts if they match criteria for our general
keyword and phrase-based social listening, and we may be directed to
specific posts as the result of a complaint raised by other social media
users inside or outside the university.

If an individual made an erasure request this would be treated in
accordance with data protection law and dealt with by the Information
Management (IMPS) department as per standard procedures.

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.

No information held, we do not perform “social media monitoring” targeted
at individuals. We do not target our social listening to defined groups
such as current students.

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.

N/A

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?

N/A

 

****************** END ****************

 

We are required to include details of our complaints procedures, including
your rights to apply to the Information Commissioner.  The procedure is
detailed in our Freedom of Information and Environmental Information
Regulations policy on the web at
[1]www.reading.ac.uk/freedom-of-information-policy

 

If we are unable to resolve any complaint, you can complain to the
Information Commissioner, the independent body who oversees the access to
information regimes: [2]https://ico.org.uk/make-a-complaint/ 

 

 

Yours sincerely, 

 

Sinead Latham

Information Compliance Officer

 

Information Management & Policy Services (IMPS), University of Reading,
Whiteknights, Reading, RG6 6AH

[3][University of Reading request email]    t: +44 (0)118 378 8981   
[4]www.reading.ac.uk/foia

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We don't know whether the most recent response to this request contains information or not – if you are Jen Persson please sign in and let everyone know.