Higher Education data: social media monitoring

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

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was successful.

Dear Brunel University,

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

FoI requests, Brunel University

Dear Ms Jen Persson,

Thank you for your recent Freedom of Information Request, you should receive a response by 30 June 2020.

Please be aware that due to the ongoing coronavirus COVID-19 outbreak, there may be a delay in us processing your request. This means that in some cases, you won’t receive a response within the usual 20 day deadline.

For further information on the latest guidance from the Information Commissioner’s Office, please visit: https://ico.org.uk/global/data-protectio...

We appreciate your patience at this challenging time, and we will endeavour to respond to all requests are quickly as possible.

Kind Regards,

Amy Pocknee
Deputy Data Protection Officer

• Please note, I am currently working from home. Please contact me by email or on Teams.
• During this period, the Data Protection team is operating as normal.
• For general information about Brunel’s response to the Coronavirus, advice or support, please visit our portal

Brunel University London

Brunel University London, Uxbridge, UB8 3PH, United Kingdom
T +44(0)1895 274000
www.brunel.ac.uk

Connect with the University on LinkedIn, Twitter, Facebook

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FoI requests, Brunel University

3 Attachments

Dear Ms Persson,

Please find attached our response to your request.

Kind Regards,

Amy Pocknee
Deputy Data Protection Officer

• Please note, I am currently working from home. Please contact me by email or on Teams.
• During this period, the Data Protection team is operating as normal.
• For general information about Brunel’s response to the Coronavirus, advice or support, please visit our portal

Brunel University London

Brunel University London, Uxbridge, UB8 3PH, United Kingdom
T +44(0)1895 274000
www.brunel.ac.uk

Connect with the University on LinkedIn, Twitter, Facebook

show quoted sections