Higher Education data: social media monitoring

Jen Persson made this Freedom of Information request to Buckinghamshire New 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.

Response to this request is long overdue. By law, under all circumstances, Buckinghamshire New University should have responded by now (details). You can complain by requesting an internal review.

Dear Buckinghamshire New 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

Buckinghamshire New University

Dear Jen Persson,
FREEDOM OF INFORMATION ACT 2000 - INFORMATION REQUEST

Thank you for your request for information about:

--------------------------------------------------------------------------

Student social media monitoring

--------------------------------------------------------------------------

Your request was received on 03/06/2020 and is being handled under the
terms of the Freedom of Information Act 2000.
Your query has been given the reference BNUFOI 00000319.

Please remember to quote the reference number above in any future
communications.
In some circumstances a fee may be payable and if that is the case we will
let you know. A fees notice will be issued to you and you will be required
to pay before I will proceed to deal with your request.
You will receive the information requested within 20 working days unless
the University does not hold the information or there is a reason for it
to be withheld. I will write to you in any event.
If you have not already done so, please supply your email address if you
are willing to receive the information electronically.
If you have any queries or concerns then please do not hesitate to contact
us quoting the reference number above.[]^
[]^
Further information about your rights is also available from the
Information Commissioner at: The Information Commissioners Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Kind regards, 
FOI Officer
Buckinghamshire New University
High Wycombe Campus
Queen Alexandra Road
High Wycombe
Buckinghamshire
HP11 2JZ
[1]www.bucks.ac.uk 
 

References

Visible links
1. file:///tmp/www.bucks.ac.uk

Buckinghamshire New University

Dear Jen Persson,
Thank you for your request for information about: 
Student Social Media Monitoring

--------------------------------------------------------------------------

Higher Education data: 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 confirm
if the same policy has continued and been applied since March 23, 2020
(lockdown) in the COVID-19 crisis?

--------------------------------------------------------------------------

The information you requested can be found below: 

1. We do not monitor students’ social media.

2. We do not monitor students’ social media.

a. N/A
b. N/A
c. No
d. N/A

3. a-e. N/A

4. No

a. N/A
b. No

5. N/A

6. a-f. N/A

7. N/A

8. N/A

9. N/A

--------------------------------------------------------------------------

If you are dissatisfied with the handling of your request, you have the
right to ask for an internal review. Internal review requests should be
submitted within two months of the date of receipt of the response to your
original letter and should be addressed to [email address].
Please remember to quote the reference number BNUFOI 00000319 in any
future communications.
If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision. 
The Information Commissioner can be contacted at: The Information
Commissioners Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire SK9 5AF.
Kind regards,
FOI Officer
Buckinghamshire New University
High Wycombe Campus
Queen Alexandra Road
High Wycombe
Buckinghamshire
HP11 2JZ
[1]www.bucks.ac.uk 
 

References

Visible links
1. file:///tmp/www.bucks.ac.uk

Dear Buckinghamshire New University,

Thank you for the reply. May I check that I have understood the response correctly, that there is no document on social media monitoring and the University policy is that it is not done in practice ?

I am checking because it seems at odds with section 11 of this published social media University policy: https://www.buckingham.ac.uk/wp-content/...

Thank you for clarification.
Sincerely,

Jen Persson