Higher Education data: social media monitoring

University of Durham did not have the information requested.

Dear Durham 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

ACCESS I., University of Durham

Dear Ms Persson

Freedom of Information Request

I acknowledge receipt of your email below requesting information from Durham University.

Please be advised that the University will respond as soon as possible and in any event within 20 working days.

The University, like other organisations, is facing unprecedented challenges during the coronavirus (COVID-19) pandemic. Please be advised that there may be a delay in our full response to you; we will let you know if this will be the case.

Yours sincerely

Information Governance Unit
Durham University

Information Governance Unit, University Secretary’s Office
t: +44 (0) 191 334 6103/46246  e: [Durham University request email]

CONFIDENTIALITY NOTICE:
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ACCESS I., University of Durham

Dear Jen Persson

 

Thank you for your request for information from Durham University. 
Colleagues have provided the information below in response to your
questions.

 

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.

 

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.

 

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

 

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

N/A

 

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

N/A

 

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:

 

a. Relevant [sections of the] privacy policy;

N/A

 

b. the data protection impact assessment;

N/A

 

c. privacy impact assessment;

N/A

 

d. equality and human rights impact assessment

N/A

 

e. training materials for those conducting social media surveillance

N/A

 

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.

N/A

 

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.

N/A

 

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)

N/A

 

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

N/A

 

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

N/A

 

d. What is the process for conducting social media monitoring

N/A

 

e. How long is data collected and retained?

N/A

 

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

N/A

 

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.

N/A

 

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

 

If you are dissatisfied with the University’s response to your freedom of
information request, you can ask us to internally review our handling of
your request, including the application of any exemptions applied.  To do
this, please email [1][Durham University request email] or write to:

 

Information Governance Unit

The Palatine Centre

Stockton Road

Durham

DH1 3LE          

 

Please state the grounds on which you wish the decision to be reviewed and
enclose any other information that may be useful in considering the matter
further.  We aim to inform you of our decision within 20 working days from
the date your request for internal review is received.

 

If you are not satisfied with the results of the internal review you may
apply to the Information Commissioner's Office for an independent review.

 

Information Commissioner's Office

Wycliffe House

Water Lane                                                  

Wilmslow

Cheshire

SK9 5AF

[2]www.ico.org.uk

 

Yours sincerely

 

Information Governance Unit

Durham University

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Information Governance Unit, University Secretary’s Office

e: [3][Durham University request email]

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