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Higher Education data: social media monitoring

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

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Dear Edinburgh Napier 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

Freedom of Information, Edinburgh Napier University

FOI 099-20

 

Dear Ms Persson,

 

Freedom of Information (Scotland) Act 2002 - Acknowledgement

 

We acknowledge receipt of your request for information and confirm that a
response will be prepared under the terms of the Freedom of Information
(Scotland) Act 2002.

 

If the information you have requested is exempt under the Act we will
advise you of this and of your right to appeal. If the information you
have requested refers to a third party we may consult them before
providing a response. A fee may be payable for the information, in which
case we will advise you of this, and await your response before proceeding
any further with the request. If we request clarification regarding the
information sought, or a fee, the 20 working day response time will be
suspended until we have received this from you.

 

Please let me know if you require your response in an alternative format.

 

Further information is available from the Office of the Scottish
Information Commissioner at:

Scottish Information Commissioner

Kinburn Castle

Doubledykes Road

St. Andrews

Fife

KY16 9DS

 

[1]http://www.itspublicknowledge.info

 

If you have any queries please contact me quoting the reference number
given above.

 

Yours sincerely,

 

Governance and Compliance Services

Edinburgh Napier University

Floor 6 Sighthill Campus 

Edinburgh

EH11 4BN

8: [2][Edinburgh Napier University request email]

[3]http://www.napier.ac.uk/about-us/univers...

Edinburgh Napier University is a registered Scottish charity. Registration
No. SC018373

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Freedom of Information, Edinburgh Napier University

1 Attachment

FOI 099-20

 

Dear Ms Persson,

 

Thank you for your recent information request.  Please find the response
to your request embedded within the attached response document, in blue
text for ease of reference.

 

Unless otherwise stated, Edinburgh Napier University reserves copyright in
all information provided under the Freedom of Information (Scotland) Act
2002 (FOISA). Although the information is available under the legislation
this does not mean that the University has waived its copyright and
therefore the information must not be reproduced in any way or made
available in whole or in part without the written permission of the
copyright holder.

 

Follow-up procedural guidance

 

If you are not satisfied with the way the University has dealt with your
request for information, you have a right under FOISA to request a review
of this decision. If you wish to exercise this right, you must write to
the University to request a review within forty working days of receipt of
this decision. Your request for a review must be in writing and you must
specify your name and address for correspondence.  You must also identify
the decision that you wish to have reviewed. 

 

Should you wish to request a review, please address your request to:

 

David Cloy

University Secretary

Governance & Compliance

Edinburgh Napier University

Room 5.B.18 Sighthill Campus,

Sighthill Court,

Edinburgh EH11 4BN, or email: [1][email address]

 

Your review will be undertaken by staff not involved in the original
decision making process. If you are dissatisfied with the outcome of a
review, you have a right under the FOISA to appeal to the Scottish
Information Commissioner. If you wish to do so, you must appeal to the
Commissioner within six months following the date of receipt of the review
notice. The Commissioner’s contact details are as follows:

 

The Scottish Information Commissioner

Kinburn Castle

Doubledykes Road

St Andrews

Fife

KY16 9DS    

Email: [2][email address]

Tel: 01334 464610

Online: [3]www.itspublicknowledge.info/Appeal

 

Yours sincerely,

 

Governance and Compliance Services

Edinburgh Napier University

Floor 6 Sighthill Campus 

Edinburgh

EH11 4BN

8: [4][Edinburgh Napier University request email]

[5]http://www.napier.ac.uk/about-us/univers...

Edinburgh Napier University is a registered Scottish charity. Registration
No. SC018373

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