Higher Education data: social media monitoring

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

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The request was successful.

Dear Glasgow Caledonian 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 Enquiries,

Dear Jen

Glasgow Caledonian University has received your request for information. The University is currently processing this and will get back to you as soon as possible. It will be responded to under the Freedom of Information (Scotland) Act 2002.

Yours sincerely

Katie

Katie Malone | Administrative Assistant
Department of Governance
Glasgow Caledonian University, Cowcaddens Road, Glasgow G4 0BA.
Email [email address]
Phone: 0141 331 3685

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Freedom of Information Enquiries,

1 Attachment

Dear Jen

I refer to your request for information below.

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)

Complaints or investigations into student conduct would be conducted under our Code of Student Conduct. This is published on our website at: https://www.gcu.ac.uk/gaq/complaintsstud...

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?

The University does not undertake this type of surveillance.

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.

Not applicable.

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

Not applicable.

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.

Not applicable.

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.

Not applicable.

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.

Not applicable.

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

Not applicable.

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

Not applicable.

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

Not applicable.

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)?

The University does not routinely monitor or undertake surveillance of students’ social media.

7. Please state how regularly social media monitoring is used, on what volume of individuals (ie targeted for individual situations or every student 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.

Please see Question 6.

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 referrals 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.

Not applicable.

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?

Not applicable.

Please find attached a review notice setting out the steps you may take if you are not satisfied with the response provided to your request.

If there are any questions in relation to this request, please contact the University at [email address]

Yours sincerely

Katie

Katie Malone | Administrative Assistant
Department of Governance
Glasgow Caledonian University, Cowcaddens Road, Glasgow G4 0BA.
Email [email address]
Phone: 0141 331 3685

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