Higher Education data: social media monitoring

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

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Dear Heriot-Watt 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, Heriot-Watt University

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Freedom of Information, Heriot-Watt University

1 Attachment

Dear Ms Persson 

 

Thank you for your recent information request dated 2 June 2020 regarding
student social media monitoring. Your request has been handled under the
Freedom of Information (Scotland) Act 2002. 

In response to your request please note that Heriot-Watt University does
not conduct any social media monitoring activities and that this policy
complies with guidelines issued by the Scottish government. This
information is therefore exempt from release under Section 17 of FOISA:
information not held. 

 

As you are aware we are a Scottish University, and we have been issued
with Prevent guidance by the Scottish Government which varies from that
issued to England and Wales. This guidance can be viewed by clicking on
the link below:

[1]https://www.gov.uk/government/publicatio...

The University also complies with the Good practice guide for Scottish
Higher Education Institutions which was prepared by the Higher Education
Prevent Working Group in June 2015. I hope you find this useful to your
research.

 

Your right to seek review of our decision 

If you are not satisfied with our response or our reasoning set-out above,
you have forty working days from today in which to request a review of our
decision. Any request should be put in writing and should be sent to Ann
Jones, Head of Information Governance, at the address detailed at the
bottom of this email. The request should: 

(a) detail your request for a review of our decision to be undertaken; 

(b) describe the nature of your original request; and 

(c) explain the reasons why you are dissatisfied with our response. 

If you remain dissatisfied with how your request for information has been
dealt with, you also have the right to apply to the Scottish Information
Commissioner for a decision as to whether we have handled your request
properly. 

  

Information relating to your right to seek review is available from the
Scottish Information Commissioner's web page
at:[2]http://www.itspublicknowledge.info/YourR...

or by contacting the Scottish Information Commissioner's Office at the
following address: 

  

Scottish Information Commissioner, 

Kinburn Castle, 

Doubledykes Road, St Andrews, 

Fife KY16 9DS 

Telephone: 01334 464610 

Fax: 01334 464611 

E-mail: [3][email address

Website: [4]http://www.itspublicknowledge.info/home/...

 

Contact us 

Finally, should you wish to discuss the contents of this email, please do
not hesitate to contact us via [5][Heriot-Watt University request email] 

FOISA Team 

Information Governance Division 

Heriot-Watt University 

Edinburgh EH14 4AS 

  

[6]cid:429163a2-d738-41ab-b34f-f593e55ad9f9 

 

 

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

From: Jen Persson <[FOI #668315 email]>
Sent: 02 June 2020 16:56
To: Freedom of Information <[email address]>
Subject: Freedom of Information request - Higher Education data: social
media monitoring

 

Dear Heriot-Watt 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

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