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Higher Education data: social media monitoring

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Dear London College of Fashion,

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 Requests, London College of Fashion

Thank you for contacting the UAL Freedom of Information team. 

Due to the current COVID-19 pandemic, the Information Governance team are
not fully staffed which means you may experience some delay in
receiving your response. 

We wish to assure you that we are continuing to work on your requests and
a response will be provided to you.

Please be aware we may not be able to provide access to physical files at
this time.

Freedom of Information Requests, London College of Fashion

Dear Jen,

Thank you for your Freedom of Information request.

London College of Fashion is one of the 6 colleges that make up the University of Arts London. As you have also made this request to the University of Arts London, please can you confirm whether a single response from the University of Arts will fulfil your requirements?

Yours sincerely,

……………………………………………………
Information Governance Team

University of the Arts London
272 High Holborn
London
WC1V 7EY
United Kingdom

E [London College of Fashion request email]
arts.ac.uk

……………………………………………………
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Dear Freedom of Information Requests,

Thank you. If the policy is the same with a single university wide approach a high level overall response would be welcome, thank you.

If there are different policies, please state how they apply to each part.

sincerely,

Jen Persson

Freedom of Information Requests, London College of Fashion

1 Attachment

Dear Jen,

 

Please find attached our response to your Freedom of Information request.
This response is from the University of Arts London, and applies to all of
our colleges.

 

Freedom of Information complaints procedure

 

UAL is committed to making information available under the Freedom of
Information Act 2000 (FOIA) and to ensuring that the service it provides
for those wishing to gain access to information is simple, efficient and
effective.

 

If you feel the service you have received does not meet these aims or your
expectations please write, giving details of your complaint, to:

 

Kastur Kerai,

Data Protection Officer,

University of the Arts London

8th Floor

272 High Holborn

London

WC1V 7EY

[1][London College of Fashion request email]

 

Your complaint will be fully investigated and treated confidentially. If
your complaint is about a response to a request for information, it will
be dealt with by an officer who was not involved in the original decision.
A full investigation and any decision will be made and conveyed to you
within 20 working days. If we are unable to deal with your complaint
within this time, we will inform you and let you know the reason for the
delay.

 

If your complaint is upheld you will be notified of what action will be
taken. If it is a request for information, the information will be
provided to you. If the complaint is not upheld you will be given a reason
for the decision.

If we do not deal with your complaint to your satisfaction, you are
entitled to refer your complaint to:

 

The Information Commissioner’s Office,

Wycliffe House,

Water Lane,

Wilmslow

Cheshire,

SK9 5AF

Tel: 0303 123 1113 (local rate)

Tel: 01625 545 745 if you prefer to use a national rate number

[2]www.informationcommissioner.gov.uk

 

Kind regards,

 

 

 

……………………………………………………

Information Governance Team

 

University of the Arts London

272 High Holborn

London

WC1V 7EY

United Kingdom

 

E [3][London College of Fashion request email]

[4]arts.ac.uk

 

References

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We don't know whether the most recent response to this request contains information or not – if you are Jen Persson please sign in and let everyone know.