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Higher Education data: social media monitoring

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Dear University of Central Lancashire,

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

DP FOIA, University of Central Lancashire

Dear Ms Persson,

Thank you for your request for information below which has been given reference FOI 2206. Please quote this on any correspondence regarding your request.

Unfortunately, we are not able to respond to your request without further clarification. Some of your questions explicitly relate to social media-monitoring for purposes related to Prevent, whilst others do not mention Prevent. For the avoidance of doubt, can you please clarify which of your questions relate only to social media monitoring for Prevent purposes and which relate to monitoring for other purposes.

Once you have provided the above clarification, the University of Central Lancashire will respond to your request within 20 working days. If there will be a charge for disbursements e.g. photocopying in order to provide the information, we will inform you as soon as possible to see if you wish to proceed.

Yours sincerely,

Clay Garland
Information Governance Officer
Legal and Governance
University of Central Lancashire
Email: [email address]

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Dear DP FOIA,

You asked for clarification. We ask for the purposes of all social media monitoring. Whether these are for Prevent, or other purposes, please set this out in your reply.

Thank you. Sincerely,

Jen Persson

DP FOIA, University of Central Lancashire

Dear Ms Persson,

Thank you for providing clarification. I can confirm we are now processing your request, and you can expect our response at the latest 20 working days from the date of your clarification.

Kind regards

Clay Garland
Information Governance Officer
Legal and Governance
University of Central Lancashire

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DP FOIA, University of Central Lancashire

1 Attachment

Dear Ms Persson,

Further to your request for information below (Ref FOI 2206), please find attached the University's response.

Please accept my apologies for the delay in responding to you.

Kind regards

Clay Garland
Information Governance Officer
Legal and Governance
University of Central Lancashire

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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.