Higher Education data: social media monitoring

The request was successful.

Dear University of Exeter,

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

InformationGovernance mailbox, University of Exeter

Dear Jen,

Thank you for your request under the information Act of 2000. Your reference number is FOI20-207

Due to the exceptional circumstances caused by current global events there may be some delay in responding to your information request. Following the guidance from the ICO the Information Governance Team continue to work to the timelines set out in law however while the University transitions to new working practices there may be some delays to the responses we receive from data owners and other colleagues across the organisation.

To avoid any of these delays we would urge you to check public data sources including the University website, HESA, UCAS and the Research Councils. Please also ensure that your request is clearly stated so that we can ensure we are directing requests to the most appropriate areas of the business.

The data you provide to allow us to process your request is collected so that you are able to exercise your lawful rights under the Freedom of Information Act. Your personal data will be held by the Information Governance Office and shared with relevant staff as necessary.

Once a request has been completed, the relevant data will be held by the Information Governance Office for three years in line with ICO guidance, this is to ensure the University has fully carried out its requirements under the legislation.

For further information on how we process your personal data, please see: http://www.exeter.ac.uk/dataprotection/

The University should respond to your FOI request as soon as possible and no later than twenty working days after the date of receipt of the request. Should The University be required to undertake a public interest test relating to the potential application of a qualified exemption we may extend the time frame by up to twenty additional days. Please be aware that our response time takes into account the workloads of the Information Governance Office and relevant data owners and will therefore not always correlate with the complexity of the request. Should The University seek clarification any resulting time spent awaiting communication will not be counted against that time limit.

Regards,

Information Governance Officer

University of Exeter
www.exeter.ac.uk
Lafrowda House, St. German’s Road, Exeter, EX4 6TL

This email and any attachment may contain information that is confidential, privileged, or subject to copyright, and which may be exempt from disclosure under applicable legislation. It is intended for the addressee only. If you received this message in error, please let me know and delete the email and any attachments immediately. The University will not accept responsibility for the accuracy/completeness of this email and its attachments.

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InformationGovernance mailbox, University of Exeter

1 Attachment

Dear Jen,

Please find the University's response to your Freedom of Information Request attached.

Kind regards,
Information Governance Officer

University of Exeter
http://www.exeter.ac.uk/foi/summary/
Lafrowda House, St. German’s Road, Exeter, EX4 6TL

This email and any attachment may contain information that is confidential, privileged, or subject to copyright, and which may be exempt from disclosure under applicable legislation. It is intended for the addressee only. If you received this message in error, please let me know and delete the email and any attachments immediately. The University will not accept responsibility for the accuracy/completeness of this email and its attachments.

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