Higher Education data: social media monitoring
Dear University of Liverpool,
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
Dear Ms Persson
This is to acknowledge receipt of your request for information from
the University of Liverpool. Your reference number is FOI/2020/226. We
will review and process your request as soon as possible.
In line with recent recommendations, many of our staff are now working
from home and we ask that you bear with us through this period. We may
take a little longer than normal to respond to certain enquiries and staff
may not have access to information requested.
We will aim to respond within 20 working days of the day we received the
request. You will hear back from us by 30 June at the latest.
If for any reason we are unable to meet this deadline, we will keep you
fully informed of the reasons for this as soon as practical.
If you have any queries about this email or your request or if at any
stage you are unhappy with the way in which your request is being handled
please do not hesitate to get in touch.
Yours sincerely
Kirsty Rothwell
Freedom of Information Officer / Data Protection Co-ordinator
Legal & Governance
University of Liverpool, Foundation Building, Brownlow Hill, Liverpool L69
7ZX
The information in this email and any attachments is confidential. Unless
you are the intended recipient, you must not read, copy, distribute, use
or retain this message or any part of it. If you are not the intended
recipient, please notify the sender immediately.
[1]Signature-Footer
FOI/2020/226
8 July 2020
Name: Jen Persson
By email to: [FOI #668380 email]
Dear Ms Persson
Thank you for your email of 2 June requesting information from the
University of Liverpool. With apologies for the delay, colleagues have
provided the information requested below.
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.
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)
The University of Liverpool does not monitor individual student social
media accounts. Guidance on social media use is given to staff and
students in the following document
[1]https://www.liverpool.ac.uk/media/livacu...
For students, failure to act in line with the above may result in the
University taking disciplinary action under the Policy on Student Conduct
and Discipline
([2]www.liverpool.ac.uk/student-administration/student-administration-centre/policies-procedures/conduct-discipline/)
as a breach of the rules on student conduct in Section 7 (c). We provide
more precise definitions and indicative sanctions in Appendix I of the
Policy.
We may refer students in Health Sciences, Dentistry, Medical and
Veterinary students to Fitness to Practise procedures under Section 3.7.
([3]www.liverpool.ac.uk/media/livacuk/student-administration/student-administration-centre/documents/Fitness_to_practice_procedures__May_2010.pdf)
Should the University of Liverpool review an individual student’s social
media account as part of an investigation into an allegation of
misconduct, we would only do so if the account was public (i.e. not set to
private) which therefore makes it a matter of public record.
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 of Liverpool does not monitor the social media accounts of
its students.
Does your University conduct social media monitoring exclusively for the
purposes of the Prevent programme?
No information held.
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.
No information held.
If no, please state whether the University has developed internal methods
to conduct automated analysis of social media / social network monitoring.
The University does not use software and/or hardware to conduct social
network / social media monitoring and/or in relation to sentiment analysis
on social media. The University has not developed internal methods to
conduct automated analysis of social media / social network monitoring.
Please confirm, if not stated already in the above, the policy on deletion
of data obtained from social networking sites
With regards to information obtained from social media in the course of
disciplinary matters resulting from an allegation of misconduct, the
information would be held for a period of 6 years after the date the
student left the University of Liverpool (paragraph 11(d), Policy on
Student Conduct And Discipline
[4]https://www.liverpool.ac.uk/media/livacu....
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.
No information held.
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.
No information held.
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?
No information held.
If you are unhappy with the way we have handled your request for
information, you have a right under Section 50 of the Freedom of
Information Act to ask the University to review it; however, you must do
so within 40 working days of the date of this response. Your request
should include our reference number and explain the reason for requesting
a review. Email [University of Liverpool request email] or write to the Freedom of Information
Reviewer, Legal & Compliance, University of Liverpool, Foundation
Building, 765 Brownlow Hill, Liverpool L69 7ZX. We will respond to your
request for an internal review within 20 working days of receipt.
Following an internal review, if you remain dissatisfied with the handling
of your request, you have a right to appeal to the Information
Commissioner at The Information Commissioner’s Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire SK9 5AF. Telephone: 0303 123 1113
www.ico.org.uk.
There is no charge for making an appeal.
Yours sincerely,
Kirsty Rothwell
Freedom of Information Officer / Data Protection Co-ordinator
Legal & Governance
University of Liverpool, Foundation Building, Brownlow Hill, Liverpool L69
7ZX
The information in this email and any attachments is confidential. Unless
you are the intended recipient, you must not read, copy, distribute, use
or retain this message or any part of it. If you are not the intended
recipient, please notify the sender immediately.
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