Monitoring of social media / ECHR Article 8

Dr. Geraint Bevan made this Freedom of Information request to Student Loans Company Limited

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was successful.

Dear Student Loans Company Limited,

Thank you for responding to my previous request [1] regarding privacy impact considerations of your exercise in January 2018 to make checks of students' social media content to establish any inconsistencies which may suggest the claimed estrangement status was inaccurate. I note that no privacy impact assessments were undertaken.

Following on from this, could you please provide me with (a) any advice, discussions or information that you may have regarding compliance of this exercise with ECHR Article 8 (respect for private and family life)?

In addition, I should be grateful if you would confirm my understanding (b) that the exercise included all students who claim estranged status and was not targetted specifically at those suspected of committing fraud.

Yours faithfully,

Dr. Geraint Bevan

[1] https://www.whatdotheyknow.com/request/m...

SLC FOI Requests - Do Not Reply, Student Loans Company Limited

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FOI Requests, Student Loans Company Limited

Dear Dr Bevan

I refer to your recent email dated 05/09/2018 requesting the following
information under the Freedom of Information Act 2000 (“FOIA”):

Following the response to FOI request 178-18 in relation to the Counter
Fraud Services (“CFS”) estranged students exercise

“.……could you please provide me with (a) any advice, discussions or
information that you may have regarding compliance of this exercise with
ECHR Article 8 (respect for private and family life)?

In addition, I should be grateful if you would confirm my understanding
(b) that the exercise included all students who claim estranged status and
was not targeted specifically at those suspected of committing fraud.”

Response

In response to your first question, I can confirm that while acknowledging
the rights established by Article 8(1) of the ECHR, the right is not
absolute and Article 8(2) does provide for exceptions to this right. SLC
is a government-owned and non-profit-making public body that administers
loans and grants to students in colleges and universities. SLC’s actions
were carried out in accordance with the exceptions detailed under Article
8(2) necessary to protect the legitimate aims of SLC such as the economic
well-being of both our customer base and the taxpayer, the prevention of
crime and the protection of the rights and freedoms of others.

I can also confirm that the personal information we collect as part of the
application process is treated respectfully and not used in any way that
could cause embarrassment.  When using social media to support an
investigation we only use open source information that is publicly
available - we do not seek to connect with customers in order to gain
additional access or information from their social media accounts.

In response to your second question I can confirm that the sample was
selected at random from a list of all first year students who had claimed
to be estranged. There was no suspicion of fraud.

Internal review process

If you are dissatisfied with the handling of your request, you have the
right to ask for an internal review.

Internal review requests should be submitted within two months of the date
of receipt of the response to your original request and should be
addressed to the Freedom of Information Office, Student Loans Company
Limited, 100 Bothwell Street, Glasgow, G2 7JD,   Email:
[SLC request email].  Please remember to quote the reference number
above in any future communications.

If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision.  The Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House  
Water Lane  
Wilmslow  
Cheshire  
SK9 5AF

Yours sincerely

Louise Chapman | Legal Executive
Student Loans Company
100 Bothwell Street, Glasgow G2 7JD
e: 32080  t: 0141 306 2080

[1]www.slc.co.uk
Follow us at [2]Twitter/SLCcomms for the latest corporate news and updates

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References

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Dr. Geraint Bevan

Dear Louise,

Thank you for that information.

Yours sincerely,

Dr. Geraint Bevan

SLC FOI Requests - Do Not Reply, Student Loans Company Limited

This is an automated response to let you know that your email has been
received by the Student Loans Company Limited ("SLC").

SLC's Freedom of Information Office is only able to deal with requests for
information under the Freedom of Information Act 2000 ("FOIA"). If your
email relates to a request for information under the FOIA, a separate
acknowledgement will be issued with a request reference.
your email is in relation to a student finance application or account
enquiry, and you have provided sufficient details to identify your account,

your email will be passed to the relevant department. Alternatively,
please contact us using the contact details available at
https://www.slc.co.uk/contact.aspx.

If your email is not a customer enquiry then it has been passed to the
relevant department.

SLC's Freedom of Information Office is unable to advise response timescales

for other departments.

show quoted sections