Transparency and legitimate interest

11. Students are informed about how their data will be processed when they are offered a place at the University, when they agree to the University's terms and conditions upon registration, and when they re-enrol. This information is provided via the University's Privacy Notice for students and personal data will be collected for Learning Analytics purposes in compliance with the Privacy Notice. The Privacy Notice is published on the University’s website.

12. The processing of personal data for Learning Analytics purposes is necessary for the legitimate interest of the University in supporting students (see point 2 of the Privacy Notice for students). A formal assessment of these interests has been carried out and the University is satisfied that these are not overridden by the interests or fundamental rights and freedoms of the data subjects in question.

13. The data for Learning Analytics comes from a variety of sources, including the student records system and the virtual learning environment. The Student Guide to Learning Analytics will clearly specify: 

• The data sources being used for Learning Analytics.
• The specific purposes for which Learning Analytics is being used.
• The data sources being used and how an engagement indicator has been produced.
• Who has access to Learning Analytics, and why.
• Guidance on how students can interpret any Learning Analytics provided to them.

Confidentiality

14. Personally identifiable data and Learning Analytics on an individual student will be provided only to: • The student

• The University staff members who require the data in their professional capacity
• Third parties which are processing Learning Analytics data on behalf of the University. In such circumstances the University will put in place contractual arrangements to ensure that the data is held securely and in compliance with the data protection legislation.

15. The University's Safeguarding Policy ensures that University staff work in a manner to protect students who are vulnerable to harm so that they can participate in a safe and secure environment, and their parents/carers can have confidence in the University. There are clear arrangements for reporting concerns and liaising with external authorities where action, advice or support is required. Learning Analytics may be used to support the delivery of the Safeguarding Policy. Data sharing in these circumstances will be carried out in accordance with the University's Privacy Notices and Data Sharing Agreements, and only where there is a clear lawful basis.

16. The University IT staff will have access to systems and data in order to maintain proper functioning of IT systems rather than to access any individual’s data.

Sensitive data

17. Data protection legislation defines “special categories of personal data” which include information about a student’s ethnicity and disability. The University only uses such data where there is a clear lawful basis for doing so. The University’s Information Governance Policy and Special Category Personal Data Policy govern this processing which will be documented in The Student Guide to Learning Analytics. Validity

18. The quality, robustness and validity of the data and analytics processes will be monitored by the University, which will use its best endeavours to ensure that:

• Data are accurate.
• The optimum range of data sources to achieve accurate analytics information is selected. • Spurious correlations and conclusions are avoided.
• Learning Analytics is seen in its wider context, and is combined with other data and approaches as appropriate.

19. Students have the right to correct any inaccurate personal data held about them, via My Student Record.