Newman University is committed to supporting the formation of students and strongly encourages their full participation in our community; working in partnership with academics and professional staff in a spirit of mutual trust and respect. In this regard, we recognise that using student engagement data across the University can support such participation. Our primary focus therefore in using such data is to support students in their personal learning journeys towards degree attainment, concurrently maintaining our reputation as a student-centred university.
This policy covers all uses of student engagement data at the University. Ethical issues relating to the use of student data in academic research are further covered by the Newman University Code of Practice for Research & Ethical Guidelines. The University bodies considering applications for research using student engagement data should assess if the research projects comply with the principles in this policy. The bodies may, within the remit of their own terms of reference, approve research proposals that test the boundaries of this policy.
1.1 The collection and use of student engagement data provides new opportunities for institutions to support learner success and to enhance educational processes. This is commonly known in the sector as learning analytics. Learning analytics systems present visualisations of student activity with some providing predictions of attainment. Such systems will be used at Newman University to assist current students in achieving their study goals, and to help us improve our overall education provision.
1.2 Drawn from the Strategic Plan 2014-2020 (2014); Learning, Teaching and Assessment Strategy (2015); People Strategy (2015-20) (2016) and forthcoming Retention and Success Strategy, Newman University will use and analyse student engagement data to help meet the following strategic objectives:
- Enable more students to fulfil their potential through fostering the development of all students into autonomous learners, able to cope with complexity
- Provide opportunities for students to proactively contribute to the enhancement of their experience within our learning community
- Promote a sense of mutual ownership, belonging and fulfilment
- Share and disseminate effective practice across all provision, including effective use of new technologies
- Support team learning through communication and dialogue within, across and beyond University disciplines, departments and stakeholders
1.3 Newman University will ensure that activities using student engagement data will be for the benefit of students, with complete transparency about the data that is being captured, processed and used. All activities in this area will comply with the Data Protection Act 2018 / General Data Protection Regulation (GDPR). Information is available here: http://www.newman.ac.uk/corporate-information/3089/data-protection.
1.4 This policy is therefore founded on the following eight principles:
- Using student engagement data is an ethical practice and aligns with our focus on formative education that seeks to develop the whole person through transformative learning
- Students are real, diverse people who cannot be wholly defined or limited by representations of their data nor any interpretations of it
- In the spirit of mutual trust and respect, students should be active partners in the design and implementation of systems and activities informed by data use and analysis
- The source, use and process of using student engagement data will be transparent and clearly explained to all stakeholders
- Using student engagement data will be based on informed consent explicitly requested at the point of initial registration and re-enrolment
- The use made of student engagement data will be clearly defined and assigned to specific individuals or groups, however, overall responsibility and accountability for the use and analysis of data at Newman University rests with the University Registrar
- Effective use of student engagement data is dependent on up-to-date data and thus, staff and students alike are responsible for maintaining accurate student records
- Data will be generated and used appropriately and responsibly without bias and in accordance with data protection and equality legislation
2.1 Overall responsibility for using student engagement data at Newman University is held by the University Registrar. Responsibility for relevant areas of activity is allocated as follows:
- Collection of student engagement data to be used for analysis: IT Director
- The anonymization or de-identification of data where appropriate: IT Director
- The analytics processes to be performed on the data, and their purposes: University Registrar
- The interventions carried out that are informed by student engagement data: PVC Formative Education
- The retention and stewardship of data used for and generated in using student engagement data: University Registrar
2.2 Engagement data presented to students is intended to help them understand their learning-associated activity, where subsequent suggestions may be made as to how they can improve their practices. Students are responsible for assessing how they can best apply any such suggestions in relation to their learning activity.
2.3 This policy is owned by Newman University Learning, Teaching and Assessment Committee. This Committee will need to set up a formal approval process to ensure compliance with this policy.
3. Transparency and consent
3.1 Students are informed about how their data will processed when they read the Privacy Notice for Students, provided before and during enrolment as well as anytime on the internet, as well as when they register for the SEAtS student engagement system. Student engagement data will be collected and analysed in compliance with the University’s data protection policies and as outlined in more detail within this document.
3.2 Student engagement data comes from a variety of sources, including the student record system, SEAtS and the virtual learning environment.
3.3 Categories of data captured by the University as part of its interaction with students and potentially available as individual or combined data sets for analysis are:
- personal information provided by the student at registration
- the student’s study record held by the University
- sensitive information that the University has consent to use. Currently consent for the use of ethnic origin and disability to identify students who may be in need of additional support is obtained at registration when students agree to the Data Collection Notice
- details of contacts between the enquirer or student and the University
- interactive content generated by enquirers or students; for example: completing diagnostic tests, student responses to surveys and research etc.
- system-generated data such as the date and frequency of accessing VLE pages;
- data derived by the University from other data, for instance, whether a student falls into a widening participation category
- data held or generated internally in combination with data provided by third parties may be used by the University to tailor support, where there is agreement to do so from the third party concerned. For example, the Library gathers information generated by student use of a subscription service. Student data supplied to third parties is subject to existing guidance, such as Data Protection
- anonymised data from external sites, e.g. social networking sites not owned by the University, where this is used to generate information on the cohort rather than the individual student. For example, where this forms part of an activity within a module
- miscellaneous sources of data, for example, forum posts could be anonymised and analysed to shape module design
3.3 Students cannot opt-out of the student engagement data collection or analysis as this activity must be conducted to fulfil regulatory reporting duties, because this is part of our registration processes. However, it will be possible for students to opt-out of receiving automated prompts or suggestions sent to them, as informed by the analysis. These may include emails, SMS messages or app notifications.
4.1 Personally identifiable data on an individual student will be provided only to:
- The student
- Newman University staff members who require the data to support students in their professional capacity, in accordance with disclosure agreements
- Third parties which are processing student engagement data on behalf of the institution. In such circumstances Newman University will put in place contractual arrangements to ensure that the data is held securely.
- Other individuals or organisations to whom the student gives specific consent
5. Special Category Data (formerly called Sensitive Data)
5.1 The Data Protection Act 2018 / UK GDPR defines categories of “special category data” such as, but not limited to, ethnicity or disability.
5.2 In using student engagement data to provide student support, the University will not use the following types of data. This list is subject to review.
- Data that identifies individuals created on external sites, e.g. social networking sites not owned by the University, third party sites where there is no permission to employ shared information, etc.
- Special category (i.e. sensitive information) on religious belief and sexual orientation will not be used as part of the analytical models. Should any other special category data items be required for learning analytics, the legal basis will have to be considered, data subjects informed, potentially consent will need to be sought. Any combinations of data or derived data that may contravene an individual’s right to respect for their private and family life will not be used.
5.4 Applications to use student data for the purposes of research will need to be made in accordance with the standard processes in place currently, such as the Research Ethics Committee. Bodies considering applications for research using student engagement data should assess whether the projects comply with this policy. The bodies, within the remit of their own terms of reference, may approve research proposals that test the boundaries of this policy. If the outcomes of that research may then be applied to operationally targeting individuals or groups of students, further alignment with this policy will be required.
6.1 The quality, robustness and validity of student engagement data and analysis will be monitored by Newman University, which will use its best endeavours to ensure that:
- Inaccuracies and gaps in the data are understood and minimised
- The optimum range of data sources to achieve accurate predictions is selected
- Spurious correlations and conclusions are avoided
- The algorithms and metrics used for predictive analytics and interventions are valid
- Using student engagement data is seen in its wider context, and is combined with other data and approaches as appropriate
7. Student access to personal data
7.1 Mechanisms will be developed to enable students to access their engagement data, and any analysis performed on it in a meaningful, accessible format at any time. Students have the right to correct any inaccurate personal data held about themselves.
7.2 Students should also be able to view any metrics derived from their data, and any labels attached to them.
7.3 If the student requests to see all their engagement data, it will be made available to them.
8.1 A range of interventions may take place with students. The types of intervention and what they are intended to achieve are documented in Supporting student learning through information: a student guide. These may include:
- Prompts or suggestions sent automatically to the student via email, SMS message or mobile app notification (subject to the student’s consent)
- University staff contacting an individual on the basis of the analytics if it is considered that the student may benefit from additional support. Students cannot opt out of the offer of support: they are entitled to refuse any support offered or ignore guidance given.
8.2 Interventions, whether automated or human-mediated, will normally be recorded. The records will be subject to periodic reviews as to their appropriateness and effectiveness.
9. Minimising adverse impacts
9.1 The University will investigate and attempt to resolve any reports of adverse impacts on students resulting from generating student engagement data, such as confusion or demotivation.
9.2 The University recognises that using student engagement data cannot present a complete picture of a student’s learning, and that predictions may not always be accurate.
9.3 Students will retain autonomy in decision making relating to their learning; using student engagement data is designed to inform their own decision making about how and what to learn.
 Newman University (2014) Strategic Plan, 2014-2020, p.13
 Newman University (2014) Strategic Plan 2014-2020, p 13-15.
 Drawn heavily from: Jisc Code of practice for learning analytics (Jisc, 2015); Ethical Use of Student Data policy (Open University, 2015) and Learning Analytics Policy (University of West London, 2016)