Documentation:Student Privacy and Consent Guidelines/Instructor Use Summary
FIPPA requires that all information about our students remain in Canada. Of course students may choose to use applications or tools that are hosted outside of the country - they just cannot be required to use use their personal accounts to meet the academic requirements of the course. Many tools and platforms, however have options for users to remain anonymous by the use of an alias. The Commissioner’s office has indicated that if use of the tool is required for a course, students must be given an option to use an alias.
- learning goals should guide your process in selecting the best option for what you are trying to achieve
- help frame choices for students (re: digital identity and impact on learning/life goals)
- allowing students to use an alias
- Keep in mind if you are tracking student particiation you will need a way to associate students names with their alias
- Note: Some tools license agreements do not allow the use of aliases
- anonymous use of the tool
- talk to your faculty support unit OR the Learning Technology Hub about supported alternatives to the service (UBC hosted or current integration)
At UBC, learning technologies hosted outside may be used under the following conditions (from: UBC's Privacy Fact Sheet: Disclosing Personal Information Outside of Canada) :
- in the course description, or in a written communication to the students, describe the cloud-based service and the information that it will be storing or accessing, and explain that if the students choose not to provide their consent to this storage or access, they must see the instructor to make alternate arrangements; and
- make alternate arrangements for students who refuse to provide their consent, such as allowing them to sign in to the service using a false name and non-identifying email address
You may also choose to link to resources for students that can help them make an informed decision about their digital presence.
Resources for Students
The Digital Tattoo project highlights resources developed by students to help their peers make decisions about their online participation and identity formation:
An important aspect of ensuring that you are complying with FIPPA as you move to integrate social media is your class is the need to document your attempts to ensure that all students are informed of the use of the tool, the reason for its use and the option to obfiscate their identity (through the use of an alias) or participate in another way, as required. These attempts may include:
- a copy of or link to your course description and syllabus, specifying the tool or platform to be used, potential learning benefits and where information is stored.
- a copy or link to any other information provided to students about the use of the tool or platform you propose.
- For students using aliases, your list of their accounts and aliases. **
In the event, there is a student complaint about a breach of privacy, these documents will be important to demonstrate that you have taken reasonable steps to comply with your obligations under FIPPA.
Note on the use of an alias: You will need to read the terms of service for the tool you are thinking of using. Some services do not allow the use of aliases and will specify this in the terms/user agreements. In this case, you may want to explore other options for hosted UBC applications or pursue a Privacy Impact Assessment. At UBC, you can begin this consultation with Joe Zerdin, Senior Support Analyst: Learning Technologies.
Resources for Instructors
- UBC's Privacy Fact Sheet: Disclosing Personal Information Outside of Canada for examples of considerations related to the use of Cloud-Based Services.
- Privacy Guide For Faculty Using 3rd Party Web Technology (Social Media) in Public Post Secondary Courses (2011): Vancouver Island University in collaboration with BCCampus
For more information/support, contact:
More About Privacy and Bill C-51
- Privacy Matters @ UBC
- Office of the University Council UBC:
- Protection of Privacy
- FIPPA: Freedom of Information and Protection of Privacy Law
- Privacy and Cyber Security - Emphasizing privacy protection in cyber security activities - a research report from the Office of the Privacy Commissioner of Canada (December, 2014)
- Privacy and Cyber-Security (Office of the Privacy Commissioner in Canada - 2014