Security and privacy

Hello Elizabeth

good questions, but also complex questions. I think I can't answer them finaly.

At first the aspects are described in seperate articles. My personal opinion ist that it has to be understand from the general background of the GDPR.

The generals are:

• People are the owner of their data.
• They give permission to store this data and can withdraw this permission.
• The people should be protected that the data are abused against the interest of the people
  
• The institution that creates and edits that data should reduce the data to a minimum and delete the data if there is no reason to store them anymore.
  
• The idea of protection is to protect against any type of abuse by private (commercial) or governmental institutions.
• GDPR make differences between data and sensible data.

There is a seperate article in GDPR about anonymization of data.

Learning analytics discussion has not yet started intensive in education. I expect that this will start over next years.

I think its a question of purpose of learning analytics. There is a strong difference inteaching culture in different countries.  I.e. Years a go I was wondering when I saw 'thank you teacher cards' in UK. This is completely unknown here in Germany. I found that its common on UK that students and parents say thank you  to the teachers  at the end of the term that teachers supported the students to success.  In Germany there  is just an other culture of teaching: parents often feels teachers have to segregate between good and not so good students. In some schools its expected that the Gaussian distribution is reached. A teacher who leads all students to success is under critizism very often.  We also have  a strong discussion about individualization of the teaching process and the role of the teacher as individual learning coach.

Something similar happens in universities with lectures that 'should' reduce the number of students and its seen as normal when 50% or more of the students fails at the final exam.

In companies we see other paradigmas: mandatory training programs, training to prepare for a special job or task. Success is sometimes requirement for an internal job, sometimes nobody is interested in success and sometimes is part of control how good they do their job.

With this cultural differences in background we can discuss learning analytics purposes in detail. What is in a special context the intention of learning analytics?

• summative evaluation to optimize a program for the next group of users
• individual support and coaching of a single learner
• control of the learner

Based on the different intention learning analytics will be accepted or critical. 

The discussion from the learner side will be different depending on the experience with the teaching process and culture in the institution. Years ago we ha  a discussion started from students at a German university that the use of the LMS should be completely anonym. They argued a professor should not be able to identify who did what on a platform. A professor could be influenced from a silly question in a forum by a student if he grades the final exam just from this student. This happens specially oif you see classes or lectures with 100-1500 students.

We also have universities with small groups and a much better relationship between professor and student.

Let me make this more complex as it is naturally.  European GDPR will be complemented by national law. In Germany  we have a state level and federal state level. On state level regulations for universities and schools are defined.  The system of insitutional data protection officers is completely independent. Because GDPR and most (federal) state laws are not defining concrete situations data protection officers can accept or deny the data processes.

My personal argumentation is:

• learning analytics will be accepted when the teachers integrate it in their quality management programs
• it will be accepted when it it is part of the teaching concepts and culture
• it will be accepted if it is really used to support users to succeed
• it will be denied if data are not used

I'm very interested in this discussion, because its a good opportunity to push teaching culture and quality management in eductional institutions. 

Ralf

Hi

thanks for your quick response.

You are correct when you argue most of the GDPR definitions are organisational and not technical.  But these aspects are not new in European laws. I.e. most of them were identical in German laws that are replaced by GDPR now.

On the other hand there are other new regulations that have to be supported by technical solutions. This are specially 'right to be forgotten' (its more than deleting an account), report about stored data, export of stored data, etc.

In combination with very high penalities this is critical.

Ralf

I'm currently in the process of building up our prototype site and hope to have it ready in the next few hours.

The API currently supports Subject Access Requests, the right to be forgotten, and privacy by design and this will be implemented by a number of the core Moodle plugins.

The tool we are writing currently only supports Subject Access Requests, and the Right to be forgotten and is not yet complete. We will be building on the tool to finish off these two components, as well as adding the data registry, and to support privacy by design over the next few weeks.

Once the prototype site is up we will comment with the details.

Andrew

I guess that @adam is referring to the fact that currently 'delete' doesn't really delete all user data from the database - just from admin view - that's what I understand by the term 'soft delete'.

Do you mean you're treating full user data deletion as entirely unrelated to GDPR requirements?

Hello all,

I'm late to this discussion but can't see the information I need anywhere in the thread.

Does anybody know where the setting is to perform a hard delete of a user or obfuscate a user record via a Data Request? I'm using 3.5 with all the GDPR stuff, but when I test it, it just marks the record as deleted and obfuscates the email address - which isn't good enough. The user name field could have the email address in it and that is isn't obfuscated, neither are the first and second names of the user.

Also, there shouldn't be any option in my view, it should either hard delete, or obfuscate everything  - it's not GDPR-compliant to have user identifying information after a request to delete. This is making me question whether Moodle is actually GDPR-compliant.

Can anybody shed any light?

Ewan