Virtual proctoring of English tests privacy notice

The English Language Teaching Unit (ELTU) is part of the University of Leicester. The University of Leicester is the Data Controller for your information and is subject to the Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR).

This privacy notice explains how we use your personal information and your rights regarding that information and supplements our Student Privacy Notice.

What information are we collecting?

The personal data we will collect from you includes:

• First and last name
• Home address
• Personal email address
• Passport number
• IP address, website and browsing history and use of cookies during the test
• University student number and university email address, where you have one

The special category data we will collect from you includes:

• Facial recognition/biometric/identification data.

Why are we collecting your data?

The personal data and special category data we are collecting is required to deliver virtual proctoring of your online English tests. You have already supplied some of the data to us when you enrolled on your University of Leicester course. A third party supplier, who owns the proctoring application, will also request data from you. The University has engaged this supplier to deliver the virtual proctoring services for the online tests provided by us as part of your course or admission.

Only information required for these purposes is obtained and processed, and without it the University may not be able to provide the online test services to you.

How will we use this information?

The personal data we collect will be used to enable you to set up an account on our supplier’s website and download the proctoring software application. This will allow you to access and sit the tests. Special category data including biometric data and other personal data will be collected from you when you set up your account and will be used in the verification of your identify and also to invigilate/monitor your behaviour whilst you are sitting the tests so that any violations can be reported the University. Verification of your identity will be undertaken every time you use the proctoring application to take a test, and during the virtual proctoring of each test.

Information about the device/s you are using when you access the online tests, your IP address and other information about your use of the device will be used by the virtual proctoring service.

Your information will be used by the ELTU staff involved in the monitoring of the tests, and other staff on a ‘need to know’ basis only. 

The data we are collecting is considered necessary and proportionate for providing the virtual invigilation of online English tests.

Anonymised data will be used by the University to evaluate the proctoring application and by our supplier to enable them to review your use of their application and to evaluate their services provided to us.

What is the legal basis for processing the data?

Our legal basis for processing your data is contract.

We have a contract with you because you are a student on one of our pre-sessional English courses or you a student taking our admissions English test.

In respect of the special category data we will be collecting from you our additional condition is explicit consent.

If we are sharing your data with others who are we sharing it with?

The University is engaging a third party supplier to provide the virtual proctoring service for its English tests and they are our data processors. They will collect the data from you on our behalf via their website.

If you are located outside the EEA, some of this data will be collected /processed outside the EEA before being transferred to a cloud data centre within the EEA.

There are risks associated with collecting/ transferring data outside the EEA in countries where local laws does not permit us, or our supplier, to impose the level of technical security arrangements we would normally provide to protect your personal and special category data.

How long we will process your data for?

The data we hold relating to the virtual proctoring of each test session you take will be held for 180 days after the test and will then be deleted. Your account data, including personal details and special category identification and biometric data, will be held for 365 days and will then be deleted.

What are your rights and how to enforce them?

In respect of our legal basis of Contract you have the following additional rights:

• The right to be informed - which is met by providing you with this notice
• The right of access – you can request access to the data we hold about you
• The right of rectification – you can ask us to correct inaccurate data
• The right to restrict processing - you can ask us not to process any data that is inaccurate.
• The right to data portability – which only relates to automated processing.

If you wish to exercise any of these rights please contact the University’s Information Assurance Service by email at ias@leicester.ac.uk.

How to complain to the Information Commissioner’s Office

The Information Commissioner can be contacted by:

• Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK95AF.
• 0303 123 1113.
• ICO website