1. An evaluation of policy
frameworks for addressing
ethical considerations in
learning analytics
Paul Prinsloo and Sharon Slade

2. Introduction
• Higher education institutions make extensive
use of student data
• Most HEIs have data related policies in place
• Policy frameworks should cover
– who benefits (and under what conditions)
– consent and de-identification
– issues of vulnerability and harm
– collection, analyses, access to and storage of data
• Review of 2 large ODL institutional policy

3. Who Benefits and Under What
Conditions?

4. Consent, De-identification and
Opting Out

5. Vulnerability and Harm

6. Collection, analyses, access and storage

7. Data policies – what do we cover?
• Reviewed all data related policies1 for 2 large
ODL institutions with reference to monitoring,
surveillance, privacy and security of data
• Neither explicitly addressed learning analytics
• Both had specific policies relating to the
ethical use of student data for research
• Both had clear data protection policies
1
14 policies from Unisa and 12 from OU

8. Who benefits?
Unisa
No specific reference
Open University
Data depersonalised…
Used for management, development and
research…
Shared with third parties
To pursue alumni donations…

9. Conditions for Consent, De-identification
of Data and Opting Out
Unisa
Reference to monitoring employees
Personal info collected for business
purposes
Not explicit except in case of research
Open University
Data protection disclosure = explicit consent
Data on LMS belongs to the OU

10. Vulnerability and Harm
Unisa
Focus on data protection rather than
misuse
Emphasis only on student responsibility to
ensure their data is correct
Open University
Recognises potential use of data to personalise
support
Makes clear student responsibility to ensure
data is correct

11. Collection, Analyses, Access and Storage
Unisa
Collection, access and storage
covered extensively
No explicit reference to analysis
Open University
Collection, access and storage covered
extensively, including advice re external sites
No explicit reference to analysis

12. Conclusion
• Current emphasis on data governance, data
security and privacy issues
• Institution as decision maker, student as
recipient of services
• Data is data is data
• Policy frameworks in need of update

13. THANK YOU
Dr Paul Prinsloo Dr Sharon Slade
University of South Africa Open University
prinsp@unisa.ac.za sharon.slade@open.ac.uk