"We deliberately choose to make as little data as possible transparent, only the ones that are really necessary to guide the student properly."
Use case: Using study data - better good than haste
Study data is hot. Everyone is talking about it, and the possibilities and opportunities are endless. So why are they not yet widely used in Dutch education? The HvA wants to make the most of the opportunities, and is proceeding with caution. Martijn de Hamer, data protection officer, explains how they deal with the phenomenon of study data.
Study data help students and teachers
On the subject of study data, Martijn de Hamer is on his guard from his position. As data protection officer, he oversees the Hogeschool van Amsterdam's (HvA) privacy and data protection policy. And study data involves processing quite a lot of data. "That's why a thorough approach is badly needed," Martijn explains. "As an institution, we see very clearly the potential of study data. But precisely because there are so many risks involved, we are deliberately going slow".
The purpose of using study data is clear for the HvA: to improve education, to guide students better through their studies, in such a way that they are optimally prepared for society. In doing so, study data can have a signalling function, for example. Suppose a student is never present and does not complete the assignments in the digital learning environment (DLO), then this is detected and you can enter into a discussion with that student. In addition, lecturers can use study data to improve their teaching. For instance, they can use the data to investigate whether a certain approach works or not. In this way, they can work more and more efficiently.
First a strategy
"So study data is going to help us, and anyway we have to keep innovating," Martijn says. "But because of the risks, we chose to take it slow and move steadily forward." Martijn came to the HvA in 2018. Back then, initiatives were already underway and plans were in place, but in consultation with the Chief Information Security Officer (CISO), Martijn made the recommendation to start writing a strategy first. This had to spell out exactly what the HvA did and did not want to do with study data. For that strategy, quite some time was spent and many people were interviewed.
Students must be able to make mistakes
"We wanted to proceed carefully and create support," Martijn explains, "Because it is a lot to process with study data: in the DLO, you could see everything students, but also teachers, do online. It is therefore very important to look closely at aspects such as privacy, protection of personal data, but also self-determination: these are fundamental rights. If you want to excel as a student, you need to be free and able to make mistakes without being caught off guard. Otherwise, the so-called chilling effect occurs: you start correcting your own behaviour when you know you are being watched. Think of the student who prefers to study between 12 and 3 at night; he might stop doing so if he knows that a lecturer can see that and might think something about it. So: as an organisation, we want to educate students efficiently and well, but it has to be done in a safe environment. We therefore consciously choose to make as little data as possible transparent, only the ones that are really necessary to properly guide the student. Incidentally, this is also in line with what the AVG requires."
Algorithms are opaque
There are more challenges when it comes to student data. Martijn: "One such challenge is posed by algorithms. More and more information will become available from so many systems, about so many students and over an increasingly long period of time, that eventually you won't be able to process it manually. So I expect that algorithms will make their appearance in student data. The problem with that is that the explainability of decisions will disappear. Algorithms are often opaque, so you cannot explain to a student how the organisation would arrive at a certain advice based on the system, for example. We need to think about that right now."
First step towards practice taken by corona
The strategy is now ready and approved. It includes guidelines such as: keep an eye on the original goals and do not process more data than you need for that purpose, do not use analyses from this data for assessments and avoid excessive control of the student or teacher.
"The HvA has turned on the class progress module in Brightspace. This module shows the student's progress in processing the class material."
The HvA then started to design an infrastructure for study data. To this end, they are working with short experiments in which they explore what you can do with study data analysis. One such experiment has already moved beyond the experiment stage. "Influenced by the corona pandemic, the HvA turned on the class progress module in Brightspace," Martijn explains. "The module shows how far the student is in processing the class material, but only as a percentage. The teacher does not see what the student has done or not done exactly. This was an interesting, concrete case to really use study data in practice. By turning on that module, we started processing more of the students' personal data, and for that you have to have a good reason for the AVG. By corona, we had that reason, namely that we need to be able to properly supervise students despite homeschooling. By the way, we set up the module very conservatively: teachers can only see the percentage of learning that the student has processed."
Guide makes AVG concretely applicable for study data
When setting up the infrastructure for study data, the HvA makes a lot of use of the guide on study data and the AVG written by SURF. Martijn: "We like the step-by-step plan because it clearly states the steps you need to take to process personal data correctly according to the AVG. It's also nice that the step-by-step plan focuses on study data. It covers the relevant AVG articles and is written in clear language: our colleagues read in the guide exactly what they need to do in their own context to apply the AVG properly."
Suddenly it's there
So there is no doubt that the HvA will really deploy study data. "But better good than hasty," says Martijn. "I see it this way: developments in the field of study data are slow, nothing much seems to happen for a long time, but there comes a moment when it's suddenly there. And at that moment we as HvA must also be ready for it, so that we can use the study data ánd ensure that everyone continues to feel the freedom to study and work in their own way."