Information on Proctorio and Privacy

The assessment of Proctorio found the implementation of the system was consistent with the University's privacy policy and the Commonwealth Privacy Act 1988.

Additional information is provided below to demonstrate how Proctorio meets the Australian privacy principles (APP) that apply to the University.

APP 1. Open and transparent management of personal information

Under this principle entities must manage personal information in an open and transparent way. This includes having a clearly expressed and up to date privacy policy.

The Australian National University has a current Privacy policy that can be found at https://policies.anu.edu.au/ppl/document/ANUP_010007. Procedure and guidelines can also be located in the University's policy website.

The University's Privacy Impact Assessment on Proctorio has been published here.

APP 2. Anonymity and pseudonymity

This principle requires entities to give individuals the option of not identifying themselves, or of using a pseudonym. Limited exceptions apply.

For the purposes of academic assessment the University requires knowledge of a student's identity. The principle covering such use is in subclause 2.2 "Subclause 2.1 does not apply if, in relation to that matter:...it is impracticable for the APP entity to deal with individuals who have not identified themselves or who have used a pseudonym."

Note that in logging into Proctorio a system generated number is supplied to the system. It does not collect personal information from any ANU system.

In order to record the results of the online examination to enable academic progress of students, the identification of the student through the recording systems within Proctorio is required. Therefore the system collects the information on the student undertaking the examination in the manner required by the course convenor. The exception on thus applies.

APP 3. Collection of solicited personal information

This principle outlines when an entity can collect personal information that is solicited. It applies higher standards to the collection of sensitive information.

The relevant subclauses from this APP are:

3.1 If an APP entity is an agency, the entity must not collect personal information (other than sensitive information) unless the information is reasonably necessary for, or directly related to, one or more of the entity's functions or activities.

3.2 If an APP entity is an organisation, the entity must not collect personal information (other than sensitive information) unless the information is reasonably necessary for one or more of the entity's functions or activities.

The University collects information relating to students that is required in order to ensure academic progress. The information that is collected with a student's consent through the annual ISIS student enrolment form.

The University does not collect information beyond what is reasonably necessary.

As noted the University does not supply personal information to Proctorio. Proctorio collects the information that is reasonably necessary to ensure a record of the student who is completing the examination.

APP 4. Dealing with unsolicited personal information

Outlines how APP entities must deal with unsolicited personal information.

Proctorio does not collect unsolicited personal information.

APP 5. Notification of the collection of personal information

Outlines when and in what circumstances an APP entity that collects personal information must tell an individual about certain matters.

The collection of information by the Proctorio system is notified to students by the following:

• Information provided to all students through communication channels about Proctorio including  FAQs and information published on the website
• The University's Privacy Impact Assessment
• The entry page displayed to students sitting examinations through Proctorio

Personal information is not supplied to Proctorio by the University. ANU has communicated this information to its community, including all students.

Proctorio collects video of the student during the examination that records an image of the student. The data collection is notified to the student by the system as well as by the University.

APP 6. Use or disclosure of personal information

Outlines the circumstances in which an APP entity may use or disclose personal information that it holds.

The University will not disclose personal information to Proctorio.

Information that is held by Proctorio will only be accessible to authorised officers of the University. Staff who are authorised to have access will have completed Privacy training including the PULSE module and will have been given with guidance about their responsibilities under the ANU Privacy Policy.

Any staff member with access will have their access removed if they leave the office that requires access to the system. Reviewing and updating access is the responsibility of the Director of Learning and Teaching.  Audit logs are a part of the system ensuring tracking of all accesses to the system. The ANU Code of Conduct and employment conditions are policy instruments that identify the requirement for staff to comply with ANU policies and legislation including the Privacy policy and Privacy Act 1988.

In addition, the contract with the vendor contains requirements that the University's privacy requirements are met.

APP 7. Direct marketing

An organisation may only use or disclose personal information for direct marketing purposes if certain conditions are met.

This Australian Privacy Principle does not apply as Proctorio is not being used for direct marketing.

APP 8. Cross-border disclosure of personal information

Outlines the steps an APP entity must take to protect personal information before it is disclosed overseas.

The University will not disclose personal information to Proctorio.

APP 9. Adoption, use or disclosure of government related identifiers

This Australian Privacy Principle does not apply to the University.

APP 10. Quality of personal information

An APP entity must take reasonable steps to ensure the personal information it collects is accurate, up to date and complete. An entity must also take reasonable steps to ensure the personal information it uses or discloses is accurate, up to date, complete and relevant, having regard to the purpose of the use or disclosure.

While noting that the University will not disclose personal information to Proctorio, ANU takes steps to ensure that the information on students is accurate, up to date and complete. Processes include the annual student form in ISIS and regular contact with students. The University's website contains information on how students can request an update of their personal information.

APP 11. Security of personal information

An APP entity must take reasonable steps to protect personal information it holds from misuse, interference and loss, and from unauthorised access, modification or disclosure. An entity has obligations to destroy or de-identify personal information in certain circumstances.

The personal information held by ANU is protected by security applied to the University's systems and networks. A significant program of work has been implemented over the past 12 months to harden the network and systems.

In respect to Proctorio, the University has conducted a detailed security assessment which is available on the University's COVID 19 website. The investigation and analysis identified that the information held by the system is collected, held and protected in a manner that is consistent with the appropriate level of security controls.

All information relating to the completion of the examination is held in the Proctorio system. Only authorised staff at the University are able to access information and only for the purpose of a student's assessment.

APP 12. Access to personal information

Outlines an APP entity's obligations when an individual requests access to personal information held about them by the entity. This includes a requirement to provide access unless a specific exception applies.

In respect to individual personal information held on the University's systems there are processes to enable the requesting of that personal information. Information is provided consistent with the Privacy Act 1988. Note that requests for information in the Electronic Records Management System are dealt with through the Freedom of Information request process, consistent with Australian Privacy Principle 12.2.

In respect of the Proctorio system a student may request access to the information collected through the Director of Learning and Teaching.

APP 13. Correction of personal information

Outlines an APP entity's obligations in relation to correcting the personal information it holds about individuals

Where personal information has been identified as needing correction an authorised officer of the University undertakes the correction. The Division of Student Administration and Academic Services is responsible for the administrative support of students through the student lifecycle from when an offer is accepted and to the completion of their studies and maintains student records. These are regularly updated through procedures that ensure data integrity.

As Proctorio does not hold personal information correction to the information in their system will not be relevant.