TEACHING & LEARNING COMMONS KNOWLEDGE BASE

Privacy Recommendations Regarding the Use of Big Blue Button and Zoom for Video Exam Invigilation

The guidance and Privacy Notice below assume KPU institutional licenses for Big Blue Button and Zoom are used by students during the course of taking any exam. Alternative sources of these products may not have settings adjusted to meet these best privacy standards.

Compliance Requirements:

• When the University requires, recommends, or encourages showing photo identification during exam invigilation, and online proctoring, the processing of the personal information involved is governed by the B.C. Freedom of Information and Protection of Privacy Act (“FIPPA”).
• KPU’s instances of Big Blue Button and Zoom both manage personal information inside of Canada. However, the collection of all types of personal information must be necessary to still be compliant with section 26 of FIPPA.
• Instructors need to verify the date and time that the students’ identity is confirmed by logging it at the time of the exam. The simplest method is to use an excel spreadsheet but any other FIPPA compliant option to record the date and time of verification could be used alternatively.
• Instructors do not need to collect an image or a recording of the students’ photo identification. Since this is not necessary to complete identity verification, do not collect an actual copy of the photo identification.
• Instructors must limit the amount of personal information that can be collected intentionally or unintentionally through these platforms.
• Instructors need to use class time to explain the purpose and privacy risks associated with online invigilation. This includes explaining the potential for unnecessary and unintentional disclosure of the student’s own personal information as revealed through the camera and microphone. Additionally, instructors need to review the risk of unnecessary and unintentional disclosure of third-party personal information when members of a household share space with the student. Students need to be directed on how to set up exam spaces at home to protect their privacy. Contact privacy@kpu.ca if you need further guidance on teaching students about protecting their privacy at home when participating in online academic activities.
• Instructors must be ready to respond to students that are not able to secure private spaces to complete exams without compromising the students’ ability to complete courses required to graduate from their academic program.
• When instructors use additional human resources to support online invigilation, those individuals need to be briefed on the appropriate practices necessary to avoid the unnecessary collection of personal information. Invigilators must avoid identifying third-party personal information when reporting concerns about a student’s academic honesty during an exam.
• Inform the students of the identity and position of any additional invigilators during the class time before the exam to allow students to ask questions or express concerns.
• Avoid using online invigilators that do not have a permanent employment position at KPU.
• Instructors must avoid recording the exam. Background noise will prompt these services to record what is seen from any student camera where sound reaches the students’ microphone leading to the unnecessary collection of personal information.

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Zoom and BBB platforms function differently. While BBB provides a setting that directly limits the students’ ability to see each other, Zoom’s capacity to limit students from seeing each other can only be achieved through providing a break-out room for each student. An invigilator can only be in one break-out room at a time, which limits the capacity to monitor students.

Recommended Actions

The following recommendations regarding confirming identity through the use of students’ photo IDs during online synchronous exam invigilation will be divided between the use of Big Blue Button and the use of Zoom. General considerations will follow product-specific recommendations.

Big Blue Button

• Ensure the appropriate settings are turned on to limit the students from seeing through classmates’ webcams. Under the “Lock viewers” settings, ensure that “see other viewers webcams” is set to “Locked”. Use the following site for reference Unlocking Student Webcams in BigBlueButton : TEACHING & LEARNING COMMONS KNOWLEDGE BASE (freshdesk.com) and contact the T&L Commons if you need support before the exam.
• Always test the settings before the exam to ensure they are working as intended.
• Confirm on the day of the exam that students cannot see each other before starting with identity verification
• Ask students to verify their identity with photo identification by holding it beside their face on camera. Only ask individual students to do this one at a time per invigilator and only ask them to do this for the minimum period of time it takes the invigilator to write/type the time that verification is completed.
• Do not write/type other information found on the card such as address or identification number.
• Do not make a copy of the photo identification through image capture, recording or other mechanisms.
• Privacy protection measures may impact the timeliness of starting the exam. Do not demand or influence a student to relinquish their right to any privacy protection measures in the verification process for the purpose of ensuring the timeliness of starting the exam.

Zoom

• Ensure the appropriate settings are turned on allow break-out rooms in Zoom meetings. Use the following site for reference: https://support.zoom.us/hc/en-us/articles/206476093 and contact the T&L Commons if you need support before the exam.
• Ensure that there are enough breakout rooms set up to accommodate one student per breakout room. There is a limit of 50 break-out rooms. Class sizes over 50 students cannot use Zoom to conduct online invigilation. To pre-assign participants to breakout rooms, use the following site for reference: https://support.zoom.us/hc/en-us/articles/360032752671 and contact the T&L Commons if you need support before the exam.
• Always test the settings before the exam to ensure they are working as intended.
• Monitor the distribution of students into break out rooms to ensure that they are working as intended
• Once the students are confirmed to be in their individual breakout rooms, ask students to verify their identity with photo identification by holding it beside their face on camera. Only ask individual students to do this one at a time per invigilator and only ask them to do this for the minimum period of time it takes the invigilator to write/type the time that verification is completed. Transitioning from a breakout room, back to the main room and to the next breakout room takes time. Students cannot be expected to have photo identification presented to the camera when an invigilator is not actively verifying photo identification.
• Do not write/type other information found on the card such as address or identification number.
• Do not make a copy of the photo identification through image capture, recording or other mechanism.
• Privacy protection measures may impact the timeliness of starting the exam more in the Zoom environment. Do not demand or influence a student to relinquish their right to any privacy protection measures in the verification process for the purpose of ensuring the timeliness of starting the exam.
• Allow students to complete the entire exam and be invigilated in the breakout room.
• Since invigilators must be in each breakout room to invigilate each student, the challenge of maintaining academic integrity is proportional to the size of the class.

General Considerations about Online Invigilation

• Online Invigilation is not an effective measure to ensure academic integrity during exams. The degree of invasion of personal privacy during online invigilation cannot exceed a standard that a reasonable person would find acceptable.
• Since web cameras do not capture a 360-degree view of the student’s assessment environment, the student may be able to effectively place notes or other references outside of the view of the camera.
• Students do not always have the privilege of having a private space to complete exams. Even when students are able to place their desks to limit the disclosure of personal information, sounds from the room or third parties walking through the camera space may cause unnecessary invasion of third-party privacy.
• In principle, each additional surveillance action required to complete online invigilation is an additional invasion of student’s personal privacy as well as potentially an invasion of third-party personal privacy.

Contact privacy@kpu.ca for support and recommendations navigating surveillance practices in online invigilation beyond requiring a stationary web camera