In a chat at the DataMatters conference I was asked about the ethics of universities and colleges using social media providers to contact students. In breaking down that question, I think it illustrates a continuum: the more we interfere with individuals’ own choices of what and how to use, the more thinking we need to do beforehand to ensure they are protected from the consequences of our actions. So, for example:
- Putting adverts on the social media platforms where we expect to find future students has little effect on their autonomy. Though we do still need to look carefully at the data flows and processes that may result from them reading or responding to our adverts;
- Staff contacting students on social media, or even asking them for their contact details, need to be aware that students may consider those platforms to be personal social spaces, where intrusions from teachers (or parents) are not welcome;
- If we expect, or require, students or staff to sign up to particular social media platforms (or anything else) as part of their learning, teaching, assessment or research, then we bear the greatest responsibility for ensuring our choice of platforms, applications, etc. is appropriate and safe. And, where possible, provide alternatives: some may have deliberately chosen not to use a particular platform for very good reasons.
This feels like an extension/generalisation of the Data Protection rule that as you process more, or more sensitive, data, the level of prior thought (there called “accountability”) must get deeper. Indeed many of the data protection tools – in particular Data Protection Impact Assessments – may well apply to choice of social media platforms as well. So it’s well worth involving your Data Protection team, who can help you use those tools and may be able to suggest alternative approaches and settings.
And, particularly at the upper end of the continuum, we need to review our choices and requirements periodically in the light of changing circumstances. Changes in platforms’ policies and practices may make them less or more appropriate for our, and our students’, purposes.
