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Policy for Online Teaching and Learning

This document describes the processing of student personal data by European University Cyprus (EUC or the University) in the context for the purposes of online teaching and learning. All such processing is undertaken by the University in compliance with the requirements of the General Data Protection Regulation (GDPR) and the Cyprus Agency of Quality Assurance and Accreditation in Higher Education (CY.Q.A.A.). At EUC, our commitment to education extends beyond the physical boundaries of our campuses. We recognize the evolving landscape of higher education and the increasing demand for flexible learning options. With this understanding, we are fully committed to delivering a high-quality education through online platforms, ensuring that our students have access to excellence regardless of their geographical location. This document concerns:

  • Students who enroll in Distance Learning programs of study (Distance Learning Students). Distance Learning Students will participate in all their courses and may take all their examinations through the online platforms used by EUC for this purpose, as EUC will determine.

 

  • Students who enroll in programs of study normally require their physical presence at University premises (Conventional Students). Conventional Students may choose to attend online classes or may be required by the University to attend online classes and take online examinations, as the University will deem appropriate (for example, as part of EUC policy for integrating digital technologies in its conventional programs -such as the policy for Digital Enhanced Learning-, or due to a decision by the University to adopt a “blended learning” approach, combining conventional and online teaching and learning methods, or due to extraordinary circumstances, such as during a pandemic).

 

  • In addition, this document refers to other special circumstances in which the University, for reasons of better application of health protocols or due to circumstances beyond its control, may apply a dual way of offering its Conventional courses. In this case, the enrolled students in a course will be able to attend it: a) either live with physical presence, b) or remotely through simultaneous online retransmission of the course for those who cannot attend physically.

Personal data refers to information about any student that is collected, recorded or otherwise processed by EUC via any of the online platforms used by EUC for online learning and teaching purposes.  These platforms are:

  • Learning Management System Blackboard, including Blackboard Collaborate (“LMS”), which is used for lectures, seminars and other presentations by teaching staff, other sessions between teaching staff and students, including presentations by students (all of the above together referred to as “Sessions”), the submission of coursework by students and the conduct of oral and written online examinations.
  • Proctorio GmbH (“Proctorio”), which is used for the supervision of written online examinations.

Blackboard and Proctorio may process data within or outside the European Union. Adequate protection of the relevant data is ensured through the Data Processing Agreement and Standard Contractual Clauses signed between EUC and these corporations as required by the GDPR.

Processing purposes

The use of these online platforms involves the processing of student personal data for the following purposes:

  • Student log-in details, for the purpose of identifying students who participate in Sessions and examinations and recording their attendance, as well as to enable them to submit coursework or presentations.
  • Student coursework, presentations and responses to oral or written examinations, submitted or recorded via the relevant online platform, for the purpose of teaching staff having access to, assessing and grading the above.
  • Student voice and image, recorded during a Session, when students activate the camera of the device they use to join such Session, so that they can be seen and heard by their instructor and other students. Activation of the camera by the students during Sessions is not mandatory, except when the students themselves are making a presentation to the professor and/or other students for the purposes of their course. Students can otherwise participate in Sessions and submit inquiries or respond to questions via written text, without activating their camera, unless they choose to do so. The recording of the students’ voice and image during a presentation, or if they choose at any other time to activate their camera, will be part of the audiovisual recording of the relevant Session and will thus be available to the instructor (for use, where appropriate, for student assessment and/or course management purposes) and to all students of the class (for use for learning purposes during their studies, for a period of up to 6 months).
  • Student voice and image recorded during an oral online examination. The recording, via the students’ camera, which must be activated, will be available to the instructor of the course for student assessment and grading purposes, to examiner(s) appointed by the University for the purpose of ensuring fairness in assessing the students, and to the Cyprus Agency of Quality Assurance and Accreditation in Higher Education (Q.A.A.) for accreditation and quality assurance purposes pursuant to the competences of the CY.Q.A.A. under applicable law.
  • Student image, sound and other data recorded during a written online examination, for the purposes of supervision and checking compliance with the rules of conduct during the examination. Sound and images from the students’ camera, which must be activated, will be recorded via Proctorio.

In more detail, Proctorio has the following capabilities that can be enabled separately at the discretion of the examiner only within the exam page and only while taking the exam. Proctorio may record if the exam taker navigated away (left the exam page), record keystrokes, record when the exam taker copies, cuts, and pastes and changes the size of the browser, record when the ambient noise reaches a level above the white noise of the exam environment, record when the exam taker moves his/her head from the web camera, record if there are other people in the area and may record exam takers who didn’t interact with the keyboard and mouse for 20-30 seconds and whose face isn’t clearly visible in the video.

Proctorio assigns each student a grade point average as an indication of the likelihood of violating the examination rules. In any case, all the findings of Proctorio are at the discretion of the examiners and only they can assess the extent to which the rules of the examination were followed and will also be able to discuss the matter with the student concerned. The data will be accessible only to persons authorized by the EUC, as well as to officers of the CY.Q.A.A., in case this is requested for the purposes of quality control of the examinations.

  • Student grades and examination results, for the purpose of notifying these to the students.
  • Some courses of conventional programs might be offered with students’ physical attendance and simultaneous webcast. In these courses:
    1. A camera is fixed in the classroom to capture only the classroom’s board. The camera is operated by the instructor to start, pause or stop the capture. The captured image of the classroom’s board along with the captured audio are shared online in real time to the students through our learning management system Blackboard Learn Ultra.
    2. In some such courses, a recording of the session may take place which will may be available to all students of the class (for use for learning purposes during their studies, for a period of up to 6 months). In these cases students’ image who are physically present will be recorded if they appear in the front of the fixed field of view of the camera, which is the classroom’s board. Similarly, students’ voice who are physically present may be recorded if they speak during the session (the microphone is worn by the current instructor).
  • All of the above-mentioned data and recordings will be available to and may be processed by authorised personnel of the Department of Information Systems and Operations of the University, for the purposes of dealing with any technical issues and for system management and maintenance purposes and/or by other authorised personnel of the University for accreditation and quality assurance purposes or when necessary for the performance of their duties.
  • All data recorded for the purpose of ensuring fairness in assessing the students during the exams will be retained for a period of 2 months and then deleted.

Security and Privacy:

All processes related to the collection, processing, and retention of personal data are always carried out in accordance with the guidelines of the Cyprus Agency of Quality Assurance and Accreditation in Higher Education (CY.Q.A.A.), the General Data Protection Regulation 2016/679 (GDPR), the provisions of Law 125(I)/2018, as well as the specific guidelines of the Office of the Commissioner for Personal Data Protection of Cyprus.

Regarding examinations, the assessment and examination procedures are designed in full compliance with the prescribed legal requirements. Ensuring confidentiality and safeguarding the integrity of the examinations are a priority for our university. The security and privacy of our students are paramount in our commitment to delivering high-quality Online Teaching and Learning. We have implemented a comprehensive set of measures to safeguard our learning platforms and protect student data:

  • Our chosen Software employs robust security protocols to ensure a secure online environment. This includes encryption of data transmission, secure login processes, and regular security updates to guard against emerging threats.
  • All the parties involved in the data transfer are implementing appropriate technical and organizational security measures. These measures are designed to protect the personal data from unauthorized access, disclosure, alteration, and destruction.
  • All data transmitted within our Software, including student submissions, communication, and assessments, is encrypted using industry-standard encryption algorithms. This ensures that even in the unlikely event of unauthorized access, the data remains secure and unreadable.
  • We strictly adhere to the General Data Protection Regulation (GDPR) and other applicable data protection laws. This ensures that student data is handled with the utmost care and in compliance with legal requirements.

Legal basis for GDPR purposes

The processing of the personal data in the manner described above is necessary for:

  1. in the case of Distance Learning Students, the provision by the University of the educational services it has agreed to provide to them, i.e. their participation in the courses of Distance Learning programs of study they have enrolled in and taking online examinations for the relevant degree;
  2. in the case of Conventional Students, the provision by the University of the educational services it has agreed to provide to them when the University considers that it is appropriate for them to participate in online sessions and/or examinations, for example:
    • when due to extraordinary circumstances, such as during a pandemic or other events giving rise to health or safety issues, the University is unable to provide its services with the physical presence of students at University premises; or
    • in the event that the University decides to adopt a “blended learning” approach which combines conventional and online teaching and learning methods; or
    • as part of EUC policies for integrating digital technologies in its conventional programs, such as the policy for Digital Enhanced Learning;
  3. the legitimate interest of the University to comply with the guidelines and other requirements of the CY.Q.A.A. for accreditation and quality assurance purposes;
  4. the legitimate interest of the University to ensure proper record keeping and administration of its programs of study and services, proper management and maintenance of its systems and resolution of any technical issues;
  5. the legitimate interest of the University to provide to all students access to appropriate learning material concerning their courses and/or program of study, including audiovisual recordings of relevant Sessions.

Processing of the image and voice of students which is recorded when students choose to activate their camera during a Session (e.g. to ask or answer a question or make a comment orally, instead of by written text) is based on the consent of students, which is evidenced by the activation of their camera or microphone.

Other processing

Note that EUC may collect, record and process personal data concerning Distance Learning and Conventional Students by other means and/or for other purposes, e.g. through the student enrollment application form and/or to confirm the payment of tuition fees. Information on such processing by the University is available in the University’s Privacy Notice – GDPR at https://euc.ac.cy/en/privacy-notice-gdpr/

Student rights

Students may exercise any of the rights granted to them by the GDPR (e.g. to access and obtain copies of their data, to request rectification or erasure of their data or to object to specific processing or ask for its restriction) by contacting the University’s Data Protection Officer at [email protected]