There is an increasingly wide array of external third-party tools available online or through application downloads, which staff may find useful to support their personal productivity or to engage their students. Whilst use of these tools can prove convenient, sometimes with features that provide a richer experience than centrally available, staff must ensure that any data or information stored on non-LSE provided services – in relation to their roles – complies with regulations on data protection, conditions of use of IT facilities at LSE, digital accessibility regulations and compliance with the software vendor’s license terms and conditions.
It is also important to note that we need to manage the number and variety of tools that we use across the School. If we have lots of different tools to do the same, or very similar tasks, it becomes expensive to provide, support and maintain. It also adds significant risk.
For most cases, the use of LSE supported services is strongly recommended, where the Eden Centre and DTS can provide full support for usage and reassurance regarding regulatory issues, licensing, support and technical quality of the tool. However, it is recognised that on occasion the use of externally available third-party tools can deliver an enhanced student experience. Under these circumstances, their use should be limited exclusively to time-bound and cohort-specific activities (e.g. group task within a seminar).
Please contact the LSE Eden Digital team for advice on use of third-party tools for teaching, or for advice about general purpose software contact DTS Tech Support. If a tool costs money or holds personal data you must seek advice before you purchase or use it.
As the ‘end user’ you will also be responsible for performing important checks. The guidance below will enable you to carry out these checks and take the appropriate actions.
Creating an account on an unsupported service must always be optional for the students i.e. you may not make it a requirement for enrolling on any course.
Individual and group accounts
Where required to complete an activity organised by a member of staff, and students can independently choose their own services and tools, students should be given the choice of whether to create an account individually or – if appropriate – work with a partner or group account. Again, within group activities, members should be reminded of appropriate behaviour online. Deletion of student entered data in-between sessions is the responsibility of the individual staff member. Staff members should consider the promotion of LSE supported alternatives for students to select from, where selecting from a variety of options is possible.
Personal account considerations
If students do decide to create a personal account within a third-party service, staff members should brief their students that
- they are signing up for an external service;
- They are entering an agreement with an external provider (not with LSE);
- it is their personal account for which they are solely responsible;
- any information uploaded may be accessible on the public web;
- There are risks associated with entering personal data or infringing copyright law.
The selection of third-party services which provide good user control over personal information, including easy deletion and export features, is always strongly recommended.
Anonymity can be a positive motivator for encouraging student contributions within a classroom setting; as well as ensuring data protection for the students. However, caution should be applied where anonymity and free text entry (or image upload) is used in combination due to the potential for abuse. In these circumstances, consideration should be given to:
- Use of allocated student accounts, following guidelines outlined in this paper
- Use of filtering, perhaps through moderation via a separate device or monitor, before publication on any public displays
- Use of closed questions or discrete options (recommended), where student interaction is confined to defined parameters
- In all circumstances, students should be advised of expectations of professional conduct and mutual respect towards all participating in any activity. Please seek advice from firstname.lastname@example.org if you have any questions.
UK data protection legislation requires that all personal data must be held securely; this includes any personally identifiable data such as names, email or IP addresses.
Use of unsupported third-party services where students are required to create a personal account should be avoided. If this is unavoidable then it is likely that a Data Protection Impact Assessment will need to be carried out. It is also likely that the service provider will be required to complete a cloud assurance questionnaire before the service can be used
Anonymous use and generic accounts
Student use of third-party tools should be anonymous wherever feasible, however, students must be reminded of appropriate conduct online and staff should avoid free text entry/free image upload without appropriate safeguards (see below). An alternative approach is the use of temporary student allocated generic accounts (for example, a list of students and their allocated account, such as student01, student02, etc.) where no personal data is uploaded to the third-party system but accounts are clearly identifiable within the cohort. In these circumstances, advice should be given to students to avoid entering details which may identify them personally, or remedial action should be taken by the staff member to delete as soon as possible.
When creating an account on a third-party system, staff and students must not use their LSE email address and LSE password in combination.
Use of the LSE email address may be convenient for collating email notifications (where this is possible), but a different and strong password should be selected for each third-party service used. Use of an LSE email address instead of using existing personal accounts will help to keep School-related activity separate from staff and student’s personal social online identity. This may be preferable and encouraged where appropriate. However, the account created remains the personal responsibility of the individual and access may become restricted once an LSE email becomes unavailable (once the staff member or student leaves LSE), as such any staff member or students should be made aware and be encouraged to delete or transfer credentials as required before leaving.
Students should also be advised that use of an LSE email address does not mean this is an LSE supported system. Staff members must also advise their students accordingly. Avoid the use of third-party services that publicly display personally identifiable data such as email addresses.
Access and intellectual property rights
Staff members should always familiarise themselves with the terms and conditions of any third-party service used. Some services may request that you grant a licence to reuse any content posted onto the service. This is often designed to protect the service provider, but careful consideration should be given to how comfortable you are with having the content of the activity shared outside of the cohort group? Wherever possible, password controls or unlisted web links should be selected within the system’s settings before sharing with students.
If any external services require students to create an account or use personal devices, the data generated (student responses etc.) as part of the activity should only be retained for as long as is necessary to reasonably complete the required activity; this should not exceed one academic year. Students should be advised on how to delete their accounts on completion of the activity.
Deletion and retention
Once an activity is complete, it is the staff member’s responsibility to delete (and export) all data related to the activity. As such, check that the data can be easily deleted and/or exported prior to the activity. Students are of course welcome to retain their personal accounts should they wish to; however, staff must advise students on how to delete their personal accounts as part of the exit process. Any staff members wishing to keep a record of the activity should export to a portable format (such as text, images, HTML or a PDF version) and upload onto Moodle for retention.
A key advantage of using a service fully supported by LSE is that data can not only be retained for longer, but has the potential to be exchanged with other supported LSE systems.
Use of third-party tools can often be initially license fee free, however, any use must conform to the license terms and conditions including payment of any other fees as appropriate. This is the responsibility of the staff member using third-party tools to check, but advice and support is available through either the Eden.Digital Team, DTS or Procurement as appropriate. It is important to look at the total long term cost of ownership, including support, maintenance and exchanging data with other LSE applications. In addition, the data provided by individuals within third-party systems can be valuable to some external organisations. Staff members should seek advice from DTS and Eden Digital to confirm that any third-party tool complies with current UK legal requirements for data protection. An initial assessment can be made by checking its Privacy Notice. If the tool is hosted outside of the UK or EU then the software company needs to have committed to protecting personal data in a similar way to that covered by UK/EU law. Unfortunately, the US-EU Privacy Shield scheme which previously certified such claims was invalidated in 2020 and has been replaced by more complex contractual clauses. A useful rule of thumb is that if the product is free to use, the supplier will expect to be able to advertise to users or sell their data on. All providers should be asked to complete the LSE cloud assurance questionnaire, but providers of free services may not always be willing. Please seek advice from Eden Digital or DTS Tech Support.
There is also no guarantee that there aren’t hidden costs (for additional tools or features) which can be promoted to students to encourage further payment. Staff members should ensure that students are not subjected to any hidden costs and only freely available features are utilised. LSE has an obligation to disclose any additional costs incurred by students, therefore, students must be warned how to avoid (where appropriate) any hidden or unnecessary additional charges. If there is any uncertainty, staff members should not use any third-party tool where free access to students cannot be guaranteed. Use of third-party tools should be reviewed yearly to avoid any changes in fee structures being applied to students or unforeseen closure to the service.
Whichever tool or service is used, it is important to ensure that new barriers to participation are not being introduced by its selection and consideration is given to access or formats for students with particular access requirements. This may include ensuring the tools selected support international accessibility standards (WCAG or Section 508). Any service that we expect students to use should comply with UK government digital accessibility regulations.
Unsupported third-party tools should not be used for delivering summative assessments.
However, use for formative assessment can offer a richer assessment menu. Under these circumstances, any utilised third-party tools should comply with the above advice on retention. In addition, students may wish to personally use third-party tools to support summative project activities or to create an online portfolio. Under these circumstances, students should be reminded that this is not an LSE managed environment and any final outputs must be uploaded to an appropriate LSE supported system, usually Moodle, for formal assessment and retention.
Original guide by Andy Beggan (University of Lincoln).
This original guide has been adapted and localised by Kris Roger (LSE) within the terms of a Creative Commons CC BY-NC-SA 4.0 licence granted to LSE by the University of Lincoln. This adapted guide is therefore shared with the same Creative Commons CC BY-NC-SA 4.0 licence