Data Management and Minimisation- Data Capture

Contents of this article:

• Data Capture
• What should I do if I have a pupil who may not be recorded?
• Editing
• Camera Positioning
• Anonymisation Feature
  • Anonymisation vs Pseudonymisation

Data Capture

Alongside the implementation of a data retention management process, the following features and approaches will assist data controllers to manage the data they collect to help ensure they are compliant with their data processing, in particular, enabling recordings when there may be individuals present who are not able to be recorded for one reason or another.

Additionally, data capture is recommended to be made using the IRIS Connect Record app or screen capture which automatically uploads to the user's account and deleted any local copies, thus creating a closed, automated, and secure capture and storage system. 

What should I do if I have a pupil who may not be recorded?

There are several options you can consider:

1) Position the camera to ensure the pupil is not recorded 

2) Use the editing tool to edit any section of the video if they are captured

3) Use the anonymisation feature

4) Do not record that class

Also, be mindful that audio data can also be considered personal data so consider if their voice has been recorded or if their name/full name has been said within the recording.

We always recommend you check with your organisation’s Data Protection Officer if unsure before making any recordings.

The following article looks at these approaches in more detail:

Camera Positioning

For information on camera positioning please see this article.

Editing

For information on editing please see this article.

Anonymisation Feature

The collection of personal data can also be limited through the use of the anonymisation feature. This can be applied to the video either:

1) Pre-recording via the Record app - useful if you do not want to record a non anonymised version

2) Post-recording via the web platforms tools - useful if you wish to record a non anonymised version but maybe need to use the filter for sharing/ safeguarding compliance).

Additionally, there is a couple of organisation anonymisation settings available:

1. Forced anonymisation - only the anonymised version of the video is ever captured
2. Optional anonymisation - the video can be selected to be anonymised after recording

How to enable the anonymisation feature.

Anonymisation vs Pseudonymisation

As our system does not track student identity (other than in the video itself), if the pre-recording method is employed then the data is anonymised, if the post-recording method is employed then there is a case to say that this is pseudonymised data as the organisation could technically reverse this process and identify the students, even if the person with whom they have shared the video cannot. However in either case, the data is only anonymised when there is nothing in the audio to triangulate the data subjects' identities.
 

Additionally, it is important that schools use these tools appropriately within a solid data protection process:

• If they are capturing images of students then they should document a lawful basis for doing so and complete a DPIA.
• If they are going to share images, then they should consider if they have the appropriate data-sharing agreements in place.
• If they are going to use anonymisation tools when sharing video, they should consider if anything in the video or audio track allows for the triangulation of student identity

This tool is a useful addition to the process that allows for an enhanced level of security for data subjects when sharing video. However, as always, common sense should be used when sharing data to ensure that it is appropriate.

Please see here for a guide on using the anonymisation feature.