NOTE: Related Articles
This article is part of three topics on data management and minimising which cover:
- Data Minimisation
- Anonymisation Feature
- Anonymisation vs Pseudonymisation
- Camera Positioning
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.
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:
- Forced anonymisation - only the anonymised version of the video is ever captured
- Optional anonymisation - the video can be selected to be anonymised after recording
Anonymisation vs Pseudonymisation
As our system does not track student identity (other than in the video itself), if the first method is employed then the data is anonymised, if the latter 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.
For information on editing please see this article
For information on camera positioning please see this article