5 tips on the use of cameras during schools and everyday learning.
The covid-19 pandemic situation and the domestic institution have arised new privacy problems compared to the normal everyday learning at school. A normal day at school in which we physically meet each other does not involve the personal data processing compared to e-learning.
Changes in learning mean that we must think to privacy of who participates in a completely new way.
Five tips
- Choose secure digital solutions that meet your personal data security requirements
- Underline and keep in mind that the obligation to use a camera is perceived as a greater burden than when it is allowed to turn it off
- Define the goals you want to achieve and assess whether there are less stressful and intrusive alternatives
- Pay attention to the relevant group of pupils/ students in the specific situation and listen to the opinions they present
- Offer alternatives if someone has special reasons that should be emphasized
The problems
The Data Inspectorate receives many requests from pupils, students, educational institutions and teachers regarding the use of cameras in digital teaching. Questions are asked about the legality of requiring the participants to have the camera on.
A lot of professors want the students to have the camera on and then show that they are participating in the teaching, and there are several instances where those who do not have the camera on are recorded with the absence.
At the same time, there are also many who describe that the cameras, switched on, are stressful, stressful and uncomfortable.
The disadvantages described are, for example, that it looks like surveillance, that you don’t have control over how your images are used and that it reveals the conditions of the house you don’t want to display. There are also reactions to the reasons for requesting the cameras to be turned on.
The Norwegian Data Protection Authority has also been contacted by teachers/professors who believe it is a disadvantage to always have the camera on when teaching.
What does the Data Inspectorate think?
It is difficult for the Data Inspectorate to decide whether the obligation to use a camera is legal or not. The privacy policy does not clearly address such specific issues. However, it is clear that digital communication imposes the need to make assessments of disadvantages compared to what you get, as well as having to think about whether the solutions are good enough in terms of security.
The Data Inspectorate sees that there may be legitimate reasons to turn on the camera, but at the same time believes that it is probably not necessary every day during the day.
The purpose or purpose must first be defined: what do you want to achieve by wearing cameras? Clearly stated and defined purposes are a prerequisite established by privacy law. The requirement for a screwed-in camera must also be clearly related to the educational purposes.
The next question to be answered is whether the use of the camera is suitable and necessary to achieve the purpose and whether it is possible to achieve the same with other less stressful methods. For example, you may consider whether there are different needs in different forms of teaching. Pure lessons can be conducted without a camera, while in discussions there may be more reasons for the camera to be turned on.
Make assessments that create balance
Checking if someone is present or as a tool to evaluate the response to a teacher’s teaching can be a legitimate reason to wear the camera. To assess whether someone is present, for example, it may be enough for the camera to be on at the beginning and end of an hour.
Be aware of when you require the camera to be turned on and why, in addition to involving and listening to the arguments of students / students, it will be possible to reduce the load and inconvenience.
It is also important to consider individual considerations where disadvantages are perceived as extra large for some. We’ve seen examples where students can contact the teacher and agree that the camera can be turned off, and we’ve also seen that some schools recommend students to use neutral backgrounds that are in the solutions they use.
There are good arguments both for and against the use of a camera. To ensure the legality, it is necessary to carry out assessments that strike a balance between the extent to which pupils have to bear by wearing something in front of the camera and what teachers and schools have to bear with a little less vision and control than if they were in a normal situation in class.