The student's use is personal/household I would say, so DP law doesn't apply to their recording. You're not a controller and no consent is required in DP terms for the person recording. I guess you could cover off any risk you feel by writing 'appropriate' behaviour/use of any personal recordings in your student's code of conduct or similar. You may also be able to cover college/lecturer copyright in the same way. Whilst you're not controller so you don't need to give student's a privacy notice, you could always put a note on the website or in enrolment docs that you support inclusion diversity and students may choose to make recordings for personal use etc
I'm not in education though so others in that field may have processes they already use.
Victoria Blyth
Privacy & Data Protection Lead (Deputy DPO) - Records & Information Management
Pronouns (She, her, hers)
Read our R&IMT guidance here: Records and Information Management (sharepoint.com)
London Borough of Barnet, 2 Bristol Avenue, Colindale, NW9 4EW
Tel: 020 8359 2015 | Web: www.barnet.gov.uk
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Stephen Geraghty
Sent: 12 May 2022 09:42
To: [log in to unmask]
Subject: [data-protection] Recording lectures
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Good morning,
We have some students who wish to use a digital voice recorder to make their own recordings of lectures because of a recognised learning difference. At present there is no specific guidance for students on appropriate permissions, use, storage or deletion of such recordings. This is something that we would like to develop. It is an individual process rather than centralised or lecturer managed.
I am reasoning through the permissions/legal basis arguments. Assuming it will be impractical to omit all class voice contributions to the lecture in this scenario, is class-wide consent to the recording the only route forward to allow the student to do this?
I also see the additional risk of this being decentralised and therefore relying on the student to manage the recordings in the spirit of good data protection practice. Given that they are making these recordings themselves on personal devices - how does this alter the Controller/Processor definitions in how they apply in this scenario?
Any advice/similar experience gratefully received.
Stephen Geraghty
Information Compliance & Policies Officer City College Norwich
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