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I am interested in the academic implications of this issue. Ian Buckland wrote: Personal data (i.e relating to living individuals) processed by the student in the course of their studies is controlled by the University. It sets the rules for processing, it tells the student what sort of data is required, it even approves any research project proposed by the student, so the University is the data controller. After David Marsh posted the original query I looked at the ODPC guidance and drew the opposite conclusion. Students may collect, compile and disclose data in the course of their studies without any employee of the University ever having sight or meaningful control of it, regardless of whether any of the processing is done on University facilities or not. For example, a student may receive supervision in the course of a project which uses a questionnaire, but it is frequently the source of complaint that this is insufficient for academic purposes. The data may only come into the hands of the University employees at present in an anonymised form. If over-stretched academics or technical support staff are going to be lumbered with DPA responsibility for the data collected, they're going to have to do a lot more than tell students what the rules are, aren't they? If Universities are controllers of such data, aren't the student also controllers? Does this make any difference? Sorry if I'm just muddying the water Paul Hubert Welfare Officer Leeds Metropolitan University Students Union Student Advice Service Beckett Park Campus Church Wood Avenue Leeds LS6 3QE. ============================ Tel 0113 209 8446 E-mail: [log in to unmask] %%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%%