Online (video) calling in education

Pupils or students can attend classes through (online) video calling if teaching in any other way is not possible. This may be a significant invasion of their privacy and of the privacy of their teachers. For example, if the educational institution films people at home. Schools and universities therefore have to ensure that the privacy invasion associated with online (video) calling is minimised.

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Carrying out a DPIA beforehand

Do you, as a school or university, want to start using online (video) calling? Be sure to carry out a data protection impact assessment (DPIA) first. A DPIA is an instrument for identifying the privacy risks of data processing beforehand And for subsequently taking measures to mitigate those risks.

Carrying out a DPIA is mandatory for data processing operations with a high privacy risk. You have to assess for yourself if your processing results in a high risk for your pupils or students and your teachers. This depends on the purpose for which and the way in which you want to implement online (video) calling. If possible, involve your pupils/students and teachers in your assessment.

For more information about the DPIA, see section 3.1 of the report Investigation into online (video) calling and online proctoring in education (in Dutch).

Tip 1: Work together with other school boards and/or umbrella organisations. Share knowledge and exchange experiences. Join forces when dealing with major players in the market.

Tip 2: Use the website lesopafstand.nl on distance education, compiled by the Ministry of Education, Culture and Science (OCW) and sector organisations, among others.

Policy or guidelines for online (video) calling

An important organisational measure to limit the privacy risks of online (video) calling is that you draw up a clear policy or clear guidelines. And that you give simple and clear instructions for your teachers and pupils or students in this policy or these guidelines.

The policy or the guidelines for online (video) calling should in any case contain agreements about:

  • recording images of pupils or students and teachers;
  • making and retaining recordings;
  • informing pupils or students about the purpose and the retention period of the recording, among other things;
  • if applicable: safe storage, the retention period and who is responsible for timely removal of the images.

For more information about frameworks and guidelines, see section 3.2 of the report Investigation into online (video) calling and online proctoring in education (in Dutch).

Informing pupils and students

Your pupils or students and/or their parents are entitled to information about the processing of their personal data or those of their child. This includes online (video) calling. Be sure to inform them actively prior to a digital class.

Which information?

You are obliged to provide information about, among other things:

  • which personal data you process;
  • for which specific purpose you do this;
  • what the legal basis for processing is;
  • whether you share the personal data with third parties.

In which form?

You have to pay attention not only to the contents of the information, but also to the form in which you provide it. The information must be understandable and easily accessible for pupils or students.

You may not, for example, expect your pupils or students to understand legal jargon or read long privacy statements. Especially not if they are under age.

Tip: Visualise the information by means of an infographic. Or have teachers provide an oral explanation before a class starts.

More information

For more information about your obligation to provide information, see section 3.3 of the Investigation into online (video) calling and online proctoring in education (in Dutch).

Sensitive information during online (video) calling

Instruct your pupils or students to keep personal belongings outside the range of the camera. For example, belongings that have to do with someone's religion or political preference.

Is too much sensitive, personal information being filmed during online video calling? Ask the pupil or student to turn off the camera. Or make sure that you can turn off the camera to protect the pupil or student.

Drawing up rules for recordings

You are not allowed to make recordings in which pupils or students are visible if you do not have a good reason to do this. This is only allowed in exceptional situations. In that case, you must be able to properly substantiate why this is necessary. And explain this clearly to your pupils or students beforehand.

Have you made a recording of the class or the lecture, for example to watch it at a later time? In principle, no pupils or students may be visible in it. Indicate, therefore, beforehand when the recording will start to ensure that your pupils or students know when they have to turn off their microphone and camera.

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Visual material in education

Sometimes you, as a school, want to make and publish visual material of pupils or employees. Under the General Data Protection Regulation (GDPR), consent is required for this purpose.
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