Processing of Feedback Data
1. Which personalisable data are stored?
The connection that makes personalisation possible when feedback is given is the respondent's ID value (a code automatically generated by the database). The respondent's ID value is uniform throughout the information system; it is associated with the personal data, study results, data of the student place, etc.
2. How is the feedback given to a course or a curriculum saved in SIS?
The learner’s answer to a concrete question is saved in the SIS data table in a pseudonymised form. This means that, on each line in the data table, there is the answer (variant of a multiple-choice answer or comment) with the respondent's ID value. Personal data cannot be associated with a concrete respondent without using additional information.
3. For what purpose are these data stored?
According to § 3 subsection 7 clause 6 of the Standard of Higher Education, the university must have a support structure for the academic staff and support systems for learners. One of the measures ensuring the quality of teaching is asking for learners’ feedback. In degree studies, the university has established a procedure for asking for feedback and taking it into consideration. Feedback results are necessary for the state for quality assessment of higher education, depending on which the teaching rights given to the higher educational establishment can be continued. For that, the university sends the feedback results to the Higher Education Quality Agency (Higher Education Act, § 37). The data received from feedback are processed according to article 6 subsection 1 clause e of the General Data Protection Regulation, as processing of data is necessary for fulfilling the obligation to provide teaching services.
Storing the respondent's ID value with the answer is necessary for the following reasons:
- feedback and the respondent’s ID value are connected so that the information system could check whether the learners have fulfilled their obligation according to the procedure of asking and giving feedback in degree studies (given feedback to the required number of courses). In exceptional cases, it can be necessary to identify the concrete respondent to find why s/he has had problems in using SIS (e.g. the respondent says that s/he has assessed all the required courses, but, for some reason, still has restrictions in SIS);
- in the last ten years, learners themselves have asked to delete the feedback given so that they could fill the questionnaire again, as for some reason, they have erred in assessment of the course or its lecturer (i.e., they have saved the answers and then discovered that they had assessed some other course or lecturer);
- the university conducts research on studies and teaching. Time series of data and the possibility of associating the data of different databases are necessary for the analysis of results and research;
- teaching staff members and learners have asked for differentiation of feedback results in SIS according to different variables (e.g. they have wished that the teaching recommendations of the course could be differentiated according to the learners’ curricula, groups and study results).
4. Where are the data stored and who can personalise the answers?
Answers to feedback questionnaires are stored in SIS servers which are located in the university’s own server rooms and are kept in work by the Information Technology Office. The respondent's ID value, the ID value of the assessed syllabus and the learner’s answer to the question are saved in the database table. The respondent's ID value corresponds to the other data in the table for identifying the person (name). Associating the feedback answer with a concrete person is possible only if there is a legal basis for it, and technically this can be done by persons who have the right of access as part of their work duties. Association of data in data tables is done only if there is substantiated need for it. Someone’s personal wish to get information is not substantiated need.
5. Who has the right to demand personalisation of feedback?
Data for identifying the learner who has given feedback can be required by the court if the comment in feedback has violated someone’s right to their good name. Damaging a person’s good name is, for example, giving an inappropriate value assessment. In addition, data for identifying the person can be required from the university by the police or prosecutor’s office if the comment hints, for example, at a crime, and the data are necessary for establishing the truth in a criminal case (Information Society Services Act, § 11, subsection 5; Code of Criminal Procedure, § 215, subsection 1).
To prevent the need for personalisation of data, the university asks the learners to read the good practice of giving feedback before answering. The Office of Academic Affairs can delete the answers ignoring the good practice. Work is also done on developments in SIS for finding inappropriate comments and preventing publicising them.
6. In how many cases has feedback been personalised and for what reasons?
The university has identified the persons who have given feedback for the following reasons:
- learners themselves have informed the Office of Academic Affairs that, while answering to the questionnaire, they have erred at selecting the course or lecturer from the list and have asked to delete their assessments so that they could give feedback to the course anew. As mentioned above, there have been ten such cases within ten years.
- In one case, the name of the person who has given feedback has been asked from the university by Tartu County Court during court proceedings.
- There has been an exceptional case when the feedback by a learner whose study result was cancelled was deleted.
If teaching staff members have asked the Office of Academic Affairs to delete offensive comments about them from SIS, the comments have not been associated with persons for finding them in the data table and deleting them. The problematic comment is found in the data table of answers (for that, the ID value of the assessed syllabus, the number of the question and some words in the comment are needed), and it is deleted.
7. How long are the answers to feedback questionnaires and the data needed for their personalisation stored?
The university has is no fixed term for deleting publicised feedback, but questions of data archiving are being discussed at the university. At a meeting in autumn 2019, universities and the Information Technology Foundation for Education made a proposal to the Ministry of Education and Research to create a united archive (repository) of education data in Estonia as education data cannot be deleted after 25 years. Still, the data cannot be stored in the same information system for decades, as all the data need not be stored in a personalisable form, and storing of data becomes burdensome for the information system (SIS of the University of Tartu has been operating for 19 years). The questions of data archiving do not concern feedback data and SIS only but also other information systems.
As for displaying of feedback, the Office of Academic Affairs would like to decrease the number of semesters/years during which feedback is still visible for everyone in course information in SIS. The feedback of the last five years must be available for attestation of teaching staff. Recommendations for future students become outdated more quickly, as the staff must improve the courses each semester considering the feedback.
8. How has the transition from SIS1 to SIS2 influenced these processes?
Personalisable data, the purpose of their storing, location of and access to data tables have not changed due to the development of SIS2. Because of SIS2 development, the number of persons who have access to the database has increased, as this is necessary for developers for fulfilling their work duties.
The system for asking feedback about courses and curricula is new, and all the decisions for its development have not been made yet; therefore, the feedback system is not technically ready in its final form yet. For example, some informative texts and notifications will still be added during development.