Fair processing notice: Taking remotely invigilated assessments
Last updated: 15 February 2022
The data we collect about you
In addition to the data we collect about you as a student (see the Fair Processing Notice for students) we collect the following information during remotely invigilated assessments:
- your unique assessment keycode
- your photo ID
- your photo taken at the start of the assessment
- your desktop recording
- webcam recordings (including sound) of you and your assessment environment before (as part of initial security checks) and during the assessment.
What we do with your data and on what grounds
We can only process your personal data if we have a basis to do so which is permitted by law. This may be that you have given your consent, or it may be one of the other lawful bases for data processing. These comprise situations where it is necessary:
- for our performance of a contract with you. We process your personal data where it’s necessary in order to fulfil a contract with you or to take steps, at your request, before entering into such a contract
- to meet our legal obligations. We process your personal data where it’s necessary for compliance with legal or regulatory obligations.
| Purpose/activity | Lawful basis for processing including basis of legitimate interest |
|---|---|
| To identify you and complete initial security checks |
|
| To carry out remote invigilation of your assessment |
|
| To identify potential irregularities, including maladministration |
|
The data collected via remote invigilation is needed to invigilate assessments, and to subsequently mark and release results to students. If the required data is not provided, the assessment will be void.
We use a wholly computer automated process, without profiling, for marking Level 1 assessments taken via remote invigilation, as part of our performance of our contract with you. This is the same process that would be used if you took the assessments at assessment centres, under normal invigilation conditions. The system is pre-programmed with the number of correct answers required to achieve a pass. The scores are automatically attributed to the candidates based on the number of correct answers in order to calculate the results.
You have the right to request human intervention to express his/her point of view and contest the decision.
See the Enquiries and appeals page for details of the appeals process.
For further details of your rights see the Privacy policy.
Who we share your personal data with
Our third-party service provider will collect Identity Information for identity verification, conducting the assessment, fraud prevention, security and integrity, and as otherwise required by law. They will undertake initial reviews of the recordings made during the assessment to flag irregularities that need further investigation by AAT. Further information about how the provider uses personal data can be found in its privacy policy.
Our provider stores data in locations in the USA and the Philippines. We rely on the Standard Contractual Clauses for data transferred to the USA and Philippines to ensure the protection of the rights and freedoms of individuals concerned.
Where a third-party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under data protection legislation. This means that they cannot do anything with your personal data unless we have instructed them to do it. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Where we get your data from
Data provided and recorded during your remotely invigilated assessment comes directly from you.
How long we keep your data
Information recorded during remotely invigilated assessments will be retained for 90 days. However, sections of an assessment recording may be held for longer if flagged irregularities need to be investigated.
Where flagged irregularities need to be investigated, the recorded information will be retained for 90 days after the investigation has been concluded, or if the outcome of the investigation leads to an appeal, for 90 days after the final appeal decision.
