The shift from exam halls to online assessment platforms has quietly created a significant data management challenge, writes Dr James Gupta, pictured, CEO of the online examination platform Synap.
With traditional, paper-based exams, the lifecycle is relatively straightforward. Papers are collected, stored according to institutional policies and destroyed when they are no longer needed. Online exams differ because they leave a much larger digital footprint. Alongside answers and results, organisations also collect identity information, video and audio recordings, screen captures, room scans and other proctoring data to maintain integrity and identify suspicious behaviour.
The temptation is to retain all of it. Storage is relatively affordable, deleting information can feel irreversible and organisations may reason that the data could prove useful if results are challenged later. However, “keep everything, just in case” is not a sustainable data strategy. In fact, it creates long-term compliance issues and exposes organisations to major security risks. More surveillance doesn’t automatically mean more security
Online exam integrity matters. Organisations need assurance that the person taking an assessment is the right candidate and that rules are being followed. There is, however, a danger of equating more monitoring with better security.
Every additional piece of data collected creates another asset that needs to be stored, protected and deleted. Video recordings are particularly contentious because they contain candidates’ faces, voices and other personally identifiable information.
That creates an important question for institutions and assessment providers: not simply can we collect this information, but do we need to? GDPR’s data-minimisation and storage-limitation principles make that distinction important. Personal data should be adequate, relevant and limited to what is necessary and it should not be kept for longer than required for the purpose for which it was collected.
This challenge, however, is not limited to the UK. Federal laws in the United States, such as the Family Educational Rights and Privacy Act and the Children’s Online Privacy Protection Act, both require institutions to keep data collection, storage and sharing to a minimum and obtain explicit consent.
Other international privacy laws, including the Privacy Act 1988 in Australia, Personal Data Protection Act in Singapore and Protection of Personal Information Act in South Africa, for example, also require organisations to follow similar principles. A truly secure exam strategy therefore needs to explain why proctoring data exists and clearly define when it’s no longer needed.
The forgotten half of exam security
Proctoring technology used by online exam platforms naturally receives significant scrutiny, and rightly so, as candidates are required to hand over their personal data and consent to some form of monitoring. By extension, how that data is managed deserves just as much attention.
Suppose an organisation has clearly defined academic appeal and investigation windows. Once those periods expire, what happens to the associated proctoring data? If the answer is effectively “nothing”, we have a problem.
Securely storing data indefinitely is not the same thing as governing it properly. Organisations should instead design online assessment processes around the entire information lifecycle: collection, access, storage, retention and permanent deletion. That means becoming data-purge-ready. A data-purge-ready organisation knows what information it holds, why it holds it and exactly when different categories of information should be deleted. Once relevant appeal or investigation periods have ended, proctoring data can be securely removed while essential records are retained in line with applicable requirements. From here, deletion stops being an occasional IT clean-up exercise and becomes an integral part of the assessment process itself.
Data hoarding has a price
Good data governance isn’t only about reducing regulatory risk. There is a practical case for restraint too. A single online exam may not create an intimidating amount of information. Multiply recordings and monitoring data across thousands of candidates, multiple assessments and several years, however and the storage footprint can quickly grow.
That means higher infrastructure and backup costs, more information for IT and security teams to manage and a larger pool of sensitive data to protect. The consequences of a breach can also become greater.
The UK Information Commissioner’s Office explicitly warns organisations against retaining personal data indefinitely. Its guidance on storage limitation also points to the unnecessary storage and security costs associated with holding more personal data than an organisation needs.
Nowhere is this vulnerability clearer than in education and professional training. As institutions across the world face an unrelenting wave of cyber attacks, establishing clearer data retention policies and focusing on proportionate proctoring is fast becoming a defining characteristic of secure institutions. For online exam users, the lesson is clear. Data minimisation should be viewed as more than a compliance exercise. It is an architectural and operational decision that can reduce complexity, control costs and make online exams easier to scale.
Governance will separate the leaders from the laggards
Online exams are likely to remain an important part of education, professional certification and workplace training. That makes questions about their data practices increasingly difficult to ignore.
Institutions and assessment providers should be able to answer some deceptively simple questions: What information are we collecting? Why do we need it? Who can access it? How long will we retain it? And crucially, can we demonstrate an auditable process showing that it has been permanently deleted when that period ends?
The next phase of online assessment therefore cannot be defined solely by better monitoring technology. It needs better information governance alongside it. Trust does not come from collecting the maximum amount of data possible. It comes from demonstrating control over data that genuinely needs to exist. For secure online exams, that means knowing when to press delete may ultimately be every bit as important as knowing when to press record.
