Recording Zoom Lectures: Privacy Guidelines for Instructors and Teaching Assistants
Introduction
As a general policy, students in Zoom-delivered classes, seminars, labs and other student meetings should not be routinely recorded. There is a real possibility that a student's personal information (e.g., name, image, voice, personal views and opinions, course work) may be inadvertently captured in a recording.
It would be a rare circumstance that would necessitate the recording of the portion of a live Zoom session that includes student personal information (student images, voices, personal views and opinions, course work). There are few situations that could not be handled in a manner using pre-recorded lectures or recordings of the “non-student” portion of the session for posting on UR Courses (rather than recording a live Zoom interaction that includes student participation). However, if an instructor believes that such a recording is necessary, the instructor should discuss the situation with the Dean/Director or Associate Dean.
Note that some students registered through the Centre for Student Accessibility (CSA) may have permission to individually audio-record lectures. More information on classroom accommodations for students can be found on the CSA website https://www.uregina.ca/student/accessibility/faculty-and-staff/classroom-accommodations.html, with updates related to the remote teaching and learning environment provided here - https://www.uregina.ca/remote-teaching/index.html
Oral exams and group presentations are subject to different considerations and may be recorded where the appropriate student consent is obtained, and the use and retention of the recording is clearly defined. Contact the University’s privacy head for guidance in these situations.
Options Related to Recording
There are situations when the posting of specific recorded material may be beneficial, such as when course registrations include a large number of international students who are taking a course remotely in a different time zone, or where the course material is of a very technical nature and review of recorded lectures would assist in the students’ learning experience.
Where an instructor / TA identifies that a Zoom lecture, etc. should be recorded, steps must be taken to ensure that such recordings do not breach students’ privacy rights. There are options that permit recording which do not include collection of student personal information.
For example, instructors may pre-record lectures and prepare materials in advance, for posting on UR Courses (rather than recording a live Zoom lecture that includes student participation).
Another option would be to record the “live” lecture portion of a class session (the instructor’s voice, image and slides), but have any questions and discussion occur following the lecture, at which point the Zoom recording is stopped.
Alternatively, instructors can “pause” the recording for student questions or discussion, and then resume recording once the lecture continues.
Students can also be encouraged to pose questions privately to the instructor or TA using the Zoom chat function, which questions the instructor / TA can then (anonymously) read and provide an answer orally in the recorded portion of the lecture, or provide written response privately in the chat.
Consent and Collection
In the rare case that an instructor needs to record a class, seminar, lab or student meeting that includes student participation or discussion (and has the permission of their Dean/Director or Associate Dean), they must be aware of the following considerations, and comply with the following requirements.
Students must be informed that a Zoom class, seminar, lab or student meeting in which their personal information will be captured will be recorded. This notice is required by law. In order for a student to provide informed consent, they must be advised as to:
(a) the purpose for making the recording;
(b) the intended use / disclosure of the recording; and
(c) how, and for how long it will be retained.
Instructors should announce that a recording is being made at the beginning of each recorded session, and also include the following language in their course syllabus and/or on UR Courses about the purpose of Zoom recordings:
Some of our Zoom class sessions will be recorded to support student [insert reason for recording here]. As a result, the University of Regina may collect your image, voice, name, personal views and opinions, and course work under the legal authority of The Local Authority Freedom of Information and Protection of Privacy Act.
Students who participate in a Zoom session with their video on or utilize a profile image are consenting to have their video or image recorded (including anything visible in the background). If you have concerns with such recording, be sure to keep your video off and do not use a profile image. In addition, students who un-mute their microphone during class and participate orally are consenting to have their voices, and personal views and opinions recorded. If you are unwilling to consent to this recording, please do not un-mute your microphone during class. If you have any questions about the collection or use of your personal information, please contact your instructor.
We recommend that instructors also inform their students that they may use an image for a virtual background, when signing into class. Sample images for this purpose are available on the Remote Learning web site https://www.uregina.ca/remote-learning.html. Note that this functionality may not be available with older computers, so this may not be an option for all students. In those cases, students should keep their video turned off if they wish to avoid others viewing their background environment or items that may be captured by their webcam.
Access and Use
Access to recordings should be limited to the instructor, the TA(s), and the students enrolled in the course.
The recordings should be used to support student learning only, through posting in UR Courses for students to review. Instructors / TAs may not use the recordings to assess student participation and assign grades, as reliance on the recordings for these purposes would require consideration of other matters, including a longer retention period in case of student grade re-assessment (appeal). Instead, instructors and TAs are to assess participation during live sessions or from their own note-taking.
Disclosure
Instructors and TAs are not to disclose or otherwise publish recorded classes, seminars, labs or student meetings outside of UR Courses. Posting or sharing these materials outside of UR Courses (such as on YouTube) may result in disclosure of the personal information of your students to individuals who are not authorized to access this information.
Retention, Storage and Disposal
Zoom recordings posted to UR Courses will be retained along with other posted UR Courses materials, with student access removed as part of the regular “course reset” process immediately following the end of each term. Recordings retained in Zoom will remain accessible until deleted by the instructor or until the expiration of the 365-day retention period established by Information Services for Zoom cloud recordings.
Instructors are not to keep a copy of the recorded Zoom classes, seminars, labs or student meetings on their work or personal computer, nor store a copy in a cloud-based service (e.g. Dropbox, Google Drive) unless the service is provided by the University and approved for the storage of personal information (such as Zoom, FILR, Kaltura). Storage in non-authorized cloud-based services could result in the recording being disclosed to a foreign jurisdiction and would have implications in relation to student notification and consent.
Important Reminders
Instructors / TAs should be advised that even if they have received the students’ consent to a live recording, a recorded lecture including student images or audio may not be used for a subsequent offering of the course. Instructors will be required to advise Information Services via the IT Support Centre if a recording contains student content, and those recordings will be flagged and purged at the conclusion of the term, in accordance with Information Services practices.
A recorded lecture containing reproductions of third party copyrighted material (including playing a music track, or part of a film) will have to comply with the Copyright Act provisions concerning the reproduction of copyrighted works in e-learning. If a recording is made of such a lecture, that recording may be subject to review by a third party in order to audit the University’s compliance with the Copyright Act. Instructors are not to use music, video, or copyrighted images in their recorded lecture material without carefully consulting the University’s copyright guidance found at https://www.uregina.ca/copyright/faculty/index.html.
If student content is unintentionally recorded, please contact Information Services IT Support Centre immediately to determine what options may be available.
To facilitate adherence to the guidelines provided in this document Information Services will have prescribed default settings in place for all Zoom users. Users who change or disable default settings without authorization may cause a breach of student privacy, and may be subject to discipline.
The University’s Freedom of Information and Protection of Privacy policy can be found here - https://www.uregina.ca/policy/browse-policy/policy-GOV-060-005.html. If you have questions about the privacy impacts of Zoom recordings, please contact the University’s privacy head at glenys.sylvestre@uregina.ca.