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On behalf of Forward on Digitalization and SURF, Dialogic has conducted an exploration into the possibilities, conditions, and potential partners for an infrastructure for managing student data. Educational institutions and service providers gather a lot of data about students, arising from the delivery of education, such as data from (digital) learning materials, as well as from processes that enable education, such as administrative data, teaching evaluations, and enrollment and progression data. The diagram below provides a schematic overview with examples of student data:

The GDPR in principle grants students certain rights regarding their student data, but these legal frameworks do not provide solid guarantees that the use of student data always aligns with ethical standards. Therefore, more control over this data from the student's perspective is desirable, meaning that the student has insight and control over the processing of personal data within the educational process. An infrastructure may offer a solution to facilitate a practical way for students to manage this data. This would also add value for educational institutions, as it would empower an institution to responsibly use personal data to enhance the educational process. Additionally, market parties could benefit from such an infrastructure as it provides a generic solution for enabling control.
The research has shown that an infrastructure can facilitate the registration and exchange of the basis and consent for the use of student data. It has also revealed that the required overview of how educational institutions process student data is incomplete. Therefore, the starting point for further development of data management is to keep the processing register up-to-date.
For potential follow-up on this exploration towards an infrastructure for managing student data, we identify two key points of attention:
- Pay attention to the needs and added value for vocational education, higher education, and research universities as well as service providers. An infrastructure essentially consists of an agreement system on the scope and manner of exchange and a technical system in which this is implemented. For the agreement system, it is important to ensure public-private collaboration across all educational sectors.
- Explore pilots for exchanging student data for which there is no legal basis for processing. Current initiatives (and pilots) mainly focus on use cases where student data is exchanged with a legal basis for processing. For more experiments towards different types of data sources and use cases (including learning analytics), it is important to explicitly design pilots for student data that lacks a legal basis for processing.
Want to learn more about this research? Download the report here or contact Max Kemman.