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Ethical use of student data policy – The Open University (LAEP Inventory)

Cloud created by:

Rebecca Ferguson
11 February 2016


The Open University (UK) policy documents include both a formal policy and guidance documents. The aim of the policy documents is to set out how the University intends that student data should be used to inform the delivery of student support in ways which conform to the University’s charter principle to ‘treat each other with dignity and respect’.

The policy, which covers use of data for both student-level interventions and institutional-level strategies and processes, but not use for academic research, is based around eight principles, which are:

  1. Learning analytics is an ethical practice that should align with core organisational principles, such as open entry to undergraduate level study.
  2. The OU has a responsibility to all stakeholders to use and extract meaning from student data for the benefit of students where feasible.
  3. Students should not be wholly defined by their visible data or our interpretation of that data.
  4. The purpose and the boundaries regarding the use of learning analytics should be well defined and visible.
  5. The University is transparent regarding data collection, and will provide students with the opportunity to update their own data and consent agreements at regular intervals.
  6. Students should be engaged as active agents in the implementation of learning analytics (e.g. informed consent, personalised learning paths, interventions).
  7. Modelling and interventions based on analysis of data should be sound and free from bias.
  8. Adoption of learning analytics within the OU requires broad acceptance of the values and benefits (organisational culture) and the development of appropriate skills across the organisation.

Guidance documents expand upon the policy, to summarise the principles for staff, and to provide answers to the ‘frequently asked questions’ of students about how data about them is used in practice.

The policy is published under a Creative Commons Licence.


Inventory type:

adoption implementation advice

analysis of policy-related issues

formal policies

good practice advice

strategy-level white paper

Document source:

The Open University: UK Higher Education establishment


ethics, data protection, privacy, student support

Policy Context




national: UK


The policy is explicitly linked to The Open University Student Charter and to policy and legal requirements for data protection.

Maturity and Evidence of Utility

The policy itself is a relatively new creation, having been adopted in September 2014. It is, however, underpinned by: a series of peer-reviewed scholarly works combining original formulations of the problem-space and review of existing related practice in higher education; and consultation with key institutional stakeholders. It is not yet fully integrated into daily practice such as registration.

Further Information

Location of policy document: (comprises the formal policy and informative guidance)


Slade, Sharon and Prinsloo, Paul (2014). Student perspectives on the use of their data: between intrusion, surveillance and care. In: Challenges for Research into Open & Distance Learning: Doing Things Better – Doing Better Things, pp. 291–300.


See also LAEP Inventory records:

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