ISO/IEC TS 20748-4:2019

TECHNICAL ISO/IEC TS
SPECIFICATION 20748-4
First edition
2019-09
Information technology for learning,
education and training — Learning
analytics interoperability —
Part 4:
Privacy and data protection policies
Reference number
©
ISO/IEC 2019
© ISO/IEC 2019
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ii © ISO/IEC 2019 – All rights reserved

Contents Page
Foreword .iv
Introduction .v
1 Scope . 1
2 Normative references . 1
3 Terms and definitions . 1
4 Abbreviated terms . 3
5 Privacy and data protection requirements . 4
5.1 General . 4
5.2 The concept of privacy and data protection in LET . 4
5.3 Privacy and data protection issues related to learning analytics . 6
5.4 Privacy framework requirements. 7
6 Learning analytics privacy and data protection attributes . 8
7 LA privacy and data protection attribute specifications .11
7.1 General .11
7.2 Specification of required information on core privacy and data protection
characteristics of LA system .11
7.2.1 Core LA privacy and data protection requirements .11
7.2.2 Institutional code of practice for use of LA .12
7.2.3 Information collection principles for LA .13
7.2.4 Information processing principles .13
7.2.5 Information dissemination principles for LA .15
7.3 Principles and data requirements for consent to share data for learning analytics .15
7.3.1 General requirements .15
7.3.2 Timing of consent .16
7.3.3 Consent frameworks and types of consent .17
7.3.4 Minimum data requirements for documentation of consent .17
7.4 Accountability and governance related to privacy and data protection for LA .18
Bibliography .19
© ISO/IEC 2019 – All rights reserved iii

Foreword
ISO (the International Organization for Standardization) and IEC (the International Electrotechnical
Commission) form the specialized system for worldwide standardization. National bodies that
are members of ISO or IEC participate in the development of International Standards through
technical committees established by the respective organization to deal with particular fields of
technical activity. ISO and IEC technical committees collaborate in fields of mutual interest. Other
international organizations, governmental and non-governmental, in liaison with ISO and IEC, also
take part in the work.
The procedures used to develop this document and those intended for its further maintenance are
described in the ISO/IEC Directives, Part 1. In particular, the different approval criteria needed for
the different types of document should be noted. This document was drafted in accordance with the
editorial rules of the ISO/IEC Directives, Part 2 (see www .iso .org/directives).
Attention is drawn to the possibility that some of the elements of this document may be the subject
of patent rights. ISO and IEC shall not be held responsible for identifying any or all such patent
rights. Details of any patent rights identified during the development of the document will be in the
Introduction and/or on the ISO list of patent declarations received (see www .iso .org/patents) or the IEC
list of patent declarations received (see http: //patents .iec .ch).
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expressions related to conformity assessment, as well as information about ISO's adherence to the
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.org/iso/foreword .html.
This document was prepared by Joint Technical Committee ISO/IEC JTC 1, Information technology,
Subcommittee SC 36, Information technology for learning, education and training.
A list of all parts in the ISO/IEC 20748 series can be found on the ISO website.
Any feedback or questions on this document should be directed to the user’s national standards body. A
complete listing of these bodies can be found at www .iso .org/members .html.
iv © ISO/IEC 2019 – All rights reserved

Introduction
The ISO/IEC 20748 series clarifies and regularizes the behaviour of components related to learning
analytics interoperability. Privacy and data protection are identified as important cross-cutting
requirements impacting all sub-processes of learning analytics (LA). Even if privacy and data protection
are regulated by law in some jurisdictions, there is a need to specify privacy requirements as part of
this series to establish principles that can influence design and operation of learning analytics systems.
The concepts of privacy and data protection are used differently around the world. In this document,
which is designed to be used in an educational setting, ‘privacy and data protection’ are used as
one concept to capture both the social and contextual aspects of privacy and the more technical
and managerial aspects of data protection for learning, education and teaching (LET). Privacy and
data protection requirements for learning analytics can be derived from multiple sources, both
written and non-written, including educational policy frameworks, ICT infrastructure principles,
international privacy frameworks (e.g., OECD, APEC, European Union), trade agreements, national
legal frameworks, ethical principles observed in LET, etc. These requirements are often expressed as
high level principles that different constituencies could agree upon. This document develops detailed
privacy and data protection attributes pertaining to the learning analytics process cycle (described
in ISO/IEC TR 20748-1). This document enables the development of LA privacy and data protection
attribute specifications, which detail how information exchange should be performed to fulfil the aims
of LA operations without compromising privacy and data protection of the individual.
This document is intended to inform system developers in designing LA systems and processes
supporting inclusive privacy and data protection policies. The primary beneficiaries of privacy and
data protection policies are the individuals who share their PII, in this case the students (and their
parents or guardians), teachers and other actors who take part in learning, education and training.
Educational organizations and third party providers are also target user groups.
© ISO/IEC 2019 – All rights reserved v

TECHNICAL SPECIFICATION ISO/IEC TS 20748-4:2019(E)
Information technology for learning, education and
training — Learning analytics interoperability —
Part 4:
Privacy and data protection policies
1 Scope
This document specifies privacy and data protection requirements and attributes to inform design of
learning analytics systems and learning analytics practices in schools, universities, workplace learning
and blended learning settings.
2 Normative references
There are no normative references in this document.
3 Terms and definitions
For the purposes of this document, the following terms and definitions apply.
ISO and IEC maintain terminological databases for use in standardization at the following addresses:
— IEC Electropedia: available at http: //www .electropedia .org/
— ISO Online browsing platform: available at http: //www .iso .org/obp
3.1
accountability
principle that individuals, organizations, and the community are responsible for their actions and may
be required to explain them to others
[SOURCE: ISO/TS 14441:2013, 3.1, modified — Note 1 to entry has been deleted]
3.2
anonymization
process by which personally identifiable information (PII) is irreversibly altered in such a way that a
PII principal can no longer be identified directly or indirectly, either by the PII controller alone or in
collaboration with any other party
[SOURCE: ISO/IEC 29100:2011, 2.2]
3.3
consent
process that provides the data subject (learner, teacher, instructor, or other natural person participating
in LET) with explanations that will help that data subject in making educated decisions about whether
to begin or continue participating in data collection, use or disclosure of personally identifiable
information (PII) (3.9)
Note 1 to entry: Consent is an ongoing, interactive process over the lifetime of the data rather than a one-time
information session.
Note 2 to entry: For the collection, use or disclosure of PII for individuals who are not of legal age or cannot
consent for other reasons, depending on the nature of the data, additional consent requirements may apply, e.g.,
permission from a responsible adult or guardian.
© ISO/IEC 2019 – All rights reserved 1

3.4
data controller
natural or legal person, public authority, agency or other body which, alone or jointly with others,
determines the purposes and means of the processing of PII
[SOURCE: Adapted from GDPR Article 4(7)]
3.5
data protection
technical and social regimen for negotiating, managing, and ensuring informational privacy,
confidentiality, and security
[SOURCE: ISO/TS 14265:2011, 2.9]
3.6
learning analytics
LA
measurement, collection, analysis and reporting of data about learners and their contexts, for purposes
of understanding and optimizing learning and the environments in which it occurs
[SOURCE: ISO/IEC TR 20748-2:2016, 3.12]
3.7
learning analytics service
system that aggregates and analyses learner data that is collected when learners interact with a
platform and software
3.8
personally identifiable information
PII
any information that (a) can be used to identify the PII principal to whom such information relates, or
(b) is or might be directly or indirectly linked to a PII principal
[SOURCE: ISO/IEC 29100:2011, 2.9, modified — Note 1 to entry has been deleted]
3.9
PII actor
stakeholder involved in the processing of PII
Note 1 to entry: According to ISO/IEC 29100:2011, 4.2 there are four types of actors who can be involved in the
processing of PII: PII principals, PII controllers, PII processors and third parties.
3.10
PII controller
privacy stakeholder (or privacy stakeholders) that determines the purposes and means for processing
personally identifiable information (PII) other than natural persons who use data for personal purposes
[SOURCE: ISO/IEC 29100:2011, 2.10, modified — Note 1 to entry has been deleted]
3.11
PII principal
natural person to whom the personally identifiable information (PII) relates
...