Preparing for LL field workshops – Part 2: What about the “Datenschutz”?
In my previous post on the EU-funded Learning Layers (LL) project I started a series of blogs on the preparation of the forthcoming Field Workshops with the Learning Toolbox (LTB). With the first post I gave an update on what all has been changing regarding the use of technology and development of tools. In this post I will discuss what implications this has on Data protection/Data Security (“Datenschutz”).
1. Stock-taking on documents for Data Protection/ Data Security
I have already reported in an earlier blog that Graham Attwell drew my attention to the documents of FutureLearn (consortium of British universities for organising MOOCs). Later on, as a response to my e-mails I have got access to some other reference documents:
- Tamsin Treasure-Jones sent me the links to Ethical clearance documents (for the LL research activities in the healthcare sector) and to the related Agreement on Research Data Management Procedure between TLU and Leeds.
- Joanna Burchert sent me the Datenschutzerklärung (declaration on Data Protection/ Data Privacy) of the expertAzubi project and a Learning Unit (Lerneinheit) document of the LernenPlus project with Deutsche Bahn.
2. Adapting the existing documents for the LL pilots in the construction sector
Below I give an overview on four kinds of documents and discuss, to what extent they might be applicable for the LL construction sector pilots and what adjustments would be needed.
2.1. “Agreement on Research Data Management Procedure” between TLU and Leeds
Original context: This agreement is linked to the Ethical clearance of the research activities in the healthcare sector (by the University of Leeds and by the NHS). The GP practices can be involved only in R&D activities in which the management of research data is covered by bilateral agreement between the two universities that are working with/ storing the data.
Adaptability: In the construction sector the situation is in multiple senses different, since no overarching ethical clearance is required and due to the Layers Box installation the data management is primarily under the control of the application partner. Yet, a similar agreement can be drafted to regulate the use of Layers Box and the mutual responsibilities with RWTH as the primary counterpart.
2.2. “Datenschutzerklärung ” (DP/DS declaration) of the expertAzubi project
Original context: This relatively short (two and half-page) document has been drafted as a single ‘Terms & Conditions/ Intellectual Property rights/ Data Protection’ document for the users (apprentices) of the expertAzubi platform that was provided as a regional platform for apprentices in Bremen region. Here the main thrust is to make the users aware that they are responsible of content and communication on the platform and to draw their attention to principles of good practice. The document was presented to the users to be signed as precondition for registration.
Adaptability: Regarding the current construction sector pilots (with LTB and complementary tools) such a single document seems more appropriate for a user organisation (like Bau-ABC) than for individual users. With such a document it is possible to address the issues mentioned above and the combined use of LTB, Baubildung.net platform and complementary tools. From this point of view this would serve as the agreement of the organisation to join in the pilot.
2.3. “Code of Conduct”/ “Data Protection”/ “Privacy policy” documents of FutureLearn
Original context: In the set of the more simple DP/DS documents of the FutureLearn consortium we see the following differentiation between the target groups/organisations and the purposes of documents:
- Code of Conduct (Verhaltenskodex) is a short document for individual users as their individual commitment to the given regulations and principles of good practice. The users are expected to sign this as a precondition for registration as a user.
- Data protection policy (Datensicherheit-Policy) is a relatively short document that clarifies the principles for gathering and using data in the context of the courses (or for us: pilot) and the mutual commitment of different parties to ensure data security.
- Privacy policy (Datenschutz in a narrower sense) is a more overarching document for the regulating the privacy issues between the FutureLearn as a service provider and the partner universities and other partner organisations.
Adaptability: The original documents have been drafted for a context in which data are available due to registration, participation in courses, submitting tasks, comments and other contents. In this respect the construction pilots with LTB, Baubildung.net and other tools are somewhat different but yet analogical. The Code of Conduct is rather close to what we need. The Data protection policy is of the kind that our application partners would prefer to have. The Privacy policy comes into picture regarding the transfer of data between LTB, SSS and the Baubildung.net platform.
2.4. Learning Unit “Datenschutz” of the LernenPlus project
Original context: The “LernenPlus” project has worked with apprentices and trainees (pre-vocational education) of the German Railways (Deutsche Bahn) and promoted their capability to use digital media and web tools in their work-related learning. In this context the project has developed a learning unit for apprentices/trainees on different aspects of data protection and good practice. Here, the point is to provide a context-oriented and exemplary learning aid to these issues. The Learning Unit document includes information inputs and exemplary tasks (that refer to working and learning situations). Also, the document contains a section of recommendations regarding private use of social media.
Adaptability: The original document was not that directly linked to a focused pilot with tools (like the construction pilot with LTB, complementary tools and Baubildung.net). Yet, the approach with short information inputs, exemplary content-oriented tasks and questions for reflection (and recommendations regarding use of social media) are appropriate for the piloting with apprentices and young construction workers. In our pilots we should develop such a material for the trainers (Lehrwerkmeister) and company representatives who will introduce these issues for their apprentices/ construction workers.
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I guess this gives a picture of the kind of homework we are doing with the issues ‘Data protection’/’Data security’. To me this is just the beginning phase of the exercise – an effort to create a minimum set of documents for the pilot phase. When we are extending the pilot activities we are facing new issues. However, I want to emphasise an interesting shift of emphasis – with these draft documents and working issues we are making the “Datenschutz” issues a matter for participative design processes. We are not merely bringing ‘expertise’ on the rules and regulations. Instead, we are facilitating joint learning processes and working together for the solutions.
More blogs to come …
