When considering the use of an educational technology tool outside of the Toolbox for teaching and learning, the first step should generally be consulting with your divisional support, or with the central Educational Technology team at q.help@utoronto.ca. There may be University-vetted alternatives that meet your needs, or other considerations around use of the tool.
Privacy Requirements for Using External Tools
Under current provincial legislation, the University is required to conduct a Privacy Impact Assessment (PIA) for any new use or collection of Personal Information (PI). In academic scenarios, the concern is primarily Student PI; Faculty/Staff business identity information (name, email, title etc.) is not considered PI.
Typical examples of PI would include:
- Student names
- Student emails
- UTORids
- Student numbers
When evaluating a new tool, go through the process of using the tool as an instructor and a student to make sure you understand what information is required from students using the tool. If there is any kind of student account creation step, that generally means PI will be involved (although not always). If the tool requires your students to share or enter PI, a PIA must be conducted to comply with current provincial legislation.
If you’re not sure, reach out to your divisional support.
What Tools Can I Use Without a PIA?
If a tool does not require any PI, it does not need a PIA before using it.
Example: A polling tool where the instructor creates an account, but students do not. Students open a link to submit responses, but none of their personal information is entered.
In some cases, a tool that requires account creation can still be used without collecting student PI.
Example: A tool requires account creation, but students only need a username and password. Students can use an anonymous username that does not include any of their personal or University identity information.
It is always best practice to try and minimize the amount of data shared with any tool that has not been approved by the University, even if they do not require PI.
Using Anonymous Usernames
If you do not need to track student use of the tool, provide your students with guidance on using an anonymous username when you introduce the tool.
If you would like to track use, you can create a spreadsheet that associates each student with the username you would like them to use. These usernames can be shared within your Quercus course.
Educational technology support contacts may be able to advise on the best ways to manage anonymous usernames, depending on the specific use case.
Pedagogical Considerations
Students are always allowed to opt out of using any external tool that collects their PI or intellectual property if that tool has not been vetted by the University. They cannot be penalized for this in any way and must be offered an alternative that provides the same general experience within the course.
When using a tool outside the Toolbox, instructors are responsible for providing guidance and support. CTSI does not provide end-user support for tools outside the Toolbox.
Guidance around use of the tool should be clearly shared with students, for example, a page or file in your Quercus course that students can easily find. Consider including:
- What the tool is.
- How the tool will be used in the course, and expectations for use (e.g. optional or not, alternatives for those that opt out).
- The process to access the tool, including explicit details around the data students are expected to enter. If it will be used without accounts, or with anonymous usernames, these steps should be clearly outlined.
- Links to any relevant support documentation provided by the tool, and what steps students should take if they encounter any issues.