Students Are Pushing Back Against Proctoring Surveillance Apps - EFF

Special thanks to legal intern Tracy Zhang, who was lead author of this post.

Privacy groups aren’t the only ones raising the alarm about the dangers of invasive proctoring apps. Through dozens of petitions across the country, and the globe, students too are pushing school administrators and teachers to consider the risks these apps create.  

Schools must take note of this level of organized activism.

Students at the University of Texas at Dallas are petitioning the school to stop using the proctoring app Honorlock. The petition has over 6,300 signatures, notes that Honorlock can collect “your face, driver’s license, and network information,” and calls use of Honorlock a “blatant violation of our privacy as students.” Students at Florida International University are petitioning their school to stop using Honorlock as well, gathering over 7,200 signatures. They highlight the amount of data that Honorlock collects and that Honorlock is allowed to keep the information for up to a year and, in some cases, 2 years. Students at California State University Fullerton are petitioning the school to stop using Proctorio, calling it “creepy and unacceptable” that students would be filmed in their own house in order to take exams. The petition has over 4,500 signatures.  

But it’s not just privacy that's at stake. While almost all the petitions we’ve seen raise very real privacy concerns—from biometric data collection, to the often overbroad permissions these apps require over the students’ devices, to the surveillance of students’ personal environments—these petitions make clear that proctoring apps also raise concerns about security, equity and accessibility, cost, increased stress, and bias in the technology.  

A petition by the students at Washington State University, which has over 1,700 signatures, raises concerns that ProctorU is not secure, pointing to a July 2020 data breach in which the information of 440,000 users was leaked. Students at University of Massachusetts Lowell are petitioning the school to stop using Respondus, in particular calling out the access that its Ring-0 software has on students’ devices, and noting that the software “creates massive security vulnerabilities and attack vectors, and thus cannot be tolerated on personal devices under any circumstances.” The petition has over 1,000 signatures.

Students at the University of Colorado Boulder raise concerns about the accessibility of proctoring app Proctorio, saying that “the added stress of such an intrusive program may make it harder for students with testing anxiety and other factors to complete the tests.” The petition has over 1,100 signatures. The Ontario Confederation of University Faculty Associations wrote a letter speaking out about proctoring technologies, noting that the need for access to high-speed internet and newer computer technologies “increase [students’] stress and anxiety levels, and leave many students behind.” 

In addition to privacy concerns, the petition from students at Florida International University notes that because Honorlock requires a webcam and microphone, “students with limited access to technology or a quiet testing location” are placed at a disadvantage, and that the required use of such technology “does not account for students with difficult living situations.” A petition against Miami University’s use of Proctorio notes that its required use “discriminates against neurodivergent students, as it tracks a student’s gaze, and flags students who look away from the screen as ‘suspicious.’ This, too, “negatively impacts people who have ADHD-like symptoms.” The petition also noted that proctoring software often had difficulty recognizing students with black or brown skin and tracking their movements. Their petition has over 400 signatures.

Students have seen success through these petitions. A petition at The City University of New York, supported by the University Student Senate and other student body groups, resulted in the decision that faculty and staff may not compel students to participate in online proctoring. After students at the University of London petitioned against the use of Proctortrack, the university decided to move away from the third-party proctoring provider.

Students have seen success through these petitions.

Below, we’ve listed some of the larger petitions and noted their major concerns. There are hundreds more, and regardless of the number of signatures, it’s important to note that even a few concerned students, teachers, or parents can make a difference at their schools.  

As remote learning continues, these petitions and other pushback from student activists, parents, and teachers will undoubtedly grow. Schools must take note of this level of organized activism. Working together, we can make the very real concerns about privacy, equity, and bias in technology important components of school policy, instead of afterthoughts.  

***** 

If you want to learn more about defending student privacy, EFF has several guides and blog posts that are a good place to start.  

• A detailed explanation of EFF’s concerns with unnecessary surveillance of proctoring apps is available here
• Our Surveillance Self-Defense Guide to student privacy covers the basics of techniques that are often used to invade privacy and track students, as well as what happens to the data that’s collected, and how to protect yourself. 
• Proctoring apps aren’t the only privacy-invasive tools schools have implemented. Cloud-based education services and devices can also jeopardize students’ privacy as they navigate the Internet—including children under the age of 13. From Chromebooks and iPads to Google Apps for Education, this FAQ provides an entry-point to learn about school-issued technology and the ramifications it can have for student privacy. 
• Parents and guardians should also understand the risks created when schools require privacy-invasive apps, devices, and technologies. Our guide for them is a great place to start, with ways to take action, and includes a printable FAQ that can be quickly shared with other parents and brought to PTA meetings. 
• All student privacy-related writing EFF does is collected on our student privacy page, which also includes basic information about the risks students are facing.
• In the spring of 2017, we released the results of a survey that we conducted in order to plumb the depths of the confusion surrounding ed tech. And as it turns out, students, parents, teachers, and even administrators have lots of concerns—and very little clarity—over how ed tech providers protect student privacy.
• COVID has forced many services online besides schools. Our guide to online tools during COVID explains the wide array of risks this creates, from online chat and virtual conferencing tools to healthcare apps.
• Some schools are mandating that students install COVID-related technology on their personal devices, but this is the wrong call. In this blog post, we explain why schools must remove any such mandates from student agreements or commitments, and further should pledge not to mandate installation of any technology, and instead should present the app to students and demonstrate that it is effective and respects their privacy. 

*****

Below is a list of just some of the larger petitions against the required use of proctoring apps as of September 24, 2020. We encourage users to read the privacy policies of any website visited via these links.

• Auburn University students note that “proctoring software is essentially legitimized spyware.”
• NJIT petitioners write that while students agreed to take classes online, they “DID NOT agree to have [their] privacy invaded.”
• CUNY students successfully leveraged 27,000 signatures to end the “despicable overreach” of proctoring app Proctorio.
• Students at the University of Texas at Dallas, Dallas College, and Texas A&M called the use of Honorlock “both a blatant violation of our privacy as students and infeasible for many.”
• University of Tennessee Chattanooga students say that “Proctorio claims to keep all information safe and doesn't store or share anything but that is simply not true. Proctorio actually keeps recordings and data on a cloud for up to 30 days after they have been collected.” 
• Washington State University students note that in July, “ProctorU had a data breach of 440,000 students/people's information leaked on the internet.”
• In a letter to the Minister of Colleges and Universities, the Ontario Confederation of University Faculty Associates argue that “Proctortrack and similar proctoring software present significant privacy, security, and equity concerns, including the collection of sensitive personal information and the need for access to high-speed internet and newer computer technologies, These requirements put students at risk, increase their stress and anxiety levels, and leave many students behind.” 
• In a popular post, a self-identified student from Florida State University wrote on Reddit that “we shouldn't be forced to have a third-party company invade our privacy, and give up our personal information by installing what is in reality glorified spyware on our computers.” An accompanying petition by students at FSU says that using Honorlock “blatantly violates privacy rights.”
• CSU Fullerton students call it “creepy and unacceptable” that students would be filmed in their own house in order to take exams, and declare they “will not accept being spied on!”
• Miami University petitioners argue that “Proctorio discriminates against neurodivergent students, as it tracks a student's gaze, and flags students who look away from the screen as 'suspicious' too, which negatively impacts people who have ADHD-like symptoms.” The petition goes on to note that “students with black or brown skin have been asked to shine more light on their faces, as the software had difficulty recognizing them or tracking their movements.”
• CU Boulder students say that, with Proctorio, the “added stress of such an intrusive program may make it harder for students with testing anxiety and other factors to complete the tests.”
•  UW Madison students are concerned about Honorlock’s “tracking of secure data whilst in software/taking an exam (cookies, browser history); Identity tracking and tracing (driver's license, date of birth, address, private personal information); Voice Tracking as well as recognition (Specifically invading on privacy of other members of my home); Facial Recognition and storage of such data.”
•  Florida International University students note that “Honorlock is allowed to keep [recordings of students] for up to a year, and in some cases up to 2 years.” The petition also notes that “Honorlock requires a webcam and microphone. This places students with limited access to technology or a quiet testing location at a disadvantage…You are required to be in the room alone for the duration of the exam. This does not account for students with difficult living situations.”
•  Georgia Tech petitioners are concerned that data collected by Honorlock “could be abused, for example for facial recognition in surveillance software or to circumvent biometric safety system.”
•  University of Central Florida students argue that “Honorlock is not a trustworthy program and students should not be forced to sign away their privacy and rights in order to take a test.”
•  UMass Lowell students call out the “countless security vulnerabilities that are almost certainly hiding in the Respondus code, waiting to be exploited by malware and/or other forms of malicious software.”
•  University of Regina students argue that “facial recognition software and biometric scanners have been shown to uphold racial bias and cannot be trusted to accurately evaluate people of color. Eye movement and body movement is natural and unconscious, and for many neurodivergent people is completely unavoidable."

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