Herzing University use of Online Proctoring
Overview
The COVID-19 pandemic forced Colleges and Universities across the nation to send students home, yet required them to continue educating students, validating student knowledge acquisition, including some third-party exams which specify the use of an online proctoring solution as a condition of use. Because Herzing is committed to providing a high-quality graduate education that prepares students for national certification exams, it needs to administer proctored exams throughout its curriculum.
Remote administration of exams presents several unique challenges, including the inability to employ traditional proctoring methods to ensure the integrity of exams. Herzing University was tasked with identification of a solution that would support the achievement of excellent and compliant pass rates, balanced with concerns to protect student privacy. After weighing several proctoring solutions and conducting due diligence, Herzing University selected Proctorio as its proctoring solution.
Data Privacy & Security
- When Herzing University selected Proctorio, Herzing audited Proctorio’s data collection and privacy policies for compliance with Herzing’s core values: professionalism, respect, integrity, caring, and engagement, which are encompassed in the “P.R.I.C.E. of Success” framework. Proctorio is transparent about its privacy and data collection policies, all of which can be accessed at http://proctorio.com/privacy
- Herzing University will conduct a Data Protection Impact Assessment to determine the extent to which there are legitimate privacy/security issues. As a result, the University will identify mitigating measures available to address valid privacy/security concerns. Herzing University will ensure compliance with privacy and security laws applicable to institutions of higher education and in the jurisdictions in which it operates.
- Herzing University limits access to exam recordings.
- Herzing University does not allow any faculty other than the course instructor or authorized staff to access any exam recordings.
- All faculty have received training on the use of Proctorio, including ensuring data privacy.
- Herzing University (not Proctorio) creates the proctoring rules and determines student compliance based on flagged activity. Students may use the standard University academic appeals process if a dispute arises.
- All exam data is deleted after six months.
- To address student privacy concerns, Herzing University will allow students to blur their Zoom background during exams so long as the Zoom background does not completely conceal movement within the room. By signing into the Zoom mobile application and tapping on Virtual Background (Android) or Background and Filters (iOS), and tapping the blur option, the background will become blurred, obscuring surroundings.
- Herzing University recently directed several questions to Proctorio. If Herzing determines, based upon its review of Proctorio’s responses, that its technology is not adequately protecting student privacy under its P.R.I.C.E. principles or as required by its contract with Proctorio, Herzing University will take swift action to address any deficiencies.
Issues regarding Discrimination and Students Experiencing Disabilities
Herzing University is committed to creating a learning experience that is as accessible and inclusive as possible. To this end, Herzing University complies with all federal education anti-discrimination laws, including but not limited to Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, the Equal Educational Opportunities Act of 1974, and Title II of the Americans with Disabilities Act of 1990, among others.
- Herzing University requires Proctorio to adhere to all applicable laws, including FERPA and the ADA.
- In alignment with Herzing’s anti-discrimination values, Herzing University employees, and not the Proctorio software, make all determinations regarding student behavior during exams.
- Though Proctorio may flag certain student behavior as allegedly “suspicious,” students will not automatically receive grade deductions or other discipline.
- Exam administrators (i.e., Herzing instructors of record and appropriate academic leadership) will independently review all flagged exams and determine whether any violations of Herzing’s academic integrity policies have occurred.
- Herzing University students who experience a disability and anticipate any issues related to the use of Proctorio can contact Emilie Thompson, ADA Coordinator, to discuss whether they qualify for support and reasonable accommodation under the University ADA Policy. http://rsl.iin3d.com/services-disabled-students.
- Herzing University intends to provide all new and continuing students with a disclosure on Proctorio.
Additional Information on Proctorio
Herzing University selected Proctorio as its proctoring solution due to its unique approach to student data privacy and collection concerns, including:
- Test taker data is secured and processed through multiple layers of encryption.
- “Transmission from the test taker’s device to Proctorio’s data center happens over TLS 1.2 or 1.3 and, if the browser supports it, Perfect Forward Secrecy (PFS). Data at rest within Proctorio’s data center is encrypted using AES-256 and is protected with FIPS 140-2 compliance. All data centers are ISO 27001 certified and SOC 2 attested. Our browser extension uses an encryption layer secured with AES-GCM. The Proctorio platform undergoes daily vulnerability and penetration tests. Proctorio engaged a leading information security consulting company to perform a month-long security assessment of its software and cloud environment in mid-2020. The audit result is posted publicly on the Proctorio website. Proctorio is also currently undergoing an SSAE 16 audit. The SOC 2 Type 1 Audit is expected to be completed by the end of February 2021, which will then lead to pursuing a SOC 2 Type 2 audit later in 2021.”[1]
Proctorio has dedicated Partner Success Managers on staff that regularly communicate and coordinate with Herzing University about compliance. Herzing University will contact Proctorio’s customer support personnel for resolution of any specific student inquiries. Students should direct their question to their student services advisor.
For additional background on Proctorio and its proctoring services, Herzing University refers students to Proctorio’s full statement in response to questions from the United States Senate: http://epic.org/privacy/dccppa/online-test-proctoring/Proctorio-senate-response-010721.pdf
[1] See Proctorio Response to the United States Senate, p. 17. http://epic.org/privacy/dccppa/online-test-proctoring/Proctorio-senate-response-010721.pdf