Using unsupported third-party tools for teaching and learning
There is an increasingly wide array of external third-party tools available online or through application downloads, which staff may find useful to support teaching and learning and student engagement. Whilst use of these tools can prove convenient, sometimes with features that provide a richer experience than those centrally available, staff must ensure that any data or information stored on non-King’s provided services – in relation to their roles – complies with Data Protection Policy, IT Acceptable Use Policy, digital accessibility regulations and compliance with the software vendor’s license terms and conditions.
It is also important to note that we need to manage the number and variety of tools that we use across the university. If we have lots of different tools to do the same, or very similar tasks, it becomes expensive to provide, support and maintain these tools.
For most cases, the use of King’s supported services is strongly recommended, and essential for summative assessments, and where IT and CTEL can provide full support for usage and reassurance regarding regulatory issues, licensing, and technical quality of the tool. However, it is recognised that on occasion the use of externally available third-party tools can deliver an enhanced student experience. Under these circumstances, their use should be limited exclusively to time-bound and cohort-specific activities (e.g. group task within a seminar).
Please contact your local TEL team or the CTEL team for further advice on the use of third-party tools for teaching, or for advice about general purpose software contact 88888@kcl.ac.uk. IT support is not offered for these technologies. Technologies already being used in faculties are supported locally. If a tool costs money or holds personal data you must seek advice before you purchase or use it.
For specific guidance about third-party AI tools see King’s guidance on generative AI for teaching, assessment and feedback.
As the ‘end user’ you will also be responsible for performing important checks. The guidance below will enable you to carry out these checks and take the appropriate actions.
What are the implications of asking my students to create an account on an unsupported service?
Creating an account on an unsupported service must always be optional for the students i.e. you may not make it a requirement on any course.
Individual and group accounts
Where required to complete an activity organised by a member of staff, and students can independently choose their own services and tools, students should be given the choice of whether to create an account individually or – if appropriate – work with a partner or group account. Within group activities, members should be reminded of appropriate behaviour online. Staff members should consider the promotion of King’s supported alternatives for students to select from, where selecting from a variety of options is possible.
Personal account considerations
If students do decide to create a personal account within a third-party service, staff members should brief their students that
- they are signing up for an external service;
- they are entering an agreement with an external provider (not with King’s);
- it is their personal account for which they are solely responsible;
- any information uploaded may be accessible on the public web;
- There are risks associated with entering personal data or infringing copyright law.
The selection of third-party services which provide good user control over personal information, including easy deletion and export features, is always strongly recommended.
What are the implications of the third party tool requiring submission of personally identifiable data by students and/or staff?
UK data protection legislation requires that all personal data must be held securely; this includes any personally identifiable data such as names, email or IP addresses.
Use of unsupported third-party services where students are required to create a personal account should be avoided. If this is unavoidable then it is likely that a Data Protection Impact Assessment will need to be carried out. It is also likely that the service provider will be required to complete a cloud readiness review before the service can be used. Please contact IT if you require any support or guidance.
Anonymous use and generic accounts
Student use of third-party tools should be anonymous wherever feasible, however, students must be reminded of appropriate conduct online and staff should avoid free text entry/free image upload without appropriate safeguards. An alternative approach is the use of temporary student allocated generic accounts (for example, a list of students and their allocated account, such as student01, student02, etc.) where no personal data is uploaded to the third-party system but accounts are clearly identifiable within the cohort. In these circumstances, advice should be given to students to avoid entering details which may identify them personally, or remedial action should be taken by the staff member to delete as soon as possible.
What do I need to consider when asking students to generate user accounts and passwords on third-party tools and services?
When creating an account on a third-party system, staff and students must not use their King’s email address and King’s password in combination.
Use of the King’s email address may be convenient for collating email notifications (where this is possible), but a different and strong password should be selected for each third-party service used. Use of a King’s email address instead of using existing personal accounts will help to keep university-related activity separate from staff and student’s personal social online identity. This may be preferable and encouraged where appropriate. However, the account created remains the personal responsibility of the individual and access may become restricted once a King’s email becomes unavailable (once the staff member or student leaves King’s), as such any staff member or students should be made aware and be encouraged to delete or transfer credentials as required before leaving.
Students should also be advised that use of a King’s email address does not mean this is a King’s supported system. Staff members must also advise their students accordingly. Avoid the use of third-party services that publicly display personally identifiable data such as email addresses.
What are my responsibilities in relation to any data collected as a result of participating in learning activities?
Access and intellectual property rights
Staff members should always familiarise themselves with the terms and conditions of any third-party service used. Some services may request that you grant a licence to reuse any content posted onto the service. This is often designed to protect the service provider, but careful consideration should be given to how comfortable you are with having the content of the activity shared outside of the cohort group? Wherever possible, password controls or unlisted web links should be selected within the system’s settings before sharing with students.
Data retention
If any external services require students to create an account or use personal devices, the data generated (student responses etc.) as part of the activity should only be retained for as long as is necessary to reasonably complete the required activity; this is unlikely to exceed one academic year. Students should be advised on how to delete their accounts on completion of the activity.
Deletion and retention
Once an activity is complete, it is the staff member’s responsibility to delete (and export) all data related to the activity if the student has not set up their own account. As such, check that the data can be easily deleted and/or exported prior to the activity. Students are of course welcome to retain their personal accounts should they wish to; however, staff must advise students on how to delete their personal accounts as part of the exit process. Any staff members wishing to keep a record of the activity should export to a portable format (such as text, images, HTML or a PDF version) and upload onto Moodle for retention.
A key advantage of using a service fully supported by King’s is that data can not only be retained for longer, but has the potential to be exchanged with other supported King’s systems.
What hidden costs do I need to consider, especially those demanded of students?
Licencing
Use of third-party tools can often be initially license fee free, however, any use must conform to the license terms and conditions including payment of any other fees as appropriate. This is the responsibility of the staff member using third-party tools to check, but advice and support is available through either the CTEL Team, IT or Procurement as appropriate (CTEL can triage any queries to Procurement). It is important to look at the total long term cost of ownership, including support, maintenance and exchanging data with other King’s applications. In addition, the data provided by individuals within third-party systems can be valuable to some external organisations. Staff members should seek advice from IT and CTEL to confirm that any third-party tool complies with current UK legal requirements for data protection. An initial assessment can be made by checking its Privacy Notice. If the tool is hosted outside of the UK or EU then the software company needs to have committed to protecting personal data in a similar way to that covered by UK/EU law. Unfortunately, the US-EU Privacy Shield scheme which previously certified such claims was invalidated in 2020 and has been replaced by more complex contractual clauses. A useful rule of thumb is that if the product is free to use, the supplier will expect to be able to advertise to users or sell their data on. All providers should be asked to complete the King’s Cloud Readiness Review, but providers of free services may not always be willing. Please seek advice from IT.
There is also no guarantee that there aren’t hidden costs (for additional tools or features) which can be promoted to students to encourage further payment. Staff members should ensure that students are not subjected to any hidden costs and only freely available features are utilised. King’s has an obligation to disclose any additional costs incurred by students, therefore, students must be warned how to avoid (where appropriate) any hidden or unnecessary additional charges. If there is any uncertainty, staff members should not use any third-party tool where free access to students cannot be guaranteed. Use of third-party tools should be reviewed yearly to avoid any changes in fee structures being applied to students or unforeseen closure to the service.
Does the service/tool conform to digital accessibility guidelines and regulations?
Accessibility
Whichever tool or service is used, it is important to ensure that new barriers to participation are not being introduced by its selection and consideration is given to access or formats for students with particular access requirements. This may include ensuring the tools selected support international accessibility standards (WCAG 2.1 AA). Any service that we expect students to use should comply with UK government digital accessibility regulations.
What are the implications of using unsupported third party tools as part of the assessment for my course?
Unsupported third-party tools should not be used for delivering summative assessments. However, use for formative assessment can offer a richer assessment menu. Under these circumstances, any utilised third-party tools should comply with the above advice on retention. In addition, students may wish to personally use third-party tools to support summative project activities or to create an online portfolio. Under these circumstances, students should be reminded that this is not a King’s managed environment and any final outputs must be uploaded to an appropriate King’s supported system, usually KEATS (Moodle), for formal assessment and retention.
Acknowledgement
Original guide by Andy Beggan (University of Lincoln).
The original guide was adapted and localised by Kris Roger (LSE) within the terms of a Creative Commons CC BY-NC-SA 4.0 licence granted to LSE by the University of Lincoln.
This guide was then adapted and localised by Amanda Kosinski (KCL). This adapted guide is therefore shared with the same Creative Commons CC BY-NC-SA 4.0 licence