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Privacy & COVID-19


Recommended Privacy Practices for UC San Diego “Return to” Programs

(11JUN2020; check back for updates as the situation evolves)
The Principles for Responsible Operation of University Locations in Light of the SARS-COV-2 Pandemic, adopted by The Regents at their May 20, 2020, meeting are meant “to guide campus scenario planning as on-site operations increase and in the event they need to be scaled back to respond to a future pandemic surge.” Developing plans for testing and contact tracing are among the first items on the roadmap to ramp up safe on-site operations. There are also significant privacy concerns associated with such large-scale programs, particularly when amplified by technology. These concerns are expressed as articles in mainstream media, papers by privacy law and other expert scholars, and by the numerous proposals for federal legislation to bound these systems to prevent them from becoming more general tools of surveillance.

Use of personal data is crucial in the delivery of healthcare as well as to ensure health and safety in the workplace, in education, and in public facilities. The rapid development of large-scale programs in our novel circumstances, prompts the need for careful consideration of the use and protection of personal data along the way. Transparency, a foundational privacy principle, enhances trust, crucial for endeavors that depend upon widespread adoption and public participation. It also provides clarity around goals and practices for the entire campus community. [1]

Background & Context

Campus reopening efforts may include any one of the following components, all of which process personal data
  • Symptom surveys/screening
  • Temperature checks/thermal imaging
  • Job site/building access controls/building visitor logs
  • Diagnostic testing
  • Antibody testing
  • Collecting doctor notes
  • Isolation housing
  • Contact tracing (analog or digital)
  • Case investigations
  • Proximity tracking
  • Research and modeling 
Key risks if privacy principles are not consistently included in the development of these programs include
  • Resistance to participation
  • Misunderstanding or misapplication of program goals
  • Community mistrust of UC San Diego
  • Discrepancies between program goals and actual practices
  • Collection, access to, or sharing of data elements beyond intended program goals
  • Mishandling or breach

Advantages of designing programs with privacy practices built-in include

  • Greater participation in, and support for, the UC San Diego “Return to” Programs
  • Fewer complaints from the community and the public
  • Demonstrable action around equity, diversity, and inclusion
  • Increased sense of safety in the campus community
  • Wider community trust in UC San Diego
  • Reduced liability – civil rights/privacy litigation, data breach management

These recommended privacy practices are offered in support of these programs. The UC San Diego Campus Privacy Officer can assist in providing practical advice for implementing these practices

Recommended Privacy Practices: Individuals

Individuals should

  • Be informed about the data handling practices of each component of the program (i.e., who, what, why, where, and when)
  • Give explicit consent for some program elements; determination may be based on a variety of considerations, for example, sensitivity or volume of data or intrusiveness of the technology used
  • Have a single point of contact for questions and concerns

Recommended Privacy Practices: Programs

Programs should

  • Be limited to concrete public health activities
  • Have a written protocol describing practices and procedures
  • Have a communications plan developed for rollout
  • Be reviewed and adjusted at each stage along the resilience roadmap to fit the circumstances
  • End when no longer needed for concrete public health activities
  • Include health and campus privacy officers in the design of the program, training materials, and communications plan
  • Be analyzed for equity, diversity, and inclusion to prevent discrimination, intimidation, conflict, and bias, which could occur through certain uses of data
  • Have an appointed oversight group to ensure accountability for the consideration of ethics, human rights, privacy, proportionality of measures to their impact and effectiveness, and the appropriate handling and segregation of personal data[2]

Recommended Privacy Practices: Data

Data should

  • Be collected only if necessary and relevant for the stated purpose(s) and for the relevant population (e.g., teleworking employees generally would not need a symptom survey); and should distinguish between collection by a healthcare provider and another entity
  • Be used only for the specified purpose communicated to individuals
  • Be properly secured from unauthorized use or disclosure, including when processed by applications that collect data, in accordance with UC information security policy and practices
  • Have written procedures allowing for data subject access rights (e.g., by students, represented staff, and the community) in accordance with applicable law and UC practices
  • Be accessible only to those with a need to know, and campuses should distinguish between medical professionals providing healthcare and administrators protecting public health and facilitating campus operations
  • Be retained no longer than necessary or as required by the UC Records Retention Schedule; if kept beyond a program’s sunset, data use should be considered a new program
  • Be de-identified, anonymized, and/or aggregated for analysis, reporting, and research to the extent feasible while maintaining usefulness for tangible public health needs
  • Be collected with practices informed by input from the health and campus privacy officers for alignment with existing campus practices
[1] OECD Guidelines on the Protection of Privacy; Privacy questions for COVID-19 testing and health monitoring
[2] World Health Organization. Ethical considerations to guide the use of digital proximity tracking technologies for COVID-19 contact tracing

 

Privacy Considerations during Modified Campus Operations due to COVID-19 

 

As campus modifies the ways in which we conduct business and moves most interactions online during this outbreak, please be mindful that general privacy requirements remain intact. Use of remote delivery software and technologies heightens the criticality of existing privacy and information security requirements. We remind the campus community to continue to follow the UC San Diego Guiding Principles for Personal Data, FERPA requirements, GDRP requirements, and privacy office guidance. Remember that privacy is the joint responsibility of the campus community and the service providers. For additional resources or questions, please contact the Campus Privacy Office, the Registrar’s Office, or the Ed Tech website for educational continuity.

General Zoom FAQs

Zoom Privacy Concerns

If you are concerned about your privacy while attending class or administrative meetings using Zoom, below are some basic tips to protect yourself. Throughout this webpage, you will find additional guidance and tips on privacy regarding online instruction, recording meetings and classes, and participating in Zoom administrative meetings as well as information specific to students, instructors, staff, and advisors.

Privacy-protective options to consider while utilizing Zoom to protect your privacy:

  • Audio-only participation as an alternative to video;

  • Using a virtual background (this feature is not available for all Zoom instances and may cause video quality issues);

  • Use an alternative to your name, such as your initials or your first name or last name only (you must let the meeting host know in advance if you will be using a pseudonym; otherwise, they may remove you from the meeting);

Please note that if you are a student who has privacy concerns about Zoom and would prefer an alternative option to using your video for online instruction, it is important that you communicate with your instructor prior to your class. Please refer to the Students section of this webpage.

Q: What are the top 10 things that I can do to ensure security and privacy of my Zoom sessions?

  1. Use the most current version of Zoom (see How do I update my Zoom application)
  2. Do not post Zoom links or invites on social media or public websites*
  3. Use a unique ID for each meeting instead of using your Personal Meeting ID*
  4. Utilize meeting passwords (see Zoom: Privacy Options)
  5. Avoid recording unless necessary; if you must record, password-protect the recording and rename the saved recording (see Zoom: Record and Share a Meeting)
  6. Turn off embed password in meeting link (if applicable). This will force users to type in a password rather than have one click access*
  7. Enable Waiting Rooms and have the host allow users in one by one, or all at the same time, once all attendees have been verified*
  8. Lock meetings once all participants have joined, if possible*
  9. Disable file transfer settings during zoom meetings*
  10. Read more about Zoom privacy and security here.

* For more information please see How to secure the Zoom Meeting Information.

Q: I have heard a lot about “Zoom bombing”, what is it?

A: Zoom sessions that are not password protected can be hijacked by invited individuals or joined by uninvited individual(s). Zoombombing, a type of cyberattack, is where an individual(s) would enter a Zoom meeting and broadcast obscenities or take control of the screen. Videoconferencing hosts should monitor participants on teleconference calls to reduce the chance of unauthorized persons on the calls.

Q: How do I protect against Zoombombing and what are the top features I need to be aware of?

A: Do Not Make Meetings or Classrooms Public. In Zoom, there are two options to make a meeting private: 

  1. Require a meeting password; instructions here.
  2. Use the waiting room feature and control the admittance of guests; instructions here.

Change Default Settings. Make sure you permit only authenticated users to join sessions; instructions here.

Do not share links. Do not share a link to a teleconference or classroom on an unrestricted publicly available social media post. Provide the link directly to specific people. 

Manage Screen Sharing Options. Change screen sharing to “Host Only”; instructions here.

Q: What do I do if I have been Zoombombed?

A: 

  • Don't Panic!
  • Restrict participants’ ability to:
    • Share their screens
    • Chat in a meeting 
    • Rename themselves 
    • Unmute themselves 
  • Use the "Participant" icon to further restrict access:
    • Disable or Stop Video
    • Mute participants (disable "allow participants to unmute themselves")
    • Remove participants
  • Note the name of the Zoom bomber - write it down
  • If there are multiple offenders consider ending the meeting and start a new, scheduled meeting with a password that you provide separately to participants
Send a detailed report to zoombombing@ucsd.edu and attach the chat transcript, the meeting ID and precise time of the meeting. You can find this information through the advanced settings of zoom: Settings → View More Settings →  Reports → Usage. If possible, please include screen captures of the offending material. It will be investigated and reported to the most appropriate campus unit, including the Office for the Prevention of Harassment & Discrimination (OPHD), if it is behavior that constitutes harassment or discrimination.   

Q: How can I keep my Zoom meeting information confidential if I have designated an individual to schedule meetings for me? 

A: The Scheduling Privilege feature in Zoom allows one individual to be given delegated rights to schedule meetings for another individual.  When the privilege is granted, the delegate can see details of all meetings scheduled under the delegator’s account.  Privacy-protection options include: (1) omit confidential information from the Topic/Description fields, or (2) train and/or notify the delegate of privacy and confidentiality requirements and needs. 

More information on scheduling privilege for Zoom meetings is available here.

Q:  What information does Zoom collect?  What are Zoom’s Privacy Policy protections?

A: Zoom’s current Privacy Policy (Zoom Privacy, revised March 29, 2020) commits to never selling customer information and to not using customer data for advertising. 

Although Zoom’s Privacy Policy describes how and the extent to which data is used and collected, it has recently been criticized as needing to be more specific. Zoom has acknowledged these criticisms and committed to changes and a more detailed policy in the coming months.  

In that spirit, Zoom’s privacy counsel recently met with UC privacy officers and verbally advised that Zoom does not share session content with any third parties, with the sole exception of recordings stored in a Zoom cloud.  Zoom cloud recordings are stored under contract with Amazon Web Services (AWS). Zoom has also advised that it does not share information with Facebook or other social media platforms; administrators may select their own data centersso that information does not route through Chinese servers; and ithas upgraded its encryption protocol andis actively exploring end-to-end encryption options. 

Zoom’s Privacy Policy also states that Zoom “collects only the user data that is required to provide you Zoom services.”  In Zoom’s recent call with UC privacy officers, Zoom’s legal counsel further advised that this data includes (but may not be limited to) location, device, IP address, operating system type, Zoom version, and connection time.  

Q: Will a participant’s “private” in-session text chats during a Zoom call ever be made visible to the host or others?

A: On April 14, 2020, Zoom’s counsel advised that private text chats are not made visible to anyone except to those whom they are addressed.  UC privacy officers have requested that this advice be provided in writing on a Zoom FAQ.  This answer will be updated when we become aware of any new published guidance. If a session is recorded, the in-session 1:1 chats with the host will beincluded in the recording transcript; if the recording is shared, then 1:1 chats will be seen by others. Hosts of recorded meetingsare advised to review recording transcripts and remove 1:1 messages before posting the recording.

UC privacy officers have requested that this advice be provided in writing on a Zoom FAQ.This answer will be updated when we become aware ofany new published guidance.

Please be aware that for all non-private text chats, any participant may save that chat as a file on their computer.  Additionally, private text chats may also be saved (as a file) by the intended recipient(s) of that text chat.

Q: Has the campus assessed Zoom’s security and privacy?  

A: Several UC campuses have reviewed Zoom's privacy and security posture, including its third-party attestations regarding security. The UC campus privacy officials are monitoring Zoom's changing privacy and security practices and hold regular meetings with Zoom's counsel and technical staff to discuss and review changes.

Q: What has Zoom communicated to the higher education community on security and privacy?

A: On April 20, 2020, Zoom gave a webinar to members of the higher education community detailing the company’s commitment to creating the best and safest Zoom meeting experiences for users and addressed security, privacy, data, and any other concerns gathered by the higher education community.  Additional information is available here.

Q: Are Zoom meeting sessions encrypted?

On April 27, 2020, Zoom upgraded their encryption method (for the curious, it is being upgraded to AES-256 GCM) with increased protection of your meeting data in transit, resistance against tampering, and improved confidentiality assurances for Zoom sessions.  Stronger audio/video stream encryption is included in Zoom 5.0, which was released on May 30, 2020. For details, see Zoom 5.0 website.

Q: I have other more general questions on how to use Zoom. Where can I find additional resources?

A: The Blink website also has resources and helpful articles:

The UC San Diego community is encouraged to check back on this website for updates as the COVID situation changes and practices evolve. Specific privacy questions that are not addressed below should be directed to the Campus Privacy Office at ucsdprivacy@ucsd.edu.

Q: These FAQs didn’t address my concerns. Who should I contact for help or to request an update to these FAQs?

A: If you are aware of other Zoom security and privacy issues, please contact the UC San Diego Privacy Office at ucsdprivacy@ucsd.edu.

Additional information and FAQs regarding Zoom specific to students can be found in our Students section.

Additional detailed information regarding the use of Zoom and other privacy concerns specific to instructors can be found in our Instructors section.

Additional detailed information regarding the use of Zoom and other privacy concerns specific to staff can be found in our Staff section.

Additional detailed information regarding the use of Zoom and other privacy concerns specific to advisors can be found in our Advising section.

Student Privacy FAQs during COVID-19

Privacy During Online Learning

Q: I have privacy concerns about an instructor requiring me to participate in class via videoconference software, using a photo of myself, or using my full name. What can I do to protect my privacy?

A: If you have privacy concerns, seek approval from your instructor for an alternative arrangement.  Sample alternative arrangements include:  

  • Allowing Audio-only participation as an alternative to video;
  • Using a virtual background (this feature is not available for all Zoom instances and may cause video quality issues);
  • Allowing a student to not use their photo; 
  • Allowing a student to use an alternative to their full name, such as the student’s initials, the student’s first name or last name only, or a pseudonymParticipants may use appropriate pseudonyms during recordings if they let the host/instructor know before the session. Due to concerns around Zoombombing and inappropriate access, anyone using a pseudonym (or other name alternative) must let the meeting host know in advance. Hosts are authorized to remove unknown participants from sessions.
All alternative arrangements should be approved by the instructor in advance and should still allow the instructor to readily identify the student.  For privacy, the student need not divulge the reason for the request (e.g. I’m a stalking victim).

Additionally, instructors should not require students who have placed a FERPA block on their directory information, or otherwise requested that the instructor not identify them in an online environment, to use their name or their camera during online classes.
If the student is uncomfortable discussing privacy concernswith instructors or TAs, they are encouraged to contact the Campus Privacy Office to facilitate a dialogue.

Q: Is my instructor allowed to record my participation in a videoconference session?

A: Instructors must give participants notice in the syllabus, if possible, and at the beginning of the recording; ideally, the notice is also recorded. Participants may use appropriate pseudonyms during recordings if they let the host/instructor know before the session. Students should be informed that when cheating is suspected, the recording may become part of an administrative disciplinary record.

Instructors are encouraged to provide other means of participation for students who do not want to be recorded (e.g., submitting questions and comments online).
 
Q: Is my instructor allowed to proctor online exams?

A: Yes. Instructors are advised, when possible, to exhaust other available privacy-protective means of assessing students, such as non-exam evaluations or group projects, before using an online proctoring service. Some classes, however, do not lend themselves to other types of assessments. In those cases, instructors are advised to inform students early and to take privacy considerations into account while balancing the need for academic integrity.

Q: I don’t have a computer available to take my final exams, what should I do?

A: Students who have no computer must inform their instructor immediately to discuss. The Vice Chancellor for Student Affairs has resources for students, including a laptop loaner program. Details are available here.
Students may take advantage of computers in most labs on campus. Students must observe social distancing and wash their hands before and after lab use.
 
Q: Can instructors ask us to take our final exams in person?

A: No. During the modified campus operations, finals CANNOT be held in a lab; that is, instructors cannot require students to gather in person for a final. Labs are available for those students who need a computer to drop in and complete their exam.
Privacy on Zoom

Q: What are the top 10 things that I can do to ensure security and privacy of my Zoom sessions?

  1. Use the most current version of Zoom (see How do I update my Zoom application)
  2. Do not post Zoom links or invites on social media or public websites*
  3. Use a unique ID for each meeting instead of using your Personal Meeting ID*
  4. Utilize meeting passwords (see Zoom: Privacy Options)
  5. Avoid recording unless necessary; if you must record, password-protect the recording and rename the saved recording (see Zoom: Record and Share a Meeting)
  6. Turn off embed password in meeting link (if applicable). This will force users to type in a password rather than have one click access*
  7. Enable Waiting Rooms and have the host allow users in one by one, or all at the same time, once all attendees have been verified*
  8. Lock meetings once all participants have joined, if possible*
  9. Disable file transfer settings during zoom meetings*
  10. Read more about Zoom privacy and security here.

* For more information please see How to secure the Zoom Meeting Information.

Q: I have heard a lot about “Zoom bombing”, what is it and how can I protect myself if I am hosting a Zoom?

A: “Zoom bombing” is the practice of uninvited individuals entering a video call, often to voice hateful and racist views. Videoconferencing hosts should monitor participants on teleconference calls to reduce the chance of unauthorized persons on the calls. Consider using a unique meeting ID for each gathering or class or requiring authentication and a passcode for participants (Settings → Profile → Personal Meeting ID; Meetings → Authenticate, Password). You may also uncheck the “join before host” option. 

Q: What do I do if I have been Zoombombed?

A:

    • Don't Panic!
    • Restrict participants’ ability to:
      • Share their screens
      • Chat in a meeting 
      • Rename themselves 
      • Unmute themselves 

     

    • Use the "Participant" icon to further restrict access:
      • Disable or Stop Video
      • Mute participants (disable "allow participants to unmute themselves")
      • Remove participants
    • Save the chat transcript
    • Note the name of the Zoom bomber - write it down
    • If there are multiple offenders consider ending the meeting and start a new, scheduled meeting with a password that you provide separately to participants
Send a detailed report to zoombombing@ucsd.edu and attach the chat transcript, the meeting ID and precise time of the meeting. You can find this information through the advanced settings of zoom: Settings → View More Settings →  Reports → Usage. If possible, please include screen captures of the offending material. It will be investigated and reported to the most appropriate campus unit, including the Office for the Prevention of Harassment & Discrimination (OPHD), if it is behavior that constitutes harassment or discrimination.   

Q:  What information does Zoom collect?  What are Zoom’s Privacy Policy protections?

A: Zoom’s current Privacy Policy (Zoom Privacy, revised March 29, 2020) commits to never selling customer information and to not using customer data for advertising. 

Although Zoom’s Privacy Policy describes how and the extent to which data is used and collected, it has recently been criticized as needing to be more specific. Zoom has acknowledged these criticisms and committed to changes and a more detailed policy in the coming months.  

In that spirit, Zoom’s privacy officials recently met with UC privacy officers and verbally advised that Zoom does not share session content with any third parties, with the sole exception of recordings stored in a Zoom cloud.  Zoom cloud recordings are stored under contract with Amazon Web Services (AWS). Zoom has also advised that it does not share information with Facebook or other social media platforms; administrators may select their own data centersso that information does not route through Chinese servers; and ithas upgraded its encryption protocol andis actively exploring end-to-end encryption options. 

Zoom’s Privacy Policy also states that Zoom “collects only the user data that is required to provide you Zoom services.”  In Zoom’s recent call with UC privacy officers, Zoom’s legal counsel further advised that this data includes (but may not be limited to) location, device, IP address, operating system type, Zoom version, and connection time. 

Zoom has posted a list of certain third parties, engaged by Zoom, who may have access to such data to assist Zoom in delivering the service.Note that additional clarification in this area has been requested of Zoom.The UC San Diego Privacy Office will continue to monitor Zoom’s privacy policy clarifications and update this FAQ accordingly.

Q: Will a participant’s “private” text chats during a Zoom call ever be made visible to the host or others?

A: On April 14, 2020, Zoom’s Privacy Officer advised UC privacy officers via telephone that private text chats are never made visible to anyone except to those whom they are addressed. UC privacy officers have requested that this advice be provided in writing on a Zoom FAQ. This answer will be updated when we become aware of any new published guidance.

Please be aware that for all non-private text chats, any participant may save that chat as a file on their computer. Additionally, private text chats may also be saved (as a file) by the intended recipient(s) of that text chat

Q: Zoom generates attendee reports for the instructor.  Reports list a student’s mobile telephone number as well as their email address.  Is this allowed under the Family Educational Rights and Privacy Act (FERPA)?  

A: FERPA allows a student’s mobile phone number and email address to be communicated to an instructor, provided the instructor does not further disclose that information and limits the use of that information for the student’s legitimate educational interest. 

Zoom also automatically individual users or administrators to mask phone numbers.

Q: Has the campus assessed Zoom’s security and privacy?  

A: Several UC campuses have reviewed Zoom's privacy and security posture, including its third-party attestations regarding security. The UC campus privacy officials are monitoring Zoom's changing privacy and security practices and hold regular meetings with Zoom's counsel and technical staff to discuss and review changes.

Q: What has Zoom communicated to the higher education community on security and privacy?

A: On April 20, 2020, Zoom gave a webinar to members of the higher education community detailing the company’s commitment to creating the best and safest Zoom meeting experiences for users and addressed security, privacy, data, and any other concerns gathered by the higher education community. Additional information is available here.

Q:I have other more general questions on how to use Zoom. Where can I find additional resources?”

A: The Blink website also has resources and helpful articles:

The UC San Diego community is encouraged to check back on this website for updates as the COVID situation changes and practices evolve. Specific privacy questions that are not addressed below should be directed to the Campus Privacy Office at ucsdprivacy@ucsd.edu. 

Additional Privacy Concerns
Q:  Are student privacy or FERPA guidelines relaxed during the pandemic?

A: The Campus Privacy Office has advised the campus community that that general privacy requirements remain intact. Some law allow for limited exceptions for use of data during an emergency. 
The Department of Education issued COVID-specific FERPA guidance, advising that the FERPA Health & Safety Emergency Exception may be used to respond to COVID-19 pandemic safety needs:  See more here

The Department of Education also reissued Remote Learning Guidance, which you can access here.

Q: What privacy considerations exist regarding online advising?

A: Online advising can occur via chat, audio, or videoconferencing but should be done using services approved by the university (e.g., Skype for Business, VAC, Zoom) or by phone. Sessions should not be recorded; rather, the advisor should log notes as they do now. Advisors are advised to not hold advising sessions in public spaces or where other household members can hear details of the conversation. Students should be mindful of security and told not to use an open network. Advisors are should take extra time to verify the identities of students and double-check email addresses, or phone numbers prior to the discussion. 

Q: If I display COVID-19 symptoms, is the university allowed to inform others of my health status?

A: University administration must inform the Campus Emergency Operations Center (EOC) if an individual shows symptoms of COVID-19 (fever and/or dry cough); and may be required to report information to public health authorities. The university will not notify contacts, family, friends, or others of your identity or symptoms and will be cognizant of information that may indirectly identify a symptomatic individual. If you test positive for COVID-19 and participate in a contact tracing survey, your contacts will be notified that they may have been in the proximity of a positive individual and may need to self-isolate; your name is not disclosed to your contacts.

If you show symptoms of COVID-19, please call Student Health Services at (858) 534-3300. SHS will provide instructions for you to follow.

Q: These FAQs didn’t address my concern. Who should I contact for help or to request an update to these FAQs?

A: If you are aware of other privacy issues, please contact the UC San Diego Campus Privacy Office at ucsdprivacy@ucsd.edu.

Instructors

Video Conferencing & Online Instructions

As the university has transitioned to online learning, teaching, and working, administrative access to the information, video, audio, and metadata of online platforms continues to be limited to the specific circumstances described in the UC Electronic Communications Policy (ECP) and must comply with the UC San Diego PPM 135-5. Please contact the Campus Privacy Office with any questions at ucsdprivacy@ucsd.edu.

Zoom Guidance for Administrative Meetings/Teaching Classes

  1. General
    • “Zoom bombing” is the practice of uninvited individuals entering a video call, often to voice hateful and racist views. Videoconferencing hosts should monitor participants on teleconference calls to reduce the chance of unauthorized persons on the calls. Consider using a unique meeting ID for each gathering or class or requiring authentication and a passcode for participants (Settings → Profile → Personal Meeting ID; Meetings → Authenticate, Password). You may also uncheck the “join before host” option. Do not use your personal meeting id (PMI) for meetings or classes.
    • In order to protect themselves and their students from risk, instructors should use Zoom as recommended by the campus; not post lectures on a publicly accessible website; and, taking into account the need for intefrity and equity, provide students privacy-protective alternatives, whenever reasonable.
    • Instructors can disallow viewers from downloading video files to their own computers by turning off the “Viewers can download” option in the sharing settings for recordings stored on Zoom. With this option disabled, viewers can only view the video in a web browser and not download the actual video files. This makes it harder for viewers to intentionally or accidentally re-share videos. More information on the sharing options for Zoom recordings is available here.
    • For more information about Zoom settings, please consult the UC San Diego Zoom page.
  2. Protecting Student Privacy
    • Individuals/students can use Zoom’s virtual background feature if they do not want to have their surroundings visible. Be mindful of others who may not wish to be visible or recorded in the background (But see note re: proctoring below).
    • If students have privacy concerns, they may seek approval from their instructor for an alternative arrangement. Sample alternative arrangements include:
      • Allowing audio-only participation as an alternative to video;
      • Using a virtual background (this feature is not available for all Zoom instances and may cause video quality issues);
      • Allowing a student to not use their photo;
      • Allowing a student to use an alternative to their full name, such as the student’s initials, the student’s first name or last name only, or a pseudonym. Participants may use appropriate pseudonyms during recordingsif they let the host/instructor know before the session. Due to concerns around Zoombombing and inappropriate access, anyone using a pseudonym (or other name alternative) must let the meeting host know in advance. Hosts are authorized to remove unknown participants from sessions.
    • All alternative arrangements should be approved by the instructor in advance and should still allow the instructor to readily identify the student. For privacy, the student need not divulge the reason for the request (e.g., I’m a stalking victim).
    • Additionally, instructors should not require students who have placed a FERPA block on their directory information, or otherwise requested that the instructor not identify them in an online environment, to use their name or their cameraduring online classes.
    • If the student is uncomfortable discussing privacy concerns with instructors or TAs, they are encouraged to contact the Campus Privacy Office to facilitate a dialogue.
  3.  Recordings 
    • Avoid video or audio recording of administrative meetings and classes unless absolutely necessary. Recordings should never be saved on personal devices (i.e., non-university-issued) and should only be stored on university-approved services (e.g., in the UC San Diego Kaltura, Canvas, or Google Drive services, not in one's personal Google account).
    • In order to disallow recordings of Zoom meetings/classes by anyone who is not the host, please update your Zoom meeting settings to remove the participant recording capability (Settings → Recordings → Local Recording).
    • If you choose to record an administrative meeting/class, you must give participants notice that you will be recording the session at the beginning of the meeting/class. Ideally, the notice is also recorded.
      • Zoom has a feature to automatically inform all users that the session is being recorded and provide an option to opt out (Settings → Recordings → Recording Disclaimer).
      • If participant video is not necessary, consider whether only the host needs to be visible in order to minimize bandwidth usage.
    • If students have privacy concerns and do not wish to appear in the recording of a class, they should not turn their video on. Students may also ask questions or provide comments through the privacy chat feature of Zoom or through other private methods.
    • Instructors are encouraged to provide other means of participation for students who do not want to be recorded (e.g., submitting questions and comments online). Instructors should explain in the class syllabus that classes will be recorded; in addition, at the beginning of the recording, notice of the recording should be provided. 
    • If a student is concerned about their personal information (such as name) being recorded, participants may use appropriate pseudonyms during recordings if they let the host/instructor know before the session.
    • Students should be informed that when cheating is suspected, the recording may become part of an administrative disciplinary record.
    • Recordings should be retained no longer than necessary; consult with the campus Policy & Records Administration Office on guidance regarding retention schedules. 
      • Sample notification language: "This program uses video and audio recording or other personal information for the purpose of facilitating the course/class/meeting. If you have privacy concerns and do not wish to appear in the recording of the class session, do not turn on your video. If you prefer to use a pseudonym instead of your name, please let the instructor know what name you will be using before class so that they will know who you are during the session. You may use the Zoom private chat feature to comment or ask questions. UC San Diego does not allow vendors to use this information for other purposes. Recordings will be deleted when no longer necessary. However, if cheating is suspected, the recording may become part of the student’s administrative disciplinary record.”   
    • Instructors should use the platform(s) selected and approved by the University. Platforms that have not been vetted by the university should not be used.
    • Instructors should not require students who have placed a FERPA block on their directory information, or otherwise requested that the instructor not identify them in an online environment, to use their name or their camera during online classes. 
  4.  Online Exams & Proctoring (In Addition to Guidance Listed Above)
    • Requiring students to turn on their camera to be watched or recorded at home during an exam poses significant privacy concerns and should not be undertaken lightly. Several proctoring services use machine learning, AI, eye-tracking, key-logging, and other technologies to detect potential cheating; these should be used only when no feasible alternatives exist. 
    • If instructors are using a proctoring service during the COVID-19 measures, they must provide explicit notice to the students before the exam.
    • Instructors are encouraged to work with the Digital Learning Hub in the Commons and the Academic Integrity Office to consider privacy-protective options, including how to use question banks (in Canvas), that will uphold integrity and good assessment design.
    • Proctors and instructors are strongly discouraged from requiring students to show their surroundings on camera.
    • Computers are available in labs for students who do not have a computer to take their final exams. Finals CANNOT be held in a lab, that is, instructors cannot be present nor can students from a specific class be asked to gather there for a final. This is only for those students who need a computer to drop in and complete their exam.

Staff

 Video Conferencing

As the university has transitioned to online learning, teaching, and working, administrative access to the information, video, audio, and metadata of online platforms continues to be limited to the specific circumstances described in the UC Electronic Communications Policy (ECP) and must comply with the UC San Diego PPM 135-5. Please contact the Campus Privacy Office with any questions at ucsdprivacy@ucsd.edu.

Zoom Guidance for Administrative Meetings
  1. General
    • Individuals can use Zoom’s virtual background feature if they do not want to have their surroundings visible. Be mindful of others who may not wish to be visible or recorded in the background (But see note re: proctoring below).
    • “Zoom bombing” is the practice of uninvited individuals entering a video call, often to voice hateful and racist views. Videoconferencing hosts should monitor participants on teleconference calls to reduce the chance of unauthorized persons on the calls. Consider using a unique meeting ID for each gathering or class or requiring authentication and a passcode for participants (Settings → Profile → Personal Meeting ID; Meetings → Authenticate, Password). You may also uncheck the “join before host” option. 
    • Users who are calling in via a phone should use the Zoom feature that masks their phone numbers.
    • For more information about Zoom settings, please consult the UC San Diego Zoom page.
  2.  Recordings
    • Avoid video or audio recording of administrative meetings unless absolutely necessary. Recordings should never be saved on personal devices (i.e., non-university-issued) and should only be stored on university-approved services (e.g., in the UC San Diego Kaltura, Canvas, or Google Drive services, not in one's personal Google account).
    • In order to disallow recordings of Zoom meetings by anyone who is not the host, please update your Zoom meeting settings to remove the participant recording capability (Settings → Recordings → Local Recording).
    • If you choose to record an administrative meeting, you must give participants notice that you will be recording the session at the beginning of the meeting/class. Ideally, the notice is also recorded.
    • Zoom has a feature to automatically inform all users that the session is being recorded and provide an option to opt out (Settings → Recordings → Recording Disclaimer).
    • If participant video is not necessary, consider whether only the host needs to be visible in order to minimize bandwidth usage.
    • If participants have privacy concerns and do not wish to appear in the recording of a class, they should not turn their video on. Meeting participants may also ask questions or provide comments through the privacy chat feature of Zoom or through other private methods.
    • If a participant is concerned about their personal information (such as name) being recorded, participants may use appropriate pseudonyms during recordings and inform the host.
    • Recordings should be retained no longer than necessary; consult with the campus Policy & Records Administration Office on guidance regarding retention schedules. 
    • Sample notification language: "This program uses video and audio recording or other personal information for the purpose of facilitating the course/class/meeting. If you have privacy concerns and do not wish to appear in the recording of the class session, do not turn on your video. If you prefer to use a pseudonym instead of your name, please let the instructor know what name you will be using before class so that they will know who you are during the session. You may use the Zoom private chat feature to comment or ask questions. UC San Diego does not allow vendors to use this information for other purposes. Recordings will be deleted when no longer necessary. However, if cheating is suspected, the recording may become part of the student’s administrative disciplinary record.”   
    • Staff should use the platform(s) selected and approved by the University. Platforms that have not been vetted by the university should not be used. 

Advising

Guidance/Tips for Student Advising 
  • Online advising can occur via chat, audio, or videoconferencing but should be done using services approved by the university (e.g., Skype for Business, VAC, Zoom) or by phone.
  • Sessions should not be recorded; rather, the advisor should log notes as they do now.
  • The advisor should always be logged in on campus or through a VPN when advising. 
  • Advisors should not hold advising sessions in public spaces or where other household members can hear details of the conversation.
  • Students should be advised about security and told not to use an open network.
  • Take extra time to verify the identities of students. Verify and double-check identities, email addresses, or phone numbers prior to the discussion. 

Student and Employee Health

Human Resources and Management Employee Health Related Questions

Managers should not ask for health information about employees and employees’ family members without discussing with campus counsel and the Campus Privacy Officer first. Generally, units should consider whether the questions they are asking, or the information they are disclosing, are really necessary to be collected or disclosed. The US Equal Employment Opportunity Commission (EEOC) has provided additional guidance to employers.

Symptomatic Individuals:
  • University administration must inform the Campus Emergency Operations Center (EOC) if an individual shows symptoms of COVID-19 (fever and/or dry cough); the EOC is the first and only entity that administration may inform. Do not take steps to notify contacts, family, friends, or others and be cognizant of information that may indirectly identify a symptomatic individual.
  • If a student shows symptoms of COVID-19, have the student call Student Health Services at (858) 534-3300. SHS will provide instructions for the student to follow.
  • If a staff member shows symptoms of COVID-19, have the staff member contact their health care provider and follow the health care provider’s direction. If the manager has any questions, they can contact the Campus Emergency Operations Center (EOC) at eoc@ucsd.edu or (858) 246-4841. Do not take steps to contact anyone without instructions from the EOC or public health authorities. 
Patient Care and HIPAA Guidance

Individuals who provide patient or student health care should contact the UC San Diego Health Compliance Program at hscomply@health.ucsd.edu, and view a recent Q&A.

Additional Privacy Concerns

Privacy reviews of tools, services, vendors, emergency purchasing protocols

Privacy considerations are crucial as campus instruction and business move almost entirely online. To assure business continuity for the Spring Quarter of 2020, many new agreements for technologies, suppliers, or expansion of existing platforms are requiring immediate privacy review as part of the procurement process. In response, expedited privacy reviews are available for consideration of new technologies, new suppliers, or new uses of existing platforms; privacy recommendations are limited to:

  1. Emergency use
  2. During the Spring Quarter and
  3. Where necessary or where more privacy-protective alternatives are not available or feasible. 

Agreements put in place as a result of an expedited review should only be for the Spring Quarter. 

Should use of the tool, service, or supplier still be needed following the Spring Quarter, the agreement must be renewed, including a standard privacy review. All uses must comply with relevant privacy laws, including FERPA and the EU GDPR.

Phishing

Opportunistic cyber attackers can take advantage of a crisis with phishing campaigns that target individuals. Do not lower your privacy or security guard! Be vigilant with COVID-19-themed phishing lures, particularly with emails that contain attachments or links. Many actors are gaining the trust of victims by using branding associated with the CDC, the WHO, or companies, such as FedEx.

Have More Questions?

Please contact Campus Privacy Office if you have a privacy question that is not covered on this page ucsdprivacy@ucsd.edu .

We are updating this list as needed to address issues arising frequently and to clarify guidance as the situation evolves.

With thanks for the gracious collaboration of UC campus privacy officials and UC San Diego colleagues