The privacy and security of faculty, staff and students’ personal information is a top priority for UW-Madison. The university carefully reviews and vets all campus-supported teaching and learning tools, including proctoring tools and takes necessary steps to ensure that tool providers prioritize proper handling of sensitive data in alignment with FERPA, industry standards and best practices.
Under the Family Educational Rights and Privacy Act (FERPA – which protects the privacy of student education records), student consent is not required for the university to share with Honorlock those student education records necessary for carrying out the proctoring service. 34 CFR 99.31(a)(1)(i)(B). FERPA specifically allows universities to treat vendors as school officials and to share student education records with them where they perform services for the university and are subject to FERPA requirements governing the use and redisclosure of personally identifiable information from education records. Honorlock is FERPA compliant and is bound by the terms of its agreement with the university to comply with FERPA’s restrictions on the use of student education records.