Remote Proctoring at Western

The information below provides answers to frequently asked questions about Proctortrack and Western's plans for remote proctoring, including responses to privacy, security and data management concerns.

Why is Western providing instructors with a remote proctoring tool?

COVID-19 has created many unforeseen challenges for Western University, including the need to move many courses online. Western's priority is to ensure the safety of all members of our community. Consequently, Western must find new ways to assess (test) students in online courses to ensure their competency in achieving key learning outcomes using methods that are fair and viable with sufficient security measures in place to protect the integrity of the course. Proctoring, whether for an online or an in-person exam, is employed to provide a measure of confidence – to instructors, students, and external bodies – in the integrity of a Western degree. It assures students that they can write an exam on equal terms with their classmates, allows instructors to confidently assign grades, and helps satisfy external stakeholders that, despite the COVID-19 pandemic, Western has endeavoured to maintain the high standards that are at the core of its degrees.

While most courses at Western are using a mix of non-proctored assessments, such as term papers, open book exams and essay-format exams, there are some courses that require proctored assessments to evaluate skills and learning outcomes. Courses in some professionally designated areas, such as accounting, medicine and dentistry have established proctoring requirements. Since it is not possible for Western to provide in-person proctored assessments for online courses during the pandemic, it is essential for Western to make remote proctoring available to meet professional designation expectations and/or for instructors who require it for their courses.

Is Western looking for a long-term remote proctoring solution?

Western is currently using the remote proctoring tool, Proctortrack, as offered by eCampusOntario through a partnership with Ontario's Ministry of Colleges and Universities. In addition, Western is assessing other remote proctoring options to ensure all the needs of the Western community and its partners – students, faculty, staff, accrediting bodies – are met over the short and longer terms.

There are several factors that need to be vetted when considering the best solution(s) for Western. The highest priorities in the vetting process are data security and privacy protection for our students. Other factors include, but are not limited to effective assessment monitoring, integration with Western's learning management system (OWL), capacity to meet Western's assessment needs, technical standards/processes, functionality and costs.

All of the effective remote proctoring services are invasive. Some have better privacy and data security practices than others. Similarly, not all vendors will agree to contractual terms that reflect Western's high standards for data security and privacy protection.

Western is committed to finding a long-term remote proctoring solution that mitigates data security and privacy risks as much as possible while providing an effective means of maintaining Western's standards for academic integrity.

What was Western's process in deciding to use Proctortrack?

Western is using the remote proctoring tool offered by eCampus Ontario through a partnership with Ontario's Ministry of Colleges and Universities. Western was not involved in the selection process when Proctortrack was chosen as the preferred vendor by eCampusOntario. Given the sudden need to find remote proctored assessments and the ease of availability provided through eCampus Ontario, Western chose to engage Proctortrack as a short-term solution.

Western has a rigorous vetting process for any third-party service providers. The review of Proctortrack involved many different University departments and our analysis of Proctortrack determined that they have robust data security and privacy practices.

As Western moves through the assessment and selection process for its own long-term solution for remote proctoring, we are involving students in the process.

Western's academic activities are subject to the Freedom of Information and Protection of Personal Information Act (FIPPA) of Ontario.

FIPPA requires that any collection of personal information be necessary in the performance of Western's educational services and that notice of the collection be provided to students. In light of the global pandemic, both these elements have been met with respect to Western's use of Proctortrack.

Western has limited the collection, use, retention and disclosure of personal information to that which is reasonably necessary for Proctortrack's remote proctoring services. The personal information includes: name, student number, email address, phone number (for tech support purposes), photograph of student's Western ONECard, photograph/face scan of student, and audio and video recordings of student taking assessments.

What assessment formats are available to instructors at Western?

Instructors decide what assessment format(s) to use based on their effectiveness to evaluate a student's competence with regards to the learning outcomes for their courses. There are many different types of assessments used at Western, including: open book exams, essays/written assignments, presentations, essay-format exams, closed book exams, etc. In the end, a course instructor must be confident that the selection of assessments used to indicate a student's level of performance is reliable and valid. Accrediting bodies may also identify expectations with regards to oversight of student performance.

Some Faculties, such as Law and Ivey Business School, use lockdown browser technology for assessments where this format is appropriate.

In some situations, instructors may choose to use a video conferencing tool (e.g., Zoom, Teams, or WebEx) to watch their students completing assessments online where they determine it is suitable to do so. Video conferencing systems are appropriate for some assessments but are not designed for remote proctoring and have functional limitations that prevent them from working effectively as solutions for all remote proctoring needs.

For assessments involving the writing of essays or long answers, plagiarism detection software, such as Turnitin, may be used as a proctoring alternative. However, this option is ineffective for answers that can be shared or copied (e.g., multiple-choice or short answers).

For these reasons, remote proctoring software is available as a tool for instructors, who require it to overcome the limitations of other online assessment options.

What information does Proctortrack have access to on students' devices?

Proctortrack does not have access to any data on students' devices when it is not running.

Once it is running, Proctortrack accesses the computer's connected device list, desktop screen, web cameras, and microphone. The system check also gives Proctortrack access to the local file system in order to check for any prohibited applications, virtual webcams, external displays, multiple keyboards, virtual machines and any test policy violations. When the blue frame is shown on the screen, Proctortrack has access to desktop screenshots, web camera, process logs and keystrokes (used for ensuring the integrity of exams). These actions do not require administrative permissions on the device. Proctortrack does not access personal files or any other processes not required for the purposes of the exam.

Proctortrack does not:

What information does Proctortrack collect about students?

Personal information collected through Proctortrack is limited to the categories Western reasonably requires for identity verification purposes. This includes name, student number, email address, phone number (for tech support purposes), photograph of student's Western ONECard, photograph/face scan of student, and audio and video recordings of student taking assessments.

Keystroke data are not collected or stored. Instructors may select keystrokes such as copy, paste, and PrtScn (used to take screenshots) that are not permitted for use during an assessment. Proctortrack may detect and restrict prohibited keystrokes to facilitate the assessment requirements.

What stops Proctortrack from collecting and using student data for unauthorized purposes?

Legal penalties for privacy violations are severe and are therefore taken very seriously at Verificient Technologies (the company that offers Proctortrack). In addition to Proctortrack's strict internal data security and privacy compliance standards and published privacy commitments (Privacy Policy and Privacy Pledge), the contractual relationship between eCampusOntario and Verificient Technologies includes provisions to protect student data. All student data will be kept confidential at all times and cannot be collected, used or disclosed except as necessary for providing the remote proctoring services.

What is Western doing to protect students who are required to use Proctortrack or other online proctoring tools?

Western will support students who experience any technical issues related to their use of Proctortrack. Support may be accessed at: https://remoteproctoring.uwo.ca/support.

Western has also taken several steps to mitigate the risks for students using Proctortrack and is committed to mitigating the same risks when it moves forward with its long-term remote proctoring solution.

Some of the risk mitigation steps that have been taken with Proctortrack include:

  1. ensuring student data is treated confidentially by the vendor;
  2. requiring student data storage in Canada;
  3. minimizing the collection of personal information;
  4. assessing the technical standards used by the remote proctoring service provider and ensuring they meet or exceed industry standards;
  5. reviewing the data security and privacy practices of the remote proctoring service provider to ensure they are compliant with applicable laws and Western's privacy standards; and
  6. working with the remote proctoring service provider to ensure student data is erased upon request.

How is Western supporting students with accessibility issues who are required to use remote proctoring for their courses?

Western is committed to ensuring students' accessibility needs are met during the COVID-19 pandemic. Proctortrack works with most accessibility tools. It is important that the long-term remote proctoring solution Western selects has the same capabilities. In cases where the remote proctoring tool does not meet the accessibility needs of a student, we will find alternatives to ensure students are not disadvantaged and are able to complete their course assessments.

Students with questions related to accessible education may visit Western's Academic Support and Engagement Website at the following link: http://academicsupport.uwo.ca/.

What alternatives are available to students who do not want to use Proctortrack?

The following options are available to students who do not want to use Proctortrack:

  1. When possible, select courses that do not use Proctortrack;
  2. Write assessments for the course the next time the course is offered in-person (a designation of incomplete (INC) or special exam privileges (SPC), as appropriate, will appear on your academic record until the assessments are completed); or,
  3. Withdraw from the course (Western's refund schedule applies to all courses and is available at the following link - https://registrar.uwo.ca/student_finances/fees_refunds/fee_refund_schedules.html.

Western does not permit students to select their assessment formats for their courses. This is consistent whether we are operating under normal or pandemic circumstances. The assessment formats are determined by instructors, and students are provided with advance notice of the assessment method(s). In addition to information provided by the instructor, the Registrar's Office sends notices to all students registered in courses using Proctortrack.

Western does not have physical capacity to permit in-person exams for online courses during the pandemic. Online courses requiring proctored assessments during this period are able to proceed through the use of remote proctoring services.

For students who have extraordinary circumstances (e.g., where online presence may jeopardize their personal safety or where use of remote proctoring software on a device violates terms of the individual's employment), Western will work with these individuals to provide alternative accommodated exams. Unfortunately, we do not have the resources and capacity to accommodate everyone with general privacy concerns toward the use of remote proctoring software.

What can students do to protect their data and privacy when using Proctortrack?

Best practice with any software is to only keep it installed when it is actively being used. For Proctortrack, students may install it before their assessment and then uninstall it once the assessment is complete.

Students may also request that the profile data and assessment recording information be deleted after their assessment is completed. Students may direct data erasure requests to Exam Central or directly to Proctortrack. As soon as the instructor does not require access to this information for exam review purposes, we can arrange to have the data securely deleted from Proctortrack.

Western recommends using the Western ONECard for identity verification purposes. If you do not have a Western ONECard and must use another form of government identification, we recommend covering all of the information except for your name and picture.

What was the nature of the security incident that occurred with Proctortrack?

On October 13, 2020, the company that runs Proctortrack (Verificient Technologies) discovered that an unauthorized user accessed one of the company's quality assurance servers used for outdated developmental source code. The unauthorized user leaked part of outdated source code, disabled the company's marketing site, sent offensive emails that appeared to be from Verificient Support to some prior users and posted the fake email on Twitter with hashtags.

Verificient has confirmed that no personally identifiable information was accessed, no data was altered, no credit card account numbers were stolen and no login credentials were compromised.

Verificient was able to stop the intrusion immediately and then suspended its Proctortrack services between October 14 and 22 to investigate and assess the impact of the incident.

On October 21, 2020, Verificient publicly announced that they would be resuming Proctortrack services following a comprehensive audit by an independent cybersecurity provider.

What steps did Western take before making the decision to start using Proctortrack again after the security incident service disruption?

Western made the decision to start using Proctortrack again on October 27. Proctortrack assessments proceeded at Western again on October 29.

Verificient had a comprehensive audit completed by an independent and reputable cybersecurity provider. The audit confirmed that the company's existing security infrastructure was effective in limiting the extent of the unauthorized access and that the unauthorized access was quickly contained.

Verificient was cooperative and transparent with respect to sharing information with clients and the public about the incident. The company also took appropriate steps to resolve the vulnerabilities exploited by the unauthorized user.

Western has reviewed the information provided by Verificient Technologies, which confirmed that the audit of the incident was conducted by a reputable, independent cybersecurity firm. Verificient Technologies has assured, and the independent cyber security firm has confirmed, that the security incident was contained to a server within their Quality Assurance (QA) environment and that no user customer data was breached. Western has reviewed the statements made by Verificient Technologies as well as additional security steps Verificient Technologies has taken to further secure their environment. Western is satisfied with the information provided and resumed use of the Proctortrack service.

What steps is Western taking to address and respond to students' concerns?

Western's goal is to offer a full complement of courses during the pandemic, including courses with learning outcomes that can only be effectively evaluated by proctored closed-book exams. We are aware of the privacy concerns that have been raised by students about the use of Proctortrack through direct communication from students, the online petition, and comments on social media threads. We are listening to these concerns and taking steps to mitigate risks as much as possible. This includes restricting the use of some Proctortrack functions and limiting the amount of data collection. We have already ensured data is stored in Canada and there are contractual terms that protect against unauthorized use and disclosure of student data.

Western is also assessing and reviewing other remote proctoring tools for its long-term solution. We will be rigorously vetting all of the products to find one that best meets our needs. A significant factor in those considerations will be data security and privacy.

Western hopes that its resilient students bear with us as we navigate the pandemic and work to continue their courses where we cannot hold in-person exams.

Students who find they cannot proceed with the use of Proctortrack are advised to contact the Academic Counselling office of their Faculty to request a late withdrawal from these courses. It is not a route that we hope our students select, but unfortunately, our options are limited in maintaining academic integrity under the confinement of pandemic control measures.

What are Western's long-term remote proctoring and online assessment plans?

Western intends to continue to provide instructors with remote proctoring services as an option for their assessments. We will continue with our review and assessment of different vendors and products and will be selecting at least one for our long-term use.

Western is committed to proceeding through this selection process with transparency and input from all stakeholders, including undergraduate and graduate student representatives.