Educational recordings policy and procedure
The Tavistock and Portman NHS Foundation Trust (the “Trust”) provides The Educational Recordings Policy & Procedure provides a framework for the
recording and distribution of educational videos recordings used in the Trust’s
courses and educational activities. It aims to ensure that all recordings, including
video, audio animations and transcripts are used effectively, inclusively and that
full consideration is given to all legal aspects of this complex area.
1. Introduction
The document sets out the policy and procedure at the Tavistock & Portman NHS
Foundation Trust (‘the Trust’) for the recording and distribution of recordings for educational purposes.The Trust’s courses are designed for the delivery of high-quality education. It is essential that video, audio, animations and transcriptions are used effectively, inclusively and that full consideration is given to all legal aspects of this complex area.
2. Purpose
The Educational Recordings Policy & Procedure is intended to provide a framework for the recording and distribution of educational recordings used in the Trust’s courses and educational activities.
Rationale for using educational video and audio – there are educational benefits to our students from using educational recordings in our courses:
- Alternative format – video, audio and animations can be more engaging than text for
some learners. - Flexible and independent learning – all students benefit from reviewing teaching
material to consolidate their learning. Recordings can support effective self-regulation
of learning. Recordings can be re-visited at a time and place that suits students. - Inclusive learning – recordings are useful to students who encounter barriers in
respect of access, note-taking or concentration; in particular students whose first
language is not English and some disabled students including those with a Specific
Learning Difficulty (SpLD).
3. Scope
- The policy is applicable to video, audio, animations and text recordings for educational purposes; ’recordings’ is used throughout for shorthand.
- The policy is only applicable to recordings relating to teaching & learning activities. This includes recordings made by staff and recordings made by students.
- It covers the recording of ‘live’ events such as lectures, delivered either on-site or online, and the creation and use of pre-recorded learning material.
- It applies to educational recordings created by or featuring staff employed by the Trust or by or featuring Guest Lecturers.
- The following types of recordings are out-of-scope: clinical recordings, research recordings and recordings made for marketing.
4. Definitions
- Recording – any form of a recording of teaching activities. This includes, but is not limited to, audio, video, animation and text transcripts
- Live recording – a recording of a live teaching activity where students / delegates are present, such as a lecture. The activity may take place on-site in a physical space or online in a tool such as Zoom.
- Pre-recorded resource – a recording involving Trust staff or a Guest Lecturer (but not usually students), produced in advance for use in a course or other learning activity.
- Recording contributor – A person participating in live recording or pre-recorded resource or creating media (e.g. images or animations).
5. Policy statements
1.The primary focus of the use of educational recordings is for presenting information to students. This includes recordings of live presentations such as lectures, referred to as ‘live recordings’ in this policy; and educational material that is recorded without a live audience, referred to as ‘pre-recorded resources’ in this policy. In live recordings, the purpose is usually to capture the ‘presenter’; it is generally not the aim to record student contributions or discursive activities.
2.The Trust recognises that not all teaching activities are appropriate for recording. Discursive activities such as seminars or similar teaching events will not usually be recorded, for example infant observation or work discussion groups.
3. Recordings of live teaching activities such as lectures are not intended to be an alternative to attendance. Recordings are usually complementary resources for reviewing after attendance. There can be exceptions to this, for example for some Short Courses.
4. Educational recordings contain personal data and are subject to UK General Data Protection Regulation (GDPR). Personal data of staff and students is processed on the lawful basis of ‘contract’.
5. Individual consent from staff employed by the Trust to be recorded in an educational recording is not required. It is implied through participation in the creation of the recording and ‘Consent’ is not used as the lawful basis for processing personal data (see 4).
6. Consent to be recorded must be obtained from Guest Lecturers or other Recording Contributors not employed by the Trust, through the completion of the Consent Form for Educational Recordings.
7. Educational recordings will usually only be made available to the students / delegates registered on the corresponding course or event and to relevant staff. Subsequent re-use of recordings (for example, use by a later cohort or another course) will require agreement from the subject of the recording. The Consent Form for Educational Recordings (See Appendix in the PDF above) must be used to record consent of this type.
8. The Intellectual Property of all teaching material created by Trust staff, including educational recordings, is owned by the Trust. The Intellectual Property and ownership of recordings made by Guest Lecturers is covered in the Consent Form for Educational Recordings.
9. The Trust is committed to inclusivity and providing digitally accessible learning material. Public Sector Bodies Accessibility Regulations (PSBAR) require that audio and video recordings made available from 23 September 2020 must meet accessibility standards, as defined by the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. All educational videos will be provided with captioning in English.
10. The use of third-party content (for example images) in any educational video requires a licence or for a statutory exception such as ‘illustration for instruction’ to be applicable. See: Copyright for Tutors for further guidance.
11. The use of confidential material requires the appropriate permission to be obtained for it to be included in an educational recording. The use of clinical recordings (made at the Trust) for teaching is covered by the Trust’s ‘Obtaining consent to record patient sessions procedure’ which includes a consent form.
12. Students/delegates will be informed in advance when educational activities are going to be recorded. This may take the form of a verbal announcement at the start of a recording, but more advanced communication is recommended.
13. Students/delegates will not usually be recorded (See Section 5.1) and they have the right to request to be removed from a recording.
14. Educational recordings are made available for personal use by students / delegates & staff at the Trust only. No wider distribution is permitted.
15. Recordings must be retained by the Trust in line with the UK General Data Protection Regulation (GDPR), as they contain personal data. Recordings shall be kept for no longer than is necessary for the purposes for which the personal data was processed. Recordings made by the Trust will be deleted in accordance with the Trust’s data retention schedule.
16. As outlined in the Terms and Conditions of Study, students may not make recordings of any Trust lecture, seminar or other teaching event, except where expressly agreed in advance with the course team and other students OR when approved as a Reasonable Adjustment.
17. Students with permission to make personal recordings as a Reasonable Adjustment do not need to disclose to staff and students that they are making a recording
- Individual students with permission to record a teaching event themselves must:
- Only record the presenter and not interactions involving students whenever possible.
- Make and store recordings securely on a password-protected device.
- Keep recordings for personal use only and not share them with anyone else, including other students.
- Delete all recordings on completion of the course.
18. In educational activities where students are required to make recordings of other people as part of their course (for example recordings of an observation of a volunteer family) it is essential that the following are adhered to:
- Explicit consent must be obtained using a consent form provided by the course.
- Recordings must be stored securely on a password-protected device.
- Recordings must not be shared beyond the course staff and students.
- Recordings must be deleted at the end of the course.
6. Duties and responsibilities
Course Lead
1. Responsible for requesting Digital Education Services to undertake a single or series
of on-site live recordings.
2. Responsible for ensuring Consent Forms for Educational Recordings are completed
by Guest Lecturers (see section 5.6)
3. Responsible for ensuring Consent Forms for Educational Recordings are completed
if needed for re-use of recordings (see section 5.7)
Development Project Lead
1. Responsible for ensuring Consent Forms for Educational Recordings are completed if needed by Recording Contributors participating in Pre-recorded video (see 5.6)
Short Course Administrator
1. Responsible for ensuring Consent Forms for Educational Recordings are completed
if needed by Recording Contributors participating in Live Recorded Video (see 5.6)
Recording Contributor
1. Responsible for ensuring their use of third-party content in presentations complies
with copyright regulations (see 5.10).
2. Responsible for obtaining permission for the use of confidential material in a
recording, including the use of clinical recordings. (see 5.11). 3.Responsible for informing students / delegates that a recording will take place (for
live recordings)
4. Responsible for starting and saving online live recordings in Zoom and ensuring the
digital file is transferred to Digital Education Services
Digital Education Services
1. Responsible for undertaking on-site live recordings and learning material recordings
requested by Course Leads & Short Course Administrators, subject to capacity.
2. Managing the hosting and availability of educational recordings on Trust platforms.
3. Ensuring educational recordings hosted on Trust platforms have appropriate
captioning.
4. Providing Trust staff with appropriate guidance and support to meet their
responsibilities in relation to educational recordings.
5. Contact for Subject Access Requests (digitaleducation@tavi-port.ac.uk)
7. Procedure
Recording & Editing
1. On-site live recordings must be made using the Trust’s approved platforms / services. Recording Contributors will be supported by IMT and the Digital Education Services (DES) team. Captioning will be added automatically or by DES/short course
administration. Minimal edits will be made to live recordings.
2. Recording Contributors & other staff may take responsibility for making on-site live
recorded video following training from Digital Education Services.
3. Live recordings from online teaching activities (using Zoom) will be the responsibility of the Recording Contributor.
Managing & Hosting
1. Recordings will be published (hosted) on approved platforms / services overseen by
Digital Education Services. Restricted access to recordings will be managed through the use of the virtual learning environment (Moodle), or the distribution functionality in Panopto for attendees without access to Moodle.
8. Training requirements
1. All Trust staff complete regular training on information governance and data security including Data Protection
2. Training on the use of digital tools for creating educational videos, including Zoom, is available from the Digital Education Services team.
3. Guidance on Copyright is available on the Library website.
4. Students are provided with guidance on Moodle and through inductions.
5. Training for specialist staff in Digital Education Services will be provided as required
9. Process for monitoring compliance with this policy
1.The Trust will monitor compliance with this policy and procedure as follows:
- Educational videos are overseen by the Digital Education Services team who work closely with Recording Contributors and act as a check on the correct use and creation of educational recordings.
- Access to educational recordings is controlled by Moodle & the Student Records system (SITS).
- Creation of captions is automated in some cases, and quality controlled by Digital
Education Services in others. - Annual student survey feedback is monitored by Head of Digital Education & Library Services.
- Evidence of non-compliance will be raised with Learning and Teaching sub-Committee (through the Digital Workstream) and with the Director of Education (Operations).
- Educational recordings are covered in the Students’ Terms and Conditions which all students sign-up to
10. References
- Data Protection Act 2018 (UK General Data Protection Regulation (GDPR)
- Public Sector Bodies Accessibility Regulations (PSBAR)
- Web Content Accessibility Guidelines (WCAG) 2.1 Level AA
- NHS Records and document management policy (2021)
- Obtaining consent to record patient sessions procedure