Data Protection: Best Practice Guidance for Moodle Assignment use

Purpose 

This guidance document provides staff with practical advice on managing student data appropriately when using Moodle Assignments. It supports colleagues in maintaining data protection compliance whilst carrying out their marking and assessment duties efficiently and effectively. 

Context 

Moodle Assignments is used by approximately 40 Higher Education Institutions across the sector as a standard platform for managing student submissions. The University of Nottingham processes around 205,000 student submissions annually through this platform. Unlike Turnitin, which allows in-browser viewing, Moodle Assignments requires files to be downloaded to view them. This is a standard feature of the platform and reflects how it is designed to work sector-wide. 

This guidance helps you manage downloaded files appropriately to minimise data protection risks and comply with University policy. 

Key Principles 

When working with student submissions in Moodle Assignments, staff should follow these core principles: 

1. Data Minimisation 

Only download and retain student data when necessary for your legitimate purposes (marking, moderation, quality assurance, misconduct investigation). 

2. Secure Storage 

Store downloaded files securely on University-managed, encrypted devices. 

3. Anonymous Marking 

Use anonymous assignment submission settings where practicable to minimise personal data processing. 

4. Timely Deletion 

Delete downloaded files as soon as they are no longer required for your immediate purpose. 

5. Appropriate Access 

Only access student submissions when you have a legitimate need to do so as part of your role. 

Best Practice Guidelines 

A. Before Marking Begins 

1. Configure Anonymous Marking Where Appropriate 

For Module Convenors and Assessment Leads: 

• When setting up Moodle Assignments, enable anonymous marking wherever practicable 

• Anonymous marking is particularly appropriate for:  

• Examinations 

• Summative coursework assessments 

• Any assessment where marking anonymity supports fairness and consistency 

• Anonymous marking helps minimise personal data processing by removing student names from submissions 

• Consult the Moodle Help Guides for staff for guidance on configuring anonymous marking 

Note: Anonymous marking may not be appropriate for all assessments, particularly formative work where personalised developmental feedback benefits from knowing the student's context. 

2. Use University Devices 

All staff should: 

• Use University-owned and managed devices for accessing and downloading student submissions 

• University devices are automatically encrypted and meet security standards 

• If you need to access Moodle Assignments away from campus, use:  

• A University laptop 

• Remote Desktop access to your University workstation 

• VPN connection when accessing from personal devices (though downloading to personal devices should be avoided) 

Why this matters: University devices have automatic encryption, regular security updates, and appropriate technical controls to protect student data. Using personal devices introduces additional risks and makes it harder to manage data appropriately. 

3. Understand Your Retention Needs 

Different roles require different retention periods: 

B. During Marking 

1. Organised File Management 

Create a clear folder structure: 

Downloads/ 

└── Current_Marking/ 

    └── [Module_Code]_[Academic_Year]/ 

        └── [Assignment_Name]/ 

            ├── Submissions/ 

            └── Feedback_Documents/ 

Benefits: 

• Easy to locate files when needed 

• Easy to identify and delete when marking complete 

• Reduces risk of accumulating forgotten files in Downloads folder 

2. Avoid Unnecessary Re-downloads 

Good practice: 

• Keep recently downloaded files organised so you can find them again 

• Only re-download if you've already deleted the file or cannot locate it 

• Use your organised folder structure to find files rather than re-downloading 

Why this matters: Each download creates a new copy of the file. Unnecessary re-downloads increase the volume of personal data on your device without benefit. 

3. Work Offline Appropriately 

It is acceptable to work offline on student submissions, but: 

• Keep files in your organised folder structure 

• Return to Moodle to enter feedback and marks as soon as practicable 

• Delete local copies once feedback has been entered in Moodle 

C. After Marking is Complete 

1. Delete Downloaded Files Promptly 

When to delete: 

• First markers: Once you have entered marks and feedback in Moodle 

• Second markers: Once moderation is complete and recorded 

• External examiners: After examination board and any queries resolved 

• All staff: When files are no longer needed for your legitimate purpose 

How to delete securely: 

Step 1 - Delete from your working folder: 

• Select the folder containing the submissions 

• Press Delete or move to Recycle Bin 

Step 2 - Empty your Recycle Bin/Trash: 

• Right-click Recycle Bin icon (Windows) or open Trash (Mac) 

• Select "Empty Recycle Bin" or "Empty Trash" 

• Confirm deletion 

Step 3 - Clear your Downloads folder: 

• Check your Downloads folder for any submissions downloaded directly 

• Delete any remaining files relating to the assignment 

• Empty Recycle Bin/Trash again 

Step 4 - Check browser downloads: 

• Some browsers create temporary copies 

• Clear browser download history if needed (though files are not stored there permanently) 

2. Regular Housekeeping 

Monthly housekeeping routine: 

1. Review your marking folder structure 

2. Identify any assignments where marking is complete 

3. Delete folders for completed assessments 

4. Empty Recycle Bin/Trash 

5. Check Downloads folder for any orphaned files 

End of academic year housekeeping: 

1. Review all marking from previous academic year 

2. Delete all student submissions unless there is a specific ongoing need (e.g., active misconduct investigation) 

3. Empty Recycle Bin/Trash 

4. Contact IT Service Desk if you need assistance with secure data deletion 

D. Special Circumstances 

1. External Examiners 

External examiners often need to sample student work as part of quality assurance processes. 

Best practice for external examiners: 

• Download only the sample of work you need to review 

• Use a University-provided device if available, or ensure your personal device is appropriately secured (see guidance below) 

• Create a dedicated folder for each institution and module you examine 

• Delete files after examination board and any subsequent queries are resolved 

• Keep files for no longer than 3 months after the relevant examination board 

If using a personal device: 

• Ensure the device has full disk encryption enabled 

• Use a strong password/PIN to access the device 

• Store files in a secure location, not in public folders 

• Delete files promptly after use 

• Empty your device's Recycle Bin/Trash 

2. Misconduct Investigations 

Staff involved in misconduct investigations may need to retain submissions for longer periods. 

Best practice: 

• Only download submissions directly relevant to the investigation 

• Store in a clearly labelled folder: Misconduct_Cases/[Student_ID]/[Date] 

• Retain files only for the duration of the investigation plus the appeals period 

• Follow the University's Academic Misconduct procedures for retention periods 

• Delete files securely once the case is closed and any appeals period has expired 

• If in doubt, consult the Academic Integrity team 

3. Appeals and Complaints 

If a student submission is subject to an appeal or complaint: 

Best practice: 

• Original submission remains available in Moodle 

• Only retain downloaded copies if specifically required for investigation 

• Delete downloaded copies once the appeal/complaint is resolved 

• Academic Registry will advise on specific retention requirements for formal cases 

4. Working with Large Cohorts 

For staff marking large numbers of submissions (100+): 

Best practice: 

• Use sub-folders to organise batches (e.g., by student ID ranges) 

• Mark in batches and delete each batch when complete 

• Don't wait until the entire cohort is marked before starting deletion 

• Consider using Moodle's offline grading workflow if appropriate for your needs 

Subject Access Requests (SARs) 

If a student makes a Subject Access Request, the University may need to identify all personal data held about them. 

Your responsibilities: 

• If you have followed this guidance and deleted files promptly, you should have minimal or no student data on your device 

• If you receive a Subject Access Request notification, check:  

• Your organised marking folders 

• Your Downloads folder 

• Your Recycle Bin/Trash 

• Report any files found to the Data Protection Officer at DPO@nottingham.ac.uk 

• Remember: The definitive copy is in Moodle - downloaded copies are temporary working copies only 

Reducing SAR risk: Following this guidance and deleting downloaded files promptly significantly reduces the risk of failing to identify relevant personal data in a Subject Access Request. 

Data Breaches and Lost Devices 

If You Lose a Device or Suspect Unauthorised Access 

Immediate actions: 

1. Report to IT Service Desk immediately:  

• Email: itservicedesk@nottingham.ac.uk 

• Phone: +44 (0)115 951 2000 

2. Report to Information Compliance Team:  

• Email: dpo@nottingham.ac.uk  

3. Provide information about:  

• What device was lost 

• Whether it contained student data 

• What security measures were in place (encryption, password protection) 

• Approximate number of students affected 

Prevention is better than cure: Using University devices with automatic encryption and following this guidance minimises the impact of device loss. 

Frequently Asked Questions 

Q1: Why can't I view submissions in-browser like in Turnitin? 

This is a design feature of Moodle Assignments and reflects how the platform works sector-wide across approximately 40 UK universities. Moodle Assignments is optimised for different workflows than Turnitin, and both have their appropriate uses. 

Q2: Is it illegal to download student work to my device? 

No. Downloading student submissions to mark them is a legitimate use of personal data under UK GDPR (it's necessary for the performance of the University's public task). However, you must manage that data appropriately by: 

• Using secure devices 

• Deleting files when no longer needed 

• Following this guidance 

Q3: What if I need to re-access a submission after I've deleted my downloaded copy? 

The original submission remains in Moodle and can be accessed at any time. You can simply download it again if needed. The key is to delete your local copy when it's no longer needed for immediate use. 

Q4: Can I keep exceptional pieces of work as examples for future teaching? 

If you wish to retain student work for teaching purposes: 

• You must obtain explicit consent from the student 

• Remove all identifying information (anonymise) 

• Consult the Data Protection Officer if unsure: DPO@nottingham.ac.uk 

Q5: What about formative work that isn't anonymous? 

The same principles apply: 

• Download only when needed 

• Store securely on University devices 

• Delete promptly when no longer needed 

• Formative work should be deleted after feedback is provided and discussed with the student 

Q6: I mark on my personal tablet/device. What should I do? 

Preferred approach: Use a University-provided device or Remote Desktop access to your University workstation. 

If you must use a personal device: 

• Ensure full disk encryption is enabled 

• Use a strong password/PIN 

• Be especially diligent about deleting files immediately after use 

• Consider whether you need access to personal data or if anonymous marking would be appropriate 

• Contact IT Service Desk for advice on securing personal devices: itservicedesk@nottingham.ac.uk 

Q7: How do I know if my University device is encrypted? 

All University-managed devices issued since 2018 have automatic full-disk encryption enabled. If you're unsure about your device: 

• Contact IT Service Desk: itservicedesk@nottingham.ac.uk 

• They can verify your device's encryption status 

Q8: What about files in OneDrive or University network drives? 

Files stored in University OneDrive or network drives (H: drive, shared drives) are: 

• Automatically backed up 

• Subject to appropriate security controls 

• Acceptable locations for working files during marking 

However: 

• Still follow retention principles - delete when no longer needed 

• The primary copy should remain in Moodle 

• OneDrive is not a long-term archive for student submissions 

Q9: Can I email student submissions to myself or colleagues? 

Avoid this. If you need to share a submission: 

• Share the Moodle link rather than the file itself 

• If file sharing is absolutely necessary (e.g., for misconduct investigation), use secure University email and delete email copies after the issue is resolved 

• Never email submissions to personal email accounts 

Q10: What about backups? Do I need to delete those too? 

If you use: 

• University OneDrive: Files deleted from OneDrive go to the recycle bin for 30 days then are permanently deleted 

• Local device backups (e.g., Time Machine): These will eventually overwrite, but for highly sensitive data, you may wish to force backup deletion 

• Cloud backup services (personal): Should not be used for University data 

Contact IT Service Desk if you need advice on backups: itservicedesk@nottingham.ac.uk 

Summary Checklist 

Before Marking 

• [ ] Configure anonymous marking where appropriate 

• [ ] Use a University-managed device 

• [ ] Create an organised folder structure for this assessment 

During Marking 

• [ ] Keep files organised in your designated folder 

• [ ] Avoid unnecessary re-downloads 

• [ ] Work efficiently to complete marking 

After Marking 

• [ ] Enter all marks and feedback in Moodle 

• [ ] Delete your local submission folder 

• [ ] Empty your Recycle Bin/Trash 

• [ ] Check and clear your Downloads folder 

Regular Housekeeping 

• [ ] Monthly: Review and delete completed assessments 

• [ ] End of year: Clear previous academic year submissions 

• [ ] Ongoing: Follow retention guidelines for your role 

Support and Guidance 

Data Protection Queries 

Information Compliance Team
Email: DPO@nottingham.ac.uk 

IT Security and Device Support 

IT Service Desk
Email: itservicedesk@nottingham.ac.uk
Phone: +44 (0)115 951 2000
Web: https://selfservice.nottingham.ac.uk/ 

Moodle Support 

Learning Technology Team
Web: Moodle Help Guides for staff
Contact your local eLearning support team 

Academic Misconduct 

Academic Integrity Team 
Follow internal procedures and guidance 

Related Policies and Documents 

• University of Nottingham Data Protection Policy 

• Information Security Policy 

• Mobile Device Standards 

• Data Retention Schedule 

• Subject Access Request Procedure 

• Data Breach Procedure 

• Moodle Help Guides for Staff 

Document Control 

Version History: 

Review: This guidance will be reviewed annually or when significant changes to Moodle Assignments functionality or University policy occur. 

Appendix A: Quick Reference Card 

The Five Key Rules 

1. Use anonymous marking where appropriate 

2. Use University devices with encryption 

3. Organise your files in clear folder structures 

4. Delete promptly when marking is complete