Is it allowed to use student exam proctoring software that records webcam and desktop activity in EU universities without student consent?

Last updated on October 2, 2025

No, under the EU General Data Protection Regulation (GDPR) and related national laws, processing special categories of personal data and intrusive monitoring require a lawful basis and strict proportionality; universities must conduct Data Protection Impact Assessments (DPIAs), adopt minimisation measures, obtain informed consent where required, provide alternative assessment arrangements for students who object, and document legal justifications; data retention, storage location, third‑party processors and cross‑border transfers must comply with GDPR; failure to meet these standards can trigger supervisory authority fines and orders to stop processing, so institutions should publish clear policies and safeguards before deploying proctoring tools.

 

https://edpb.europa.eu/our-work-tools/our-documents/guidelines/guidelines-52020-processing-personal-data-through_en

7/12/2023

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