Background
Recently the University’s Blackboard instance has moved from being a locally hosted service to being a Cloud service hosted by Blackboard. While Blackboard was a self-hosted service there was theoretically no limit to how much storage space it could use to run. As such there was no urgent need to consider a data retention policy for Blackboard’s courses and content. During the transition of the Blackboard service to the cloud, all legacy courses with content were also transferred over, whether the data was needed or not. The amount of potentially unnecessary cloud storage will continue to grow unless someone were to manually delete it.
Problem
With the migration process around 15 years’ worth of courses/modules and content data were transferred from the University’s self-hosted Blackboard site over to the Blackboard cloud service. This includes a vast amount of resource that is unused and potentially unneeded for any teaching/reference purposes, on courses set to be unavailable for even students to see.
In addition, the lack of a data retention policy raises GDPR concerns in relation to former students’ data that remains intact from areas such as discussion boards, forum/blog posts or other stored course content. Some of the information might be considered private and sensitive to former students who might assume such data would have been deleted when they left the University. The same also applies to some staff who have left the University and assume the same.
This is creating a knock-on effect to our current cloud data plan with Blackboard, as it limits us to 7.16TB of total storage. The University has now gone beyond this storage limit having used 7.18TB of data already.
Data storage graph from Blackboard:
Proposal
Data retention policy
Blackboard needs a data retention policy; it is proposed that a retention policy for Blackboard should be created/applied to all individually Banner created courses/modules (e.g. BIOL1001-10362-04-05) and all data/content that is stored on them. Included in this data will be all Blackboard tests and assignments, including Turnitin assignments. However for Turnitin, students’ work will be kept in the central Turnitin plagiarism repository as normal.
It should be the case that Blackboard courses should be kept for no more than five years if there are no active students on them, and so long as there is no specific teaching requirement to keep the course. Any course that fails to meet the specified criterion will have its user access disabled, then after a set amount of time it will be deleted from Blackboard along with any stored course backups.
A nonactive student is defined as a student who no longer has an active account or has an account moved to alumni status. Students with disabled/suspended accounts will still be counted as being active on the course, meaning the course would not meet the criteria for being disabled then deleted.
Therefore, a course will be considered for being disabled if it meets the following criteria:
- The course is over 5 years old.
- The course has been created by Banner.
- The course has no active students.
- No academic has said it should be kept.
| Active students | No active students | |
| Banner course newer than 5 years old | Keep | Keep |
| Banner course older than 5 years old | Keep | Delete |
| Arbitrary course | Keep | Keep |
Part of the policy will first allow module leaders the right to exempt the course from the data retention policy for a full academic year. After a set period if no action has been taken by module leaders, it will then roll onto the course instructors the option to exempt a course. This would allow course owners to reorganise content elsewhere should they still need it. Once the academic year has passed the course would then be again subject to the data retention policy.
This policy should be applied to Banner provisioned Blackboard courses as soon as possible. This proposal does not discuss arbitrary Blackboard courses (those provisioned by ServiceLine request rather than from Banner). In future we may update this policy to include arbitrary Blackboard courses as well. But we have no plans to do this at present.
Policy implementation
The retention policy should be enacted by an automated solution to retire identified courses. Before proceeding, a Blackboard system report should be created to identify how many courses will be subject to this data retention policy. The report data should then be used to inform faculty staff of the proposed changes and negotiate a sensible date for automatic file deletion to always take place on.
A new automated service will first check courses against the retention criteria and make a list. It will then send an email to the module leaders of the course informing them of the upcoming deletion of a Blackboard course, at a pre-determined date. The email will also allow staff to exempt a course from being deleted for another year, should they deem it necessary to keep it.
After a 90 day period for module leaders to decide upon what to do with the courses, the system will then go on to email the course instructors of any courses that were not previously selected as being kept by the module leaders. The course instructors will then be given an opportunity to keep any courses as well.
Should neither any module leaders nor course instructors wish to keep a course, the service will automatically disable the course after 28 days. The course will be kept in a disabled state for 365 days, in this state it would be possible to request the course is reactivated again. However, if not after the end of the 365 day disablement period, the course and all its related data will be deleted. It is suggested for the initial rollout of this policy the wait for deletion period might be reduced to 90 days from 365 days.
Finally, a rigorous and thorough comms should be in place to inform all staff about the changes to old courses data.
The retention policy should reduce clutter in blackboard making it easier to navigate and reduce the amount of storage needed for the Universities Blackboard service. In turn it will help keep maintenance costs down, whilst allowing future room for storage capacity should usage of Blackboard continue to increase.
Approval
This policy was written by Patrick McSweeny and Louis Pliskin (Education Application Support, iSolutions) on 06/05/2021.
This policy approved in 2021 by Legal Services, the Blackboard Business Owner, Deputy Heads of School and Student Services.
Feedback
If you would like to provide any feedback on the proposed policy, then you can do so on the following MS Form.