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2015-11-24-CH_instructor_request.txt
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2015-11-24-CH_instructor_request.txt
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From: Paul-Olivier Dehaye
To: legal@coursera.org
Subject: Access and Notice under US-CH Safe Harbor as Coursera instructor
Dear Coursera Representative,
My name is Paul-Olivier Dehaye, I am a resident of Zurich, Switzerland. I have
accounts on the Coursera website associated to the email addresses
xxxxxxxxxx@math.uzh.ch and xxxxxxxxxx@gmail.com .
In June 2014, I have offered a course on the Coursera platform called "Massive
Teaching: New Skills Required", which was meant to discuss online platforms for
Massive Open Online Courses. The course intended to cover issues of data
protection (particularly with a Swiss viewpoint), and also discuss leaked
Coursera contracts. This course was unilaterally suspended half-way through,
and my instructor account was blocked. The circumstances of those actions are
not entirely clear to me. You can see the remnants of this course at [1].
Since January 2014, Coursera has agreed to comply to the self-regulatory data
protection framework called US-CH Safe Harbor, to be enforced by the FTC [2,
where I in fact found your email address]. This framework encompasses seven
principles [3], and is meant to offer equivalent protection to the Swiss
Federal Act on Data Protection [4]. Two of those principles are Access and
Notice.
I would like to ask you for the following:
1. Under Access, I would like to get all the information associated to the
deletion and moderation of my own posts (including method used, logic, and
timing information) in my own course "Massive Teaching". I seek also to have
information whether this moderation or deletion was automated, semi-automated
or purely manual.
2. Under Access, I would like to get any email internal to Coursera associated
with that course. Since I was sole instructor, this is directly related to me,
and thus falls under the "personal data" definition included in [3].
3. Under Access, I would like to get any email associated with that course that
has been exchanged between Coursera and non-journalistic external parties (for
instance, members of its Advisory Board or employees of the University of
Zurich). Again, since I was sole instructor, this is directly related to me,
and thus falls under the "personal data" definition included in [3].
4. Under Notice, please inform me of any data that might have been collected or
computed about me. This includes any of the hundreds of A/B tests that I might
have unknowingly participated in, as an instructor on the platform, either at
the time of collection or later on. Under Notice, please also inform me of the
logic followed to decide whether to include me or not in those experiments.
This would include information about the ethical protocols followed by Coursera
to decide whether and how to run this experimentation. This request also
includes any information about the building of a "personality profile" [4],
based on my interactions with the platform.
5. Under Notice, please provide me with a listing of all the third parties that
Coursera has shared or intends to share my data with, and the conditions that
governed this transfer (a data policy, for instance). This would include
confirmation or denial of any transfer or intent to transfer my data to law
enforcement or intelligence services, confirmation or denial of any transfer or
intent to transfer my data to for-profit or nonprofit universities, and
confirmation or denial of any transfer or intent to transfer my data with
potential investors or buyers of Coursera.
It is my understanding that Coursera has 40 days to comply with this request,
which would bring us to January 4th 2016. Should you have any clarifying
question, for instance about the scope of my requests, I would be happy to
answer, but this would most likely eat into that time period. Should you fail
to fully comply with this request within that time period, I reserve the right
to use any or all possible avenues to exercise my rights.
Sincerely,
Paul-Olivier Dehaye
Zurich
[1] https://www.coursera.org/course/massiveteaching
[2] https://safeharbor.export.gov/companyinfo.aspx?id=26126 (accessed Nov 24
2015)
[3] http://export.gov/safeharbor/swiss/eg_main_018500.asp (accessed Nov 24 2015)
[4] https://www.admin.ch/opc/en/classified-compilation/19920153/index.html
(accessed Nov 24 2015)