• Central storage location for media
• Purposes of media content
• Retention periods based on the Education and Examination Regulations (EER)
• Automated cleanup actions
• Attachment: Retention of student-produced assessment work and related assignments, assessment models, and signature lists containing participant names.

Kaltura is an interactive media platform for students and staff that enables streaming of media (video & audio) and provides storage for this media. Within Saxion, the video platform serves as the central location for sharing video and audio content, and we apply the following content guidelines:

• Content has one standard storage location

• Content is classified based on confidentiality

• Content has a content owner who holds final responsibility

• Content is provided with accurate and sufficient metadata

• Content has an end date and is deleted once this end date is reached

Media content from students:

1. Submitted as part of an assignment in the learning environment, which may include graduation work.
2. Posted in a course within the learning environment (e.g., discussion forum).
3. Uploaded under the student’s own account in Kaltura and shared outside the learning environment by sharing an unlisted link to video.saxion.nl, an embed code, or by granting another user view/edit/publish rights. This may also include portfolio videos.
4. Uploaded under the student’s own account in Kaltura but never shared.

Media content from staff:

1. Posted in a course within the learning environment, such as educational content or video feedback in the grade center.
2. Uploaded under the staff member’s own account in Kaltura and shared outside the learning environment via a link to video.saxion.nl, an embed code, or by granting another user view/edit/publish rights. This may also include recordings of assessments, which are stored in a closed channel on video.saxion.nl. The content belongs to the academy and may continue to be used even if the staff member leaves the organization.
3. Uploaded under the staff member’s own account in Kaltura but never shared.

According to Saxion’s EER retention periods (see appendix), all media content is retained for 7 years after assessment. This decision was made because it is not automatically visible in the learning environment whether a submitted assignment qualifies as graduation work.

All media content that was not submitted as part of an assignment falls under the responsibility of the media owner. This means the media may be deleted earlier by the respective owner. Users are advised to apply GDPR guidelines when handling media.

For media content that has not been viewed for 2 years, the original source files are cleaned up, while the converted playable resolutions are retained so that the content remains playable for the remaining 5 years.

EER Retention Rules:

1. For assessment work created by a student on any date during an academic year (other than graduation work), the following must be retained for at least 2 years after assessment: the student’s product, the assessment, and any second assessment.
2. For assessment work created by a student on any date during an academic year (other than graduation work), the following must be retained for at least 7 years after assessment: the assessment protocol, the answer key, the grading criteria, the attendance list, the test/assignment, and the evaluation.
3. For graduation work created by a student on any date during an academic year, the following must be retained for at least 7 years after assessment. This includes at minimum the work plan, the graduation project, the graduation report, and the assessment.
4. For any other assessment created by a student on any date during an academic year that demonstrates the final level, the following must be retained for at least 7 years after assessment. This includes at minimum the test/assignment, the student’s product, and the assessment.

The following rules are executed daily within the video platform.

Rule 1
Applies to: Entries that have not been viewed for 730 days (2 years)
Action: Remove all flavors except HD/1080, HD/720, H264/400, and MP3 256. The source file is deleted.

Rule 2
Applies to: Entries that have not been viewed for 2555 days (7 years)
Action: Remove all flavors except HD/720, H264/400, and MP3 256. Move the entry to the archive (unpublish and change owner) and notify the user that the entry has been archived.

Rule 3
Applies to: Entries that have not been viewed for 2615 days (7 years + 60 days) and are in the “Archive” category
Action: Delete the entry

Notification to content owner

Email Subject:

Your media entry will be deleted in 60 days

Email Body:

E-mail Body:

--- Read English below ---

Beste media entry eigenaar,

Deze e-mail is om je te informeren dat we jouw kaltura media entry {entry naam} {entry ID} hebben gearchiveerd. De entry is de afgelopen 7 jaar niet bekeken en zal volgens ons dataretentiebeleid over 60 dagen worden verwijderd. Mocht je nog vragen hebben, neem dan contact op met [email protected].

Met vriendelijke groet,
Functioneel beheer
Kaltura

------------------------------

Dear media entry owner,

This email is to notify you that we have archived your Kaltura Media Entry {entry name} {entry ID}. The entry has not been viewed for the last 7 years and as per our data retention policy, the entry will be deleted in 60 days. In case you have any questions, please contact [email protected]

Kind regards,
System administrator
Kaltura

Rules:

1. Assessment work created by a student on any date during an academic year (other than graduation work) must be retained for at least 2 years after assessment. This includes: the student’s product, the assessment, and any second assessment (if applicable).
2. Assessment work created by a student on any date during an academic year (other than graduation work) must be retained for at least 7 years after assessment. This includes: the assessment protocol, the answer key, the cut-off score (cesuur), the attendance list, the test/assignment, and the evaluation.
3. Graduation work created by a student on any date during an academic year must be retained for at least 7 years after assessment. This includes at minimum: the work plan, the graduation project, the graduation report, and the assessment.

Any other assessment work created by a student on any date during an academic year that demonstrates final attainment levels must be retained for at least 7 years after assessment. This includes at minimum: the assignment/test, the student’s product, and the assessment.

In principle (see article B20/M16 of the Education and Examination Regulations), all graduation work is stored in Saxion’s digital archive. This means that documents can be made available from this archive if needed.

If this is not the case, the academy itself is responsible for archiving. Saxion maintains an archive containing all graduation work. This material is not publicly accessible. Graduation work that is publicly accessible (as decided by the student, in accordance with any agreements made with the client) is placed by Saxion in a publication archive, from which it can be retrieved via the Knowledge Base.

In situations where material is required for the auditor or quality assurance system, all materials can be made available (after signing a confidentiality agreement) from Saxion’s archive.

If the academy cannot guarantee that all required materials are available in Saxion’s archive, the academy is itself responsible for retaining the materials.

Justification:

With regard to this topic, the following matters are important:

1. Legal provisions (currently limited to WHW Article 7.3 paragraph 5),
2. The ‘retention schedule’ established for higher professional education (a list of retention periods and related destruction periods),
3. The additions made to that retention schedule specifically for Saxion,
4. The general principle of keeping large volumes of documents for the shortest time possible, and
5. The general principle of having as simple a system as possible for management (in this case, retention and destruction): fixed points within the academic year.

The retention of completed work and assignments is also necessary due to the existence of appeal periods (e.g., against the result of an exam), but the periods required for this purpose are amply covered by the retention periods that are important for other reasons mentioned here.

Storage format (hardcopy and/or digital)

Digitization of test-related materials does not necessarily offer a solution to all the issues associated with managing hardcopy material. Before proceeding with the digitization of all test-related material, an academy should ask itself the following questions:

1. How much hardcopy and how much digital material is involved?
2. How much physical space and how much investment in manpower does hardcopy storage and sensible management (being able to retrieve the right material at the right time) require?
3. Given the volume of hardcopy material and the workload involved, is it worthwhile to invest in digitized storage and its management?
4. Is the quality of the digitization such that destroying the hardcopy archive is a sound decision, or would that entail unacceptable risks?

Saxion, as a foundation, is not a government institution and has only one public authority task that falls under the Archives Act, and is therefore not required to establish a substitution regulation. The only public authority task concerns the awarding of degrees. Nevertheless, as a foundation, one can still consider the legal requirements set by the National Archives for replacement or substitution. This body defines replacement or substitution as “the creation of (digital) reproductions of archival documents in accordance with legal regulations, so that these take the place of the original archival documents, which are then destroyed.”

The National Archives applies the following principles:

• Replacement must be carried out with an accurate and complete representation of the data contained in the archival documents being replaced. If this is done correctly, the reproductions in principle have the same legal force and evidentiary value as the original archival documents.
• The original, replaced archival documents must be destroyed. As long as the originals have not been destroyed, no actual replacement has occurred. Only upon the destruction of the original does its legal status automatically transfer to the reproduction.
• The reproductions become the archival documents in the sense of the Archives Act 1995. For example, they must remain accessible for as long as determined by the relevant retention schedule.

Additionally, the following aspects are of crucial importance:

• Scope of the replacement process.
• Configuration of the equipment used for replacement, the chosen settings, and any peripheral devices.
• Software and the chosen settings (if applicable).
• Criteria for choosing reproduction in color, grayscale, or black and white.
• Method by which the reproduction is produced.
• Design of the quality control for accurate and complete representation, and the correction of any errors.
• Process for destroying the replaced archival documents.

Any questions?

Questions regarding archiving and retention periods can best be directed to Saxion Content Services of the Saxion Library, preferably by using the email address: [email protected]