Policy on Audio or Video Recording for Educational Purposes
This policy was approved by the Senate on 9 July 2025 (S/24/70).
Our Audio-Visual Recording Policy is designed to support a flexible, inclusive, and empowering learning experience for all students - whether they study online or in-person on campus. Recognising that learning is not confined to scheduled sessions or traditional environments, this policy supports students' ability to engage with academic content in ways that align with their individual needs, preferences, and circumstances.
By promoting independence of place, space, and time, the policy aims to:
- Provide equitable access to academic expertise, accommodating a wide range of learning requirements
- Enable flexible engagement with course material, supporting students from diverse backgrounds
- Enhance learning, reflection, and revision through access to resources in multiple formats
In doing so, we affirm our commitment to creating an inclusive educational environment that values choice, accessibility, and student success across all modes of study.
Introduction
1. This Policy deals with the recording by the University, its students or others of activities with an educational purpose (“educational activities”) [educational purpose means any purpose related to taught student education at the University, and may include research activity or the repurposing of research activity as appropriate. This policy does not however cover the recordings made for purely research or archival purposes]. All types of audio or video recordings are covered in all media. Unless indicated otherwise "recordings" referred to under this Policy are to both audio ad video recordings.
2. Recording by the University of educational activities is an important part of the University’s strategy to enhance the quality of the student experience (see https://spotlight.leeds.ac.uk/strategy), and the University sees it increasingly as part of mainstream academic work. .
3. The University cannot guarantee the availability of recordings for every educational activity. However, recordings are an important part of the University’s delivery of its educational objectives in the public good. The use of recordings is a well-established practice at many Universities and something that students expect as part of a 21st century University offering. Recordings are often invaluable to those students whose circumstances, including disabled students, mean they cannot otherwise fully benefit from the educational activity. Recordings support the Inclusive Teaching Practice baselines (see: https://inclusiveteaching.leeds.ac.uk/), and help to ensure that the teaching requirements of our diverse student population are met.
4. The University recognises that sometimes members of staff or students may have legitimate reasons for not wishing to be recorded, especially by video recording. These reasons will be considered and where appropriate, respected. This policy – which aims to promote responsible recording within a practical, legal and ethical framework – establishes a right to opt out of recording, with the agreement of the Head of School/Service.
5. Recordings by the University may be used for any purpose supporting the University’s educational objectives. This may include making recordings available internally in any media or platform. Subject to the explicit consent of the member of staff concerned, it may also include making recordings available externally in any media or platform and may also involve granting rights to other third parties and generating income.
6. Recordings will not be used as a performance management tool.
7. Recordings may be used to respond to complaints by staff or students, or be provided where requested by external regulatory bodies for example the OfS or the Office of the Independent Adjudicator.
8. This policy applies to the recording of all educational activities using any system. Currently, most audio and video recordings are made using the institutional media-enhanced learning system, but recordings of educational activities using other systems including virtual classroom and meeting platforms are covered by this policy. [Updates to information about system functionality referenced in this policy will be reviewed annually, but due to rapid changes in system functionality (sometimes outside of the University’s control) it may become outdated before review]
Deciding when to record
9. It is to be assumed that all educational activities may be recorded by the University, but recording by students and others is not permitted except as provided in paragraph 20 below.
10. The University's general position is that where possible all appropriate educational activities will be recorded, but the decision as to when the University shall record, which activity is to be recorded, how to record [for example, recording audio and screen capture as a minimum or video, audio and screen capture if preferred] and how best to use those recordings [it is assumed recordings will be made available to students via the VLE. Explicit consent from the member of staff concerned will be required for external publication], is ultimately the responsibility of the Head of School/Service [throughout this Policy the Head of School/Service may nominate individuals to act on their behalf] where the educational activity is primarily based. It is recommended that a decision by a Head of School is made after consideration by the School's Taught Student Education Committee/School's Research and Innovation Committee (as appropriate).
University Recording
Agreement
11. Staff and students are required to familiarise themselves with this policy, and will be deemed to have read and understood it. Any questions or concerns should be raised with the contacts referred to at the end of this Policy at the earliest opportunity.
12. Unless the University’s Data Protection Officer has explicitly agreed otherwise [under GDPR there can be occasions where recordings of special category data do not need consent, but these should be exceptional and will require close scrutiny and additional actions to protect the privacy of those concerned] no recordings of special category personal data will be permitted without the explicit (opt-in) consent of those being recorded. Educational activities which may potentially involve recording special category data should consider use of the live editing facilities, or request an exemption (see paragraph 17). ‘Special categories” of personal data’ are defined under Article 9 of the General Data Protection Regulation ("GDPR"). Special categories of personal data consist of “personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”. See Annex for model express consent form (doc 1).
13. Recordings will only be edited, published or shared by the content owner in the system, unless that individual gives written permission for someone else to edit, publish or share recordings on their behalf.
Editing
14. Recordings shall include an editing function. If staff or students at any stage wish to have a recording edited, they must request a change from the person responsible for the activity being recorded. This request must specify which material they wish to have changed and why they want the change. A request must be made immediately after the recording otherwise it is unlikely to be considered. In cases of disagreement, the matter shall be resolved by the Head of School/Services where the recorded activity is primarily based. When using the institutional media-enhanced learning system, staff are advised to make use of the pause button provided in all rooms with recording facilities, to conduct live editing of recordings. Live editing should be used carefully so as not undermine the general principle to have activities recorded as much as possible.
Notice
15. The University will inform students and staff about the recording of teaching activities and the existence of this Policy. Information will be given as part of the student contract and the student and staff privacy notices.
16. In addition to the above there shall be a notice in all rooms where recordings are to be made. These notices will remind staff and students that they may be recorded and who they should contact if they wish to opt out of or edit a recording. See Annex (doc 2).
Exceptions
17. The University recognises that recording is not appropriate for all teaching and learning activities; for this reason, subject to the caveats in paragraph 20, staff, can with the agreement of their Head of School or their nominee, be exempted from having their teaching activities recorded where they can demonstrate a sound pedagogical, legal or other justifiable reason based on their particular situation.
18. A request by a member of staff or student for an exemption from recording must be sent in writing to the relevant Director for Student Education and the relevant Head of School. The request should explain the reasons for the desired exemption from the general practice of recording. The decision on whether to allow opt out will rest with Head of School. Where the Head of School wishes to seek further guidance this can be obtained from the Audio Video Recording Policy Guidance for Heads of School document. Until a decision has been made by the Head of School the default position will be that the recordings will take place. Where exemptions are agreed, the member of staff concerned is responsible for informing relevant module and programme leaders.
19. When considering requests for exemption, Heads of School will in particular consider the use of editing and audio-only recording and screen capture of teaching material e.g. power point slides.
Disabled students who need a recording
20. If a disabled student has a requirement to have recordings available this will be respected, even where the member of staff to be recorded has an exemption. Unless there are exceptional circumstances and an acceptable compromise can be found, recording will take place. Sometimes as an alternative, because of the particular needs of the student, e.g. relating to format, the student shall be permitted to make their own recording e.g. through use of their own laptop or other recording device (see paragraphs 34 to 36).
21. If there is a disabled student(s) who needs access to a University recording through the institutional media-enhanced learning system, then the member of staff concerned either (a) makes the recording available to all those attending in the normal way (an inclusive approach), or (b) they have the option to specifically limit access to the recording to the disabled student(s) who need the recording.
22. If the member of staff wishes to elect (b) above then they will still need to have obtained the Head of School’s agreement not to make the recording available generally to the other students present. In addition, because the in-room media-enhanced learning system will indicate through the red light facility that the activity is being recorded, the member of staff will need to inform all present that the recording is only going to be accessible to those who have a need because of their disability. The purpose of this announcement is to avoid any confusion as to general availability of the recording.
Quality and accessibility standards
23. The University is committed to creating an inclusive learning environment that supports collective growth and knowledge generation, and we recognise the critical importance of high-quality audio-visual resources that are accessible to all students. Our approach to audio-visual recording and technology is guided by the need to guarantee a baseline of quality and inclusivity with a focus on:
a. Continuous improvement of institutional audio-visual infrastructure
b. Establishing minimum digital accessibility standards (in line with external digital accessibility standards and best practice)
c. Ensuring technological solutions support diverse learning needs
d. Providing reasonable adjustments for students with specific accessibility requirements.
The University acknowledges that technology evolves rapidly, and our policy will be regularly reviewed to reflect the most current best practices in audio-visual accessibility and educational technology
24. The University expects lecturers to view quality and accessibility of audio-visual recordings as integral part of high-quality educational practice that supports all learners. This will include:
a. Technical preparation
i. Using available technologies to support accessibility
ii. Positioning microphones to capture clear audio and carrying out all appropriate actions to ensure that input from students is captured on the recording. This could include (but should not be restricted to) the use of lapel microphones when these are available. [where a lapel microphone is provided in a teaching space, staff must make use of this equipment when talking. The use of lapel microphones enables effective voice reinforcement for students in the room, and provides high quality audio content to enable effective automatic captioning. Use of lapel microphones supports voice protection and projection and avoids the need for students to strain to hear the lecturer. Use of the lapel microphone is likely to be very important to students with disabilities that need to access the recording. In educational activities where students are asking questions, and these may not be picked up by the microphones in the room, staff are expected to repeat questions before answering, to ensure all students present have heard the question, and for the purposes of the recording. Where there is a lot of student interaction in an educational activity, staff may consider use of other digital technologies including classroom engagement tools to record interactivity]
b. Accessibility awareness
i. Understanding and implementing minimum digital accessibility standards
ii. Recognising when human-generated captions or additional support might be necessary [where a disabled student has a requirement for transcripts from educational activities, captions which do not meet the required level of accuracy should be highlighted to staff. Depending on the system, the captions will either be (i) sent for human captioning by a third-party; (ii) referred to the Disability Services for individual support for the affected student(s); (iii) produced, as required, from systems where auto-captioning is not available]
iii. Collaborating with Disability Services to ensure that specialised student needs are met.
Captioning of recordings
25. In line with regulation, all recordings All audio and video recordings will be automatically captioned within the institutional media-enhanced learning system (including scheduled recordings, desktop captures and adhoc/record now), using speech- to-text technology. Staff and students need to be aware that captions whilst helpful are not a hundred percent accurate. Students should seek advice from teaching staff where they have concerns about the accuracy of the captions. Staff can edit the captions within the institutional media-enhanced learning system prior to, or after, publication of recordings (but are not required to edit inaccuracies in captions).
26. Captions will media-enhanced learning be provided in the English language. They may also be available in multiple languages.
27. Speech-to-text technology cannot guarantee accuracy. Whilst the University is doing its best by having good technology, it cannot accept responsibility for any inaccuracies. Students should feel free to verify the content of captions with staff.
Auto-publication of recordings
28. All scheduled recordings (i.e. those recordings scheduled via the University’s timetable system) will be automatically published two working days after the recording takes place. Users will receive email notification of the intention to auto-publish and will be able to prevent auto-publication if required and permitted. Users will be able to publish recordings at any time before the auto-publication is due to take place.
Data protection
29. Recordings will often engage data protection rights because they include the “processing” of personal data where individuals can be identified. For example, a video may show faces of those attending, while audio recordings will include the voices and words of the speakers. Anything done with personal data must comply with the University’s duties under data protection law, i.e. (at present) the GDPR and the DPA 2018. It must also comply with the University’s duties as a public authority for the purposes of the Human Rights Act 1998, and in particular the right to privacy under Article 8(1) ECHR.
30. The University has carefully considered the data protection rights of staff and students in relation to this Policy. The University’s position is that the processing of personal data governed by this policy on recording is justified because it is reasonably necessary for the effective performance of the University’s public interests tasks (Article 6(1)(e) GDPR) – specifically as regards the provision of educational services. Alternatively, the recording practices governed by this policy would be justified by the legitimate interests of the University (in delivering its educational services effectively) and students (in receiving an optimum university education). Where the recording is a legal requirement, particularly where required to fulfil the University’s legal responsibilities to a disabled student, the University has grounds to require the recording in accordance with Article 6 (1) (c) of GDPR. The University has concluded that its approach to recordings is balanced and proportionate.
31. Where the recording is to include special category data then in accordance with paragraph 12 above the explicit consent of those concerned will be required unless the University’s Data Protection Officer has agreed that other grounds may be relied upon to justify that processing of special category data based on the particular circumstances of that case.
Student recordings
32. Unless students are specifically required by the University under a programme of study or research to make recordings, prior authorisation by the member of University staff managing that activity will be required. If the member of staff does not give consent then the student may ask the Head of School to review the decision that has been made. The Head of School may permit the student to proceed to record where they believe it is reasonable to do so under the circumstances of that case. The Head of School shall be mindful of the possibility of limiting access to that student as detailed under 18 above.
33. Only in exceptional circumstances will authorisation for recording by students be given. An example of an exceptional circumstance could be where a disabled student needs to make a personal recording. Where authorisation is given, this will be on condition that the recording may only be used for private study. This will not allow for further copying or sharing with other students. In cases where there is evidence of students breaching this condition, the University’s disciplinary processes will be followed.
34. Where a recording by a student is permitted all those present must be informed and have the ability to object and ask for the recording to be edited. The process for notifying and considering objections is as stated above for University recordings.
Use of Artificial Intelligence
35. The University of Leeds has defined Generative AI guidance for taught students and principles set out in this guidance will apply as appropriate. The principles set out in these guidance documents are updated on a regular basis and should be referred to as appropriate in implementing this Policy. The University acknowledges the emerging capabilities of AI-powered tools in audio-visual recording and transcription and commits to: (a) Maintaining a watching brief on technological developments in AI transcription and recording tools; and (b) Ensuring that existing recorded content will not be used for generative AI purposes without explicit consultation and consent.
36. In particular the section on ‘Copyright and ownership’ of content within the Generative AI guidance is relevant to the use of generative AI for translation/transcription of lectures, seminars, group activities etc. When using generative AI tools for translation or transcription of lectures, seminars, group activities etc. (whether online or in-person), users must adhere to the following key principles:
a. Consent: Obtain explicit permission from the Educator and all participants before using any AI tool to translate or transcribe spoken or written content [the use of free service translation and transcription tools is allowed for any self-authored content. The principles in this policy refer to spoken or written content developed by a third party (i.e. lecturer, tutor, assessor, fellow student etc.)]
b. Data Privacy: Use only translation/transcription tools provided/approved by the University that comply with GDPR regulations This means ensuring that data is not transmitted to unauthorised third parties (all University provided tools will ensure GDPR compliance). This ensures protection of the intellectual property of the original content creators
c. Accuracy: There is a recognition of the potential limitations of AI translation and transcription tools. The user will as far as possible, verify the accuracy of generated content and will only use this for their own purposes (i.e. not be shared with others)
d. Scope: These principles apply to all users, including taught students, research students, staff, and external participants in university spaces. Applies to both in-person and online environments
e. Permitted Use: Translation of self-authored or publicly available content is permitted. Translation of university-created materials requires careful consideration of Intellectual Property and consent (see also clauses 33-35 on Student recordings and 38-40 on IP).
Violation of these principles may result in action under the disciplinary procedure or academic misconduct procedure as appropriate; and in line with the Students Contract.
Intellectual Property
37. In accordance with the University’s Policy on Intellectual Property Rights in general where staff make a recording, all rights in that recording (including rights in the sounds made) will belong to the University.
38. Recordings by students will be owned by them, subject to the conditions in the University’s Policy on Intellectual Property Rights (“IP”). Where a student is to be the owner of the IP the student grants the University a free, irrevocable non-exclusive licence to allow the University to complete its commitments to the student e.g. relating to the supervision and assessment of the student’s work.
39. The University seeks to respect student and staff rights to be acknowledged as authors and performers. Otherwise, to the extent allowed under the general law, any individual interests in the recordings are waived, allowing the University to act in effect as a custodian, to maximise educational objectives in the general interest of all. The final reminder that a recording is about to commence will reconfirm the position (see doc 2 of the Annex).
Statement of Rights
40. When using recordings owned by the University students and staff should always assert the University’s rights. Please see Annex for common statement asserting ownership of copyright (doc 3).
Authorship and Identification as Performer
41. Students or staff should wherever practicable look to assert a right to be identified as an author or performer. Individuals will need to come forward at the time the recording is made and assert these rights. For guidance on when someone should be acknowledged as an author or performer see here. Please see Annex for common wording asserting authorship rights (doc 3).
Staff leaving the University
42. As with any teaching material staff leaving the University are not permitted to delete recordings in the belief that it belongs to them. Teaching material belongs to the University and is likely to be needed by other colleagues and students involved in the programme.
Downloading and Retention of recordings
43. As a default where downloading of a recording is permitted the user accessing the downloaded recording may not (i) edit the recording unless they were the person responsible for the recording; or (ii) share the recording with others; and may only use the recording for private academic study.
44. Recordings (both timetabled and non-timetabled) stored within the institutional media-enhanced learning platform will be kept for a period of seven years. Recordings that are more than three years old and have not been accessed within the last year will be archived but can still be accessed following a request to retrieve the recording. Archived recordings within the institutional media enhanced-learning platform will automatically be deleted once they are seven years old. Recordings stored elsewhere will need to be manually deleted.
Appropriate Material
45. Third party material – for example, a YouTube clip or research participant data – may be included in a recording only where it is lawful to do so and ethical requirements have been met. The University does hold licences that allow the use of some third party material, but often permission is limited to internal use only e.g. not outside of the VLE. Additional clearances for both internal and external use may be required. It must not be assumed that since the activity is educational “it will be all right”. For guidance on where further clearance may need to be sought please see here.
46. A situation may occur where a recording is challenged by rights holders or deemed unacceptable for other reasons e.g. defamatory in nature. The University may itself, or require others to, edit or remove inappropriate material.
Visitors
47. It is recognised that the position with visitors (being subject to a University recording or where the visitor wishes to make their own recording), may take some reflection and negotiation with the visitor. The arrangements should be agreed in writing (exchange of e- mail will suffice) and relevant information contained within this policy should be drawn to the attention of the visitor so that an approach can be agreed and/or any concerns discussed.
48. As a general default position visitors will retain their rights in a recording made of them or by them. However, the visitor allows the University under non-exclusive licence, the right to use the recording in the most general terms available. In particular the University may use the recording for any purpose, free of charge, in perpetuity and with the right to take legal action against any party breaching the University’s rights. Where the University is to record, the visitor should be given the Recording Notice (see paragraph 15 and 16) alongside other anticipated participants. The visitor should also be given the right to object to being recorded and to request an edit of the recording. Where the visitor is to do the recording other participants again should generally have the same rights to object to being recorded and request an edit of the recording.
Safe Keeping
49. Where a recording identifies individuals it must be stored safely and accessed only in a way compatible with the agreed purposes (and any other stated conditions) e.g. where just for use by members of a particular class a password system may be appropriate. Security measures should be commensurate with the sensitivity of data involved. For more guidance see the University’s Data Protection Code of Practice and the University’s Information Protection Policy.
APPENDIX
Further Help
General queries relating to the implementation of this policy should be sent to the Director of Digital Education and Learning Innovation (Margaret Korosec, [email protected]).
50. Specific concerns relating to intellectual property rights should be sent to [email protected].
51. Specific concerns relating to data protection and other legal issues should be sent to the University's Legal Services team (James Fearn, [email protected]) or the University’s Data Protection Officer, [email protected].
52. If any part of the University’s recording equipment is not working this should be immediately reported to the IT Service Desk (computer facilities) or Facilities Help Desk (audio video facilities).
Responsibility
53. The Pro Vice-Chancellor for Student Education and Experience and the University Secretary and Registrar shall have overall responsibility for this Policy