School, reputation rating algorithms under the lens of the privacy guarantee: our analysis

With press release of May 3, 2022the Guarantee of Personal Data has announced that he “sent a request for information toCrop News Onlus Association operating in the reputation assessment sector. According to press releases, the association has promoted Virtue 4 Students Project to test the reputation assessment developed on the basis of algorithms from the Mevaluate platform. A higher education institution would have joined the project ”.

The guarantor’s initiative seems necessary as they would be interested minor students, therefore vulnerable subjects.

On the other hand, the request is in fact not excessive at all: in addition to providing a serious description of the function of the platform algorithm, the association will also have to account for the mechanism underlying the database associated with the platform.

In other words, everything you need for make a serious impact assessment.

The privacy knots on the Mevaluate platform

From the Mevaluate Group’s website we learn that “Mevaluate Holding Ltd (Ireland) was founded in 2013. Among its members it comprises more than 20 professionals and managers as well as a software house. Holding controls the Mevaluate Regional companies and has the intellectual property rights to the computer algorithms in” The Mevaluate system “. The company’s goal is to develop the necessary infrastructure to launch Mevaluate around the world. To date, the company has achieved its goals both in terms of alliances necessary for the deployment of the service, both for software development to the sophisticated algorithm on which the assessment will be based and to the protection of intellectual property rights worldwide “.

GDPR certifications: all the benefits for the organizations that join them

Also from the institutional website, we learn that the Crop News Onlus Association “has the primary purpose of promoting ideals of justice, legality and meritocracy in a spirit of delegation and cooperation. The founding principle of the association expressed by Plato in itRepublic ” it consists in believing that the basis that enables delegation and cooperation is trust, and that this is built on the basis of the reputation of natural and legal persons, documented and verified ”.

That website of the Mevaluate Platform welcomes us with one cookie banner which only allows the acceptance of cookies as the only option; from privacy policy we learn that our data can be transferred to other European states.

The Crop News onlus Association website (also accessible via the link on the previous site) has a much more structured policy, which correctly identifies the data controller and the data processor.

But curious to learn the list of common owners:

  • Consumer Italia (Association for the Protection of Citizens’ Rights and the Environment);
  • AN S;
  • APART – Professional Association of Traceable Reputation Auditors;
  • 12,000 RAM (Reputation Audit Manager);
  • APART ordinary members, with a limited number;
  • 30,000 RATER (Reputation And Trust Expertise Representative);
  • Crop News Srl (under establishment);
  • Mevaluate Holding Ltd (Dublin – Ireland).

Conclusions

The investigation launched by the Privacy Officer into the processing of personal data seems in itself more than appropriate.

The platform, though inspired by noble ideals, can be used to record any student, almost from birth, and somehow determine their future in an inevitable way.

In other words, an archive of the proposed type aims to evaluate – by what parameters it is not currently known – the skills, attitudes, grades and perhaps even behaviors of the students concerned.

The processing of data, potentially worldwide, would make it almost impossible to delete what has been entered into the company’s database.

From what we have been able to read with an extremely superficial examination of cookie policies and privacy policies, The guarantor can only issue at least one recommendation for websites.

That is, a thorough investigation is made.

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