2.1 Data Subject Rights and Algorithmic Transparency in Educational Profiling
The deployment of automated learning analytics within public higher education institutions creates critical tensions between institutional monitoring and European privacy mandates. As the General Data Protection Regulation establishes comprehensive protections across the European Union, its regulatory framework strictly governs any processing of student data, regardless of where analytical platforms or processing entities reside (The General Data Protection Regulation (GDPR): A Landmark in Privacy Law, 2025). When applied to educational telemetry, predictive models, and behavioral evaluation, universities operate as data controllers bound by structural duties that directly constrain pervasive surveillance mechanisms. In public higher education, analytical profiling frequently impinges upon student autonomy and networked privacy, demanding heightened scrutiny of the lawful bases utilized for automated tracking (General Data Protection Regulation (GDPR), 2021). Although institutions seek actionable metrics to enhance academic retention, data processing mechanisms must align with core principles such as transparency, purpose limitation, and data subject rights. The asymmetric relationship between students and university administrations mirrors structural workplace imbalances, wherein genuine, uncoerced consent remains difficult to obtain, thereby compelling institutions to rely on public task justifications while upholding strict data minimization (General Data Protection Regulation (GDPR), 2021). Furthermore, the broader enforcement landscape demonstrates that institutional controllers must systematically implement foundational safeguards, including Data Protection Impact Assessments and Privacy by Design, to mitigate regulatory exposure and protect fundamental rights (The EU General Data Protection Regulation (GDPR): Five Years After and the Future of Data Privacy Protection in Review, 2023). Consequently, lawful educational analytics necessitates embedding algorithmic transparency directly into computational design.