Discussion: Reconciling Secondary Analytics with GDPR Mandates in EMI Contexts
The intersection of pedagogical digitisation and secondary data processing in English-medium instruction (EMI) exposes structural challenges within European institutional governance. As universities strategically position EMI to project internationalisation, institutional excellence, and global competitiveness (crossref-10-2139-ssrn-6004254, 2026), the continuous collection of student interaction records across digital learning platforms generates extensive repositories of behavioural metrics. However, repurposed learning analytics frequently collide with core GDPR principles, particularly purpose limitation, transparency, and data minimisation. When higher education institutions integrate blended frameworks such as flipped classroom models to foster communicative collaboration and task-based pedagogical engagement in EMI settings (crossref-10-4018-978-1-7998-2318-6-ch016, 2020), institutional learning architectures capture granular, multidimensional datasets that extend significantly beyond initial instructional needs. This operational reality introduces acute legal and ethical ambiguities when records gathered for primary course delivery are subsequently repurposed for predictive modelling, curricular benchmarking, or administrative performance tracking without explicit, informed student consent or a well-defined legal basis. To resolve this mounting regulatory tension, university leadership must reconcile innovative educational technology deployment with robust data protection impact assessments and strict governance mechanisms. Aligning secondary data analytics with statutory European requirements prevents unwarranted surveillance and privacy violations while preserving curricular flexibility. Consequently, academic institutions must establish transparent compliance frameworks that systematically delineate between legitimate pedagogical evaluation and excessive secondary profiling. By embedding continuous oversight into academic systems, universities can maintain pedagogical vitality without compromising student fundamental rights.