3.3. Institutional Governance, DPO Oversight, and Accountability Deficits
The deployment of learning analytics in French public higher education operates at the intersection of technological advancement and strict regulatory oversight. When evaluating institutional platforms through the supervisory framework established by the Commission Nationale de l'Informatique et des Libertés (CNIL), governance mechanisms reveal substantial operational friction. As established in broader organizational contexts, the General Data Protection Regulation introduces critical privacy safeguards that recalibrate analytical progression without outright prohibiting systematic data evaluation (MARBLE, 2018). In public universities, this balance becomes particularly sensitive because student profiling touches upon fundamental academic rights and administrative transparency obligations. A central structural impediment within public universities concerns the institutional role and competence of designated compliance officers. The implementation of European regulatory mandates shows marked national diversity, particularly regarding the formal certification and human resource allocation for Data Protection Officers across French supervisory practices (UUKL8163, 2021). Within public higher education institutions, the absence of standardized analytical oversight exacerbates accountability deficits. CNIL doctrines require controllers to demonstrate rigorous purpose limitation, continuous impact assessments, and strict algorithmic accountability when tracking student interactions on virtual learning environments. Consequently, higher education decision-makers cannot treat compliance as an ex-post administrative formality. Instead, institutional governance must integrate certified data protection expertise directly into software procurement, dashboard design, and pedagogical evaluation workflows. By aligning institutional data practices with national regulatory standards, French universities can harness pedagogical insights while fully maintaining the essential privacy guarantees mandated for public educational bodies.