Respondus Monitor Privacy Policy Supplement

Last Updated: September 12, 2025
Effective Date: October 12, 2025

Respondus Monitor is a companion product to LockDown Browser that enables Students to record themselves with a webcam and microphone during an online exam. The recordings are Processed to identify event flags to assist an Instructor’s subsequent review. This Respondus Monitor Privacy Policy Supplement provides details about how Respondus Monitor Processes Personal Information about Students. It is part of and incorporated into the LockDown Browser Privacy Policy Supplement and the Privacy Policy. You should read them all carefully.

This Respondus Monitor Privacy Policy Supplement specifically addresses information Processed through Respondus Monitor about Students. It does not apply to other Respondus Services. If you are an Administrator, please see our Privacy Policy to better understand how we Process your Personal Information.

For simplicity, terms used here have the same definitions as in our Privacy Policy unless otherwise noted below.

What Using Respondus Monitor Means to You

Respondus Monitor is an automated proctoring system that builds on LockDown Browser. You can learn more about LockDown Browser from the LockDown Browser Privacy Policy Supplement. Respondus Monitor is accessed from within a learning or assessment platform (“Learning System”) such as a learning management system (LMS) or publisher learning system and must be used in conjunction with LockDown Browser. Respondus Monitor Processes information strictly on behalf of and in accordance with the written instructions of our end customers, consisting primarily of Institutions. Respondus acts as a data processor on the behalf of our customers. Our customers agree not to use Respondus Monitor in any way that conflicts with or violates any applicable law.

In our standard use case, our customer is an Institution whose Students, Instructors and Administrators access Respondus Monitor from within one of our Learning System integrations. In these instances, Respondus directly integrates Respondus Monitor with a Learning System, typically through an API. In other instances, our customer is a Learning System technology provider who also performs the role of the Institution for purposes herein.

The Institution's Instructors use Respondus Monitor to proctor a particular online exam, select exam-specific settings for Respondus Monitor, review proctoring results from Respondus Monitor and make or recommend decisions about whether an exam violation has occurred. Administrators are responsible for the Institution’s license of Respondus Monitor, the integration of Respondus Monitor with other systems used by the Institution and the selection of Institution-wide settings for Respondus Monitor.

Respondus Monitor uses webcam videos, screen recordings, and other data from the computing device and online exam to analyze a Student’s exam session. The recordings and other information from the exam session are processed automatically and summary information is provided to the Instructor.

Respondus Monitor’s primary purposes are to collect webcam and screen recording data from a Student’s exam session and to generate “event flags” from data to assist with an Instructor’s review of the exam session and “alerts” that guide or warn Students of certain situations during an exam session. Computer vision technology is used to detect conditions and objects, such as faces, lighting conditions, and handheld devices, in order to determine events, such as whether the Student remained in the video frame or if multiple people appear in the video frame. When creating an exam in a Learning System that will be delivered with LockDown Browser, an Instructor may enable Respondus Monitor to proctor the exam. The Instructor may then select exam-specific settings that determine what is required from a Student during an exam, such as whether to request a Student photo or photo ID. We provide extensive support, training, tool-tips and on-screen information to assist Instructors in customizing the configurations that control exam-specific Respondus Monitor settings. Depending on settings selected by the Instructor, the system can also detect if the Student is leaning out of the video frame or turned away from their computer screen and notify Students through alerts during the exam if the Student’s face cannot be detected in the webcam video. Respondus Monitor only retains an event flag to alert the Instructor to such occurrences. The summary information that is provided to the Instructor includes an overall review priority value for an exam session that helps the Instructor determine whether exam violations have occurred. If an Instructor determines that an exam violation may have occurred, the Instructor may provide information about the exam session, including a downloaded copy of the webcam video and screen recording, to other Administrators as determined by the Institution and Instructor.

One piece of summary information that may be provided to the Instructor is whether the person who started the exam differs from the person currently in the video during the exam. To determine this, Respondus Monitor creates a template of the facial features of the person who appears at the start of the exam and compares it to any person in the video during the exam. The templates are not used to identify an individual, but rather, are used to confirm that the person first present in the test session remains the same throughout the session. No identifying information about a person is linked to the template. Respondus cannot and will not link a template to any individual. The templates only exist in temporary memory on the Student’s computer and are automatically cleared from the computer by Respondus Monitor immediately after exam completion. However, under some laws, these temporary facial templates may be considered biometric information. Respondus provides the option for an Institution’s Administrator to disable this facial template feature.

Respondus Monitor uses machine learning for development of its computer vision technology and for the specific task of assisting with the analysis of video data. The computer vision in Respondus Monitor exclusively generates event flags and alerts and does not make any determinations, automated decisions, or recommendations. Institutions, acting through Instructors and other Administrators, are solely responsible for interpretation and decision-making of how to respond to event flags generated with computer vision.

Respondus Monitor does not mimic human problem-solving. It also does not use any large-language models (LLMs). However, some laws may treat the use of computer vision and development of computer vision using machine learning as artificial intelligence or “profiling”. We provide more information about our use of this technology below.

Institutions work together with Respondus to help ensure Students’ privacy and to comply with applicable laws and regulations as to any Personal Information Processed by Respondus Monitor. If an Institution uses Respondus Monitor for online exams, Students may be able to choose whether to participate or not. Each Institution determines how Students may exercise this choice, and Students must contact their Instructor and/or Institution for more information about exercising their choice whether to participate or not.

Respondus Monitor and Automatic Processing

As described above, computer vision technology is used to generate in-exam “alerts” that guide or warn Students of certain situations, and to produce “event flags” to be reviewed by the Instructor after an exam.

Computer vision based event flags are described above at a high level. However, many of the event flags that are created by Respondus Monitor do not involve machine learning and are simply indications of an event occurring or an exam milestone reached (e.g. internet interruption, webcam was disconnected, a question was answered, etc.).

The main in-exam alerts for Students created with computer vision are to let a Student know when their face cannot be detected, to detect very poor lighting environments even if face detection is achieved, and to detect situations where a camera adjustment is recommended (e.g., the webcam needs to be tilted downward because the bottom of the face is being cropped).

To better understand Respondus Monitor’s commitment to ensuring its algorithms are systematically tested for fairness, please review Algorithm Fairness and Respondus Monitor Proctoring: A study using Casual Conversations.

More Information Regarding the Personal Information Processed by Respondus Monitor

There are some special circumstances for the Processing of some Personal Information. Instructors may seek to verify a Student’s identity through a photo ID. The type of photo ID to be used (e.g., government-issued, Institution-issued, etc.) is based on the instructions set up by the Instructor or Administrator. This requires Students to show a photo ID to the webcam at the outset of an exam session, from which a photo will be taken. The photo image is transmitted to the Respondus Monitor server, stored there, and made available to the Instructor through the Learning System when reviewing the Student’s exam session. Respondus does no further Processing on this photo ID.

Using Respondus Monitor’s Photo on File feature, an Administrator may also choose to upload Student photos from Institution records to Respondus Monitor, which in rare cases may include an image of a Student’s ID card. As with the photo ID above, Respondus does no further Processing on these photos or photo IDs.

Respondus Monitor uses APIs from the Learning System to display other Personal Information, such as grades, within the Respondus Monitor application. This information is obtained in real-time from the Learning System using APIs and is not otherwise Processed or stored after the Instructor’s review of the exam session using Respondus Monitor.

Respondus Monitor does not require Students to create an account in Respondus Monitor since the Learning System APIs include "single sign-on" capabilities for authentication purposes. The APIs pass the Learning System unique identifier, first name, and last name to the Respondus Monitor server where they are stored.

Some additional Personal Information Processed by Respondus Monitor is provided to Instructors through the Learning System. The original recordings and other Personal Information Processed by Respondus Monitor may be evaluated by the Institution, including Instructors and other Administrators, to review, assess, and analyze Student performance and conduct for the purpose of improving educational processes for Students, including investigating conduct violations, among other reasons (please review the relevant Institution’s privacy policies for more information about how it uses Student information). Respondus personnel do not review or analyze the recordings except as may be required to resolve technical problems, improve system performance, improve the product and create feature enhancements, modify Respondus Monitor, investigate violations of the Terms of Use, or as may be directed by an Institution, law enforcement or other legal authority.

When a Student uses the Help Center within Respondus Monitor, the Student may connect with customer support through an online chat service. This service collects the Student’s name to engage with the Student, email address to provide a transcript of the chat if requested by the Student, and the IP address for security purposes. Students’ chats through the Help Center are recorded and shared with our customer support service provider.

Personal Information We Collect about Students

Below we provide the categories and specific pieces of Personal Information Processed about Students, the categories of sources from which Personal Information is collected, the business or commercial purposes for collecting and using each category of Personal Information, and the categories of third parties to whom that Personal Information was disclosed in the last 12 months. Please note that some types of Personal Information are duplicated among categories.

Student Information Generally

This section describes the information that Respondus Monitor Processes generally.

Categories and Specific Pieces of Personal Information Processed about Students

  • Identifiers, including name and Learning System unique identifier.
  • Customer Records, including name.
  • Internet and network activity information, including data about Student interactions with Respondus Monitor.
  • Sensory data, including video and audio recordings and photos.
  • Education information, including course identification number, course name, and grade.
  • Sensitive Personal Information, including facial templates.

Categories of Sources of Students’ Personal Information

  • The Identifiers, Customer Records, Internet and network activity information, Sensory data, and Education information that Respondus Monitor Processes generally are collected automatically from the Learning System when Students use Respondus Monitor.
  • The Sensitive Personal Information that Respondus Monitor Processes generally is collected directly from Students when they use Respondus Monitor.

Business or Commercial Purpose(s) for Processing Students’ Personal Information

  • The Identifiers, Customer Records, Internet and network activity information, Sensory data, Education information, and Sensitive Personal Information that Respondus Monitor Processes generally are Processed to perform services on behalf of a Student’s Institution, including to provide the Respondus Monitor Service and provide customer support, improve Respondus Monitor, conduct internal research, help ensure security and investigate potential fraud, and as may be directed by an Institution, law enforcement or other legal authority.

Categories of Recipients of Students’ Personal Information

  • The Identifiers, Customer Records, Internet and network activity information, Sensory data, and Education information that Respondus Monitor Processes generally are disclosed to a Student’s Institution and our data storage service provider.
  • The Sensitive Personal Information that Respondus Monitor Processes generally is temporarily stored on a Student’s device.

Student Photo IDs

This section describes examples of the additional information that may be printed on a Student’s photo ID and which Respondus Monitor may receive, store and provide to an Instructor when an exam requires the use of a photo ID or uses the Photo on File feature.

Categories and Specific Pieces of Personal Information Processed about Students

  • Identifiers, which may include address, passport number, and driver’s license or state identification card number.
  • Customer Records, which may include signature, address, passport number, and driver’s license or state identification card number.
  • Protected Demographic Information, which may include sex and national origin.
  • Education information, including student identification number.
  • Sensitive Personal Information, which may include passport number and driver’s license or state identification card number.

Categories of Sources of Students’ Personal Information

  • The Identifiers, Customer Records, Protected Demographic Information, Education information, and Sensitive Personal Information that Respondus Monitor Processes when an Instructor requires the use of a photo ID are collected directly from a Student. When an Instructor uses the Photo on File feature, the Personal Information within these categories are uploaded by an Administrator.

Business or Commercial Purpose(s) for Processing Students’ Personal Information

  • The Identifiers, Customer Records, Protected Demographic Information, Education information, and Sensitive Personal Information that Respondus Monitor Processes under these circumstances are to perform services on behalf of the Institution, including to provide the Respondus Monitor Service and provide customer support, improve Respondus Monitor, conduct internal research, help ensure security and investigate potential fraud, and as may be directed by the Institution, law enforcement or other legal authority.

Categories of Recipients of Students’ Personal Information

  • The Identifiers, Customer Records, Protected Demographic Information, Education information, and Sensitive Personal Information that Respondus Monitor Processes when an Instructor requires the use of a photo ID are disclosed to the Institution, the Instructor, and our data storage service provider.

Respondus Monitor Help Center

This section describes the additional Personal Information Processed about Students when they use the Help Center within Respondus Monitor.

Categories and Specific Pieces of Personal Information Processed about Students

  • Identifiers, including IP address, and may include name and email address.
  • Customer records, which may include name.

Categories of Sources of Students’ Personal Information

  • The Identifiers that Respondus Monitor Processes are collected automatically from Students when they use the Help Center and directly from Students when they chat with customer support representatives and request a copy of their transcript.

Business or Commercial Purpose(s) for Processing Students’ Personal Information

  • The Identifiers are Processed by Respondus Monitor to provide the Help Center feature of Respondus Monitor, to answer Students’ questions, to provide customer service, and to help ensure security and investigate potential fraud.
  • The Customer records are Processed by Respondus Monitor to provide the Help Center feature of Respondus Monitor, to answer Students’ questions, and to provide customer service.

Categories of Recipients of Students’ Personal Information

  • The Identifiers and Customer records that Respondus Monitor Processes when a Student uses the Help Center are disclosed to customer support service providers.

Data Retention

As described in the Privacy Policy, generally, when a Student’s information is collected in order to use Respondus Monitor, the Institution has control of the retention and deletion of that information, and the Institution’s data retention policies and practices apply. However, as described above, a Student’s facial templates only exist in temporary memory on the Student’s computer and are cleared from the computer by Respondus Monitor immediately after exam completion.

When a Student’s information is collected in order to use the Help Center feature of Respondus Monitor, that data is retained for no longer than one year.

Contact Us

If you have any questions or concerns about this Respondus Monitor Privacy Policy Supplement, you may contact us through our Privacy Contact.