The privacy concerns we hear most
When students, faculty and data protection officers raise privacy concerns about online proctoring, they usually come down to five questions. Our short answers are below.
- “Are you watching me without telling me?” No. Candidates are told what is captured before the exam starts, and nothing is monitored in secret. An on-screen indicator that shows when the camera, microphone or screen is being captured is planned.
- “Is AI judging my face or my behavior?” We do not infer emotion, personality or intent from a candidate’s face or voice. AI raises flags for known threats, a trained person reviews every one of them, and your institution makes the decision.
- “Can you see my files?” No. The Windows desktop agent notes that an app is open. It never reads the candidate’s documents.
- “How long do you keep the recording?” For as long as your institution’s policy says. After that, it is deleted.
- “Will my video train your AI?” No, unless your institution opts in.
You’ll find the detail behind each answer in the sections below.
What we capture at each assurance level
You choose an assurance level for each exam. The levels need different data, so a weekly quiz doesn’t collect what a licensing exam does. These are the data types:
| Data | Purpose |
|---|---|
| ID image | Confirm that the candidate shows a government or institutional ID before the exam, when your exam requires it |
| Face checks | Match the candidate’s face at the start and throughout the session, and reject photo or video replays |
| Audio | Raise unusual audio as a signal for a person to review in context |
| Video | Record the session so a reviewer can see the flagged moment |
| Screen | Record the screen so a reviewer can see what was on it at the flagged moment |
| Event logs | Record browser lock, tab and window events, extra monitors and other exam events on one timeline |
| Support records | Keep a record of help requests and technical issues during the exam |
The four levels, from the lightest watching to the closest:
- Recorded. Identity check, recording and automated flags. Your own staff review cases in the reviewer console.
- Every flag reviewed. Everything in Recorded, plus a Proctorly reviewer who looks at every automated flag and records a decision. Only reviewed cases reach you.
- Live pop-in. Everything in Every flag reviewed, plus a proctor watching a group who steps in by chat or audio when a signal fires.
- Live dedicated. A proctor watches a small group for the whole exam, with a live check-in and identity confirmation.
For practice or low-stakes tests, you can also run record-only sittings, which record the session without raising flags. Our online proctoring page has full details of each level.
What we do not capture
- No emotion, personality or “suspicion” scoring of candidates, ever.
- No reading of the candidate’s documents or files.
- No monitoring the candidate has not been told about.
Face data and identity checks
Face matching is the most sensitive part of proctoring data privacy, and many laws treat biometric data more strictly than other personal data.
We tell candidates what is captured, why, and when it will be deleted. Face checks are kept only as hashed, unchangeable signatures, and only when an institution runs repeat exams for the same students. When the contract ends, they are deleted on request.
A face match is a signal, not a verdict. If a check fails, it goes to a person and never to an automatic fail. If some of your candidates cannot use face verification, talk to us and we will plan the exam with you. Our identity verification for online exams page explains how identity checks work.
The Windows desktop agent
Some higher-stakes exams ask candidates to install a small Proctorly app on a Windows computer. The exam link tells them in advance.
The agent looks for remote-access and recording tools, screen overlays, extra or mirrored displays, USB devices, Bluetooth earphones, virtual machines, VPNs, extra browser windows, tabs and extensions, and open office apps. It notes that an app is open but never reads the candidate’s documents. Each check is a signal for review, not proof.
Proctoring data retention and deletion
Your institution decides how long proctoring data is kept, not us. You set retention for each exam policy. A quiz recording might be kept for a few weeks, while a licensing exam that could face an appeal might be kept longer. When the period ends, the data is deleted across live storage and backups. A documented deletion process is planned.
When you set a retention period, think about:
- How long your appeal and reconsideration windows stay open.
- Any record-keeping duties your regulator or accreditor sets.
- What your privacy law says about keeping data no longer than the purpose needs.
- Whether a case under review should be held until it closes.
Where data is stored
Data is hosted in the client’s geographic location by default. Institutions can also keep data in their own S3 bucket, which helps when your data protection assessment or your contract sets a location requirement.
Our main subprocessor is listed on our subprocessors page. The full, current list is in the data processing agreement, and we can send it on request.
Who can see candidate data
- Each institution’s data is kept separate from every other institution’s.
- Staff get least-privilege access, and every access is logged, our reviewers’ included.
- A tamper-evident audit trail records every view, decision and change in a case.
- A reviewer role that sees only assigned exams and cannot change marks, change your policies or impose a sanction is planned.
Hosting, access controls and penetration testing are covered on our security at Proctorly page.
AI training and your data
Candidate recordings and data are not used to train AI models unless the institution opts in. Without that opt-in, your candidates’ data is used to run and review your exams and for nothing else.
Laws we design for
We design Proctorly to support institutions’ obligations under India’s DPDP Act, GDPR, FERPA and biometric privacy laws such as Illinois BIPA. Proctorly follows our Privacy Policy.
For an explainer on what these laws ask of institutions, see is proctoring legal. If you’re in India, read our dpdp act guide for universities.
What candidates are told
Candidates are told what is captured before the exam starts. Depending on the rules your institution sets, their face, audio and screen may be recorded. The candidate guide explains that your institution decides how long recordings are kept, and that a person reviews every flag before your institution decides any outcome.
We recommend that your own candidate notice also covers why the data is needed, who will see it, how to ask questions and how to appeal a decision.
Frequently asked questions
What data does online proctoring collect?
That depends on the assurance level your institution chooses. Proctorly can capture an ID image, face checks, audio, video, screen recording, event logs and support records, and each has a stated purpose. A low-stakes recorded quiz needs less than a live dedicated licensing exam. Candidates are told what is captured before the exam starts, and nothing is monitored in secret.
How long does Proctorly keep exam recordings?
Your institution sets retention for each exam policy. When the period ends, data is deleted across live storage and backups, and a documented deletion process is planned. Face signatures are kept only when an institution runs repeat exams for the same students, and they are deleted on request when the contract ends. Ask your institution what its own retention period is.
Can the proctoring software read my files?
No. The optional Windows desktop agent checks for things like remote-access tools, overlays, extra displays, virtual machines and open office apps. It notes that an app is open and never reads your documents. In browser-based exams, the screen and the exam events your institution has chosen are recorded, and you are told what is captured before you start.
Is my exam data used to train AI?
Not unless your institution opts in. By default, candidate recordings and data are not used to train Proctorly’s AI models. Without an opt-in, your data is used to run the exam, review flags and give your institution the case record it needs for decisions and appeals.
Where is proctoring data stored?
Proctorly data is hosted in the client’s geographic location by default, and institutions can keep data in their own S3 bucket. Each institution’s data is kept separate from every other institution’s, and all staff access is logged, including our reviewers’. Our main subprocessor is listed on our subprocessors page, and the full, current list is in the data processing agreement and available on request.