Board Case Study · Education (EdTech)

The Eyes on the Exam

The AI proctoring tool flagged students for suspicious behavior, and flagged disabled students, students of color, and noisy-home students far more often. Remote exams drive enrollment.

The situation

An education company providing remote learning deployed an AI proctoring tool that monitors students through webcam and microphone, flagging "suspicious" behavior during exams. Investigation shows the system disproportionately flags disabled students, students of color, and those in noisy or shared home environments.

Flagged students face academic-integrity proceedings on the basis of a model's judgment. The tool collects biometric data on minors, raising privacy-law exposure (BIPA-style statutes, FERPA, student-data laws). Remote exams are core to the enrollment and accreditation model.

The board must weigh integrity and scalability against discrimination, surveillance of children, biometric-privacy liability, and the institution's duty of care to its students.

“We're flagging the kid with a learning disability and the kid in a loud apartment as cheaters. Is this integrity, or are we surveilling children?”

Chair, Academic & Ethics Committee

The decision on the table

  • Address discrimination and disparate flagging in AI proctoring and its consequences for students.
  • Resolve biometric-privacy and student-data exposure for monitoring minors.
  • Reconcile exam integrity and scale with the duty of care to students.

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