At Miami University, in our code of Love and Honor, we demonstrate Love and Honor by supporting and caring for our fellow Miamians. We send this letter to you out of concern that the software is inconsistent with our code of Love and Honor that we uphold. 

We are writing to you out of concern with the use of Proctorio at Miami University and to address our grievances about the software's and the company's behavior. Proctorio's design invades student rights, is inherently ableist and discriminatory, and is inconsistent with peer reviewed research about memory and recollection. The company's leadership, including CEO Mike Olsen, insults and calls into question the integrity of academic rigor and of peer-reviewed research, and demonstrates a complete disregard for student privacy and for broader academic principles.

Our first concern is that it violates Miamians' right to privacy. Proctorio can be made to require a student to scan their room periodically during a test. A person’s room has a lot of information about their personal life - their calendar, posters of their favorite affiliated groups, medications, and more - and in many cases, they are not associations they want to bring up with a professor or with anyone else besides their close friends. For example, a trans student may have medications or needles in their personal space, and they may not be ready or willing to share that information with others.

Our second concern is that Proctorio is ableist and discriminatory. "Our Bodies Encoded: Algorithmic Test Proctoring in Higher Education", a peer-reviewed paper by Shea Swauger, goes into great detail about the inequalities that are perpetuated by online test proctoring. Proctorio discriminates against neurodivergent students, as it tracks a student's gaze, and flags students who look away from the screen as "suspicious" too, which negatively impacts people who have ADHD-like symptoms. As such, Proctorio is ableist by design. In addition, students with black or brown skin have been asked to shine more light on their faces, as the software had difficulty recognizing them or tracking their movements. This is tantamount to racism in software - informing Black students that they weren't considered while designing the software, and that they aren't seen as important.

Our third concern is that it is inconsistent with peer-reviewed research about memory and recollection. "Eye Movement Reinstatement and Neural Reactivation During Mental Imagery" notes that there is a correlation between the replaying of eye movements and the recollection and reconstruction of mental imagery. Proctorio flags excessive gaze shifts as suspicious, which is not proven to be a good indicator of cheating. Eye tracking for online proctoring is little more than snake oil, and is a poor indicator to tell if students are attempting to cheat. It is essential that students do not feel actively suffocated while taking an exam, and Proctorio fails this completely. 

In addition, we would like to state our concerns about the behavior of the leadership of Proctorio Inc. and their CEO, Mike Olsen (@artfulhacker on Twitter). 

First in this regard is how "The Proctorio Team" has called into question and insulted the practice of scholarship and peer-reviewed research. In their response to a blog post, "Unfeeling AI and Assessment", "Response From Proctorio", they call Shea Swauger's peer-reviewed article published in a journal an "opinion piece". This statement is slanderous and defamatory. In addition, in a tweet, Proctorio CEO Mike Olsen called Shea Swauger a "liar". (The tweet is no longer accessible, as he has set his Twitter account to private, and we are not aware of any retractions.) Making such claims is disrespectful to academia and should not be tolerated, especially from a company selling solutions to higher education institutions. (We strongly recommend reading Shea Swauger's response, "Taking Back the Narrative of Ed Tech").

Second, they exhibit a complete disregard for student privacy. Proctorio CEO Mike Olsen got involved in a personal squabble with a student on Reddit, who suggested that a Proctorio support agent went missing during an interaction about a technical issue. In retaliation, Mike Olsen publicly posted a transcript of the student's interaction with the Proctorio agent, and said "If you’re gonna lie bro... don’t do it when the company clearly has an entire transcript of your conversation,". For reference, the company agent took 10 minutes to say hello, and another 5 to tell the student to reinstall Google Chrome. This is not a good look for Proctorio, nor is it for CEO Mike Olsen. He has since apologised for this behavior, but this still shows disrespect towards and contempt of students by the CEO.

Third, Proctorio Inc. does not value academic freedom. Proctorio Inc., sued a staff member at The University of British Columbia (UBC) for posting a Proctorio instructor training video about room scans, blowing the whistle about an invasion of privacy. Proctorio Inc. calls whistleblowing a matter of "corporate privacy", while simultaneously showing no respect for the privacy of students. Scholars should be free to communicate ideas and information without fear of repercussions, yet Proctorio targets scholars with frivolous lawsuits.

Similarly to the UBC staff member, one of our own Miami students thought that Proctorio might not be up to the standard they hold themselves to. In this twitter thread (PDF), they go in-depth into what metrics Proctorio can collect, how they could collect it, and publicly outlines many details about the software. Shortly after, Proctorio permanently banned this student’s IP address from the service, essentially crippling their academic career if professors don’t allow alternate exam options. It is very alarming that a CEO of a company can directly target students for openly voicing their concerns about a platform. It is very likely that Proctorio will file legal action against this student in order to further censor public voices, similar to how they did with the UBC staff member in the form of a SLAPP suit. (A strategic lawsuit against public participation is a lawsuit intended to censor, intimidate, and silence critics by burdening them with the cost of a legal defense until they abandon their criticism or opposition.)

Proctorio, by design, invades student privacy, and espouses ableism and discrimination. Proctorio Inc. does not value the freedom of inquiry. The CEO's conduct is unprofessional and unethical. Proctorio's design as software and Proctorio Inc's conduct as a company is fundamentally inconsistent with Miami's Code of Love and Honor. At Miami, we believe strongly in personal responsibility, and in the idea that we should be held morally accountable for our decisions. We, as students of Miami University, believe Proctorio's business practices reflect poorly on our history of upholding morals and empowering minorities, and that our continued business relationship enables their bad behavior. We call for a condemnation of Proctorio, for an end to the invasion of student rights, and for an end to discrimination in the name of academic integrity. As a compromise, we suggest restructuring course exams to an open-notes model which will not require the use of such software. In addition, instructors and professors can provide alternative means of proctoring that does not require the use of Proctorio. (Notably, Proctorio’s Terms of Service requires that the university not mandate students use Proctorio, and provide alternative accommodations for any course or exam).

Many students have already voiced their concerns about Proctorio and similar platforms. We recognize that the student government cannot make or suggest change without a wide platform of supporters. This petition solidifies the support of Miami students. This is in addition to the thousands of others who have already signed petitions for their own schools. (Ex. CUNY, ANU, CSUF,)

Yours,

 Erik Johnson & Various Anonymous Contributors

 

Additional peer-reviewed research about the oculomotor complex and memory:

Eye Movements Actively Reinstate Spatiotemporal Mnemonic Content

Recurrence quantification analysis of eye movements during mental imagery

The relationship between eye movements and autobiographical recollection is mediated by individual differences in autobiographical capacity

Eye movements support behavioral pattern completion