by Carlene Kyeremeh

A student sent me a photograph of a handwritten waybill. Dated November 2022, it records a unit price for printed sachet film. It also carries the names of a supplier and a customer and the given name of the person who issued it. The waybill appeared in a term paper on fiscal consolidation as evidence of a cost increase that no statistical series I have found records.

It is in my files. Not the department’s. Mine.

I describe the waybill here but do not reproduce it, identify those named, or give the figure it records. The students who wrote the paper agreed to this account. I have no record that the supplier, the customer or the person named agreed to the document’s retention or wider use, so I have minimised the identifying detail, including the price, which is the most commercially sensitive thing on the page.

I have argued elsewhere that the curriculum can help to thicken a thin documentary record. Ask each student to obtain one item of locally sourced evidence: an interview, a quoted price, a document from a firm or public office, and, over successive cohorts, a course can assemble material that no database previously held. This is no longer only my ambition. Programmes are already redesigning assessment in response to generative AI, and one attractive move is to require evidence a model cannot retrieve: a price obtained in a market, an interview conducted locally, a document held by a firm or public office. That redesign brings third-party material into course files at scale, often without a parallel decision about what should happen to it after assessment.

That is the promise. The waybill in my files is the problem that follows it.

What universities already know how to govern

Research ethics and commercial confidentiality are not routinely ignored in student work. Professionally oriented programmes have long had to decide what an organisation may disclose, who may see it and when it must be returned. For example, McMaster University’s course-based research guidance explicitly covers undergraduate, MBA and graduate courses. The University of Toronto provides both a course-based ethics route and a classroom confidentiality agreement for third-party proprietary information. In the UK, the University of Manchester’s ethics guidance asks researchers to establish first whether an activity is research training conducted as coursework, described as collecting and analysing a small amount of data to gain experience in method, or research proper. These arrangements show that collection, consent, confidentiality and use within a defined project can be governed. My argument is therefore not that universities lack such protections. It begins where a normal project would end.

The problem begins when the course ends

If material is returned, destroyed or retained only with the assessed work, its lifecycle has a clear end. But the design I am proposing depends on the evidence outliving the assignment. A document collected by one student in 2026 should be available to another cohort in 2028 or 2029, alongside prices, interviews and documents gathered in the intervening years. The course is not only assessing students. It is building a local source collection.

That changes the questions. What exactly does the university hold after the assessment period? Who is its custodian? How long may it be retained? May another cohort consult it? What fresh permission is needed if it is later used for research or publication? These procedures can help answer those questions, but not automatically. An agreement that properly confines information to one course may rule out the very reuse on which the proposed archive depends.

The evidence is not the assignment

The student’s analysis is coursework. The material used to produce it is not necessarily the same thing. A waybill may contain personal or commercially sensitive information. Interview notes are harder still: they are neither the source’s own record nor the student’s analysis, but one person’s written account of what another person said, made for an assignment and now held by a lecturer.

Where the activity is classified as teaching rather than research, this third-party material can still raise a lifecycle question: do institutional rules cover its custody, retention and reuse after the assessment for which it was collected? The Manchester distinction is instructive here. A course collection built to outlive its cohorts is not a small amount of data gathered to practise a method, but neither does it fit neatly within research as that definition intends. It is a lifecycle problem created by a particular curricular ambition.

The reuse is the point

Ghana’s Data Protection Act, 2012 (Act 843) requires personal data to be collected for a specific, explicitly defined and lawful purpose, limits retention and requires further processing to be compatible with the original purpose. Material obtained for one student’s term paper and later made available to another cohort may involve further processing. Nothing in the waybill I received establishes permission for it to become part of a standing course collection.

The Act contains provisions for historical, statistical and research uses where the relevant conditions are met. Those provisions offer a governed route, not a retrospective blank cheque. They do not turn a lecturer’s folder into an institutional archive. The underlying principle is not unique to Ghana: UK guidance likewise treats purpose, storage and research-related reuse as connected but distinct questions.

Ordinary assignment governance is adequate for ordinary assignments. The problem appears when coursework is asked to do something additional: to enlarge a locally available documentary record over time.

The archival value and the governance risk arise from the same feature. An archive that cannot be consulted next year is not an archive. A collection that can be consulted next year without the source having been told is not a defensible one.

A small institutional answer

The answer need not be a new bureaucracy. It could begin with a short institutional instrument that separates use in a student’s assessment from retention in a course source collection. Before collection begins, it should state the teaching purpose, what may be collected, who may later consult it, how long it will be kept, which unit is responsible and what choices the source has. Research use or publication should require a separate decision rather than being hidden inside the phrase ‘educational purposes’.

The remaining requirement is custody. What one lecturer can require, only an institution can keep. A named custodian, controlled access, a retention and disposal schedule, and a record of what the course has produced would convert a personal folder into an accountable institutional practice. Existing MBA, ethics and confidentiality processes provide models; the task is to extend their discipline to the intended afterlife of the evidence.

Proportionality matters. If the process becomes heavier than the assessment it supports, colleagues may stop asking students to gather local evidence. But a department unable to provide a clear collection notice, a retention rule and somebody accountable for what returns should not require the fieldwork. Otherwise, institutional risk is transferred to students and to the businesses that agree to speak with them.

Readers can test this in ten minutes. Take your own institution’s course-based ethics route or classroom confidentiality agreement and look for two things: whether either says anything about third-party material after the assessment period, and who is named as responsible for it. If neither appears, ask where else the institution governs the evidence after the assignment ends. If there is no answer, the arrangements may govern the assignment without governing its evidentiary afterlife.

Before we ask for more

The curriculum can enlarge the archive. The qualification is that the archival ambition creates an additional governance obligation. The question is not only whether the evidence was collected ethically and kept confidentially. It is whether its intended custody, retention and reuse were made explicit before collection began.

I have a waybill in my files and no good institutional answer to those questions. That is not an argument against asking students to go and find out. It is an argument for deciding what we will do with what comes back, before we ask them to go.

Dr Carlene Kyeremeh is Associate Professor and Vice President, University Advancement, Recruitment and Research at All Nations University, Koforidua, Ghana. Her research addresses curriculum decolonisation, higher education policy in Africa and the Caribbean, and the political economy of educational technology.This post develops a governance question raised in Issues 14 and 15 of The Decolonized Curriculum, her LinkedIn newsletter.