When you’re the source of alcohol service training for a provincial population of more than 15 million people, there’s a lot riding on your ability to provide fast, easy-to-use certification. That’s exactly the position Smart Serve Ontario (SSO) was in when they chose Integrity Advocate as their complete solution for online ID verification, participation monitoring, reviewing and support.

Recently, we sat down with SSO’s Executive Director, Richard Anderson, to talk about the organization’s evolving training requirements, and why he thinks similar alcohol and food server training organizations should consider adopting Integrity Advocate.

Big Territory, Big Challenges

To understand the challenges facing SSO, you need to understand Ontario. The province is home to more than 40% of Canada’s population, representing dozens of languages and ethnic groups spread out over 415,000 square miles. If you live in Ontario, and you sell, serve, handle or deliver alcohol, you need Smart Serve certification.  

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With such a diverse group of participants, a major challenge for Smart Serve Ontario is making sure training is accessible and easy-to-use for everyone who needs it.

Maintaining Privacy and Ease-of-Use

Smart Serve Ontario was an early adopter of online training; when they first started working with Integrity Advocate, in 2019, the organization already had a robust online training program built out. However, their proctoring solution at the time was raising some significant red flags around privacy and accessibility:

“With our previous proctoring solution, you had to download an app, which people objected to; there was also a scheduling component that was inconvenient,” said Anderson.

"With our previous proctoring solution, you had to download an app, which people objected to; there was also a scheduling component that was inconvenient,” said Anderson.

What drew them to Integrity Advocate was the platform’s ability to offer a full-service solution — technology, reviewing and support from one vendor — that is customizable, and built for privacy and accessibility.

"“ntegrity Advocate works on all devices. We don’t hear any complaints, you don’t need to download any applications. The validation is very quick, the turnaround is very quick, the support is great, and it’s on demand. We don’t have any complaints from our users. We’ve been very happy!”

Things were going great. And in 2023, a major certification change would create a stress test that proved the scalability of Integrity Advocate’s solution.

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The National Payroll Institute issues two professional designations, the Payroll Compliance Professional and the Payroll Leadership Professional, held today by more than 21,000 members. Integrity is one of NPI's four core values, so when the COVID-19 pandemic forced a rapid shift away from honor-based, supervisor-led proctoring, NPI needed an online solution that could uphold that standard at scale.

Key Outcomes

• 57% reduction in academic integrity incidents, from an average of 86 per month down to 37
• Fewer than 1% of users require technical support
• More than 30,000 exams proctored with a seamless experience

Challenge

NPI's first attempt at online proctoring didn't hold up. The system required plugin downloads, ran on a limited set of browsers, and offered no French-language support for the 12% of NPI's membership that operates in French. Close to half of students hit a technical issue during their exam. For a body responsible for validating the competency of more than 17,000 PCP and 4,000 PLP designation holders, that wasn't a minor inconvenience. It was a threat to the credibility of the credential itself.

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A Complete Transformation in User Experience

After switching to Integrity Advocate, the technical support burden that used to consume staff time became close to invisible. Integration with NPI's D2L Brightspace LMS meant students could move directly from coursework into a proctored exam without separate logins or downloads, and the entire implementation took a single 45-minute setup meeting, compared to weeks of troubleshooting under the previous system.

"We're getting very little feedback," Pacella said. "And that's amazing. That speaks volumes. That's exactly what we want. You don't hear about software that works well typically... But if it didn't work, you better believe we're going to hear about it a lot."

Dramatic Improvement in Academic Integrity

Paired with a proactive integrity education module, NPI's average dropped from 86 incidents per month to 37, a reduction of more than half, and the improvement held steady over time.

"We went from an average of 86 incidents per month, and it dropped more than in half, down to 37," Pacella said. "And that's been very consistent since we implemented some of these resources and things for people to understand what academic integrity means."

The reduction wasn't just about fewer incidents. It was about quality. The incidents that remained were genuine violations, not technical false positives or misunderstandings about proctoring protocols. That let NPI's review committees spend their time on legitimate concerns instead of sorting through noise, producing more consistent, more defensible decisions.

Seamless Student Experience

Daniela Kwiatkowski, NPI's Manager of Learning and Professional Development, experienced the system firsthand when she took one of NPI's own courses. Her experience highlighted how the technology disappeared into the background, letting students focus on demonstrating their professional competency.

"Before you do it for the first time, you're thinking, how am I going to do this?" Kwiatkowski said. "I moved the camera to one corner and then I forgot about it, and it was easy to forget about it. It wasn't constantly there... now I could focus on the exam, which is what we want people to do."

Scaling Success Across the Organization

NPI's growth didn't stop once the technical problems were solved. According to Steven Van Alstine, Vice President of Professional Standards and Education, NPI moved from proctoring a few thousand students to e-proctoring every student pursuing the Payroll Compliance Professional designation, a ramp-up that happened in under three months.

"We were able to scale that up dramatically through our move to D2L Brightspace and the integration with Integrity Advocate," Van Alstine said. "There was a point at which we maybe had a few thousand students being e-proctored, to the point now where every one of our students is e-proctored... and that ramp-up happened in less than three months."

That rapid scaling extended across NPI's mixed delivery model, including partnerships with public and private academic institutions alongside direct-to-student programs, without requiring different standards across channels.

Administrative Efficiency and Confidence

Decision-making that previously took weeks now happens within 48 hours, with clear evidence and streamlined processes. The administrative team developed communication templates and tracking systems to ensure consistent, fair handling of every incident.

"Giving someone a zero on an exam or failing a course is a big deal," Kwiatkowski said. "I cannot emphasize it enough... Having the peace of mind to know this is an incident that was flagged for the right reasons... we are very confident that this is legitimate."

Advice for Other Organizations

NPI's guidance to other certifying bodies is straightforward: technical due diligence up front saves significant time later.

"There are a lot of products out there," Pacella said. "And you're going to reach out to them, and the sales team will talk a big game about all the wonderful things they can do. Take your time and understand the technical aspects of implementation before making a decision."

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The Family Educational Rights and Privacy Act has governed student education records in the United States since 1974. For most of its history, compliance meant controlling access to paper files and transcripts. Today, it means carefully evaluating every technology platform that touches student data, including online proctoring.

If your institution is subject to FERPA and you use online proctoring, the data your proctoring vendor collects may constitute part of a student's education record. That makes vendor selection a FERPA decision, not just a technology decision.

This guide explains what FERPA requires, how it applies to online proctoring, and how Integrity Advocate is built to support your institution's compliance obligations.

What Is FERPA and Who Does It Apply To?

The Family Educational Rights and Privacy Act is a United States federal law that protects the privacy of personally identifiable information in students' education records. It applies to any educational institution that receives funding from the US Department of Education, which includes virtually all public schools, colleges, and universities.

FERPA gives students two primary rights. First, the right to access their own education records. Second, the right to control the disclosure of those records to third parties. Institutions that violate FERPA risk losing federal funding.

Under FERPA, an education record includes any record directly related to a student that is maintained by an institution or a party acting on its behalf. When a proctoring platform collects session data, identity images, and behavioral flags tied to a specific student, that data can fall within the definition of an education record.

How FERPA Applies to Online Proctoring

FERPA addresses proctoring vendors through the concept of a school official with legitimate educational interest. Institutions can share student education records with third-party vendors without explicit student consent if the vendor meets specific criteria:

• The vendor performs a service or function that the institution would otherwise perform itself
• The vendor is under the direct control of the institution with respect to the use and maintenance of education records
• The vendor uses the data only for the purposes for which the disclosure was made
• The vendor does not re-disclose the data without authorization

This means your proctoring vendor must operate as a legitimate school official under your institution's direction, not as an independent party free to use student data for its own purposes.

Proctoring vendors that use student session data for product development, algorithmic training, secondary research, or any purpose beyond delivering the proctoring service are operating outside what FERPA permits.

What FERPA Requires of Proctoring Vendors

For a proctoring vendor to support rather than undermine your FERPA compliance, they must be able to demonstrate the following:

Data Use Limitation

Student data collected during proctoring sessions must be used only for the purpose of delivering the proctoring service. It cannot be sold, transferred, or used for any secondary purpose without explicit institutional authorization.

Integrity Advocate uses session data exclusively for assessment integrity purposes. Student data is not sold, leased, repurposed for research, or used to train algorithms beyond the scope of the specific session it was collected for.

No Unauthorized Re-disclosure

FERPA prohibits vendors from re-disclosing student education records to third parties without authorization from the institution.

Integrity Advocate does not disclose session data to any third party beyond the institution that deployed the assessment. When a session is flagged, only the minimum information required to document the specific concern is shared. Data from sessions with no violations is not shared at all.

Collection Limitation

While FERPA does not specify collection limits as precisely as some privacy laws, the requirement that vendors act under institutional direction and use data only for authorized purposes creates an implicit obligation to collect only what is necessary.

Integrity Advocate collects only the data required to verify a student's identity and monitor their session. Browser history, desktop file contents, and program inventories are not collected. If a student is not permitted to access other tabs during their exam, Integrity Advocate monitors that and nothing more.

Data Security

Institutions are responsible for ensuring that the vendors they work with protect student data with appropriate security measures.

Integrity Advocate uses 256-bit encryption in transit and at rest, stores data on AWS infrastructure in Montreal by default, and has maintained zero data breaches across 12 or more years of operation. The platform holds SOC 2 certification, providing independent verification of security controls. Student identity images and session recordings are deleted within 24 hours of session completion for sessions with no violations.

Student Notification

FERPA gives students the right to know what information is maintained about them. Integrity Advocate proactively addresses this by sending every student an email after their completed and reviewed session, detailing what data was retained and what conclusions were drawn.

FERPA and the Annual Notification Requirement

FERPA requires institutions to notify students annually of their rights under the Act. If your institution uses online proctoring, that notification should include information about how proctoring session data is handled, how long it is retained, and what rights students have to access it.

Working with a proctoring vendor that provides clear, documented data practices makes this notification straightforward. Working with a vendor whose data practices are opaque or poorly documented creates a disclosure problem your institution has to solve on its own.

FERPA in the Context of AI-Based Proctoring

One area where FERPA compliance is increasingly relevant is the use of automated AI systems to make decisions about students based on session data. When an algorithm flags a student for suspected misconduct and that flag becomes part of the student's record, the accuracy of that flag matters under FERPA.

Integrity Advocate's human review process directly addresses this concern. Every automated finding is reviewed by a trained person before any conclusion is recorded. Students are not penalized based on an algorithm alone, and the information that enters any record reflects a reviewed, documented judgment rather than an automated output.

FERPA Is a Floor, Not a Ceiling

FERPA sets minimum standards for the protection of student education records. Institutions in states with stronger privacy laws, or those serving students subject to GDPR, PIPEDA, or other frameworks, need to meet the higher standard where applicable.

Integrity Advocate is built to support compliance across multiple frameworks simultaneously. The same Privacy by Design architecture that meets FERPA's requirements also supports PIPEDA, FIPPA, PIPA, POPIA, and GDPR, making it a consistent choice for institutions with a geographically diverse student population.

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