I can certainly understand the argument in favour of a code of practice for learning analytics. It would be needed to address questions of ownership, privacy, retention, and more. But I don't think that such a code would accomplish anything. Those who would behave ethically don't need a code, while those who don't behave ethically will either ignore the code or mine it for loopholes. (p.s. most institutions fall into the 'unethical' or 'just don't care' categories - see Hellman on libraries giving away the privacy store and privacy leakage on a catalogue web page). The solution, in my view, is technological. We need to return the property of individual students (specifically, their information) to the students. We shouldn't possess it at all.
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