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[Forums Moderator]

The U.S. Education Department has submitted its final report to Congress on the controversial "student unit record" database. Rather than continue to collect data in summary form, the department would require every college in the nation to report students' Social Security numbers and other information to a centralized national database. Will better information help improve rates of retention and graduation? If so, is that worth the potential invasion of students' privacy? Read more...

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[common sense]

Oh my goodness. A federal government agency is asking for a student's SSN.  And that's an invasion of privacy?

Uh, excuse me, but

1. didn't a federal government agency issue that SSN in the first place?

2. IRS data, next to medical information, is the most private information about an individual.  Doesn't a student have to put their SSN on the taxforms they submit?  Why therefore is it a privacy issue if one federal agency asks for the SSN but not a privacy issue if another federal agency asks for the SSN?

3. Universities require a student to furnish their SSN. So why is it NOT a privacy issue when a taxpayer funded public university asks for the SSN, but it IS a privacy issue when a federal government agency (also taxpayer funded) asks for the SSN?

Me thinks this is just another "the sky is falling" from the liberal left...

[not senseless]

What was it that's been said about the difference between "liberal" and "conservative" individuals' command of nuance?  Me thinks you over simplify.  It's not the SSN; it's the SSN in conjunction with every other bit of student datum the feds think they want or need.

[Jay Pfeiffer, Florida DOE]

Florida is very experienced in establishing unit record systems that are used to administer all parts of its public education system at all levels, kindergarten through graduate school.  It also develops follow-up data about former students as they move out of schools into the labor force and has developed a K20 data repository of its data resources. This level of experience with all of the steps involved included collaborating with institutional partners, determining and defining data elements, developing data dictionaries and meta data, continually editing and correcting data, and reporting data in aggregate form exceeds that of most other states in the United States.  

Data managers at institutional and state levels in Florida have a number of concerns about this proposal.  Their concerns are outlined in this paper. The concerns have been expressed in various forms by managers and policy makers at public and private institutions. They are broadly representative of discussions that have occurred among business and trade schools, vocational-technical institutions, community colleges, and universities as well as policy makers within the Florida Department of Education, Independent Colleges and Universities of Florida, and the Council of Independent Education at the state level.

It must be stated at the outset that these interests in Florida share a near-universal agreement that this proposal is inappropriate and should not be pursued further at this time.  It is possible to accomplish the goals stated in the proposal without creating a nationwide data base of individually-identifiable student records by the federal government. Simply stated, the primary reporting objectives of IPEDS could be met by redesigning the aggregate reporting requirements and periodic sample surveys. However, there is also an understanding that this proposal may result in further development, including conducting the proposed pilot test and an eventual implementation strategy.  

Purpose:  This report discusses concerns that must be carefully addressed if this proposal is carried forward. These concerns are based on Florida¡¦s extensive experience with the collection, management, and reporting of unit record data at the state level.

Fundamental to all of the outlined concerns is the caution that incomplete planning and an overly aggressive time line will lead to failure. The consequences of failure will be greater than loss of funds and waste of time:
„X   Policy decisions based on ill-conceived designs for data transmission and verification will move higher education resources in the wrong direction.
„X   Public perceptions about the potential abuse of the data base will erode the public trust. The resulting backlash could bury research advances and push back the progress that states have made in developing and using accurate data to describe the progress of students and the results of their education experiences.

Issues: There are five major concerns that summarize Florida¡¦s perspective on the potential redesign of the IPEDS collection of individually-identifiable student data and attendant education records. These concerns are:

1.   Issues of privacy, security, and confidentiality must be central and not tangential to the effort.
The technical review panels operated on the assumption that privacy and security will be adequately assured, but transmittal of individual information through the Internet, even when encrypted, is not secure.  There are numerous examples of instances of identity theft and public release of private information to make this a very public concern.  This level of public concern doomed discussions within the NCES Forum regarding the collection of individually-identifiable data from the nation¡¦s public schools.

Even if no security breaches occur, the level of public concern may damage this effort and call into question state and institutional systems with appropriate security protection. Results of a recent survey of higher education information technology issues and concerns ranked security and privacy as the second most important issue facing administrators.   Currently, there is considerable pressure on secondary and postsecondary institutions regarding their collections of student-level data.  Local institutions will be impacted by public reaction as well.

Last year in Florida, the Legislature passed a law requiring the collection of individual information on school personnel, including social security numbers. Public outcry doomed the project and the law was immediately repealed. Taken to the national level, such risks will be magnified.

2.   Unit Record data bases designed for reporting and research purposes should not be used to sanction an individual student. This caution extends to the indirect sanction imposed on students if a federal benefit is withheld from them as a sanction to their college or university.
The USDOE proposal for IPEDS includes the potential to develop a unit record data base designed to fulfill IPEDS reporting requirements and meet requirements associated with IRS 1098-T reporting.  A data base established to determine the eligibility of individual students for benefits or sanctions is different from a data base that is used for research and reporting. This difference is profound.  Any student has the right to challenge the accuracy of data that are used to award or withhold a benefit, such as participation in federal programs or tax benefits. Data bases designed for evaluation or program improvement represent exceptions to this type of requirement in the Privacy Act of 1974 (PL 93-579), the Computer Matching and Privacy Protection Act (PL 100-503) , and the Family Education Records Protection Act (Buckley Amendments, PL 93-380).

Florida has developed a K20 Data Warehouse that acts as a repository for unit record data reported by institutions to state data bases used for annual administration and funding.  While the Data Warehouse is used for research and evaluation, it is not used for funding decisions or other decisions directly affecting students because it is too far removed from  original sources of the data.  A similar federal repository would be even more removed than Florida¡¦s Warehouse.

3.   Collecting unit records should be the last option to consider, not the first. Laws authorizing the collection of data by federal agencies including the Privacy Protection Act of 1974, limit those collections to those data that are necessary for the administration of an authorized program or operation. This means that the first question to ask when data are required for reporting, evaluation, or research is: How can we meet the request and avoid release of unit records?  Most needs for data or for improvements in data quality do NOT require transmission of unit records.

4.   State roles and responsibilities should be strengthened, not bypassed. State Legislatures provide most of the funding for postsecondary institutions and their students, not the federal government.  Administrative responsibilities lie within state legislatures and state governing boards and they need information regarding operations and outcomes more than the federal government does. The US Department of Education experience with NCLB has strengthened the relationship between states and local educational entities while not requiring unit record collections at the federal level. This is the model that should be pursued.

Further, any data that are used to research or evaluate educational programs provided by states should be negotiated with full cooperation and approval of the states. Unless the state data managers are integrally involved, reports generated from a national data base will inevitably differ from the same reports generated at the state and the institution levels.  These differences will be apparent as measures will be reported on websites sponsored by institutions, by states, and by NCES.  Such differences will confuse the public and anger policy-makers.

5.   Significant new resources will be required at the institution level to enable those not equipped to report, to do so. Postsecondary institutions do not all have the same kinds of data bases and technological capabilities. Postsecondary institutions in Florida include universities with over 50,000 enrollments and Carnegie Classed Research I institutions. They also include private postsecondary trade schools with less than 100 students which focus on a limited number of occupational education programs.  The common thread between these two extremes is that they provide opportunities for federal financial assistance to students.

The data bases that serve larger institutions are robust, include many common data elements, and are backed by robust information technology.  The common data elements were largely formed through requirements for unit record reporting to the state legislature in public institutions and available software products for others. The data bases that serve the smaller institutions are often paper-based with little or no technological underpinnings. If smaller institutions do use data bases, they are usually not integrated or consistent from one application to another. There is no form of unit record reporting requirement for these institutions.

These issues will be further compounded with fifty states and thousands of institutions.

Recommendations: The primary reporting objectives of IPEDS can be met by redesigning the aggregate reporting requirements in lieu of moving to a system of collecting, maintaining, and reporting individually-identifiable student records at the federal level.  There are many organizations in states and at the national level that could contribute to the redesign of these reporting requirements.  Florida supports the concept of a more robust data collection system for postsecondary education and submits the following recommendations to contribute to this important discussion:
1.   Improve the accuracy and coverage of the IPEDS system through alternative approaches to reporting individual student records. New requirements in the Higher Education Act should call for improvements in the IPEDS data collection system including accuracy, breadth-of-coverage, and more robust reporting capabilities. This process should require the evaluation of options other than collecting student records and maintaining them in a federal data base of individually identifiable data on every person who enrolls in a postsecondary education institution at any time in the future.
2.   Engage established mechanisms such as the National Postsecondary Education Cooperative (NPEC) to advise NCES as to the alternative approaches. NPEC has engaged in a number of projects regarding the collection and use of national data sets.  It also engaged in lengthy projects with representative postsecondary education institutions regarding the efficacy of establishing unit record data bases.    
3.   Refrain from amending federal laws related to maintaining individually identifiable student records.  Accountability systems will suffer from public trust issues if Congress changes the rules in the middle of the game. Those who already have submitted individual information voluntarily will feel betrayed if disclosure is required and the conditions abandoned under which they agreed to submit their information.

[WICHE]

Today, a number of states already have student record data bases, which include information similar to what is being proposed by NCES for the national student record data base, and to my knowledge there has never been a case or even much of a concern that any student's privacy has been breeched.  That is because the states have taken care to protect student privacy -- yes, it can be done.

Let's get real.  Opposition to the student record data base is not about student privacy but about institutional privacy.  A student record data base would allow us to answer the real questions about students' access to success -- that is, their progression through our swirling system of higher education.  That would be extremely useful for public policy purposes.  But it would make it difficult to perpetuate many of the myths that currently exist.  Today we can say just about anything because no data exists to prove us wrong.  With good information we would be accountable and some amongst us would prefer that wasn't the case.

[in the middle]

I see both sides. But I do think anyone who is accepting federal scholarship/grant money should be obligated to provide basic information to the federal governement in order to help the US Dept of Education track its performance and adjust it budget appropriately. I would have to see an itemized list of the requested information to judge for myself whether this is privacy invasion. Most folks don't have much problem with divulging extremely personal information in order to obtain a mortgage from a bank to purchase a new home. One would hope their education would be worth as much personal sacrifice.

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[Joseph, U of Alabama]

People have no qualms about handing over their social security number when it comes to opening a bank account, applying for a loan, filling out an I-9 form for a new employer, etc. etc.

But if the United States government asks for the SSN then we should suddenly be suspicious? I'm not buying it.

Folks, we've just got to stop swallowing this conspiracy theory crap from the ACLU.  I find nothing wrong with the government requesting this information. If the universities don't want to comply, then they should have all of their federal funding yanked.

[Dale]

So if an institution fails to comply with something that could cause serious harm to its students (i.e. identity theft - notice how the government can't keep track of its secrets?  Yes I know this is something that may or may not happen.), they should have all their federal funding pulled?

I hope U of Alabama doesn't do anything even slightly wrong in the next couple of years, as I'd hate for it to lose its federal financial aid.  

I don't know whether this is a good idea or not, but reactions such as Joseph's don't really do much to advance the issue.

It seems to me that the federal government already has too many roles to play, and ought to be the recipient of such retention data, not its collector and analyzer.  Institutions are doing this work already and can report data in the aggregate - why do it singly?

[u asked]

The Department of Education is the prime example of a government agency gone amok.  It  does not and can not handle the work load it has now, much less any increase in that work load.

For 10, yes ... ten, years, I have been  seeking a discharge of my student loans
based   on disab8olity.  The paper work goes in.  No answer ever comes back.
Then three years later comes an "attach your assets" for lack of payment
leter.

Then the whole process starts over.  Last time around, I had my congressman
send in the required paperwork and they did the same thing.  Said, "oh, we never got anything."

You want this agency to have more responsibility.  No way.

[student]

I find it interesting that the federal government wants to track students -- even those who receive no federal financial aid -- but it does not track gun ownership. Is it becuase they consider education more dangerous than guns?

[dark globe]

this administration is holding hundreds of people, including american citizens, without the right of due process, access to attorneys or the "evidence" they're supposedly being held for, or even charged with a crime, for years, and you're bellyaching about socsec numbers?

[common sense]

You have a debt owed to the taxpayers. You should pay it.

Have you ever thought that the Dept. of Education is purposely ignoring your bogus request because they want your money?

Seems perfectly efficient to me!

[Tom Amlie]

Uhhhhh, I hate to break this to you, but they're not tracking student SS numbers because of the "danger" of education.  

Similarly, the uses to which that information might be put, and the useulness (for valid purposes) of that information, makes your analogy inappropriate.

[John]

A centralized database would be a good idea if the purpose were to track violent felons, sexual predators, potential Islamic terrorists, potential financial supporters of Islamic terrorists, and/or potential encouragers of Islamic terrorism.  A database to track students is definitely not a good idea.

However, a database to track students who don't repay their federally funded or federally subsidized college loans is a very, very good idea.

[%sig%]