1. Data Release Policies & Procedures
Kansas State Department of Education
NCES Forum
July 2009
Kathy Gosa

2. Data Release Issues Releasing data is more than a legal concern
Large number of requests
Consistent treatment of requesters
Consistent response to requests
Tracking of where request is / what has been completed
Ability to replicate the report over time or for another requester
Concerns regarding recipients’ understanding of the data
Concerns regarding Open Records, FERPA and personally identifiable data
Not just a legal problem!!!
These are some of the problems we’ve faced that are part of our Data Release process.
Major issues:
Requests for data came from many sources and could enter the agency in numerous ways
We couldn’t evaluate how much work was being done to respond to requests – often redundant
Requesters treated differently depending on how / who they asked
No oversight in the quality of the data being provided
No tracking so couldn’t tell where a request is
Didn’t have a good feel for how much work was being done re Data Requests
No awareness of whether the same question was being answered differently or if work was redundant
Couldn’t re-use results
Large number of requests – perception that we had hundreds – but couldn’t substantiate. Perception that many people spent a lot of time fulfilling, but we couldn’t substantiate.
Inconsistent treatment of requests/requesters - Includes how the requester is communicated with, priority given the work
No tracking of where request is / what has been completed
No ability to replicate over time or for another requester.
Concerns regarding FERPA and personally identifiable data
The Problem – we couldn’t tell
Who? …was asking for data and who was giving the answers.
What? … specifically was the question – this was often left to the interpretation of the individual who received the request.
Why? … was the data needed? … were responses to similar requests inconsistent?
Where? … was the request at any given time? …was the data that was provided to a previous request?
When? … would we respond to the request? … when did we have a request similar to this before?
How Much? There was a perception that a huge number of requests were being received and processed, and a large amount of agency staff time was being used to do that work – but we had no data to back that up so could not evaluate how to best use our resources.

3. Data Requests & Data Governance
Data Stewards and Programmers
Data Manager / Coordinator
Data Owner
Data
Governance Board
Executive
Leadership
Data Request
Review Board
Data Stewards
& Programmers
Our DGB established the
Data Request Review Board to address the issues that surround data requests.
Definition of a Data Governance Program:
The individuals and process with responsibility for establishing and enforcing policies and guidance involving data.
Data Governance brought even more process around our treatment of data. Our Data Governance Board (made up of Data Owners) began discussing our problems with the volume of data requests that our agency received and the issues with responding to them.
The
Data Governance Board formed the Data Request Review Board to focus on and address this issues.

4. Data Request Review Board
Membership
Subgroup of DGB
5 Directors, including Legal Counsel
Mission:
implement processes for the provision of accurate, timely data and information to our internal and external customers while protecting personally identifiable student information and other confidential information.
DRRB Process
Monthly meetings
Virtual meetings as needed
Defined Workflow
Tracking tools
Mission of the Data Request Review Board
 The mission of the Data Request Review Board (DRRB) is to implement processes for the provision of accurate, timely data and information to our internal and external customers while protecting personally identifiable student information and other confidential information.
Scope/Responsibilities and Goals/ Objectives of the Data Request Review Board
 The DRRB was established to support the flow of data and information requests. Data Request Review Board member responsibilities* include:
Establish, encourage, and enforce policies and procedures for responding to data and information requests.
Provide and continually improve standard procedures for entering, prioritizing, and responding to data and information requests.
Provide for training of KSDE staff to initiate and manage data requests.
Prioritize requests as needed.
Assignments of requests as needed.
Review and determine the legality of responding to the request as needed.
Report and escalate issues to the Data Governance Board as needed.
Report denials by the DRRB to fulfill requests to the Data Governance Board.
Review the flow and completion of requests.

5. Data Request Tracking Who’s asking? When did they ask?
What do they want to know?
Can we answer?
Must we answer?
Do we need a contract?
Who has the answer?
When is it needed?
Who can do it?
Who did it?
How did they do it?
Did it include PISI?
When was it done?
When was it sent?
If at all possible we provided de-identified data.

6. Data Request Tracking Automated email reports Reports on demand

7. Data Request Workflow: from request to closeout
Start tracking from the beginning
Know who’s responsible for each step in the process
Data Request Workflow: from request to closeout
Determine up front if legal agreement is required.
Archive in case you need it again (RECORDATION)

8. Data Request Policies Charging for requests Request Denial
Consistent logic
Request Denial
Can’t violate Open Records Act
Have
We have had a DAUP ever since we began collecting individual student data in 2005.
Focused on FERPA issues regarding research requests for identifiable student data.
But there was no gate-keeper or policies to ensure it was applied consistently and evenly
Other data requests were not tracked.
samples of MOU / Contract addendaum / DAUP

9. For Personally Identifiable Student Information
MOU / Contract Required:
Customized from standard template
List specific data elements requested/provided
Includes stated purpose of research / evaluation and limits use to that purpose
Specifies individuals who may have access and holds requester responsible for training and signed acknowledgement by those individuals
Requires results to be provided to KSDE prior to publication
Outlines required physical and access security requirements
Specifies cell-size requirement for disclosure of summarized data
Specifies data destruction requirements
FERPA Addendum included

10. Releasing Federal Data & Public Reports
Data Stewards review and sign off
Content and consistency
Public (aggregate) reports have cell size mask

11. Questions?