MASSACHUSETTS DEPARTMENT OF ELEMENTARY
AND SECONDARY EDUCATION

June 18, 2014

Policies Relating to the Collection and Use of Student Data

This paper describes the policies and practices of the Department of Elementary and Secondary Education (DESE) regarding the collection, use and disclosure of individual student data. Massachusetts public schools collect and maintain detailed information about each of the nearly one million students enrolled each year, a portion of which is shared with us. In turn, we use this data to administer state education programs; to ensure compliance with state and federal education laws; and to help educators improve the quality of classroom instruction. At all times, we are cognizant of the sensitive and private nature of this data, and we have an obligation to ensure that it is carefully safeguarded and used only for lawful and appropriate purposes.

What is our authority to collect and maintain student data?

Most student data is initially collected from students and their parents and guardians by the public schools and districts that enroll and educate those students. (These schools and districts are collectively referred to as “local education authorities” or LEAs.) DESE, in turn, has authority under various state statutes to request and receive this data from the LEAs. (See, for example, G.L. c.69, ss. 1A, 1B, and 1I.) Because DESE needs individual student data to carry out its statutory responsibilities, LEAs are permitted to share their student data with DESE without parental notification or consent.

DESE’s use of student data is subject to the requirements and limitations of the Federal Educational Rights and Privacy Act (FERPA), 20 USC 1232g, and its associated regulations, 34 CFR Part99. We are also governed by the Commonwealth’s Fair Information Practices Act (FIPA), G.L. c.66A.In general, these laws require us to keep personally identifiable student information confidential. We may not re-disclose or share such information without the consent of the parent or guardian (or the student’s consent, in the case of adult-age students).There are a limited number of exceptions to this rule, which are discussed later in this paper.

What student data do we collect?

We collect a wide range of individual student data. We collect information on school enrollment and attendance, demographics, test scores, courses and grades, disciplinary actions, and post-graduation plans, to name just a few categories. Appendix A contains a comprehensive list of the data categories, with links to data dictionaries posted on our website.

Most of our individual student data is collected initially by LEAs. We do not ask LEAs for all of the student information that they collect, but only those data elements that we need for our work. For example, LEAs collect students’ home addresses, telephone numbers, and names of parents and guardians; none of that information is provided to DESE. Requests to collect additional data elements from LEAs go through a review process within the Department, to validate the need for the information and to weigh the benefits against the extra effort.

Some student-level data comes from sources other than LEAs. For example, the Department’s testing contractors are responsible for scoring our state-sponsored assessments and sending us the student-level scores. Appendix A indicates the source for each major category of information.

We do not collect students’ social security numbers. We use state-assigned student identification numbers(SASIDs) to identify individual student records. SASIDs help us to track student movement between schools and districts.

How do we keep student data secure?

The computer systems used to maintain our student records are operated by the Executive Office of Education’s Information Technology (EOE IT) group, under the direction of the Secretariat Chief Information Officer. This group provides IT services to all of the executive branch education agencies under the Secretary of Education.

  • Oversight and policy direction for secretariat IT activities, including data security, is provided by the Commonwealth’s Information Technology Division (ITD), headed by the Commonwealth Chief Information Officer. Secretariat and agency IT activities must conform to the Commonwealth’s Technical Security Policies and Practices, which in turn are based on ISO-27000 and NIST industry standards. More information on ITD’s security policies and standards is available on the ITD website.
  • EOE IT maintains a role-based user authentication system for users within DESE. Access to individual student data is provided only to those staff members whose work requires it. Most DESE staff members do not have such access.
  • Tools are provided to allow LEA superintendents or heads of school to authorize individual LEA staff members to access the student records for that LEA.
  • Student data is transferred between LEAs and DESE using secure, encrypted file transfer protocols.

What do we do with student data?

Individual student data is used extensively by DESE staff as part of our administration of educational programs and our obligation to ensure compliance with state and federal education laws. For example, the data is used to help gauge how well individual schools and districts are doing; to identify students who have met the competency determination required for high school graduation; to distribute funding under Chapter 70, Title I, and other state and federal school aid programs; and to study the effectiveness of our programs and initiatives.The Commissioner and the Board of Elementary and Secondary Education routinely rely on data analysis to inform their policy decisions.

Individual student data is also aggregated into summary tables and charts for public information. Aggregated student data does not contain information from which a student could be personally identified. To further insure privacy, each table cell in an aggregated summary must contain a minimum number of records; cells containing fewer than the minimum number are not displayed.

Much of this aggregated data is published in the school profiles section of the DESE website. Aggregated data is also published in various Department reports, including periodic reports requested by the Legislature on a variety of topics. Finally, aggregated data is reported to the Census Bureau, for inclusion in national statistical compilations, and to the U.S. Department of Education.

Who do we share student data with?

As noted earlier, under certain limited circumstances DESE is permitted by law to re-disclose personally identifiable student-level data to outside individuals or organizations. These include individuals or organizations who are: assisting DESE in carrying out its administrative responsibilities; conducting research or evaluation studies; or conducting audits and program compliance reviews.

In each instance, we enter into a formal data-sharing agreement that incorporates safeguards and limitations on usage, data security, and re-disclosuresimilar to those that apply to us. These include limitations on the allowable use of the data; requirements for data security and access control; prohibitions against any further re-disclosure of the data except as permitted by the agreement; and protocols for the destruction of the data when the use has been completed.In addition to the data-sharing agreement, FERPA and FIPA requirements also apply to these individuals and organizations and to their employees and subcontractors.

Other publicagencies

We occasionally share individual student data with other public agencies as we jointly carry out our statutory responsibilities. For example:

  • We provide information to the Department of Children and Families and the Department of Youth Services relating to students in their custody, to assist them in providing services to those children.
  • We match our student records with records at the Department of Transitional Assistance, to help identify students eligible for free school lunches.
  • We provide individual student data to the State Auditor when the data is needed to complete a program audit or investigation.
  • We provide student lists to the National Center for Education Statistics (NCES), a branch of the U.S. Department of Education, to assist in the administration of the National Assessment of Educational Progress (NAEP) tests. NCES’s current testing contractor is Westat.

DESEcontractors

We occasionally engage private firms to conduct projects with individual student data on our behalf. The major example in this category are the testing contractors who assist us with the MCAS tests and other DESE-administered student assessments. The testing contractors need individual student data in order to prepare the testing materials, score the tests, and provide the results in various formats. Another example is the contractor currently helping us to design the Edwinteaching and learning system, which is described below.

Firms that work with us on these projects are prohibited from using or selling any of the student data for marketing or other commercial purposes, both by the terms of our contract and by federal and state law.

Researchers

We receive frequent requests from researchers for access to individual student data. High quality research helps inform our policy and spending decisions. But each request is closely reviewed to ensure that the data release is in the state’s interest. Research projects must meet the following criteria:

  • The researcher must be affiliated with an academic institution or an independent, nonpartisan research organization.
  • The researcher must be free of any appearance of a conflict of interest with the study’s outcome and cannot be an advocate with respect to the study topic.
  • The researcher must have expertise in the topic to be studied and the methodology to be used.
  • The proposed project must be relevant to state educational policymaking or to high priority district and school issues.
  • The proposal must include specific research questions and a detailed, rigorous methodology for answering those questions.

Approved researchers are required to provide DESE with a draft of any presentations or publications based on our data at least 30 days in advance of release. We review the drafts to ensure that no confidential data has been released.

If a researcher does not meet our criteria for access to individual student data, they can access anonymized public research files that we make available for this purpose. These public files contain “stripped down” student-level records without names or SASIDs. The information they contain is deliberately limited to ensure that the records are not personally identifiable.

LEA staff

A recent DESE initiative has been the development of theEdwin system, which provides a secure portal for teachers, guidance counselors, principals, and other educators to see and analyze detailed information about their students and to help inform their classroom instruction. Edwin includes a growing suite of on-line curriculum materials and resources, helping teachers to target each student’s individual needs. Edwin also includes the capability to “move” student records over the summer, as students change schools and districts. This will allow teachers to become familiar with their incoming classes even before the first day of school. More information is available on the Edwinpage of the DESE website.

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Appendix B contains a complete list of all the organizations with whom we have shared individual student data since 2012.

Appendix A

Personally Identifiable Student Data Collected by DESE

A list of the categories of student data collected by DESE. Data is obtained from local education authorities (LEAs) unless otherwise noted. Links are to data dictionaries posted on the DESE website for the major categories.

  1. Student Information Management System (SIMS) – directory, demographic, and program participation for all publicly funded students in the Commonwealth.


  1. Student Course Schedule (SCS) – collection of courses taken by publicly funded students in the Commonwealth including course title, course level, numeric and letter marks, and credits earned.


  1. School Safety and Discipline Report (SSDR) – incident-level collection of all offenses and disciplines throughout the school year.


  1. Massachusetts Comprehensive Assessment System (MCAS) – MCAS administration data (booklet numbers, assessments taken), item level results, accommodations received and overall performance levels for ELA, mathematics and science MCAS assessments. Data is obtained from DESE’s current MCAS testing contractor, Measured Progress.
  2. Massachusetts English Proficiency Assessment (MEPA) – English language proficiency assessment results. Data was obtained from our testing contractor, Measured Progress, up through 2012.
  3. Assessing Comprehension and Communication in English State-to-State for English Language Learners (ACCESS for ELLs) – English language proficiency assessment results; replaced MEPA in 2013. Data is obtained from our current testing contractor,the WIDA Consortium.
  4. Advanced Placement (AP) test – student-level AP test results. Data is obtained from the College Board. (AP course enrollments are found in SCS).
  5. SAT test – student-level SAT results. Data is obtained from the College Board.
  6. Postsecondary enrollment – student-level database of enrollment and degree completion in colleges and universities.Data is obtained from the National Student Clearinghouse (NSC).
  7. High school equivalency – student-level databaseof students receiving a Massachusetts high school equivalency certificate. Data is obtained from DESE’s testing contractor, currently ETS.
  8. Charter school waitlist – student-level database of all students on charter school waitlists.
  9. Homeless – student-level database of all students reported as homeless by LEAs.

In addition to the student data described above, DESE also collects information on teachers and other educators through two systems: the Educator Personnel Information Management System (EPIMS), which includes data submitted by LEAs; and the Educator Licensure and Recruitment System (ELAR), which tracks our issuance of educator licenses. Teachers and students are linked through the Student Course Schedule database described above.

Information regarding student enrollment in public higher education programs and publicly-funded pre-school programs is also provided to the Executive Office of Education(EOE) by the Department of Higher Education and the Department of Early Education and Care, respectively. This data is used by EOE in conjunction with DESE data for program analysis and reporting.

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Appendix B

Student Data Sharing -- List of Outside Organizations

Includes all outside organizations that have received personally identifiable student data from DESE since 2012.

DISCLOSURE MADE TO / ORGANIZATION TYPE / TITLE OF PROJECT / DATE EXECUTED / DATA DISCLOSURE
Measured Progress / State contractor / MCAS and MEPA Administration / 2012 / All SIMS files for label generation
Measured Progress / State contractor / MCAS Administration / 2013 / All SIMS files for label generation
Measured Progress / State contractor / MCAS Administration / 2014 / All SIMS files for label generation
Westat / Federal contractor / NAEP Administration / 2012 / Student data for NAEP sample
Westat / Federal contractor / NAEP Administration / 2013 / Student data for NAEP sample
Westat / Federal contractor / NAEP Administration / 2014 / Student data for NAEP sample
WIDA / State Contractor / ACCESS for ELLs
Administration / 2013 / SIMS files for test administration
WIDA / State Contractor / ACCESS for ELLs
Administration / 2014 / SIMS files for test administration
Thinkgate / State contractor / Edwin Teaching and Learning / 2013 / SIMS, EPIMS and SCS data to populate district-run application
Thinkgate / State contractor / Edwin Teaching and Learning / 2014 / SIMS, EPIMS and SCS data to populate district-run application
National Student Clearinghouse (NSC) / State contractor / Student Tracker Agreement for State Education Agencies / 2012 / Directory information for matching to enrolled postsecondary students
National Student Clearinghouse (NSC) / State contractor / Student Tracker Agreement for State Education Agencies / 2013 / Directory information for matching to enrolled postsecondary students
Department of Transitional Assistance / State agency / Interagency data exchange / 2012 / Free and Reduced price lunch information
Department of Transitional Assistance / State agency / Interagency data exchange / 2013 / Free and Reduced price lunch information; TAFDC eligibility
Department of Transitional Assistance / State agency / Interagency data exchange / 2014 / Free and Reduced price lunch information; TAFDC eligibility
Department of Youth Services / State agency / Interagency data exchange / 2012 / SIMS, SCS, SSDR and MCAS information for students in DYS custody
Department of Youth Services / State agency / Interagency data exchange / 2013 / SIMS, SCS, SSDR and MCAS information for students in DYS custody
Department of Youth Services / State agency / Interagency data exchange / 2014 / SIMS, SCS, SSDR and MCAS information for students in DYS custody
Department of Children and Families / State agency / Interagency data exchange / 2012 / SIMS, SCS, SSDR and MCAS information for students in DCF custody
Department of Children and Families / State agency / Interagency data exchange / 2013 / SIMS, SCS, SSDR and MCAS information for students in DCF custody
Department of Children and Families / State agency / Interagency data exchange / 2014 / SIMS, SCS, SSDR and MCAS information for students in DCF custody
State Auditor’s Office / State agency / Interagency data exchange / 2013 / Data on charter school students and charter school waitlist information in response to audit
State Auditor’s Office / State agency / Interagency data exchange / 2014 / Data on charter school students and charter school waitlist information in response to audit
Executive Office of Education / State agency / Interagency data exchange / 2012 / All collected data for population into Edwin Analytics
Brown University / Research organization / A Study of the Causal Relationship Between Turnaround School Strategies & Student Achievement Outcomes / 2/11/2013 / SIMS, MCAS and GED
Center for Research on Educational Outcomes at Stanford University (CREDO) / Research organization / National Study of the Effectiveness of Charter Schools / 12/18/2012 / MCAS 2012 thru 2017 (12 elements)
Center for Research on Educational Outcomes at Stanford University (CREDO) / Research organization / National Study of the Effectiveness of Charter Schools / 1/18/2013 / SIMS, EPIMS, SCS and MCAS 2004-2012 where available