November 1, 2017
Contact: Rachael Stickland, rachael@studentprivacymatters.org, 303-204-1272
The Parent Coalition for Student Privacy opposes the College Transparency Act and overturning the federal ban on a student unit record system
The Parent Coalition for Student Privacy urges sponsors and supporters of the H.R. 2434 – College Transparency Act (CTA) to reconsider their support for this bill which would require the non-consensual collection by the federal government of the personally identifiable information of every student attending a post-secondary institution. Our members, made up of parents and privacy advocates from throughout the country, believe strongly that the 2008 Higher Education Act’s ban on the creation of a federal unit-record system should not be overturned by the CTA, and that any attempt to authorize a national student database would create an unacceptable and unaccountable surveillance system that would place our citizens at risk.
In recent months it has become clear that data held by post-secondary institutions and government agencies are under increased threat of breaches and cyberattacks. Even our “best protected” national data has been breached, including the hacking in recent years of the National Security Agency (NSA), Department of Defense (DoD), the Office of Personnel and Management (OPM), and the Securities and Exchange Commission (SEC). Specifically, the U.S. Department of Education was found to have weaknesses in four out of five security categories according to a 2015 security audit by the Inspector General’s Office.
Said Rachael Stickland, co-chair of the Parent Coalition for Student Privacy: “It’s inconceivable that Congress should entertain legislation that would increase federal collection of personal student data at a time when they have demonstrably proven they are unable to protect what data they already hold.”
Moreover, individual student data held at the federal level could be used in the future as a go-to repository of information for purposes beyond their originally prescribed intent. Even if the CTA specifies permissible uses of the data today, no Congress can limit the actions of future administrations once the data are in the government’s possession. The bill also allows for the expansion and collection of more categories of student data by the Commissioner of the National Center for Education Statistics (NCES) without authorization by Congress. This could easily lead to widespread abuse of personal information for political or ideological gain.
While we agree in principle that students seeking to attend post-secondary institutions should have sufficient information to make informed decisions, it’s possible to do so without the creation of a national student database. New NCES surveys provide previously unavailable statistics on “nontraditional” populations, making passage of the CTA an unnecessary overreach by the federal government at a time when we should minimize data collection rather than expand it.
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Leonie Haimson
Executive Director
Class Size Matters
124 Waverly Pl.
New York, NY 10011
phone: 212-529-3539
leonie@classsizematters.org
leoniehaimson@gmail.com
Reblogged this on David R. Taylor-Thoughts on Education.
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It all relates back to the longitudinal databases of the Data Quality Campaign https://dataqualitycampaign.org. and the Workforce Data Quality Campaign http://www.workforcedqc.org. If you’re not familiar with these databases I suggest you link to the websites and become acquainted.
The online grade book I am being forced to use has social networking and badges. We don’t need no stinking badges.
House Bill 2434 reads like it was born and bred in the hot-house of the Bill and Melinda Gates Foundation. Gates supported a series of 11 papers , created under the auspices of the Institute of Higher Education Policy, a non-public organization substantially funded by the Bill and Melinda Gates Foundation, Ford Foundation, Kresge Foundation, Lumina Foundation, TG™ (Texas, guidance for loan seekers), USA Funds (largest guarantor of student loans), W. K. Kellogg Foundation, Walmart Foundation (initiatives for first generation students of color seeking college degree) with token funding from the National Center for Education Statistics and National Science Foundation, and unnamed foreign governments.
The papers had one major aim—get rid federal legislation that prohibits the use of a federal “student unit record system” based on personally identifiable information of students http://postsecondary.gatesfoundation.org/wp-content/uploads/2016/09/PostsecondarySuccessAdvocacyPriorities2016.pdf
House Bill 2434 achieves that aim. It abolishes the federal prohibition against the use of a “student unit record system” based on a student’s personally identifiable information. In effect, social security numbers and other identifiers tied to these could become part of an extended data base managed by the Commissioner of the National Center for Education Statistics–a position currently held by holdover from the Obama administration–a temporary position.
The bill gives the Commissioner extraordinary power to determine policies and practices in data gathering for the stated purpose of calculating the cost effectiveness of higher education. But there is also an unparalleled opportunity to create a more extensive national student database connected to others.
The Bill states: “The Commissioner shall coordinate, and enter into sharing agreements, with other Federal agencies to create secure linkages with relevant Federal data systems, including data systems of the Office of Federal Student Aid, the Department of Treasury, the Department of Defense, the Department of Veterans Affairs, the Social Security Administration, and the Bureau of the Census.
Although this law prohibits the use of data from K-12 education, the opening is nevertheless there for data to be sucked into IPEDS—Integrated Postsecondary Education Data System and linked to The National Student Clearinghouse, a non-profit organization founded by the higher education community in 1993 with records on over 252 million students… Transcripts, Reverse Transfers, Financial Aid, Credential Verifications and research based on this information.
Since 2009, NSC has also operated a national secondary education research and reporting system. Hundreds of high school districts and thousands of high schools participate in the Clearinghouse. The Clearinghouse has Partners, and that is where the nearly 2 million students each year who use the free Student Self-Service program enter information such as their GPA, ACT, SAT scores and other information of potential use in searching for a good college fit.
That pre-collegiate information can enter the data stream of “partner relationships” with the National Student Clearinghouse. Who are the “partners?” One is Ellucian, an international provider of software and management services for postsecondary programs that wish to boost their enrollments. Another is Hobsons. Hobsons “helps more than 12 million students around the globe identify their strengths, explore careers, create academic plans, and find the right college match.”
Hobsons has “strategic partners.” One is the National Student Clearinghouse, another is the “Enhanced Personalized ACT Online Prep Program.” Data helps market many products and services.
For Example, Hobson’s also has a lot of “Alliance Partners.” These include Blackboard; Career Key®; EdMin; Experian® Data Quality; Front Rush; GeoLabs (based in UK, a call and marketing service for 65 higher ed institutions, including some in USA); iData Management for Higher Education; Kira Talent (a video admissions platform); mongoose (responds to inquiries with personalized mass texts — from a phone, tablet or computer); parchment (career and college planning resources with 13 “partners” able to tap K-12 data); Pearson; Sallie Mae® (publicly traded consumer bank with newly named loan management, servicing and asset recovery business, Navient Corporation); Teen Life® (Catholic ministry for high schools) among others. Every one of these partners has a privacy policy filled with legal loopholes.
We have no clue about who will be “The Commissioner for Education Statistics” under the Trump administration. I think that House Bill 2434 includes a lot of posturing about the privacy of student data but these stipulations are contradicted by the details in the bill. https://www.congress.gov/bill/115th-congress/house-bill/2434/text
Here is an example of the contradiction. The bill prohibits the use of data to rank postsecondary institutions but the bill also says the system should be compatible with IPEDS.
Among other activities, IPEDS presents data from federal sources in the form of a College Score Card. That Score Card is a rating scheme with a focus on financial outcomes of postsecondary education e.g., how much students from a particular school earn after graduation and how well they are able to repay their loans.
Readers of this blog should know that the work of IPEDS have been outsourced to the international company known as RTI, “Research Triangle Park” with a basecamp in North Carolina. RTI has multiple offices in and beyond the USA. https://www.rti.org/office-locations
Anyone who thinks we need to expand data gathering on a national scale should take note of this recent data breech connected with the use of a “Free Application for Federal Student Aid : IRS Data Retrieval Tool.“ The tool allowed family tax information to be migrated into the forms needed to apply for student aid. More at https://www.nytimes.com/2017/04/06/us/politics/internal-revenue-service-breach-taxpayer-data.html
Bottom line. Do not believe anyone who postures about privacy while demanding more data-driven anything.