Summary and Technical Information
on
Student Data⁽¹⁾
 

June 15, 1999

Executive Summary

This document defines the student unit record data system used by the Alabama Commission on Higher Education (ACHE) in collecting data about students in Alabama's postsecondary education institutions. Student data gathered from the institutions will be used to generate reports to assist decision makers at all levels to make informed decisions on education issues. Specific uses of the data, the format of the files, and definitions of all the data fields are defined in the following sections.

Objectives

• To collect reliable and comparable student information from all postsecondary education institutions in Alabama as required by Act 96-509.

• To provide reliable, meaningful, and timely information pertinent to the formulation of decisions and recommendations made by the Alabama Commission on Higher Education.

Benefits

• Provide uniform compatible data for planning and evaluation, including tracking of student transfers.
  
• Insure consistency of data and allow for comparative analysis through the use of common definitions.
  
• Enable the collection of data in a manner to provide flexibility that is not possible with aggregate data. Aggregate data, while useful for answering specific questions, cannot be utilized for more complex inquiries.

Description

The Student Data System is composed of six types of information:

• Biographical and Demographic
• Previous Educational Experience
• Current Educational Activity
• Residency Status
• Student Migration Enrollment
• Student Graduation

Data extracted comes directly from student information systems maintained at the individual public institutions. All analyses and aggregations, therefore, are based on similar source data from all institutions.

Disclosure

Personally identifiable information will not be disclosed to any individual or state agency, with the exception of the Alabama Department of Examiners of Public Accounts, which may be requested to perform audits of the submitted data as called for by Section 1(f) of Act 96-509.

Privacy of Student Records

The Family Educational Rights and Privacy Act of 1974 (FERPA) - The Buckley Amendment, federal statute 20 U.S.C. Section 1232g, protects the rights of students to insist that their educational records be kept confidential. Section 1232g(b)(5) of this Act states that:

Nothing in this section shall be construed to prohibit State and local educational officials from having access to student or other records which may be necessary in connection with the audit and evaluation of any federally or State supported education program or in connection with the enforcement of the Federal legal requirements which related to any such program, subject to the conditions specified in the proviso in paragraph (3). (20 U.S.C. Section 1232g(b) (5))

The proviso in paragraph (3) referred to in the above paragraph states:

Provided, that except when collection of personally identifiable information is specifically authorized by Federal law, any data collected by such officials shall be protected in a manner which will not permit the personal identification of students and their parents by other than those officials, and such personally identifiable data shall be destroyed when no longer needed for such audit, evaluation, and enforcement of Federal legal requirements.

The proviso of the Buckley Amendment is usually interpreted to allow data on individuals to be collected from student records by a state agency for the purpose of constructing aggregated or summary reports, as long as students are still provided the same protections regarding their rights to privacy as are provided by the institutions providing the data.

In addition to the Federal requirements mentioned above concerning privacy of Student Records the Alabama Commission on Higher Education passed a Resolution on March 19, 1993 which states in part:

NOW, THEREFORE, BE IT RESOLVED, that in the establishment of any statewide student records data base, the Alabama Commission on Higher Education commits to abide by all provisions relating to the disclosure of student record information as outlined in the Family Educational Rights and Privacy Act, United States Code, Section 1232(g). In particular, the Commission commits that any studies conducted based on student records will be conducted in such a manner as will not permit the personal identification of students.

BE IT FURTHER RESOLVED, that the Alabama Commission on Higher Education will file all procedures relating to the collection and dissemination of student record information with the Alabama Administrative Procedure Division as required by the Alabama Administrative Procedure Act.

BE IT FURTHER RESOLVED, that the Alabama Commission on Higher Education will not be considered the Office of Record for student data files, and that any request for information on an identified student will not be accepted by the Alabama Commission on Higher Education but will always be referred to the appropriate institutional Office of Record.

BE IT FURTHER RESOLVED, that all employees of the Alabama Commission on Higher Education shall be made aware that it is their responsibility to maintain the privacy of student records and that failure on their part to follow established guidelines relating to the operation of the student record data base will result in disciplinary action up to and including dismissal as well as possible legal action.

BE IT FURTHER RESOLVED_, that the Alabama Commission on Higher Education agrees to accept legal liability for any unlawful disclosure of student records, which can be directly attributed solely to its own actions.

Security

Data will be housed at the Commission in a physically secured area. Data files will NOT be viewed via on-line transactions. All processing of data will be handled in a batch environment.

File Design

Student data will be stored in three files at the commission:

• Demographic/Educational Activity File
• Graduation File
• Change History File

Demographic/Educational Activity -

There will be a student demographic record for each unique student identification number at an institution for each institution for every term reported. A student who has been enrolled at two institutions during a term will have two student demographic records for that term.

Graduation -

There will be a student graduation record for each degree conferred.

Change History File -

There will be one record created for each change requested by an institution to a student id or DOB.

File Relationships

Each file contains the same primary key fields: Institution FICE code, student identification number and student date of birth. These primary key fields allow the files to be interlinked. The secondary key fields are academic year and academic term.

System Responsibilities

• The commission staff will be responsible for designing, developing and maintaining the system and ensuring that backup/recovery safeguards are in place.
  
  
• The commission staff is responsible for maintaining security and confidentiality on student data.
  
  
• The commission staff will also provide an encryption routine to the institutions that will be applied to every student identification number in an effort to ensure this confidentiality.
  
  
• The commission staff will maintain an FTP site to assist with electronic transmission of information/data.

Media of Submission

The data are submitted, in order of preference: 1) via file transfer protocol (FTP), 2)   via computer cartridges, and 3) via computer tape. Each institution will also submit a certification document for each initial data submission.

Electronic Data Interchange

Electronic Data Interchange (EDI) is still being considered as a possibility for this project in the future.

Record Selection Criteria

A record shall be submitted on all students enrolled in courses creditable toward a degree or other formal award. Include students enrolled in courses that are part of a vocational or occupational program, including those enrolled in off-campus sites. Also, include students enrolled in "institutional credit only" or "audit only" classes. High school students taking regular college courses for credit should also be included.

Reporting Data/Frequency

The demographic/educational activity records will be submitted each term for each student in a predefined format.

The graduation records will be submitted once a year at the end of spring term. Submissions will include a record for each award conferred for the academic year (summer, fall, winter, or spring).

Data submitted should reflect data as of  the end of the reporting term.

Submission Deadlines

Submission dates and deadlines are maintained on our web site at www.ache.state.al.us. (Ex: January 15, 1999 is the deadline for submitting data for the Fall term of 1998-99.)

Acceptable Threshold of Errors

The responsibility for ensuring the accuracy of the data and the readability of the files submitted is primarily that of the submitting institution. Files with errors and files that cannot be read will be returned to the institution for correction with appropriate written feedback.

The commission staff will provide the institutions with edits for each file. Institutions will use these edits for error checking before submitting the files to the commission.

Validation & Verification

Specific edit routines are posted on our web site at www.ache.state.al.us.

Processing of Data

The commission staff processes all files in the following manner:

The raw data received will be loaded to a disk file on the AS400. A certification sheet signed by the designated institutional contact must be submitted to ACHE via mail or fax. The next step is the edit checking procedure, which produces three reports for each file submitted:

• A detailed exception report of all records that failed the range, reasonableness, or completeness test.

• A preliminary summary report that provides an institutional perspective of the data.

• A summary exception report that summarizes the number of errors for each data field.

Institutions at this point have the opportunity to review the data and make any necessary corrections to the file before data from these files are published or analyzed. An approval sheet is provided to indicate that an institution will certify approval of the initial file as submitted. A resubmission sheet is provided to indicate that an institution is submitting and certifying corrections to error records or resubmitting and certifying the entire file.

Data Changes/Data Corrections

The following procedures regarding error resolution are in effect:

All corrections must be submitted in writing, signed and dated. No telephone corrections are accepted. Phone conversations may be utilized to resolve a problem, but until these are received in writing, the file remains uncorrected.

All corrections are related to an individual student record or group of records. No aggregate number on a report may be adjusted.

Cutoff date for corrections are posted on the web site at www.ache.state.al.us.

There will be no corrections to any data files for prior reporting cycles. The error resolution/verification period is the appropriate time for an institution to settle any inconsistencies. A file may be resubmitted for the previous year but this resubmission must be pre-approved by the commission staff and be substantiated by significant rationale.

The error resolution/verification phase ranges from four weeks to two months, depending on the commission’s determined correction cutoff date. It is mandatory that the institution respond within this predetermined period. A memo accompanying each approval and resubmittal form has the final cutoff listed on it so that there is no misunderstanding regarding the importance of responding within this period.

When the final approval form is signed by the institution (indicated by the signature of the certifying officer as designated by the President/Chancellor), the institution authorizes the commission to use the data for reporting and legislative analysis. Student records that passed all data edits will be moved to a master student file and will be used to generate reports.

Changes and/or corrections that are made to student id and date of birth fields are required to be submitted to ACHE each term using the format defined and published on the web site as student date of birth and/or student identification. ACHE will provide information reports to institutions each term for review to help determine possible changes and/or corrections that need to be made.

Data Retention

At this time there are no plans to purge student records. They will be retained for use with longitudinal studies.

Reports

Act 96-509 specifies at least four reports to be generated from the student data:

• Reports to individual high school officials and the State Board of Education using information captured by the student unit record data base concerning the progress made by their respective graduates within the public institutions of higher education in Alabama;

• Student retention and graduation rates;

• Student transfers across sectors, Institutions and within Institutions;

• Status of out-of-state students.

Reports generated will be designed/developed around the data collected that passed all edits. Ad hoc reports may be generated; however, they will be carefully scrutinized and the format will be approved by the HEIAG Steering committee to assure that the information compiled is not misrepresented or misinterpreted.

Disclosure Related Data Suppression

The Alabama Commission on Higher Education is especially sensitive to the issue of privacy of student data and the use of student information. It has resolved through its administrative actions to assure that the data will not be able to identify individuals and will not be reported in any form that would allow comparisons of individual students.

Release of Data

Data released from the commission will only be released in the form of reports generated in the format approved by the Higher Education Information Advisory Group (HEIAG) steering committee. Published reports will use aggregate data that does not identify individuals. The exception is for transfer/migration reports that include individually identifiable information for institutions where that student has been (or is) enrolled.

HEIAG Steering Committee

At the Alabama Commission on Higher Education's June 6, 1997 meeting, the HEIAG Steering Committee was appointed by the commission as the advisory committee for the Student Unit Record Data System project "to assure that the expertise and concerns of the institutions . . . shall be provided to the commission." (Act 96-509 Section (d))

Report Distribution (Who, when, where, how, what)

As the advisory committee for the Student Unit Record Data System project, the HEIAG Steering Committee will 'provide consultation and advice on database development and report generation....' In this capacity, the HEIAG Steering Committee will review reports generated with sensitivity to the appropriate use of data.

Audit Considerations

All data contained in records submitted to the commission is subject to audit by the commission or by the Department of Examiners of Public Accounts. (Act 96-509)

Failure of Institutions to Comply

If public institutions fail to comply with the requirements of Act 96-509 they will be identified in a written notice to the Lieutenant Governor, the Speaker of the House, the Chair of the Senate Committee on Finance and Taxation-Education and the Chair of the House Committee on Ways and Means. (Act 96-509)

1. Revised June 1999.