For anyone who has ever filled out a college application, or scholarship or grant application, you know the incredible amount of personal information these forms require.  What if there was a massive database that combined and shared not only all of that personal information, but also answers from surveys you took over the years, social media posts you made, information normally kept protected and isolated in agencies like the Social Security Administration, Health and Human Services, HUD, IRS, and the US Census Bureau.  This kind of database, linking (and sharing) data across agencies, with a profile on each individual citizen is something that countries like China has, but a national student database is not legal in the US, currently banned by this 2008 Act.

This database is about to happen, not for you parents, but for your kids, starting with students in college.

(The focus of this blog will be on the push for a national higher ed database, but we remind you that there is also a push (Student data systems unite!-2010) and recently re-fueled by Bill Gates’ 2016 Priorities, which outlines the need to link k12 data with higher ed data, creating a national database.  MEW wrote about this and another commission on collecting, ranking student emotions here.  Gates is lobbying to create a national student tracking database on k-12 children, which is currently banned.)

History behind the push for a national unit-record database

There has been a push to create this type of database to track and link student data across agencies for years, and has always been rejected due to privacy or cost concerns. However, this year, a special commission, (created by the passage of this law, HR1381–jointly sponsored by Speaker Paul Ryan (R-WI) and Senator Patty Murray (D-WA), and signed by President Barack Obama on March 30, 2016),  has convened for the purpose of lifting the ban on this national database, that they refer to as the student unit record.  For background on the push for a national student database/unit record, see this 2013 HigherEd publication where they hoped to lift this ban and link the data, with a previous bill:

“The previous version of the bill called for stitching together state longitudinal databases in order to better track students — a project that some observers said would be technically difficult, perhaps unworkable and take years to accomplish, but which would also avoid confronting a federal ban on a national unit record system.
A unit record database has long been the holy grail for many policy makers, who argue that collecting data at the federal level is the only way to get an accurate view of postsecondary education. But privacy advocates, private colleges and Congressional Republicans, all of whom oppose the creation of such a database, teamed up in opposition the last time the idea was proposed, by the Bush administration in 2005. Then, the opponents succeeded; the 2008 reauthorization of the Higher Education Act included a provision specifically forbidding the creation of a federal unit record data system…

An increasing number of groups, including some federal panels, have called for a federal unit record system since 2006: the Education Department’s advisory panel on accreditation, last year; the Committee on Measures of Student Success, in 2011; and nearly every advocacy group and think tank that wrote white papers earlier this year for a project funded by the Bill & Melinda Gates Foundation on rethinking financial aid.

A federal system, those groups agree, is the only way to accurately measure student success. It would allow the Education Department to account for part-time students, transfers and others not currently captured in the Integrated Postsecondary Education Data System, the clearinghouse of data colleges report to the federal government.  And, through linkage with Social Security or other databases, it could track graduates’ wages more accurately than is currently possible.

The Obama administration — unable to create a federal unit record database — has offered states money to construct longitudinal databases of their own, including funding in the 2009 stimulus bill. Nearly all states now have, or are developing, some version of a [ K12, SLDS] database to track students throughout their educational careers.”


The 2016 Hearings to create a national student tracking database: unit-record

You may have read about the Congressional Commission on Evidence-Based Policymaking held on Oct. 21, 2016, with many heavily funded panelists  giving testimony in support of creating this student tracking database. You can watch the entire Oct. 21 hearing here. Additionally, written testimony (109 pages) has now been made available.

Wait, what’s that?  You clicked on the link above and found there are only 105 pages of testimony – why did we say 109 pages?

A Freedom of Information request obtained this written testimony from panelist RK Paleru of Booz Allen Hamilton.  Upon requesting all written testimony for the Oct 21 hearing, the Commission eventually supplied the 105 pages of testimony but stated, “RK Paleru of Booze Allen Hamilton, has not yet provided his statement to Commission staff. Once we receive it, it will be added to this package.”

It is unclear why Mr. Paleru, of Booz Allen Hamilton was not required to follow the Commission’s published guidance, requiring all written testimony to be submitted no later than October 16, 2016.  But, we are happy to provide it here as it contains valuable information.  Here’s some background on Booz Allen Hamilton:


Booz Allen Hamilton, who testified in support of this national student tracking database, employed Edward Snowden.

What else is important to know about Booze Allen and their relationship with data, the US Intelligence and the federal government?  This report from News.Mic gives 6 facts about Booz Allen Hamilton, we suggest you read this short document, but a few highlights:

Booze Allen Hamilton reported $5.8 billion in revenue for 2013…  Of that revenue, $1.3 billion, came from U.S. Intelligence agencies.   They are Working on Predictive Intelligence.

“The Post reports that the company put together a “Strategic Innovation Group,” on August 1, staffing it with 1,500 employees.  Among the group’s goals are “developing predictive intelligence services that include anticipatory cyber threat solutions, protection, and detection capabilities and the application of social media analytics  designed to provide early identification of trends that would otherwise not be possible using after-the-fact analysis of traditional data sources.”

          …and now they, along with many other agencies and nonprofits,  want your children’s data.

Presenter: RK Paleru of Booz Allen Hamilton’s testimony. You can see by his written testimony, that BAH supports, among other things, linking student data from surveys, multiple agencies, public-private partnerships, and data analytics.  (Clearly, we are not just talking college student grades or the classes they took.)


During his testimony, Paleru says he is “bringing the private sector perspective to the conversation”.  He sees the need for a data clearinghouse.  Paleru suggests  that this national database be self-service and calls it a  “Pinterest for data“,  wants crowd sourcing for data, and data as paid service, and promotes inter-agency data sharing.  He mentions the need to link  statistical and survey data.
@ 3hour 22 min of the hearing, Paleru acknowledges the need for better accountability of Government spending and mentions concerns of breaches, security and loss of privacy. (MEW NOTE: addressing these concerns does not require linking public-private databases. It requires compliance with existing laws and enforceable penalties for non-compliance.)
@ 3 hour 26 min  Paleru discusses the need for better algorithms, Pinterest for data


Who else testified in favor of this national student tracking database?

Moneyball,  Behavioral Insights, Bloomberg Cities, and data.

Go to this link.  You may need to type in the link itself to access (this particular link keeps getting broken): https://www.youtube.com/watch?time_continue=2823&v=Uxu4Fj4qT5E

   begins @3hr:51 minute mark

Presenter: David Medina,  Co-Founder of Results for America.   *written testimony shows that Mr. Medina is also testifying on behalf of :  Actionable Intelligence for Social Policy (AISP), America Forward Center for Employment Opportunities,  Center for Research and Reform in Education, Johns Hopkins University,  KIPP,  REDF,  Results for America,  Sorenson Center for Impact,  Success for All Foundation,  Sunlight Foundation
Mr. Medina’s testimony begins at 3hour 50 minute mark of the Oct. 21 hearingMedina/Results for America wants to accelerate the use of data, via 2002 Moneyball for Government  Principles, which is also supported by PEW, MacArthur Foundation, Speaker Ryan and Senator Murray.

Medina and all those he represents, propose that 1% of all Federal funds should be set aside for investment in this national student data clearinghouse.  Also, see table on page 5 of written testimony .
Results for America  also partners with Bloomberg Cities. “Over the course of the next three years, 100 mid-sized cities in the United States will benefit from approaches that address the unique challenges mayors face. Specifically, cities will receive help creating sustainable open data programs that promote transparency and robust citizen engagement; incorporating data into budget, operational, and policy decision making; conducting low-cost evaluations; and steering funding to programs that get results for citizens.
Joining in the effort are partners The Behavioral Insights Team, Harvard University’s Government Performance Lab at Harvard Kennedy School, Johns Hopkins University’s Center for Government Excellence, and Sunlight Foundation. Results for America will oversee the implementation of the initiative ”

Mr. Medina’s testimony calls for, among other things,

·State Education and Workforce Data Systems: The Commission should recommend that Congress and the Administration support the enhancement of the existing State Longitudinal Data Systems (SLDS) program administered by the U.S. Department of Education, which helps states integrate education and workforce data, and the proposed expansion of the Workforce Data Quality Initiative* that would help build state and local capacity to track employment and educational outcomes of Workforce Innovation and Opportunity Act program participants, including those with disabilities, and provide information about job success rates and training programs.
·Federal Education Data Identifiers: The Commission should consider recommending that Congress and the Administration direct federal agencies to standardize the way they collect and share student-level identifiers (e.g., de-identified but encrypted) so that researchers can more effectively evaluate publicly-supported education and workforce development programs. This information should be housed in one federal agency in order to promote appropriate sharing and usage of this standardized data.
·Federal Programmatic Data: The Commission should consider recommending that Congress and the Administration authorize every federal agency to set aside 1% of their program funds for program evaluations that generate programmatic outcomes data that can help make federal programs more effective and efficient.

*for more on how the Federal Department of Labor hopes to use the state SLDS database to track every individual  student, starting in pre-school, see here.



Presenter: Clyde Tucker, former chair of the American Statistical Association’s Scientific and Public Affairs Advisory Committee,  ASA.  The ASA states thatStatistical agencies should have complete control over data collection, analysis, and publication. Such autonomy should include control over an agency’s planning, budget, press releases, and information technology… The ASA lauds Speaker Ryan and Senator Murray for their actions and efforts to bring evidence-based policymaking into the limelight. The ASA heartily supports the Commission for Evidence-Based Policymaking.  … ASA encourages the use of modern statistical and data science methods in program evaluations—methods such as Bayesian modeling, decision analysis, and big data techniques.”  *In his testimony, at 32 minute mark of the hearing, Mr. Tucker  also notes that 3 Commissioners on the CEP board also belong to ASA. In fact, the ASA lists the  appointed Commission in this pdf below, and ASA lists Katharine AbrahamBruce Meyer, Robert Groves as members.



Tucker, on behalf of the ASA , views IRBs and privacy concerns as a barrier to gaining access to student data.

@32 minutes and again @ 36 minutes of the Oct. 21 hearing, Tucker states the ASA has “Concerns relating to privacy and confidentiality that may present barriers to the release of data needed for evidence-based policy making.”  @40 minutes into the hearing, Tucker states that when sharing data between agencies, there are currently multiple gates that must be cleared and reviewed, that slow down access to data.

Indeed, in his written testimony, Tucker again states the need to override privacy concerns and IRBs:   “In particular, researchers’ access to data often is delayed as a result of the need to undergo reviews by multiple Institutional Review Boards (IRBs).”

MEW NOTE: it is important to note the purpose of an IRB, as defined:

An institutional review board (IRB), also known as an independent ethics committee (IEC), ethical review board (ERB), or research ethics board (REB), is a type of committee used in research in the United States that has been formally designated to approve, monitor, and review biomedical and behavioral research involving humans. They often conduct some form of risk-benefit analysis in an attempt to determine whether or not research should be done.[1] The purpose of the IRB is to assure that appropriate steps are taken to protect the rights and welfare of humans participating as subjects in a research study.

WHY would someone collecting and using data of children, be opposed to the ethics and risk-benefit review, controlled study, required by IRBs?  IRBs promote using randomized controlled studies in research.



Presenter: George Grob– Chair, Evaluation Policy Task Force American Evaluation Association,  AEA, formerly Director of Evaluation at the Office of Inspector General, Department of Health and Human Services and the Federal Housing Finance Agency

@ 38 to 42 minute mark of Oct. 21 hearing testimony, Grob, much like the presenter [Tucker] before him,  infers that he is opposed to randomized control trials (such as those required by IRBs) .

@ 42 minute mark,  Grob states,  “The AEA  argues strongly against making these required.”
American Evaluation Association has developed professional standards for the quality of studies and ethics for the multidisciplinary members of the field. Of particular interest today is AEA’s paper: An Evaluation Roadmap for a More Effective Government.  This document describes many types of evaluation that can address management requirements, as well as principles and practices for ensuring evaluation quality and usefulness, including methods, human resources, budgets, independence, transparency, and professional ethics in a government setting. For your convenience, I have attached a copy for your reference.

@ 38 to46 minute mark, during his testimony, Grob states,
“We support the Commission in its efforts to consider whether and how a clearinghouse for program and survey data should be established.  We encourage efforts to ensure that verifiable, reliable, and timely data are available to permit the objective evaluation of programs, including an assessment of assumptions and limitations in such evaluations.   Agencies should use evolving best practices for data security, and ensure that publicly available data are aggregated or otherwise stripped of all information that could be used to identify particular individuals or businesses.

The proposed clearinghouse could also serve as a repository for the evidence contained in evaluation reports,** providing an archive capacity for the collection, dissemination, and preservation of knowledge and lessons learned from evaluation studies. “

OF NOTE: Chairwoman of the commission, Katherine Abraham, told Grob that the charge of the commission is to consider if and how DATA should be stored in a national clearinghouse.  She tells Grob that including REPORTS appears to be “an expansion of our charge” (46 minute mark of video hearing).



Presenter: Rachel Zinn, test, WDQC
@ 1 hour 3 minute mark of Oct 21 CEP hearing, Zinn remarks that “stakeholders”, because of current ban on a federal student database, don’t have access to student information, she goes on to say in order to link and share data, stakeholders often have to use “non-standard processes, often goes through personal relationships or particular capacities within agencies at particular times” (listen to short audio snippet here)

Did Ms. Zinn from the Gates funded WDQC just say they skirt the law when accessing student data?

Per Ms. Zinn’s written testimony:

“Workforce Data Quality Campaign (WDQC) is a non-profit initiative that promotes inclusive, aligned, and market-relevant education and workforce data. We engage hundreds of national experts, state officials, and workforce development advocates, encouraging the use of data to ensure that all of our nation’s education and training programs are preparing students and workers to succeed in a changing economy. Given our mission, we are excited about the promise of the Commission’s work, and are pleased to have the opportunity to share our recommendations
In some instances, surveys have been able to answer those questions over a limited time frame, but with great effort and expense. A growing number of state longitudinal data systems are linking administrative records to answer questions. However, geographical coverage is limited, so they cannot answer questions about students who leave the state, or compare outcomes across states. The federal government already collects data through numerous administrative sources, in addition to conducting regular surveys. With improved coordination, these data could be systematically shared and linked to answer those and other critical questions for generations to come.”

*Interestingly, what Workforce Data Quality Campaign (funded by Bill Gates) is asking for sounds a lot like the Workforce Data Quality Initiative ,  the US Dept of Labor and US Dept of Ed collaborative partnership that shares student-level pii data from each state SLDS with the US Dept of Labor. Even The Federal Reserve wants to monetize kids data for the workforce pipeline.

Many more wanting data…

There are 109 pages of written testimony, over 4 hours of hearing,  which you can watch for yourself. You will see foundations like PEW and MacArthur, New America, or The Education Trust, who said, The commission should recommend the overturn of the unit record ban and the ban on a federal database of Workforce Innovation Act data, so that we can have a nationwide, inclusive dataset…”   All those from bigdata, big corporations, big government were  in favor of accessing and using student data. No one questioned whether it was ethical or necessary for the government and private sectors to have access to this personal data of students, no one except, ONE.

One who said No.


Presenter:  Emmett J. McGroarty, American Principles Project

What’s wrong with a federal unit-tracking system? Plenty.  Read Mr. McGroarty’s full testimony here, starting page 85.  He addresses the fact that with this national unit-record database, the government would upon enrollment, require students to hand over the personal data, not knowing how it will be used or shared without their consent, and makes the excellent point of reminding the commission that the Federal Government has a less than stellar track record of keeping data safe and secure.  (The OPM breach. The 2015 Audit of US Dept of Ed that found over 400 repeat offenses and security issues, with the federal government receiving a FITARA score of F.
@2 hour and 51mark in the hearing, McGraorty states, (much to the apparent displeasure of those smirking behind him),

“The call for this commission is backed by powerful interests and lots of money.  I work almost full-time with grass-roots organizations, across the country. These groups are not well funded, they are funded mostly by passing the hat. However, they are highly skilled, highly organized and very effective.  The grass-roots are essentially moms and dads who are fighting for their children and I don’t think they will be defeated.”

 Thank you Mr. McGroarty.  Parents, teachers, America, this is your call to action. If not you, then WHO?

Image result for parent protecting children

Now, like no other, is the time to say something, say no to the student unit record. Protect the privacy of children. There is a reason this database has been banned for years.

To paraphrase the words of the privacy expert Paul Ohm, some data should not be mixed.   Data collection is much more pervasive – and much less controlled – than people realize. Algorithms are often biased and wrong.

Until there are LAWS and enforceable PENALTIES that restrict how data is collected, how it is shared, mixed, and transparency around algorithms and ways to audit and regulate the data analytics used to profile and predict a person,  there should be no expansion of data collection.

Rather, people should own their own data and as in Europe, large nonprofits and corporations should not have access to citizens’ personal data without consent.

To submit comments to the Commission, see instructions here, or visit Cep.gov for more information. To see previously submitted comments, click here.  The last public CEP hearing is scheduled for February 9, 2017

(You can see my submitted comment here.)







Cheri Kiesecker

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