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Balancing disclosure requirements with privacy

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​The U.S. Department of Education on Tuesday issued guidance on how community colleges can publish federally required graduation information without inadvertently running afoul of privacy laws.

The 2008 Higher Education Opportunity Act requires all colleges and universities that receive federal funding to annually disclose graduation rates on first-time, full-time, degree- or certificate-seeking students, categorized by gender, race/ethnic group and receipt of Pell Grants or federal student loans. Four-year institutions are already required to disclose such data publicly, but community colleges are not required to do so until this academic year.

Some community colleges are already publishing the information, usually on their websites. A review of 30 two-year colleges that do so showed that none of them took precautions to mask certain information that could easily identify a student, which prompted the department’s National Center for Education Statistics (NCES) to issue the guidance.

"We appreciate the initiative of NCES to better inform the higher education community about best practices when disclosing data," said Christopher Mullin, program director for policy analysis of the American Association of Community Colleges.

Issues with aggregate data

While colleges typically release aggregate data on students when publishing information on students’ outcomes, there are instances when personal information may be disclosed. This can happen when such information is released on a small group of students, which makes it easy to identify them. The NCES guidance noted that one community college it reviewed—which it did not name—published information that it had one American Indian/Alaskan Native student enrolled and that the student did not graduate within three years.

“This information results in disclosure because anyone who knows this individual student would then learn his or her graduation status from the table,” NCES said.

The college's published data also showed that among 14 enrolled black students, only one graduated within three years. This also is a disclosure because the graduate then knows that the other 13 students did not graduate.

Having separate data tables isn’t necessarily a solution, NCES said, as someone can find those tables and reconstruct outcomes that could disclose personal information about individual students.

Methods to lower risk

NCES outlined three methods to lower the risk of inadvertently disclosing personal information. The first is to use percentages instead of headcounts. To provide further safeguards, colleges can round up graduation rates, which is especially useful when disclosing graduation rates for small groups.

The second method is to withhold data regarding small groups, usually for groups of 10 or fewer students.

The third method is to provide a range rather than a specific rate. Instead of showing a graduation rate of 3 percent, a college can instead publish the rate as “less than 5 percent.”

NCES noted that the best method would be to combine the three.