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Maintaining Confidentiaity

The Data for Student Success Dynamic Inquiry tool has aggregate and student level data. The latter is given by special permission and needs to be handled in the strictest of confience. As you work with your districts, it is important to review confidentiality of data rules. To support this conversation, we have provided the following:

Direction from CEPI

Before district personnel log in to a CEPI application that can provide "drill-down" access to the status of an individual student's eligibility, ISD, LEA and PSA districts should ensure that they have implemented the following recommendations:

  • The intent of the confidentiality provisions in the NSLA is to limit the disclosure of a child's eligibility status to those who have a "need to know" for proper administration and enforcement of a Federal education program. As such, CEPI expects schools to establish procedures that limit access to a child's eligibility status to as few individuals as possible.
  • Prior to disclosing information on the eligibility of individual students, school officials should enter into a memorandum of understanding or other agreement to which all involved parties (including both school lunch administrators and educational officials) would adhere. This agreement would specify the names of the individuals who would have access to the information, how the information would be used in implementing Title I requirements, and how the information would be protected from unauthorized uses and third-party disclosures, and would include a statement of the penalties for misuse of the information.

See the 2010 USDA Memo  that also outlines requriements around 'need to know.'

See the 2013 Memo  regarding changes to FERPA enacted January 3, 2013 

See the Electronic Code of Federal Regulations, Title 34, Part 99 - FERPA section 99.3 where it addresses use of student ID numbers. The number can be directory information "only if the identifier cannot be used to gain access to education records except when used in conjunction with one or more factors that authenticate the user's identity, such as a personal identification number (PIN), password or other factor known or possessed only by the authorized user." It is also recommended that if sharing a student ID number with those that have an educational interest and appropriate permissions that they not be paired with other student information as that narrows the identifiability of the student as well as risks sharing other data that may be considered as an education record by the student's district. 


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