Office of Management Privacy Safeguards Division 

Privacy Impact Assessment

For

National Longitudinal Transition Study 2012

Date: December 19, 2012

Point of Contact: Yumiko Sekino

(202) 219-2046

Yumiko.Sekino@ed.gov

System Owner: Audrey Pendleton 

(202) 208-7078

Audrey.Pendleton@ed.gov

Author: Yumiko Sekino

(202) 219-2046

Yumiko.Sekino@ed.gov

Institute of Education Sciences

U.S. Department of Education 
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2 

1. System Information. Describe the system - include system name, system acronym, and a 

description of the system, to include scope, purpose and major functions. 

The system name is “National Longitudinal Transition Study 2012” or “NLTS 2012”. The 

system will contain records on approximately 15,000 students and their parents, and 15,000 

teachers and 2,000 principals from 500 districts, which will be used to conduct a study to 

describe the characteristics of, receipt of services by, and outcomes of transition-age 

students. The NLTS 2012 was commissioned by the National Center for Education 

Evaluation and Regional Assistance at the Department’s Institute of Education Sciences 

(IES) as part of the congressionally mandated national assessment of Individuals with 

Disability Education Act (IDEA). 

2. Legal Authority. Cite the legal authority to collect and use this data. What specific legal 

authorities, arrangements, and/or agreements regulate the collection of information? 

The study is authorized under Individuals with Disability Education Act (IDEA), Title I, Part 

D, Subpart 2, Section 664. The 2004 authorization of IDEA was signed into law (P.L. 108-

446) on December 3, 2004. Section 664(e) of IDEA 2004 authorizes studies and evaluations 

of transitional services and results, including postsecondary placement and employment, for 

individuals with disabilities identified for services under IDEA. Section 664(a) of IDEA 

2004 instructs the Secretary of Education to delegate responsibility for such studies to the 

Institute of Education Sciences (IES). 

3. Characterization of the Information. What elements of personally identifiable information 

(PII) are collected and maintained by the system (e.g., name, social security number, date of 

birth, address, phone number)? What are the sources of information (e.g., student, teacher, 

employee, university)? How is the information collected (website, paper form, on-line form)? 

Is the information used to link or cross-reference multiple databases? 

The system of records will include, but will not be limited to information about the students 

who agree to participate in the study, specifically name, birth date, and contact information, 

which will be obtained from the student or parent via phone interviews. The system of 

records will also include student demographic information such as race, ethnicity, gender, 

age, and educational background; information on attendance and disciplinary incidences; 

information on employment history and college attended; scores on reading and mathematics 

achievement tests; and administrative data on the students including school transcripts. The 

system of records will also include information about the parents, teachers, and principals, of 

participating students, including name and contact information; demographic information 

such as race and ethnicity; and teaching experience. 

4. Why is the information collected? How is this information necessary to the mission of the 

program, or contributes to a necessary agency activity? Given the amount and any type of data 

collected, discuss the privacy risks (internally and/or externally) identified and how they were 

mitigated. 

This information is being collected for statistical purposes. The purpose of the information 

collection under this study is to provide information on the characteristics of youth receiving 

special education services under IDEA, their courses of study, the transition and other 
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3 

services and accommodations they receive, the barriers and challenges they face, and their 

postsecondary education and employment outcomes. More than 2.7 million youth with 

disabilities between the ages of 13 and 21 receive special education services funded under 

Part B of IDEA. In addition to the challenges all youth encounter as they leave high school 

and become young adults, youth with disabilities sometimes face barriers related to health, 

social isolation, service needs, and access to supports. This collection has been planned to 

help to address a national goal of significantly increasing the number of students entering and 

completing postsecondary education. 

A major challenge in developing policies and improving practice to assist transition-age 

youth is securing reliable and complete information on their diverse needs, school 

experiences, and postsecondary paths. NLTS 2012 is the third in a series of longitudinal 

studies of students with disabilities, conducted approximately a decade apart. The study will 

not only be able to provide information about a current cohort of transition-age students 

receiving special education, but also , for the first time, identical information for students 

with Section 504 plans, a growing part of the youth population, and for students without 

disabilities or a 504 plan. Finally, the NLTS 2012 was designed to replicate many questions 

from the earlier studies of students with disabilities. These features allow the study to serve 

as a benchmark for assessing national progress in meeting the academic and other needs of 

all students, and a base of information for better understanding the pathways youth follow as 

they move from high school to young adulthood. 

5. Social Security Number (SSN). If an SSN is collected and used, describe the purpose of the 

collection, the type of use, and any disclosures. Also specify any alternatives that you 

considered, and why the alternative was not selected. If system collects SSN, the PIA will require 

a signature by the Assistant Secretary or designee. If no SSN is collected, no signature is required.

We currently plan to collect SSNs in Wave 2 of the surveys. Data on students’ post-high 

school employment and earnings are critical to the objectives for the study. Self-reported 

information (e.g., through surveys) has generally been found to be unreliable and difficult to 

obtain after students leave high school and, in many cases, their parents homes. Past 

longitudinal surveys have had very low response rates to long-term follow up, in some cases 

making data on earnings unusable. 

We are beginning to develop an agreement with the Social Security Administration (SSA) in 

which they will tabulate employment and earnings information for the NLTS 2012 sample 

using their Master Earnings File. This method will place low burden on students and low 

costs on the government. Historically, SSN has been necessary to match with SSA’s 

Earnings File. While we have discussed with SSA the possibility of conducting a test of the 

effectiveness of matching based only on student name, date of birth, and location, such a test 

has not yet been conducted. If it proves to be successful, we will not collect SSN under 

Wave 2 of the surveys. 

6. Uses of the Information. What is the intended use of the information? How will the 

information be used? Describe all internal and/or external uses of the information. What types 

of methods are used to analyze the data? Explain how the information is used, if the system 

uses commercial information, publicly available information, or information from other 

Federal agency databases. 
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NLTS 2012 will provide up-to-date information on the characteristics, transition experiences, 

and transition outcomes of youth with disabilities that will help policymakers, educators, and 

parents improve policy and education practice to support successful outcomes. It will 

describe the secondary and postsecondary trajectories of youth with IEPs and how they differ 

from those of youth with Section 504 plans and youth with no identified disability. The study 

will inform policy, practice, and future research by examining the needs of various subgroups 

of youth with disabilities; how those needs are being addressed by schools and other 

organizations; barriers perceived by youth, parents, and school staff; and how youth 

outcomes are related to specific competencies, school experiences, and the services and 

supports youth receive. The study will also examine the extent to which school experiences 

and outcomes are changing in ways consistent with the goals of IDEA. In addition to 

supporting the specific analyses planned as part of NLTS 2012 Phase I, the data will be made 

available to other researchers and practitioners through well-documented restricted use files. 

The system will include new data collected through surveys, administrative school records 

obtained from state and local education agencies (districts), and publicly available 

information on school districts and schools maintained by the National Center for Education 

Statistics (NCES). Information on earnings obtained from SSA will not be in the system of 

records; under SSA’s rules and procedures, matching and data tabulations will be performed 

by their analysts and provided to ED only in aggregate form. 

7. Internal Sharing and Disclosure. With which internal ED organizations will the information be 

shared? What information is shared? For what purpose is the information shared? 

IES will share name and date of birth of the student with Rehabilitation Services 

Administration (RSA) in order to collect aggregate information about the vocational 

rehabilitation services students received once they left school and with FSA in order to obtain 

financial aid data.

The Department may disclose information contained in a record in this system of records 

under the routine uses listed in this system of records without the consent of the individual if 

the disclosure is compatible with the purposes for which the record was collected. Any 

disclosure of individually identifiable information from a record in this system must comply 

with the requirements of section 183 of the Education Sciences Reform Act (ESRA) (20 

U.S.C. 9573), which provides confidentiality standards that apply to all collection, reporting, 

and publication of data by IES. 

(1) Research Disclosure. The Director of IES may license de-identified confidential 

information from this system of records to qualified external researchers solely for the 

purpose of carrying out specific research that is compatible with the purpose(s) of this system 

of records. The researcher shall be required to maintain the confidentiality of the licensed 

data and to use it only for statistical purposes. All licensing shall be accomplished pursuant to 

the National Center for Education Statistics Licensing Program, described in the following 

website: http://nces.ed.gov/statprog/instruct.asp.: 

(2) Contract Disclosure. If the Department contracts with an entity to perform any function 

that requires disclosing records in this system to the contractor’s employees, the Department 

may disclose the records to those employees who have received the appropriate level of 
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security clearance from the Department. Before entering into such a contract, the 

Department will require the contractor to establish and maintain the safeguards required 

under the Privacy Act (5 U.S.C. 552a(m)) with respect to the records in the system. 

8. External Sharing and Disclosure. With what external entity will the information be shared 

(e.g., another agency for a specified programmatic purpose)? What information is shared? For 

what purpose is the information shared? How is the information shared outside of the 

Department? Is the sharing pursuant to a Computer Matching Agreement (CMA), 

Memorandum of Understanding or other type of approved sharing agreement with another 

agency?

We are beginning to develop a Memorandum of Understanding with the Social Security 

Administration (SSA) for data transferring in order to collect aggregate employment and earnings 

information for the NLTS 2012 sample. We are discussing with SSA to conduct testing as part of this 

agreement of the effectiveness of matching based only on student name, date of birth, and location, to 

tabulate employment and earnings information for the NLTS 2012 sample using SSA’s Master 

Earnings File. See response to question 5.

9. Notice. Is notice provided to the individual prior to collection of their information (e.g., a 

posted Privacy Notice)? What opportunities do individuals have to decline to provide 

information (where providing the information is voluntary) or to consent to particular uses of 

the information (other than required or authorized uses), and how individuals can grant 

consent? 

Participation in the study is voluntary. All participants are informed of this in writing via preinterview letters and during the course of the interview. Participants may decline to 

participate at any time during the study or in any component of the study (e.g., providing 

SSN).

In addition, the following verbatim language will appear on the parent consent form and other 

applicable study-related materials: 

All information gathered for the study will be kept confidential and will only be used for 

research purposes. The information collected about this student will be used only for 

statistical purposes and may not be disclosed or used, in identifiable form, for any other 

purpose except as required by law (Public Law 107-279, Section 183). 

10. Web Addresses. List the web addresses (known or planned) that have a Privacy Notice. 

http://ies.ed.gov/ncee/nlts/index.asp

11. Security. What administrative, technical, and physical security safeguards are in place to 

protect the PII? Examples include: monitoring, auditing, authentication, firewalls, etc. Has a 

C&A been completed? Is the system compliant with any federal security requirements? 

All physical access to the Department’s site and to the sites of the Department’s contractor 

and subcontractors, where this system of records is maintained, is controlled and monitored 

by security personnel. The computer system employed by the Department offers a high 

degree of resistance to tampering and circumvention. This security system limits data access 

to Department and contract staff on a need-to-know basis and controls individual users’ 

ability to access and alter records within the system. The contractor and subcontractors will 

establish a similar set of procedures at their sites to ensure confidentiality of data. The 
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contractor and subcontractors are required to ensure that print data identifying individuals are 

in files physically separated from other research data and electronic files identifying 

individuals are separated from other electronic research data files. The contractor and 

subcontractors will maintain security of the complete set of all master data files and 

documentation. Access to individually identifying data will be strictly controlled. At each 

site, all print data will be kept in locked file cabinets during nonworking hours and work on 

hardcopy data will take place in a single room, except for data entry. Physical security of 

electronic data will also be maintained. Security features that protect project data include: 

password-protected accounts that authorize users to use the contractor’s system but to access 

only specific network directories and network software; user rights and directory and file 

attributes that limit those who can use particular directories and files and determine how they 

can use them; and additional security features that the network administrators will establish 

for projects as needed. The Department’s, contractor’s, and subcontractors’ employees who 

“maintain” (collect, maintain, use, or disseminate) data in this system must comply with the 

requirements of the Privacy Act and the confidentiality standards in section 183 of the ESRA 

(20 U.S.C. 9573), which provides criminal penalties for violations.

12. Privacy Act System of Records. Is a system of records being created or altered under the 

Privacy Act, 5 U.S.C. 552a? Is this a Department-wide or Federal Government-wide SORN? If 

a SORN already exists, what is the SORN Number?

The system is covered under the system of records notice entitled National Longitudinal 

Transitions Study 2012 (18-13-27), dated April 27, 2012, (77 FR 25152-25155).

13. Records Retention and Disposition. Is there a records retention and disposition schedule 

approved by the National Archives and Records Administration (NARA) for the records 

created by the system development lifecycle AND for the data collected? If yes – provide 

records schedule number: 

Records are maintained and disposed of in accordance with the Department’s Records 

Disposition Schedules ED 068.a (NARA Job Number: N1-441-08-18).