Privacy Impact Assessment

For

Study of Teacher Preparation Experiences and Early Teacher Effectiveness

Date:

February 9, 2014

Point of Contact and Author: 

Melanie Ali

Melanie.Ali@ed.gov

System Owner:

Dr. Audrey Pendleton

Audrey.Pendleton@ed.gov

Institute of Education Sciences (IES) 

U.S. Department of Education

Office of Management Privacy Safeguards Division
Privacy Impact Assessment

1. System Information. 

Describe the system - include system name, system acronym, and a description of the system, to include 

scope, purpose and major functions. Indicate whether the system is new or existing and whether or not 

the PIA is new or being updated from a previous version; specify whether the system is “agency” or 

“contractor.”

This is a new system and a new Privacy Impact Assessment. The system name is the “Study of Teacher 

Preparation Experiences and Early Teacher Effectiveness.” The system, which is housed by a contractor 

and its subcontractors, will maintain records on approximately 1,518,950 students and 8,000 novice 

teachers from up to 50 school districts. These records will be used to conduct a study to examine the 

relationship between student learning outcomes and teacher preparation experiences that vary in terms of 

type (e.g., coursework, fieldwork, and substantive feedback in the field) and content (e.g., classroom 

management and instructional strategies).

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 the Education Sciences Reform Act of 2002, Part D, Section 171(b)(2) 

(20 U.S.C. 9561(b)(2)), which authorizes the Institute of Education Sciences to “conduct evaluations of 

Federal education programs administered by the Secretary (and as time and resources allow, other 

education programs) to determine the impact of such programs (especially on student academic 

achievement in the core academic areas of reading, mathematics, and science).” The collection of 

information is regulated by the Education Sciences Reform Act of 2002, the Privacy Act of 1974, and 

the Family Educational Rights and Privacy Act.

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 will include, but will not necessarily be limited to, data on: (1) Students - school name; 

student identification number; birth date; demographic information such as race, ethnicity, and gender; 

educational background, including individualized education program status, primary disability code (if 

applicable), English language learner status, and English language proficiency level (if applicable); 

whether enrolled in the National School Lunch Program; and scores on reading and mathematics 

achievement tests; (2) Teachers - name and contact information; teacher identification number; Social 

Security number; demographic information such as race and ethnicity; information on postsecondary 

institution attended and teaching preparation experiences; and scores on postsecondary entrance exams. 

The sources of information are district administrative records and online surveys of teachers. Data will be 

collected and maintained in secure electronic form that complies with all federal security requirements 

(see response to question 11). Data will not be used to link or cross-reference databases that are external

to the study.

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Privacy Impact Assessment

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 central purpose and reason why the 

Department is establishing this system of records is to examine the relationship between student 

learning outcomes and teachers’ preparation experiences. In particular, the study will address the 

following primary research questions: (1) What are the relationships between teacher preparation 

experiences and student outcomes in the first year of teaching? (2) What are the relationships between 

teacher preparation experiences and student outcomes of English learners in the first year of teaching? 

(3) Do relationships between teachers’ preparation experiences and student outcomes differ depending 

on teachers’ assessments of the usefulness of the preparation experiences?

The potential privacy risks from this system include any adverse consequences such as embarrassment 

to students or teachers from having their privacy-protected information used and disclosed by 

unauthorized means. To mitigate these risks, the system establishes strict rules, procedures and security 

requirements related to the collection, maintenance, use, disclosure, and destruction of the data, that are 

outlined in responses to other questions in this Privacy Impact Assessment (PIA) and in the System of 

Records Notice (SORN), which together will protect the sensitive student and teacher data collected for 

the purposes of this study from unauthorized use and disclosure.

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.

SSNs will be voluntarily collected from teachers. The SSNs will be used to obtain information on 

teachers’ postsecondary entrance exams from the College Board. The College Board will have a data 

sharing agreement in place that binds them to all of the confidentiality and privacy regulations pertinent 

to IES contractors.

As an alternative to the collection of SSNs, the Department considered asking teachers to self-report their 

postsecondary entrance exam scores. However, this is not feasible because teachers could have taken the 

exam up to eight or more years prior to data collection, in which case teacher reports could be subject to 

recall error.

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.

The intended use of the information is to examine the relationship between student outcomes and 

teachers’ preparation experiences. See response to question 4 for more information on the specific 

research questions that the information will be used to address. 

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Privacy Impact Assessment

To analyze the data and generate findings that meet Institute of Education Sciences research standards, 

quantitative statistical methods will be used. Data analysis will be conducted using data that have been 

stripped of identifiers (e.g., names), other than encrypted identifiers. Data or results that are reported or 

published will not contain any individually identifiable information. Any disclosures of information from 

the system will be made only in compliance with the requirements of section 183 of the Education 

Sciences Reform Act of 2002 (20 U.S.C 9573), the Privacy Act of 1974, as amended (5 U.S.C 552a) and 

the Family Educational Rights and Privacy Act (20 U.S.C. 1232g).

See response to questions 7 and 8 for information on internal and/or external uses and sharing of the 

information.

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?

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.

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?

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) Contract Disclosure. The Department may contract with a contractor to perform certain functions on 

behalf of the Department, which could require the disclosure of records in the system. The Department 

may disclose records to contractors (i.e., government contractors/employees) who have received the 

appropriate security clearance level from the Department. However, before entering into such a contract, 

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

respect to the records in the system.

(2) 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 on the following website: http://nces.ed.gov/statprog/instruct.asp.

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Privacy Impact Assessment

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? 

A Privacy Notice on data collection forms that meets the requirements of the Privacy Act, 5 U.S.C. 

552a(e)(3), is not required in this study since identifying information is being collected from the district 

and not directly from the students. No notice is required for teachers since those individuals are 

provided a consent form, as part of the study’s teacher survey, which informs them that the data 

collection is voluntary and that they do have the right to skip any question that they do not wish to 

answer. The teacher survey, which is administered online, collects teachers’ demographic information 

such as race and ethnicity, information on postsecondary institutions attended and teaching preparation 

experiences, and SSNs.

10. Web Addresses. 

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

None are planned.

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 is required by contract to establish a similar set of procedures at their sites to ensure 

confidentiality of data. The contractor 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 contractors 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.

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Privacy Impact Assessment

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 will be covered under an altered SORN, “Study of Teacher Preparation Experiences and Early 

Teacher Effectiveness” (18-13-29).

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).

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