Privacy Impact Assessment

for the

Graduate Assistance in Areas of National Need (GAANN)

Performance Report System

Date

April 3, 2012

Contact Point

System Owner: Katie Blanding, Director, SSB

Author: Rebecca Green, GAANN Program Manager

Office of Postsecondary Education

U.S. Department of Education 
Privacy Impact Assessment

Office of Postsecondary Education

GAANN Program Performance Report System

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US Department 

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1. What information will be collected for the system (e.g., name, SSN, 

address, income info, etc.)?

The Graduate Assistance in Areas of National Need (GAANN) program is a 

program that awards fellowships through academic institutions of higher 

education. Both the Annual Performance Report (APR) and the Final 

Performance Report (FPR) collect individual student records provided by the 

grantee institution. The individual student records contain such information 

as the student’s name, citizenship status, race and ethnicity, and education 

and financial data. 

2. Why is this information being collected (i.e., how is this information 

necessary to the purpose of the program?). 

The information contained in this system is being collected to assist in 

monitoring grantee performance and to determine program outcomes in 

response to the requirements of the Government Performance and Results 

Act (GPRA). GPRA does not specifically require the collection of individual 

participant records with personal information. However, to determine if the 

goals of the program are being met, the academic progress of program 

participants must be tracked over multiple years. Collecting name, citizenship, 

race and ethnicity, student education and financial information is the most 

reliable method for tracking a student during the grant period to determine 

program effectiveness and grantee compliance. Although the collection of this 

information is not required by statute, it serves a distinct business need of the 

Department. The collection of this information serves as an identifier for 

matching participant records during the period of the grant and tracking those 

students during the grant period. The information collected is compiled for the 

three program goals: 

1) Graduate school completion: the percentage of GAANN Fellows 

completing the terminal degree in the designated areas of national 

need; 

2) Enrollment of targeted populations: the percentage of GAANN Fellows 

from traditionally underrepresented groups; and 

3) Time-to-Degree: the median time to completion of Master’s and 

Doctorate degrees for GAANN students. 

Grantees are required to submit a supplement to the FPR two years after the 

expiration of their GAANN grant. This will provide updated academic and 

employment outcomes of each GAANN Fellow reported on the FPR

submitted two years earlier. The information collected will allow the program

to demonstrate the efficiency and effectiveness of the program. 
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3. How will this information be used (e.g., to verify existing data)?

The Department of Education (Department) uses APR and FPR data to: (1) 

evaluate program accomplishments; (2) demonstrate program effectiveness, 

and (3) aid in compliance monitoring.

Collecting performance report data on an annual basis provides the 

Department with the ability to assess each grantee’s progress in meeting the 

program’ s goals and objectives and to determine compliance with the statute 

and program regulations. APR and FPA data has also been instrumental in 

determining whether grantees are entitled to continuation funding by 

analyzing financial data submitted by grantees. 

The data collected from the FPR also produces data for the web-based 

software platform the Department uses that extrapolates data from the FPR in 

a consistent format. This data enables the Department to meet the 

requirements of GPRA. 

With the updates provided to the supplemental FPR two years after a grant 

ends, we will be able to capture updated academic and employment status for 

fellows previously reported. This will provide the Department with an 

opportunity to collect more complete performance data for GPRA.

4. Will this information be shared with any other agency or entity? If so,

with which agency or agencies/entities?

Department staff and one contractual employee have shared access to the 

performance-based data. The contractual employee maintains a web-based 

database to collect APR and FPR data and to develop reports to meet the 

requirements of GPRA. 

5. Describe the notice or opportunities for consent that are provided to 

individuals about what information is collected and how that 

information is used or shared (e.g., posted Privacy Notice).

Institutions of higher education that receive a GAANN grant are required to 

submit APR and FPR data. These OMB approved documents require 

grantees to submit student-level data on each student served. Institutions that 

use the program’s web-based software must read a statement, and login to 

access the system used for data collection. Prior to gaining access to the 

system, grantees must read the following notices:
Privacy Impact Assessment

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GAANN Program Performance Report System

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Warning

This is a United States Department of Education computer system, which 

may be accessed and used only for official Government business by 

authorized personnel. Unauthorized access or use of this computer system 

may subject violators to criminal, civil, and/or administrative action. 

Use of this network constitutes consent to monitoring, retrieval, and 

disclosures of any information stored within the network for any purpose 

including criminal prosecution. 

Privacy Act 

This system contains personal information protected under the provisions of 

the Privacy Act of 1974, 5 U.S.C. § 552a -- as amended. Violations of the 

provisions of the Act may subject the offender to criminal penalties.

6. How will the information be secured?

Performance-based data submitted by grantees contains confidential studentbased information. This information is collected through a secured Website 

that meets the Departments’ rules and standards for security of sensitive 

data. The data reside in a secured facility in a secured server behind a 

Department approved firewall system that continuously monitors for intrusion 

and unauthorized access. The IT contractor security staff is notified of 

Windows security updates and view server security status reports and applies 

updates as needed and uses anti-virus software on all servers and 

workstations.

The data collection site requires grantees to log in with a Department issued 

login ID and password. All screens and data transfers are encrypted and 

transmitted using HTTPS protocols. The IT contractor transfers the data to 

the analysis contractor via a secured FTP site. As with the IT contractor, the 

data analysis contractor’s security program is compliant with federal 

government regulation and NIST standards.

Only contractor staff that supports the data collection or data analysis and a 

small number of Department staff are allowed access to the data. Contractor 

staff has appropriate security clearances and also signs confidentiality and 

non-disclosure agreements to protect against unauthorized disclosure of 

confidential information. 
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7. Is a system of records being created or updated with the collection of 

this information under the Privacy Act?

No. This is an update of the PIA submitted with the information clearance in 

2009. The information collected is compiled to show grantee progress. We do 

not intent to have a system of records. One is not being created.