October  2020

On October 23, AERA joined 13 other member and partner organizations of the Postsecondary Data Collaborative (PostsecData) on a letter responding to the Federal Student Aid 2020–24 draft strategic plan. The comments, sent to Mark A. Brown, chief operating officer of Federal Student Aid (FSA) at the U.S. Department of Education, focused on privacy, transparency, and access with regard to federal student aid data for research.

“It is critically important to use high-quality data to understand inequitable outcomes among student groups and advance student success while also ensuring security and safeguarding students’ privacy,” said the letter. “We commend FSA for its commitment to creating a secure data environment and encourage you to consider ways to also overtly prioritize student privacy and continue to improve transparency.”

The letter requested that additional emphasis be given to issues of privacy, risk management, and data governance both at postsecondary institutions and at FSA. It encouraged FSA to “explore resources related to the ‘five safes’ framework and National Institute of Standards and Technology’s Privacy Framework, to marry its work on prevention of cybersecurity risks with recognition of privacy risks.”

The letter also recommended adding a new strategic objective—“Improve Insights Into and Understanding of Variations in Student Aid by Race/Ethnicity”—and disaggregating “Performance Metrics” by race/ethnicity and institution sector.

“These disaggregated data would offer a more comprehensive understanding of disparate outcomes, especially critical for Black students,” the letter said.

The letter also recommended that FSA couple its emphasis on transparency with increased access to data for researches, through privacy-protected microdata or research partnerships.