Forum Guide to Protecting the Privacy of Student Information: State and Local Education Agencies

3.B. Justifying Data Collection

In general, schools and education agencies are not restricted in what they may request about students; this is determined by state laws and regulations, and the policies of the school, district, or state education agency. However, federal law (i.e., the Protection of Pupil Rights Amendment [PPRA]) does specify several types of questions that cannot be asked without prior consent of the parents. (See section 2C for a detailed discussion.) A good practice is to collect and maintain in the education records only those data for which a clear and specific purpose has been identified.

In deciding what data can be requested from individuals, first consider several important and practical factors. Data collection can be a burden on the data providers if too many questions are asked or the completion of the form is too time-consuming. If the way in which questions are asked makes it unclear what information is requested, the accuracy of the data may be undermined. An important rule of thumb in data collection is that the data need should outweigh data burden and collection problems. Justification for data collection could include what methods will be used to guard against nonresponse, inaccuracy, privacy intrusion, and infringement of information security.