Chapter 3—Teaming Up: The Groups, Roles, and Responsibilities of Data Governance

In an education agency’s data governance system, a range of responsibilities may be assigned to staff to manage the collection, maintenance, reporting, and use of data. This chapter provides a more granular view of the practical workings of the process, detailing the personnel and activities involved; and describing a sample set of groups, roles, and responsibilities your organization may choose to assign in its data governance structure. The information is presented generically and should not be considered the only possible data governance structure. Rather, it is a suggested framework that may be adapted based on your agency’s specific needs, staffing capacities, and available resources.

Figure 3 presents a list of individual roles and groups that may constitute a data governance structure. As depicted in the figure, the data governance coordinator and data stewards work as individuals at the "core" of the data governance process. Several important peripheral roles may initiate, support, inform, or draw from the process.

Several groups should also work to drive the initiative forward, identifying data issues and collectively creating responses. As discussed in chapter 2, the core groups include the Data Governance Committee and the Data Steward Working Groups. Two peripheral groups, the Data Policy Committee and the Data Request Review Board, also serve important functions. The discussion below consolidates many activities into these four groups, though your agency may assign some of these tasks to additional groups.

Individual Role Descriptions

The following draws on the Tennessee Department of Education (draft 2008), DQC 2008, EIMAC 2008, and Rozelle 2006 and 2008.

Several players may be involved in a data governance structure, but a few roles are essential and should always be included. Specifically, every data governance structure should have a data governance coordinator, a group of data stewards, and a Data Management Committee. However, aside from these key functions, many of the roles and responsibilities may be assigned differently than in the manner outlined below.

What is important is not necessarily the roles you define, the titles you choose, or how the responsibilities are assigned to each individual. What matters is that all major responsibilities are clearly assigned and staff know their duties. In designating and managing these roles, at least three guidelines should be kept in mind:

• Develop and follow clear criteria for selecting staff members for each role. Careful assignment at the onset will help mitigate staff turnover later on.
• Provide ample support to help staff successfully meet their responsibilities. Getting everyone up to speed may take time, so persistence and patience are very important.
• Reexamine periodically why each role was designated and if each position is filled correctly. Make staffing adjustments if necessary.

Education chief (or other high-ranking staff member)

A high ranking executive such as the education chief, or other high-level executive should provide support for the data governance initiative. Some of this staff member’s specific data governance-related responsibilities may include

• participating in Data Policy Committee meetings;
• mandating staff participation in data governance groups; and
• exercising authority to enforce contentious decisions.

Chief information officer

The chief information officer (CIO) usually initiates the data governance process within the organization; and should take the important early steps to establish the initiative and the team. Thereafter, the CIO should remain heavily involved in many of the structure’s ongoing activities. Some specific data governance responsibilities may include

• seeking executive support for the data governance initiative;
• forming, and serving on, the Data Policy Committee and the Data Governance Committee;
• working with the Data Policy Committee to develop the data governance policy;
• appointing the data governance coordinator;
• working with the data governance coordinator to identify the data stewards; and
• working with the Data Governance and the Data Policy Committees to identify and resolve critical data issues that require leadership support.

Data governance coordinator

One individual should lead the data governance process: the data governance coordinator, perhaps the most important player in the data governance structure. In fact, no agency should undertake data governance without this single overseer. The coordinator should drive the data governance agenda, direct data steward activities around data quality efforts, and ensure that data issues are resolved. Many data governance efforts fail due to a loss of momentum, and the data governance coordinator must work as a catalyst to keep the initiative moving (NASCIO 2008). This individual must focus on the mission of the group, keeping an eye on the organization’s overarching goals, following timelines and managing deliverables, reinforcing the principles of good data stewardship, and working with staff to determine how the agency can better handle its data. The coordinator must stay positive throughout the process because data governance involves significant culture change and this can be hard on staff morale: the constant scrutiny and the focus on improving agency practices can be disheartening. The coordinator must assure everyone that this is necessary and will benefit the agency in the long run. Some specific data governance responsibilities may include

• working with the CIO to identify the data stewards, maintain the data steward roster, and train and oversee data stewards’ work;
• working with the CIO to form the Data Governance Committee;
• leading the Data Governance Committee, including scheduling and facilitating meetings, preparing agendas, tracking and following up on action items, and recording and distributing minutes;
• participating in the Data Policy Committee meetings by taking data issues to leadership;
• convening, and participating in, the Data Steward Working Groups to resolve shared data issues (though individual data stewards should take on greater leadership responsibilities as the data governance process matures).
• working with the Data Governance Committee to identify, track, and resolve critical data issues—maintain a log of these issues and ensure a data steward is accountable for resolving each one (see appendix D for a sample critical data issues log);
  
  

  LDS Lore: Guns and governance

  In its Sunday issue, the county newspaper reported that a local school had recorded ten firearm incidents during the previous school year. The following morning, the school was a ghost town. Frantic parents flooded the office with calls, demanding to know why they had not been notified of these incidents. The staff assured callers that the article was wrong and children could safely return to school: there had been no firearm incidents in the school’s history. Zero. A call to the newspaper revealed that the reporter found the information on the state’s website. Sure enough, after a few mouse clicks, the school principal located the error. But how could this have happened? At the state level, the problem was traced back to three possible staff members, but all three said that reviewing those particular data was someone else’s job this year. A call to the district found similar confusion: no one could figure out who had dropped the ball there either. Further sleuthing found that a simple typo by an overworked school office staffer had made its way through the quality assurance efforts of both the district and the state, and into the state’s LDS. One thing was sure: a pervasive lack of clear roles, responsibilities, and procedures had clearly caused the education community a lot of embarrassment, not to mention unnecessary anxiety at the school.

  
  
• providing support to data stewards and other staff to ensure all involved know their responsibilities and are capable of meeting them;
• facilitating internal communication and collaboration about data quality issues between program areas, and between program areas and technology;
• facilitating communication with districts by serving as the main point of contact for data topics; and serving as the district liaison if a state program area undermines or deviates from the data governance policy (e.g., a program area makes a duplicate data request or provides inadequate notice before making changes to a collection);
• working with the Data Governance Committee and the IT division to develop and review standards for data elements (see chapter 6);
• maintaining a data collection and reporting calendar;
• creating and managing the data request approval process to ensure the accuracy and security of shared data (alternatively, the Data Request and Review Board may be responsible for this activity); and
• participating in national data conferences and member associations to stay abreast of best practices.

The "data owner"

Some agencies distinguish “data owners” from “data stewards.” The “owners” may be program area directors assigned particular, higher level authority for specific sets of data, while much of the work related to managing those data is assigned to the "steward." Whereas in the simpler data governance structure proposed in this chapter, these responsibilities are assigned to the data stewards, many agencies find this additional level to the hierarchy helpful, even critical. If your agency adopts this extra level of authority, each data owner must support the data governance process and understand that two-way communication with the data stewards is vital. A good rule of thumb is to keep the data governance structure as simple as possible, but whether or not that means adding another level of authority depends on the agency. Specifically, the data owners’ responsibilities may include participating in the Data Governance Committee; working with the IT division (specifically the security team) to determine the level of security required for each data element they "own"; and approving all requests for the data for which they are responsible.

Data stewards (a.k.a. data managers)

Data stewards should be selected to manage the organization’s data, with a single steward charged with managing the data and held accountable for ensuring the quality of specific data elements within a particular program area. It is critical that every data element be the responsibility of a single data steward. Note that some agencies divide the steward’s role into two levels, including the additional role of data owner in their data governance structure as discussed in the box above (KSDE 2008). Some specific data governance responsibilities may include

• participating in the Data Governance Committee (if there is one, this may be the responsibility of the data owner);
• identifying and resolving critical data issues involving the data in their charge;
• participating in Data Steward Working Groups to collectively resolve data issues;
• working with the data governance coordinator to develop and review standards for data elements (see chapter 6);
• evaluating data quality (integrity, timeliness, accuracy, and completeness) and management (storage, reporting, adherence to policies, and data architecture);
• implementing data quality standards and all decisions of the Data Governance Committee;
• ensuring that the data dictionary and the data collection and reporting calendar contain the most current information about their data elements;
• documenting and updating metadata related to data elements for which they are responsible;
• working with the IT division (specifically security) to determine the sensitivity of each element and the corresponding level of security and access rights required (while the security team may lead this process, stewards should have substantial input; if data owners are a part of the structure, they may fulfill this task instead of the data stewards);
• assisting users with the use and analysis of data;
• communicating to districts any changes in the way data will be collected, calculated, or reported;
• approving the release of data (for internal or external use);
• identifying opportunities to share and re-use data (e.g., for federal or state reporting); and
• staying abreast of laws that impact their data.

Public information officer

The public information officer (PIO) identifies and communicates data of interest to the public, and responds to data requests from the press. The PIO should be a member of the Data Governance Committee to stay apprised of data issues, and knowledgeable about ownership and data-sharing procedures. However, PIOs are not data stewards because they are not responsible for any data. When responding to press requests, agency procedures must be followed and data should be released only by the appropriate data steward to reduce the risk of inconsistent or inaccurate information. The PIO may also contribute to the Data Governance Committee by sharing news of any emerging public interest in certain types of data. (This role may also be fulfilled by the communications officer or other staff member with public relations responsibilities.)

Local education agency representative

As they are the source of all data the state agency collects, schools and districts should actively participate in the data governance process to ensure that local perspective informs all decisions. For instance, district representatives will know whether a proposed change to a collection can reasonably be met, and may suggest alterations to facilitate district compliance. Local education agency (LEA) staff can also offer information about district contracts, software, workload, and costs. They can help the state create solutions that will improve its communications and relationships with districts, and effectively decrease the local reporting burden. In addition, participating in the state’s data governance process will help increase the districts’ awareness of the importance of data quality and provide a model that could be implemented at the local level. At least one LEA representative should sit on the Data Governance Committee, but several would be preferable for a more rounded local perspective (representing districts of various sizes, from different geographic regions, etc.). Some states create an external group of districts and others, such as noneducation state agencies, specifically to review proposed changes to data collections. Some specific data governance responsibilities may include

• participating in the Data Governance Committee (as a member, not as a data manager); and
• participating in Data Steward Working Groups to resolve data issues that directly involve the relationship and communication between the state agency and districts.

LEA representative selection

State education agencies (SEA) may find it useful to recruit local education agency (LEA) representation in the governance structure to increase perspective. To identify possible candidates, ask state program area leaders to identify district staff who contact them frequently about data (both with questions and with suggestions for improving collections—LEA representation will ideally come from both ends of the spectrum); care about data accuracy even when the data do not flatter the district; and have a program area, rather than a technology, background.

LDS Lore: The effects of disorder trickle down

The districts were accustomed to supplying the state with a lot of data. Sure, they had to provide the same information multiple times, with some of the elements reported in both student-level and aggregate forms. Sure, changes to data collection requirements were often decreed without prior notice, and confusion about what was required and when it was due. And no, they didn’t really get much out of the deal—sending data to the state, but never getting anything useful back. If they realized the data were wrong due to a local or a state mistake, local staff often didn’t know whom to contact; and even state staff had trouble directing them to someone who could help. Since the state’s system didn’t meet local data needs, the district spent its time and money maintaining its own records, while grumbling about the state’s shortcomings. Unbeknownst to the districts, however, the state was implementing a data governance process. Gradually, word got around that several local representatives were working with the state to improve operations. Districts cheered the first sign of change: an email to the districts listing all of the state’s data stewards. Finally, district staff knew whom to call if they had questions about a particular program area or submission! Next came a data collection calendar accompanied by a notice that several of the state’s data collections were being eliminated or pared down due to redundancy. District staff gave a collective sigh of relief: not only was some burden being lifted, but they finally had an authoritative source of collection due dates. Of course, data governance hadn’t solved every problem, but it was quickly and noticeably improving operations as well as the districts’ relationships with the state. At the state level, goodwill and better data from the districts were confirming that their efforts were bearing fruit.

Federal reporting coordinator

The federal reporting coordinator oversees the federal reporting activities across the agency and, as such, should be involved in the data governance process. Some specific data governance responsibilities may include

• participating in the Data Governance Committee (as a member, not as a data manager);
• providing periodic updates on federal reporting to the Data Governance Committee; and
• working with the Data Governance Committee to address issues related to federal data submissions.

Business analysts

In essence, the business analyst resides at the border between the business and technology sides of the agency and, within the organizational structure, may be in either area. Acting as a link between the two domains, the analyst harvests, assembles, and translates business needs into foundational technical specifications. One of the agency’s business analysts should actively participate in the data governance process. Some specific data governance responsibilities may include

• participating in the Data Governance Committee (as a member, not as a data steward);
• working with Data Steward Working Groups to design the technology component of the solutions developed to resolve data issues; and
• reviewing data element and technology standards.

Business first, then technology

Program areas should lead the data governance process. Good data governance forces business staff to think more deeply about their needs. If the content area experts don’t think through the data’s purpose, definitions, and standards, IT will inevitably make assumptions in order to get the job done. If their assumptions are wrong—a common occurrence that is not the fault of IT—data quality will suffer and undue burden could be imposed on school districts. For instance, if a business rule is defined incorrectly (should a student who doesn’t earn a high school diploma but enrolls in college be counted as a dropout?) or if the option set for an element does not meet business needs (allowing “Null” in error, for instance), the resulting data may be problematic or even useless. In creating new specifications or amending existing ones, program area staff should work out the business solution to the very last detail, leaving no room for guesswork. Only then should IT be asked to determine how to implement the solution with technology.

Data Governance Groups

The following draws on the Tennessee Department of Education (draft 2008), DQC 2008, EIMAC 2008, and Rozelle 2006 and 2008, Chatis Consulting, and KSDE 2007.

In addition to the individual roles involved in the data governance structure, several groups of policymakers, data managers, and other stakeholders should be convened to address data issues collectively. When data issues affect multiple program areas, all affected stakeholders should be included to formulate the best response. These groups also help foster coordination and shared decisionmaking, ensuring that the agency approaches data issues consistently across program areas and over time.

Data Policy Committee

The Data Policy Committee is a group of executive management stakeholders that may include the education chief (or other high-level staff member), the chief information officer, the data governance coordinator, and executive leaders from each program area that has data stewards. Rather than creating a new committee, it would be preferable to identify an existing group that includes these members and insert a standing time slot during regular meetings to focus on data governance issues. The relationship between this group and the Data Governance Committee (see below) is the critical link between leadership and those working directly with the data. The Data Policy Committee provides high-level sponsorship of the initiative as well as leverage for implementing major data-related decisions affecting multiple program areas. This committee also puts the executive “stamp of approval” on new or amended policies. Additionally, decisions that are contentious or beyond the authority of the Data Governance Committee should be referred to this committee for an authoritative resolution. For example, if staff resists a decision made by the Data Governance Committee, the Data Policy Committee can provide the authority to enforce it. Policies that significantly change the organization’s handling of data and data collections should also be discussed by this committee. This relatively small group need not meet as frequently as the Data Governance Committee, perhaps once every other month. Some specific data governance responsibilities may include

• establishing the data governance policy to guide the agency’s efforts;
• selecting the data governance coordinator;
• establishing the Data Governance Committee;
• approving data policies and major data-related decisions referred by the Data Governance Committee; and
• identifying critical issues to be resolved by the Data Governance Committee.

Data collection and reporting calendar

Led by the data governance coordinator, the Data Governance Committee should create and maintain a comprehensive, up-to-date calendar of data collection and reporting. The calendar should document and detail all current and planned data collections, including due dates, descriptions of the data and their uses, collection format, and the staff member responsible for each submission. This resource should be made available to all staff and to the public. Additional resources: Tennessee Data Collection Calendar (2005) This is a sample data collection calendar developed by the state of Tennessee South Carolina Data Collection Manual (2006–2007) This manual lists the data elements collected from the School Administrative SIS by the South Carolina Department of Education. Also included is a table of the various collections, a table describing how the data were used in 2005–06, and a table listing the offices in the department that use the data.

Data Governance Committee

The Data Governance Committee is the center of control in the data governance structure, accountable for the quality of all agency data. It is an enterprise-wide group of data stewards chaired by the data governance coordinator. Ideally, the committee will also include the chief information officer, the public information officer, the lead business analyst, and at least one district representative (though involving multiple districts is preferable). Depending on the scope of the desired data system, this group may also include representatives from other external organizations, such as higher education; and other agencies, such as labor and child services. By including a variety of stakeholders, this group facilitates the collaboration necessary to address shared data issues. Meetings should occur frequently, perhaps monthly or even more if necessary. An effort should be made to make this group act as a resource for data stewards, rather than an obligation. Some specific data governance responsibilities may include

• creating a clear mission statement to guide the group’s data governance plan (see appendix D for a sample mission statement);
• working together to identify, prioritize, track, and resolve critical data issues;
• identifying the primary, authoritative sources of each data element (where multiple sources exist), and determining authoritative definitions and values for each data element;
• creating a schedule of deadlines for proposed changes to data collections;
• approving all new data collections and changes to existing collections—a group of district representatives and other affected stakeholders (e.g., other state agencies) should be involved in this process of "change management" (see the Change management box later in this chapter);
• creating and maintaining a data collection and reporting calendar;
• eliminating the collection of redundant or unnecessary data—agencies may conduct periodic sunset reviews to evaluate the continued need for every data element it collects; this sizeable task may also be assigned to a separate working group (see the Change management box later in this chapter);
• creating Data Steward Working Groups to address shared data issues that affect or involve multiple program areas;
• recommending new policies and policy changes concerning the management, quality, security, and use of data to the Data Policy Committee (via the data governance coordinator);
• overseeing the implementation of the work dictated by data-related policies;
• establishing standard business rules for data collection, sharing, and reporting to streamline operations across the enterprise;
• working with the agency’s security team to determine the sensitivity of each element and the corresponding level of security required;
• referring data issues beyond the committee’s authority to the Data Policy Committee (via the data governance coordinator);
• facilitating communication and collaboration about data issues across the agency between data stewards and other staff, and with districts and other external organizations—a standard process for communication should be created and followed, including standard form(s) and frequency of communications; and
• reviewing and approving standards for data elements with the IT division.

If the Data Governance Committee does not include much representation from districts and other affected stakeholders, the agency may adopt other strategies for collecting their feedback. For instance, it may hold in-person or online meetings with districts and other affected groups to periodically review proposed data collection changes. It is beneficial to include both program area and technology staff from each agency in these meetings. Alternatively, a separate group of state staff and affected external stakeholders may be formed to take on the responsibility of considering and approving proposed changes.

Data Steward Working Groups

The Data Steward Working Groups are formed by the Data Governance Committee to resolve critical data issues that span more than one program area. Basically teams of data stewards, the groups work together to collectively identify the source of each issue and develop a solution that addresses each program area’s needs. While all members of a working group should contribute to formulating solutions, one steward should be responsible for ensuring that the team creates and implements an effective solution. (See appendix D for guidelines for Data Steward Working Group activities.) As Chatis Consulting explains, specific data governance responsibilities may include

• defining and documenting the source (not the symptoms) of the shared data issue (communication breakdowns, technology issues, unclear definitions, etc.);
• defining the goals of resolving the issue (why the problem should be solved);
• creating mini-projects to resolve the problem, including well-documented steps, roles, and due dates;
• providing monthly updates to the Data Governance Committee;
• notifying the data governance coordinator of issues beyond the Data Governance Committee’s authority so they can be referred to the Data Policy Committee;
• collaborating with IT to implement the business solution to the issue; and
• documenting and communicating the solutions to the Data Governance Committee.

LDS Lore: The committee becomes a resource

When the agency began its data governance initiative, Gary was tapped as his program area’s data steward. He was less than thrilled to find out he’d need to attend a monthly meeting with other stewards and staff from other program areas. At the first meeting, he must have rolled his eyes a dozen times. “What a waste of time,” he thought. He had a ton of work to do and needed to call one of the districts as its data were on the verge of being late for the third cycle in a row. Towards the end of the meeting, Patti, the woman from the English language learner team asked, “Is anyone else having trouble with the district over in Stuckeyville?” Gary perked up. “Oh, yeah,” he said. “The guy Steve over there never returns my calls and they’re two days away from their deadline.” “Forget about Steve. Call Fran. She’ll help you out,” Tara, another data steward, suggested from the other end of the table. The room erupted as more and more participants began sharing stories and offering tips. At the next meeting, one of the stewards, Christina, mentioned “master data management.” “Sorry, but what on earth is master data management?” Tara asked. Most sat silently, a few shrugged; finally, Christina explained what she knew about the subject. Gary jumped in, “So, it’s kind of like horizontal integration?” "I don’t know. What’s that?” Steve asked. Yori, the data governance coordinator, suggested they set up a professional development session. It seemed everyone was at least a little unclear on the subject. Thanks to conversations like these, Gary and the others started looking forward to the meetings, which they now saw as a resource, and a sense of camaraderie began to form. Staff from previously isolated program areas started helping each other as they realized they shared many of the same problems. The Data Governance Committee had shown them they were not alone.

Change management

While getting a handle on the agency’s data early on in the LDS development process is very important, as time goes by, it becomes clear that managing the changes made to the system is also crucial and challenging. As a result, some have developed sophisticated approaches to manage these changes. System changes sometimes impose additional costs and burdens on districts, and introduce data quality challenges. And poor management of change can also be a source of tension between a state agency and its districts. For these reasons, a systematic approach to managing change with the involvement of representatives from school districts and other affected stakeholder groups is essential for the long-term success of the LDS. Create annual schedules of deadlines for program areas to submit requests for additions or changes to data collections. Establish data governance group(s) to review all proposed changes to the agency’s data collections. Invite a large and varied group of district representatives to provide feedback on changes. This local perspective will inform better solutions. Clearly communicate all changes to districts as early as possible. Effective communication strategies include district staff involvement in the data governance process; periodic training for regional or district staff and school district vendor staff on changes to the data collections such as alterations to record structures, reporting requirements, business rules, standards, edits, etc.); Web meetings; and prominent, public online posting of new documentation such as new standards, due dates, etc. Conduct periodic sunset reviews to evaluate the need for every data element the agency collects. Justify the continued collection of each element and record, considering whether the item is required by state or federal law, or is otherwise useful to the enterprise. Eliminating unnecessary data items decreases reporting burdens and increases data collection efficiency. A lesson from Texas The Texas Education Agency has been collecting student-level data for nearly two decades. Early on, the agency realized how difficult and costly districts found complying with changes to the state data collection (new data elements, altered codes sets, etc.). The state quickly grasped the need to systematically manage the changes by involving districts and other stakeholders in the process, and effectively communicating all modifications across the enterprise. Putting its plan into action, the state created a data governance structure that includes two groups of external staff focused on managing changes to the state’s data collections. One group, the Information Task Force (ITF), includes representatives from districts, regional education agencies, and other organizations; and receives all proposed changes to the agency’s data collections, including sunsets. Approved changes are referred to the second group, the Policy Committee on Public Education Information, which includes representatives from school districts, regional education agencies, and several state agencies (the Office of the Governor, Office of the Speaker of the House, the State Auditor’s Office, and others). This committee considers all changes recommended by the ITF and either approves, denies, or suggests alternatives to each proposal. In addition, every two years, the agency conducts sunset reviews of all of its data elements and records. During these reviews, a group of agency data managers and program area staff evaluate the need for each and every data item. The findings are presented to the state’s data governance committees with, for each item, a justification for continued collection (including descriptions of data usage and any state or federal collection mandates) or a proposal to cease collection. Finally, revised standards (definitions, code sets, etc.) and collection requirements (submissions and resubmissions timelines, record layouts, edits, etc.) are created and posted prominently on a public website. All changes to collections and resulting state reports are also highlighted in periodic training sessions with district, regional, and vendor staff. This process has been very effective in reducing district burden, and ensuring that districts and their vendors have ample time to prepare for collection changes. Source: The above is largely based on input from the Texas Education Agency (TEA), May 2009. For more information, visit TEA’s Public Education Information Management System

Data Request Review Board

A Data Request Review Board may be formed to manage the data-sharing process and to handle data requests, which are likely to increase dramatically once the agency starts collecting student-level longitudinal data. This group of directors, legal counsel staff, and data stewards (or data owners) should meet monthly. Some specific data governance responsibilities may include

• creating and enforcing policies and procedures for handling data requests that standardize the review of, and response to, data requests (for instance, standard criteria for approval and denial, such as legality under privacy laws and potential benefits to the educational system);
• documenting all approvals and denials of information requests—in addition to internal recordkeeping, this allows staff to more easily identify common data requests that might be fulfilled through a data mart or other “self-service” resource, and it fulfills the recordation requirement under the Family Educational Rights and Privacy Act (FERPA);
• prioritizing approved data requests based on factors such as merit and staff capacity;
• referring requests to appropriate data stewards, ensuring consistency in data sharing;
• monitoring the flow and completion of requests;
• referring issues to the Data Governance Committee as needed; and
• supporting data-for-fee service—if a request will not benefit the education system, or is frivolous or especially time-consuming (for example, the requestor asks the agency to reformat existing data to meet their needs), the agency may decide to charge a fee to offset the costs of processing the request.

Whether or not the agency forms this group, clear policies and processes for handling data requests should be developed. Establishing standard processes at the onset will increase efficiency and help avoid improper data sharing. (Kansas State Department of Education 2008)

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