· Web viewThe purpose of the Quad Cities Data Warehouse (the “Data Warehouse”) is to facilitate the creation and maintenance of a master regional data set of individual-level

THE QUAD CITIES DATA WAREHOUSE

FERPA Protections Data-Sharing Agreement

between

St. Ambrose University

United Way of the Quad Cities Area

QCDW FERPA Protection Data-Sharing Agreement 1

Bettendorf Community School District

Davenport Community School District

East Moline School District

Moline/Coal Valley School District

North Scott Community School District

Pleasant Valley Community School District

Rock Island/Milan School District

United Township School District

Mississippi Bend Area Education Agency

1. THE PURPOSE OF THE QUAD CITIES DATA WAREHOUSE PROJECT. By signing this Agreement, the participating school districts (“Districts”) and the Mississippi Bend Area Education Agency (“AEA”) confirm their understanding that:

1.1. The purpose of the Quad Cities Data Warehouse (the “Data Warehouse”) is to facilitate the creation and maintenance of a master regional data set of individual-level identified data from multiple sources. This master regional data set will be used to link together individual-level data from two or more sources in order to conduct local, real-time research designed to identify and address community needs for the citizens of the Quad Cities area. This research may include such activities as the measurement and segmentation of current gaps in student achievement, the testing of new or adjusted interventions to address those gaps, or the development of predictive models to allow for the creation and application of preventative interventions.

1.2. Participation in this Data Warehouse project on the part of the Districts and AEA entails providing individual-level and individually-identifiable data to Saint Ambrose University (“SAU”) for the purpose of creating cross-district analytical data sets for identifying disparities, tracking student outcome measures, research, and/or evaluation of interventions of students in the Quad Cities area.

1.3. Individual-level data uploaded into the Data Warehouse is collected solely for the purposes of aggregation. The Data Warehouse is not intended to be used as, and will not be used as, a tool for tracking and assigning services to individual students.

2. THE PURPOSE OF THIS AGREEMENT. This Agreement is one of many which will govern the operations of the Data Warehouse. The specific purpose of this Agreement is to codify and confirm agreement on those restrictions on the Data Warehouse designed to protect the privacy rights of all students, and the confidentiality responsibilities of the Districts and AEA, in the handling of student data, as mandated by the Family Educational Rights & Privacy Act (FERPA”).

2.1. In accordance with the research provision of FERPA (20 U.S.C. § 1232g; 34 CFR 99:31), the Data Warehouse will have access to individual-level identified data only for the purpose of conducting research studies for the benefit of the students of of the Districts and the AEA. FERPA-protected data in the Data Warehouse will not be used for any other purpose.

2.2. The value to the Districts for participating in the Data Warehouse is:

2.2.1. To be able to coordinate data from multiple districts (and across the Illinois-Iowa border) to create regional data points for deeper analysis of community issues and possible solutions to those issues.

2.2.2. To facilitate multi-year comparison studies and cohort tracking by keeping community-wide measurements of core educational outcomes comparatively constant from year to year, even as district, state, and federal measurement practices change.

2.2.3. To better track longitudinal educational outcomes for students even if they move from one district in the Quad Cities area to another, as is typical of our community’s lowest-income families.

2.3. Other documents that govern the operations of the Data Warehouse project include The Quad Cities Data Warehouse: Standards of Practice and Operation (the “SOPO”), a complete copy of which is attached hereto and incorporated herein as Attachment B. Note that all signatories to this Agreement are confirming their understanding of, and agreement to abide by, the protocols, restrictions, and procedures outlined in the SOPO and all other agreements, current or future, which govern Data Warehouse operations.

3. PERIOD OF AGREEMENT. The Data Warehouse project will last a minimum of ten years from first data collection, which took place in August 2014. This Agreement shall be in effect from the date of signature until July 31, 2024, or until terminated in writing by the United Way of the Quad Cities Area Education Council.

3.1. All data collected will be maintained and kept secure throughout this timeframe.

3.2. The Data Warehouse project may be extended after this date by agreement of participating parties, either through a continuance or by the drafting of a new partnership agreement.

4. PARTIES TO THIS AGREEMENT AND ROLES. The Data Warehouse organizations will carry out the following roles in their handling and processing of FERPA-protected data:

4.1. St. Ambrose University (“SAU”) will serve as the lead organization for the Data Warehouse project: housing, staffing, and overseeing the day-to-day operation of the Data Warehouse. SAU staff will supervise all data uploads into the system, and carry out any requests for data draw-downs (as defined in the SOPO) in accordance with the restrictions outlined in the SOPO (see Attachment B). Only designated staff members of SAU who have signed the required confidentiality forms (see Attachment C) are allowed to view FERPA-regulated data from all Data Warehouse contributors, and then only in carrying out the specific work of the Data Warehouse.

4.2. The School Districts (“Districts”) will be contributing specific student-level, individually-identified school district data to the Data Warehouse upon request, in accordance with the research provision in the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR 99:31) and the conditions of this Agreement. As spelled out in this Agreement, and the SOPO, ownership of the data remains with the individual District which submitted it, and no data will be released from the Data Warehouse for any purpose, nor using any other process for approval, other than those outlined in this Agreement.

4.3. Mississippi Bend Area Education Agency (“AEA”) will be managing accounts in the National Student Clearinghouse for all participating Districts for the purpose of contributing specific student-level, individually-identified post-secondary performance data to the Data Warehouse upon request, in accordance with the research provision in the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g; 34 CFR 99:31) and the conditions of this Agreement.

4.4. United Way of the Quad Cities Area Education Council (“Education Council”) will serve as the body that guides and monitors the operation of the Data Warehouse, in accordance to Provision 6.3 of the SOPO (see Attachment B). All Education Council decisions are subject to approval by the United Way of the Quad Cities Area Board of Directors.

4.4.1. Participating District Superintendents will serve on this body to oversee the project and have a voice in the decisions about the release of data.

4.4.2. Note that the Education Council’s role in Data Warehouse operations does not permit individual members of the Education Council, nor the Education Council as a whole, nor the members of the United Way of the Quad Cities Area Board of Directors, nor the United Way of the Quad Cities Area Board of Directors as a whole, to have access to individual-identified nor FERPA-protected data under any circumstances.

4.5. Assorted Quad-Cities-Area Social Service Agencies (“Agencies”) will also be invited, by the Education Council, to submit their own internal assessment data into the system. The Social Service Agency Data-Sharing Agreement and Guidelines for Use of FERPA-Protected Data agreement (the “Agency Partner Data Agreement”) (see Attachment D) outlines the restrictions governing the interactions between the Agencies’ data and the FERPA-protected data contributed by the Districts and AEA. All Agency Data Warehouse partners must enter into an Agency Partner Data Agreement as a condition of participating in the Data Warehouse project.

5. DATA WAREHOUSE PARTNER PERSONNEL.

5.1. District and AEA Data Warehouse Points of Contact.

5.1.1. The Districts and AEA will each appoint one or two individuals to serve as the main point of contact between their organization and the Data Warehouse Personnel. This person will be designated as that partner organization’s “Data Steward.”

5.1.2. The Districts and AEA are responsible for the collection, verification, and transmission of their own data as outlined listed in Attachment A of this Agreement, and agree to provide appropriate staff support to carry out these duties, and to cover any costs which arise from these activities.

5.2. SAU Data Warehouse Personnel Roles and Responsibilities. For all Data Warehouse operations, SAU will assign an appropriate and qualified staff member to perform the roles of “Data Warehouse Research Project Consultant” and “Data Warehouse Data Steward.”

5.2.1. SAU Data Warehouse Research Project Consultant. On behalf of the Districts and AEA, the Data Warehouse Research Project Consultant’s duties will include:

5.2.1.1. Overseeing the day-to-day functions of the Data Warehouse and ensuring that all operations comply with Federal law, the terms of this Agreement, and the dictates of the Education Council.

5.2.1.2. Reviewing all requests for data draw-downs to determine whether the request is a valid one, in accordance with Provision 10 of the SOPO, (see Attachment B).

5.2.1.3. Giving final approval for data draw-down requests.

5.2.1.4. Giving a final review of all Data Warehouse Findings (as defined in the SOPO) before they are released to the Data Warehouse partner which requested them, to ensure that the numbers are accurate and are appropriately represented.

5.2.1.5. Reviewing the language of all public releases of Data Warehouse results in accordance with Provision 11.2.2 of the SOPO (see Attachment B).

5.2.1.6. Making regular reports to the Education Council of all approved data research requests and the results of all approved data draw-downs.

5.2.2. SAU Data Warehouse Data Steward. On behalf of the Districts and AEA, the Data Warehouse Data Steward’s duties will include:

5.2.2.1. Serving as the main point of contact between the Data Warehouse and the assigned data stewards of AEA and each District, as outlined in Provision 8.3 of the SOPO (see Attachment B).

5.2.2.2. Serving as the liaison between the District and AEA data stewards and the company overseeing the mainframe where the Data Warehouse data are stored.

5.2.2.3. Monitoring and protecting the security of the Data Warehouse, and limiting access to all Protected Information as specified in Provision 9.4 of the SOPO (see Attachment B).

5.2.2.4. Reporting any compliance issue or breach to the Data Warehouse Research Project Consultant immediately upon discovery of such compliance issue or breach, as specified in Provision 9.5 of the SOPO (see Attachment B).

5.2.3. In addition, the Data Warehouse Research Project Consultant and the Data Warehouse Data Steward may involve one or more research assistants to assist in a support role with various tasks under this Agreement and any approved Data Use Agreements executed under this Agreement, so long as these research assistants sign and adhere to the conditions of the Confidentiality Agreement in Attachment C.

5.2.4. The Education Council, Districts, and AEA will be informed in writing of which SAU staff member(s) are assigned to each role as well as to any changes in staffing for these roles.

5.2.5. Parties agree that both assigned roles may be performed by one staff member, or more than two staff members, as is most convenient and expedient for SAU.

6. TERMS AND DEFINITIONS.

6.1. FERPA-Protected Data. In accordance with the Family Educational Rights & Privacy Act, “FERPA-protected data” is defined as any information collected by the Districts or AEA on behalf of their students through which an individual student may reasonably be identified from out of the general population. Note that this definition includes so-called “directory information,” defined as “an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed.” For further guidance, consult Provision 34 C.F.R. Part 99 of the Code of Federal Regulations.

6.2. Primary Data Set. The “Primary Data Set” is the full contents of the Data Warehouse at any given time, consisting of the individual-level data uploaded by the Data Warehouse Partners, any cohort identifications and data set linkages created by the Data Warehouse, and any Data Warehouse findings generated from these data linkages. The data fields to be contributed to the Primary Data Set by the Districts and AEA are listed in Attachment A to this Agreement.

6.3. Linked Data Sets. A “Linked Data Set” is defined as any action within the Data Warehouse that matches, correlates, or blends individual-level student data which has been provided by two or more separate partners in the Data Warehouse project. The Data Warehouse was created specifically to make such data linkages possible. SAU warrants that no Linked Data Sets will be created except under the direction of the Education Council and/or in response to an approved research request (see Provision 10 in the SOPO, Attachment B), and that all data released from the Data Warehouse will be in aggregate, not-individually-identifiable form (see Provision 4.8.4 in the SOPO, Attachment B).

7. TIMING AND FREQUENCY OF DATA UPLOADS. The Districts and AEA agree to provide the data specified, and by the deadlines specified, in Attachments A to this Agreement. The primary method of data sharing will be through an FTP upload of data in CSV format into the Data Warehouse system. See Provision 8 of the SOPO (Attachment B) for the policies and procedures for data uploads.

7.1. In addition, the Data Steward appointed at AEA will receive a data upload directly from the districts annually, identifying the students who completed high school in the previous school year. AEA is empowered to upload information from these data sets into the Data Warehouse on behalf of the Districts as part of their own upload commitment, and do so without violation of the FERPA responsibilities of the Districts involved nor the students whose data is so transferred. For more guidance, see Attachment A, Section II.A.

8. SAU’S CUSTODIAL RESPONSIBILITY AND DATA STEWARDSHIP. The parties mutually agree that SAU will be designated as the custodian of FERPA-protected student data and will be responsible for the observance of all conditions for use and for the establishment and maintenance of security arrangements as specified in this Agreement to prevent unauthorized use.

8.1. By signing this Agreement, the Districts and AEA give their permission for SAU to store and manage FERPA-protected data on their behalf, in accordance with the policies and restrictions outlined in Provisions 8 through 11 of the SOPO (see Attachment B). The Districts further permit individual SAU employees, so designated by SAU administration, to view and conduct research with these FERPA-protected data without any violation of FERPA, so long as those employees have signed, and abide by the conditions set forth in, the Individual Confidentiality Agreement (Attachment C).

8.2. SAU is hereby informed and agrees that the Districts and AEA will release data under this Agreement only upon the condition that SAU will not disclose the information to any other party for any purpose, nor use any process for approval, other than those outlined in this Agreement, and that SAU will not use the information for any purpose other than the purpose for which the disclosure was made.

8.3. SAU is not responsible for ensuring the internal or network security of the Districts and AEA or for any breaches of security occurring prior to the confirmed receipt of data. Once the Data Warehouse Data Steward has confirmed receipt, however, SAU takes full responsibility for controlling access to these data on behalf of the Districts and AEA and to protecting the confidentiality of the students whose data has been contributed.

8.4. In its role as the Data Warehouse backbone organization, SAU agrees that it shall:

8.4.1. Utilize the Districts’ and AEA’s FERPA-protected student data only for the educational research purposes outlined in Provision 2.1, above;

8.4.2. Re-disclose the Districts’ and AEA’s FERPA-protected student data to only those SAU employees required to carry out the assigned work of the Data Warehouse project, only for the research purposes described above, and only in accordance with the guidelines contained in the SOPO (see Attachment B);

8.4.3. Create Linked Data Sets and conduct data correlations or other analyses only in accordance with Provision 9.4, below, and Provision 10 of the SOPO (see Attachment B);

8.4.4. Distribute any statistical analyses based (in whole or in part) on FERPA-protected student data only in accordance with Provisions 9.5 and 9.6, below, and Provision 11 of the SOPO (see Attachment B), and/or under the direction of the United Way of the Quad Cities Area Education Council;

8.4.5. Maintain records identifying all organizations and individuals who receive any data derived (in whole or in part) from FERPA-protected data, and make such records available to the Districts or AEA upon request;

8.4.6. Inform all SAU employees to whom FERPA-protected data are disclosed of the obligations of this Agreement;

8.4.7. Destroy all the Districts’ and AEA’s individual-level identified student data, as well as any Linked Data Sets which contain these data, within thirty (30) days of the completion of the Data Warehouse project, in accordance with Provision 9.7, of the SOPO (see Attachment B).

8.4.8. Indemnify the Districts, AEA, United Way of the Quad Cities Area, and those organizations’ board members, administrators, employees, and agents for any damages, costs, attorneys’ fees, charges, suits, complaints or causes of action of any kind or nature whatsoever resulting from a violation of this Agreement by SAU, its officers, management team, employees, or by any individual to whom the Districts’ or AEA’s FERPA-protected student data are disclosed.

8.5. SAU agrees to fully cooperate with the Districts and AEA in the event that a parent or eligible student requests the opportunity to review their personally identifiable information that was disclosed to SAU. SAU also agrees to notify the District and/or AEA in the event that a parent or eligible student submits a written request to SAU for a review of their personally identifiable information supplied by that partner’s organization. For purposes of this Agreement and its attachments, “eligible student” means and includes a student 18 years or older or an emancipated student.

8.6. No Warranty for Data or Data Linkage Quality. The accuracy and utility of data linkages and data findings generated by the Data Warehouse are dependent on the quality and consistency of the data provided by the Data Warehouse Partners. Although SAU will use reasonable efforts to promote accurate record linkage and the creation of appropriate data sets for analysis, no warranty is made as to the achievement of any particular match rate, nor as to the ultimate accuracy or utility of any findings generated using data contributed under this Agreement.

9. MANAGEMENT OF FERPA-PROTECTED DATA.

9.1. Agency. SAU may request individually-identifiable information from the Districts and AEA only under the direction of the Education Council, and/or as codified in this Agreement. The Districts and AEA hereby agree that SAU’s Data Warehouse Research Project Consultant and Data Warehouse Data Steward are empowered by the Education Council to make these requests on behalf of the Education Council.

9.2. Ownership. All data shared as part of this Agreement and any related Data Use Agreements remain the property of the original source of those data. In addition, all Data Warehouse Partners (as defined in the SOPO) who contributed data to a Linked Data Set will share ownership of any findings derived from the data linkage. The Education Council is empowered to manage the dissemination of linked data findings on behalf of these joint owners, so long as they do so in accordance with the policies and restrictions outlined in Provision 11 of the SOPO (see Attachment B).

9.3. Access to FERPA-Protected Data. The data covered under this Agreement shall not be disclosed, released, revealed, showed, sold, rented, leased, or loaned to any person or organization except as: (a) specified herein (see Provisions 9.5 and 9.6, below); (b) approved in an executed Data Sharing Agreement; (c) otherwise authorized in writing by the original data source; or (d) required by law. Access to individually-identifiable, FERPA-protected data shall be limited to the minimum number of individuals necessary to achieve the purpose stated in this section and to those individuals on a need-to-know basis only. Each person who is authorized to access individually-identifiable FERPA-protected data shall sign the Confidentiality Agreement contained in Attachment C acknowledging that s/he shall comply with the restrictions within this Agreement regarding the uses and disclosure of such data.

9.4. Creation of Linked Data Sets and Draw-Downs of Data. In accordance with Provision 20 U.S.C. § 1232g; 34 CFR Part 99:31 of FERPA, FERPA-protected data can be linked with other data sets and the results examined only for the purpose of conducting research designed to improve educational outcomes and services for the students of the Quad Cities community. It will be the decision of the Data Warehouse Research Project Consultant to determine if individual data draw-down requests conform to this restriction, in accordance with Provision 10.4 of the SOPO (see Attachment B).

9.5. Internal Data Releases. Research findings using Linked Data Sets formed, in whole or in part, from FERPA-protected data can be disseminated to other Data Warehouse Partners and/or the Education Council only in accordance with Provision 11.1 of the SOPO (see Attachment B) and Provisions 6 and 7 in the Agency Partner Data Agreement (see Attachment D).

9.6. Public Data Releases. Research findings using Linked Data Sets formed, in whole or in part, from FERPA-protected data can be disseminated to the public (as defined in Provision 4.8.3 of the SOPO) only in accordance with Provision 11.2 of the SOPO (see Attachment B), Provision 9.6.1 of this Agreement (below), and Provisions 6 and 7 in the Agency Partner Data Agreement (see Attachment D).

9.6.1. SAU agrees that any Data Warehouse Findings based in whole or in part on FERPA-protected data can be disseminated through a Public Data Release (as defined in the SOPO) only after both of the following two conditions have been met:

9.6.1.1. The Data Warehouse Research Project Consultant approves the wording of the Public Data Release, as stipulated in Provision 11.2.2 of the SOPO (see Attachment B), and

9.6.1.2. The Superintendents of each District whose data was linked to create the Data Warehouse Finding has also approved the wording of the Public Data Release. It is the responsibility of the Data Warehouse Research Project Consultant to seek out and secure these approvals.

9.6.2. It is not the purpose of the Data Warehouse to draw comparisons between different Districts nor to single out any one District as the site of the greatest educational challenges or success. Because of this, no Data Warehouse Findings disseminated in a Public Data Release (as defined in the SOPO) will specifically identify individual Districts nor compare the performance on one District’s students to another’s. This provision may be abrogated only with the approval of the Education Council.

9.7. Other. In all other matters, the storage, management, and use of FERPA-protected data in the Data Warehouse will adhere to the policies, procedures, and restrictions outlined in the SOPO (see Attachment B).

10. RESOURCES AND COSTS OF DATA SHARING AND DATA MANAGEMENT. Fees for SAU’s services and funds to provide necessary technology will be negotiated on an annual basis and agreed upon in a separate agreement between SAU and the Education Council. The Districts and AEA are not responsible for funding any part of the Data Warehouse project except for those internal expenses necessary for the district to comply with the terms of this agreement, specifically in terms of data collection, technology maintenance, data transfers, and the staff time required to manage and upload their own student data.

11. INDEMNIFICATION. The parties agree that statutory and common law theories and principles of liability, indemnification, contribution, and equitable restitution shall govern all claims, costs, actions, causes of action, losses or expenses (including attorney fees) resulting from or caused by the actions or omission of the parties hereto. Furthermore, if a party becomes aware of a claim involving another within the relationship, the party with knowledge of the claim shall inform the other party in writing within ten (10) days of receiving knowledge of the claim, demand, or other loss. No party signing this Agreement shall be liable for the acts of another party to this Agreement. This Provision 11 shall in no way limit SAU’s duty to provide indemnification pursuant to Provision 8.4.8 above.

12. MODIFICATION OF THIS AGREEMENT. The parties hereto may amend this Agreement by a majority vote of the Education Council and/or by mutual consent of all the parties hereto in writing, at any time.

13. TERMINATION OF THIS AGREEMENT.

13.1. In the event of the termination of this Agreement (either by mutual agreement of all parties or by the passing of the July 31, 2024 end date of this Agreement without a new agreement or a continuance being issued), SAU will delete all Primary Data Sets containing FERPA-protected information collected from the Districts and AEA in the course of the term of the Data Warehouse project, in accordance with Provision 9.7 of the SOPO (see Attachment B).

13.2. All representations, warranties, disclaimers of liabilities, indemnifications, and covenants between the parties will survive the termination of this Agreement for any reason and in any manner and will remain in full force and effect between the parties.

14. COUNTERPARTS; ELECTRONIC DELIVERY. This Agreement may be executed in counterparts each of which shall be fully effective as an original and all of which together shall constitute one and same instrument and may be transmitted electronically via facsimile or email of pdf files and such transfer shall have the same force and effect as an original.

[SIGNATURE PAGE FOLLOWS]

QCDW FERPA Protections Data-Sharing Agreement11

SIGNATURES. By the signatures of their duly authorized representatives below, the parties hereby agree to all of the provisions of this Agreement and execute this Agreement effective with this signing for the period set forth in Provision 3, above.

For Saint Ambrose University

Signature:

Name:

Date:

Title:

For United Way of the Quad Cities Area

Signature:

Name:

Date:

Title:

For Bettendorf Community School District

Signature:

Name:

Date:

Title:

For Davenport Community School District

Signature:

Name:

Date:

Title:

For East Moline School District

Signature:

Name:

Date:

Title:

For Moline/Coal Valley School District

Signature:

Name:

Date:

Title:

For North Scott School District

Signature:

Name:

Date:

Title:

For Pleasant Valley School District

Signature:

Name:

Date:

Title:

For Rock Island/Milan School District

Signature:

Name:

Date:

Title:

For United Township School District

Signature:

Name:

Date:

Title:

For Mississippi Bend Area Education Agency

Signature:

Name:

Date:

Title:

Attachment A

Primary Data Set

I. DATA FROM THE SCHOOL DISTRICTS. Each School District will provide the Data Warehouse with each of these data points, for each individual student, on an annual basis, by the due dates specified if at all possible. If any of these exact data points are not collected or stored by a District, the District and Data Warehouse Data Steward will work together to develop a reasonable proxy, and to program the necessary data translations into the Data Warehouse system.

A. Identifier Data – Incoming Kindergarteners

NOTE: These data are required for United Way of the Quad Cities Area to administer its Kindergarten Skills Inventory each year.

Data Point

Scope: Population

Scope: Time Frame/As Of

Due to Data Warehouse By:

First Name

Incoming Kindergarteners

As of 3rd week of the current academic year

September 15th

Middle Name



September 15th

Last Name



September 15th

Name Suffix



September 15th

School District



September 15th

State of School District (Iowa or Illinois)



September 15th

Unique State ID



September 15th

Most Recent Address – Number and Street



September 15th

Most Recent Address – City



September 15th

Most Recent Address – Zip Code



September 15th

Birthdate



September 15th

Race



September 15th

Ethnicity (Hispanic)



September 15th

Gender



September 15th

ELL Status (if applicable)



September 15th

IEP Status (if applicable)



September 15th

RTI Tier (if applicable)



September 15th

Federal 504 Plan Determination (if applicable)



September 15th

Home School ID



September 15th

Home School Name



September 15th

Serving School ID



September 15th

Serving School Name



September 15th

Assigned Classroom Teacher



September 15th

B. Identifier Data – All Other Students

NOTE: We will collect these same data points on all students each year – even those we will not be collecting Performance Data (see IV, below) on. This will give us an annual “snapshot” of where each child is, allowing us to better track mobility and student grade advancement. We are collecting this information only to create additional demographic categories (for example, “Students who have changed school districts more than 3 times by the time they enter high school”) by which the Performance Data can be sifted.

Data Point

Scope: Population



First Name

Last Year’s K-12 Students

As of the last day of the previous school year

August 31st

Middle Name



August 31st

Last Name



August 31st

Name Suffix



August 31st

School District



August 31st

State of School District (Iowa or Illinois)



August 31st

Unique State ID



August 31st

Most Recent Address – Number and Street



August 31st

Most Recent Address – City



August 31st

Most Recent Address – Zip Code



August 31st

Birthdate



August 31st

Race



August 31st

Ethnicity (Hispanic)



August 31st

Gender



August 31st

Grade Level Most Recently Completed


Current

August 31st

ELL Status (if applicable)



August 31st

IEP Status (if applicable)



August 31st

RTI Tier (if applicable)



August 31st

Federal 504 Plan Determination (if applicable)



August 31st

Home School ID



August 31st

Home School Name



August 31st

Serving School ID



August 31st

Serving School Name



August 31st

C. Student Performance Data

NOTE: These are the core performance data points that the Education Council will be tracking to conduct research, as specified in the SOPO.

Data Point

Scope: Population


Submitted to Data Warehouse By:

Standardized test scores in Reading (Below Proficient, Proficient, Above Proficient)

Last Year’s K-12 Students (where applicable)

Fall assessment of the previous school year

August 31st

Standardized test scores in Reading (Below Proficient, Proficient, Above Proficient)


Spring assessment of the previous school year

August 31st

Standardized test scores in Math (Below Proficient, Proficient, Above Proficient)


Fall assessment of the previous school year

August 31st

Standardized test scores in Math (Below Proficient, Proficient, Above Proficient)


Spring assessment of the previous school year

August 31st

Did this student have 20+ absences in the previous school year? (Y/N)



August 31st

Student grades in all classes from the previous school year



August 31st

Grade point average



August 31st

Has this student accrued 25% of the credits necessary for graduation?

Students who just completed their first year of high school.


August 31st


Students who just completed their second year of high school.


August 31st


Students who just completed their third year of high school.


August 31st

Number of credits accrued

All students in their fourth year of high school or later.


August 31st

Did this student drop out of school during the previous school year?

All students


August 31st

Did this student graduate from high school during the previous school year?

All students who just completed their 4th year of high school


August 31st

II. DATA FROM THE MISSISSIPPI BEND AREA EDUCATION AGENCY. The Mississippi Bend Area Education Agency will collect post-secondary data through the National Student Clearing House on behalf of Bettendorf Community School District, Davenport Community School District, Moline/Coal Valley School District, North Scott Community School District, Pleasant Valley Community School District, Rock Island/Milan School District, and United Township School District.

A. Identifier Data – Previous Year’s High School Graduates

NOTE: These data are required for AEA to track post-secondary attainment of students through the National Student Clearinghouse. AEA will receive this information directly from the Districts and then upload it into the system as part of their data contribution to the Data Warehouse.

Data Point

Scope: Population



First Name

Grads from previous school year

End of the previous academic year

August 1st

Middle Name



August 1st

Last Name



August 1st

Date of Birth



August 1st

Date of Graduation



August 1st

School of Graduation



August 1st

State Identification Number



August 1st

B. Post-Secondary Education Performance Data

Data Point

Scope: Population


Submitted to Data Warehouse By:

First Name

All students who completed high school in a QCA District in the past 8 years

End of November of the previous year

January 15th

Middle Name



January 15th

Last Name



January 15th

Date of Birth



January 15th

State Identification Number



January 15th

Post-Secondary Enrollment Status



January 15th

List of Degrees Earned to Date



January 15th

Attachment B

THE QUAD CITIES DATA WAREHOUSE

STANDARDS OF PRACTICE AND OPERATION

An agreement between:

St. Ambrose University

and

United Way of the Quad Cities Area,

representing the United Way of the Quad Cities Area Education Council

1. THE PURPOSE OF THE QUAD CITIES DATA WAREHOUSE PROJECT. The purpose of the Quad Cities Data Warehouse (the “Data Warehouse”) is to facilitate the creation and maintenance of a master regional data set of individual-level identified data from multiple sources. This master regional data set will be used to link together individual-level data from two or more sources in order to conduct local, real-time research designed to identify and address community needs for the citizens of the Quad Cities area. This research may include such activities as the measurement and segmentation of current gaps in student achievement, the testing of new or adjusted interventions to address those gaps, or the development of predictive models to allow for the creation and application of preventative interventions.

0. Individual-level data is uploaded into the Data Warehouse solely for the purposes of linkage and aggregation. The Data Warehouse is not intended to be used as, and will not be used as, a tool for tracking and assigning services to individuals.

0. It is not the purpose of the Data Warehouse to draw public comparisons between different organizations nor to single out any one organization as the site of the greatest challenges or success. Because of this, no Data Warehouse Findings disseminated in a Public Data Release (see Provision 4.8.3, below) will specifically identify individual organizations nor compare the performance of one organization’s work to another’s. This provision may be abrogated only with the approval of the Education Council.

1. THE PURPOSE OF THIS AGREEMENT. The purpose of this document is to codify and confirm agreement on the management and oversight of the Data Warehouse, all raw data held within the Data Warehouse, and any findings derived from the data held in the Data Warehouse.

1. PERIOD OF AGREEMENT. The Data Warehouse project will last a minimum of ten years from first data collection, which took place in August 2014. This Agreement shall be in effect from the date of signature until July 31, 2024, or until terminated in writing by the United Way of the Quad Cities Area Education Council. The project may be extended after this date by agreement of participating parties, either through a continuance or by the drafting of a new partnership agreement.

1. TERMS and Definitions.

3. Data Warehouse Partner is defined as any organization who has executed a Data-Sharing Agreement with St. Ambrose University and has uploaded its own data into the Data Warehouse. An organization which has not contributed its own data into the Data Warehouse shall not be considered a Data Warehouse Partner.

3. Personal Computer is defined as a microcomputer designed for individual use, including, but not limited to, desktop computers, laptops, tablets, and mobile devices that have the ability to access applications and documents containing confidential data.

3. Public Information is defined as information, at an aggregate or individual-level, which is available to the general public and the use of which is not governed by any legal or organizational restrictions.

3. Protected Information is defined as information which is confidential, private, personal or otherwise sensitive in nature. Protected Information includes the following categories:

3. Personally Identifiable Information, including an individual’s name, address, social security number, driver license or state ID number, organizational ID number, or any biometric identifier. See also the description of “Individual Identifiability” in Provision 10.5.3, below.

3. Legislatively Protected Data are data which are subject to some government regulation or oversight. This includes, but is not limited to, data as defined under the Family Educational Rights and Privacy Act (FERPA) and Health Insurance Portability and Accountability Act (HIPAA).

3. Organizationally Protected Data are data provided by any Data Warehouse Partner organization which does not fall under governmental confidentiality regulations, but which the partner has specified is to remain confidential. Note that even revealing that a specific individual has a record in a specific database is defined as a breach of that individual’s confidentiality.

3. Other sensitive data are data where unauthorized disclosure could lead to liability issues or a business, financial, or reputational loss.

3. Data Warehouse Findings, as defined in Provision 4.5, below. Note that, because the operations and functions of the Data Warehouse themselves are proprietary, any Data Warehouse Finding is considered as Protected Information under this definition, even if all of the source data on which the finding was based were themselves Public Information.

3. Data Warehouse Finding is defined as any information derived through the operation of the Data Warehouse through the linking of separate (organizational and/or longitudinal) data sets.

3. Data Draw-Down is defined as the creation of linked data sets to generate a Data Warehouse Finding.

3. Data Warehouse Personnel is defined as the people who oversee the day-to-day operations of the Data Warehouse, as defined in Provision 7 of this Agreement.

6. For the carrying out of their duties, these individuals will have access to Protected Information before release of that information has been approved by the Education Council (see Provision 4.8.1, below).

6. Certain individuals among the Data Warehouse Personnel will also have access to individual-level, identified data (see Provisions 7.2.1 through 7.2.3, below).

3. Release of Data is defined as the disclosure, to anyone outside of Data Warehouse Personnel and their organizational supervisors, of any Data Warehouse Finding.

7. Any disclosure of Data Warehouse Findings to designated Data Warehouse Personnel and their organizational supervisors is not considered to be a release of information so long as that information was extracted in accordance with the conditions and procedures of this agreement, as outlined in Provision 10, below. This allows these individuals to properly prepare for the presentation of Data Warehouse Findings to the Data Warehouse Partners and/or Education Council.

7. Internal Data Release is defined as the disclosure of Data Warehouse Findings to the Education Council and the United Way of the Quad Cities Area Board of Directors as a body (though not such disclosures to specific members of these groups as individuals), and/or the dissemination of Data Warehouse Findings from a research request approved under Provision 10 below to the Data Warehouse Partner who made that request. By definition, these Data Warehouse Findings must be the result of an approved research question, the specific goal of which is to aid the Education Council and/or Data Warehouse Partner(s) in data-driven decision-making about need, gaps, outcomes, or services in the Quad Cities area.

7. Public Data Release is defined as the dissemination of Data Warehouse Findings to individuals or organizations outside the Education Council, the United Way of the Quad Cities Area Board of Directors, and the Data Warehouse Partners. All Public Data Releases must strictly adhere to the conditions and procedures outlined in Provision 11.2, below. Public Releases of Data include but are not limited to the sharing of any Data Warehouse Findings with:

2. Any individual or organization without representation on the Education Council or who are not Data Warehouse Partners

2. Other staff members of organizations with Education Council or United Way of the Quad Cities Area Board of Directors representation beyond the individual who the organization has appointed to represent them on the Education Council or the United Way of the Quad Cities Area Board of Directors

2. The press, including press releases and interviews

2. The general public, including use in speeches, marketing materials, PSAs, annual reports, grant applications, and outcomes reports

2. Any parent organization or body, even if that organization or body has a local representative, affiliate, or agent which is a Data Warehouse Partner, Education Council member or member of the United Way of the Quad Cities Area Board of Directors.

7. Aggregate Finding is defined as any statistic, expressed as a single number or percentage, which is based on the analysis of a Data Warehouse data linkage. For example, an aggregate sample may state that 50% of members of a specific population achieved a specific benchmark, but that sample cannot include information on which individual members from that population met or failed to meet that benchmark.

3. All Aggregate Findings must adhere to the restrictions on individual identifiability outlined in Provision 10.5.3.

3. By definition and design, the only information which can be generated by the Data Warehouse are Aggregate Findings.

1. PARTIES TO THIS AGREEMENT AND ROLES. Organizations involved in the Data Warehouse will carry out the following roles:

4. St. Ambrose University (“SAU”) will serve as the lead organization for the Data Warehouse project: housing, staffing, and overseeing the day-to-day operation of the Data Warehouse. SAU staff will supervise all data uploads into the system and carry out any requests for Data Draw-Downs, in accordance with Provision 7.2, below. Only designated staff members of SAU who have signed the required confidentiality form (see Attachment A) are allowed to view individual-level and/or confidential data from any Data Warehouse contributors – and then only in carrying out the specific work of the Data Warehouse.

4. United Way of the Quad Cities Area Education Council (“Education Council”) will serve as the body that guides and monitors the execution of the overall Data Warehouse project, in accordance with Provision 6.3, below. All Education Council decisions are subject to approval by the United Way of the Quad Cities Area Board of Directors. Note that this role does not permit individual members of the Education Council, nor the Council as a whole, nor the members of the United Way of the Quad Cities Area Board of Directors, nor the United Way of the Quad Cities Area Board of Directors as a whole, to have access to individual-level identified data or other Protected Information (as defined by Provision 4.4, above) under any circumstances.

4. Assorted Quad Cities Data Warehouse Partners will also be invited, by the United Way of the Quad Cities Area Education Council, to submit their own internal data into the system.

2. All organizations and individuals submitting to, or drawing down data from, the Data Warehouse must agree to abide by the conditions, policies, procedures, and restrictions outlined in this Agreement and all other agreements which govern Data Warehouse operations.

2. In specific cases, Data Warehouse Partners may (as individual organizations or by category) request or require separate agreements governing the management, access to, and disposition of their data. These ad hoc agreements must by necessity incorporate this Agreement by reference as an Attachment, and by signing their ad hoc agreement these Data Warehouse Partners are at the same time agreeing to abide by the conditions, policies, procedures, and restrictions outlined in this Agreement.

1. DATA WAREHOUSE OVERSIGHT.

5. Ownership. Although the individual data sets contributed to the Data Warehouse belong to the Data Warehouse Partners who contributed each set, the Data Warehouse as a whole is under the ownership of SAU and under the direction of the Education Council (and, through them, of the United Way of the Quad Cities Area Board of Directors).

5. SAU. The day-to-day operation of the Warehouse is the responsibility of the Data Warehouse Research Project Consultant and the Data Warehouse Data Steward, who will be SAU employees and who will operate under the direct supervision of SAU administrators. See Provision 7.2, below.

5. Education Council. The protocols, restrictions, procedures, use, and expansion of the Data Warehouse are set by the Education Council. Although the Data Warehouse Research Project Consultant will make ongoing decisions about which data is drawn down (see Provision 10.4, below), the Education Council will make decisions about the Data Warehouse’s overall design and functions: specifically:

2. The Education Council will decide what types of research, and what areas of study, the Data Warehouse will be used to investigate.

2. The Education Council will decide which organizations (by category and by name) are invited to upload data in the Data Warehouse.

2. The Education Council will serve as the neutral body to settle disputes between Data Warehouse Partners and/or between Data Warehouse Partners and SAU, in accordance with Provision 12.1, below.

2. The Education Council will investigate any allegations of misuse of data or breaches of security or confidentiality, in accordance with Provisions 9.5.2.4 and 9.5.3.4, below, and to suspend a Data Warehouse Partner from the project while this investigation is taking place, in accordance with Provision 12.2, below.

2. The Education Council is empowered to unilaterally terminate Data Warehouse Partners from the project, in accordance with Provision 12.4, below.

2. The Education Council is empowered to make Data Draw-Down requests in accordance with the procedures outlined in Provision 10, below.

2. The Education Council is also responsible for securing the funds necessary to cover Data Warehouse operations, including the staff time required of SAU’s Data Warehouse Personnel to fulfill their duties and responsibilities to this project.

2. The Education Council is empowered to terminate, issue a continuance on, or renegotiate the terms of this Agreement and all other agreements governing the Data Warehouse project.

5. Communication between parties. SAU agrees to abide by the decisions of the Education Council concerning the Data Warehouse project, and the Education Council must inform the Data Warehouse Research Project Consultant on any changes to Data Warehouse function within twenty-four (24) hours of those changes being approved.

1. DATA WAREHOUSE PERSONNEL.

6. General Guidance.

0. SAU agrees to provide appropriate staff support to execute its data stewardship, data management, and custodial responsibilities outlined in this Agreement.

0. The individual Data Warehouse Partners are responsible for the collection, verification, and transmission of their own data, and agree to provide appropriate staff support to carry out these duties, and to cover any costs which arise from these activities.

0. United Way of the Quad Cities Area agrees to provide a staff member to serve as a day-to-day liaison between the Education Council and all Data Warehouse Partners: communicating the decisions of the Education Council to SAU Data Warehouse Personnel and communicating back to the Education Council any questions or concerns which the SAU Data Warehouse Personnel have concerning Data Warehouse disposition or operations.

6. SAU Data Warehouse Personnel Roles and Responsibilities. For all Data Warehouse operations, including any ad hoc Data-Sharing Agreements executed under the terms of this document, SAU will assign an appropriate and qualified staff member for the roles of “Data Warehouse Research Project Consultant” and “Data Warehouse Data Steward.”

1. SAU Data Warehouse Research Project Consultant. The Data Warehouse Research Project Consultant will be responsible for:

0. Overseeing the day-to-day functions of the Data Warehouse and ensuring that all operations comply with Federal law, the terms of this Agreement, and the dictates of the Education Council.

0. Reviewing each request for Data Draw-Downs to determine whether the request is a valid one, in accordance with Provision 10.4, below.

0. Giving final approval for Data Draw-Down requests.

0. Giving a final review of all Data Warehouse Findings before they are released to the Data Warehouse Partner which requested them, to ensure that the numbers are accurate and are appropriately represented.

0. Reviewing the language of all public releases of Data Warehouse Findings in accordance with Provision 11.2.2, below.

0. Making regular reports to the Education Council of all approved data research requests and the results of all approved Data Draw-Downs.

0. Making regular reports to the Education Council of the general findings of each year’s annual data upload.

0. Making recommendations to the Education Council of new research they may wish to use the Data Warehouse to conduct.

1. SAU Data Warehouse Data Steward. The Data Warehouse Data Steward will be responsible for:

1. Serving as the main point of contact between the Data Warehouse and the assigned data stewards of all Data Warehouse Partner organizations, as outlined in Provision 8.3, below.

1. Developing and executing appropriate data queries from the primary data set to create linked data sets in response to approved research requests.

1. Maintaining communication with and reviewing the work of the company overseeing the mainframe where the Data Warehouse data is stored.

1. Monitoring and protecting the security of the Data Warehouse, and limiting access to all Protected Information as specified in Provision 9.4, below.

1. Reporting any compliance issue or breach to the Data Warehouse Research Project Consultant immediately upon discovery of such.

1. In addition, the Data Warehouse Research Project Consultant and the Data Warehouse Data Steward may involve one or more research assistants to assist in a support role with various tasks outlined in this Agreement or other agreements which govern Data Warehouse operations, so long as these research assistants sign and adhere to the conditions of the Confidentiality Agreement in Attachment A.

1. The Education Council and Data Warehouse Partners will be informed in writing of which SAU staff member(s) are assigned to each role as well as to any changes in staffing for these roles.

1. Parties agree that both assigned roles may be performed by one staff member, or more than two staff members, as is most convenient and expedient for SAU.

1. PROCEDURES FOR Data UPLOADS

7. Agency. SAU may request individually-identifiable information from Data Warehouse Partners only under the direction of the Education Council, and/or as codified in this Agreement or any other data-sharing agreement which governs Data Warehouse operations. SAU’s Data Warehouse Research Project Consultant and Data Warehouse Data Steward are empowered by the Education Council to make these requests on behalf of the Education Council.

7. Valid Data Uploads. A Data Warehouse Partner can upload a data set into the Data Warehouse only if at least one of the following four conditions is met:

1. The data set as been requested by the Education Council.

1. The Data Warehouse Partner has signed an agreement with the Data Warehouse project to upload the specific data set.

1. The Data Warehouse Partner wishes to contribute this data set in order to complete a data linkage within the Data Warehouse, so long as this linkage is part of a Data Draw-Down request which has already been approved by the Data Warehouse Research Project Consultant, as outlined in Provision 10, below.

1. An approved Data Warehouse Partner wishes to upload its own additional data into the Data Warehouse, so long as they abide by the procedures and restrictions outlined in Provision 9.3, below.

7. Data Stewardship. In accordance with in Provision 7.2.2, above, the Data Warehouse Data Steward will:

2. Coordinate with the data steward from each Data Warehouse Partner in standardizing definitions of data points

2. Work with the in-house data steward appointed by each Data Warehouse Partner to determine how each data point will be measured, formatted, and stored

2. Coordinate the programing of data translation into the Data Warehouse upload software

2. Maintain a schedule of all data uploads, and inform all Data Warehouse Partners of upcoming deadlines

2. Provide a format for all data uploads

2. Troubleshoot the technical aspects of data uploads

2. Check uploaded data for errors, duplications, and omissions, and work with the Data Warehouse Partner’s data steward to correct them

2. Confirm with the Data Warehouse Partner data steward when the required data has been accepted

2. Work with Data Warehouse Partners who have missed upload deadlines to secure the agreed-upon data in a timely manner

2. Serve as a liaison between each individual Data Warehouse Partner and the third-party software provider who is housing the Data Warehouse.

7. Upload Provisions.

3. All Data Warehouse Partners agree to upload requested data on schedule or in as timely a manner as possible.

3. The primary method of data sharing will be through an FTP upload of data in CSV format directly into the Data Warehouse system. These FTP uploads will be conducted by the data steward of the Data Warehouse Partner which owns the data. It is not the responsibility of the Data Warehouse Data Steward to carry out an upload on behalf of a Data Warehouse Partner.

3. Data sharing through other forms of digital media (by email, or on disks or other storage devices) is allowed but discouraged.

3. No data may be shared in paper hard copy, and any manual data entry which is required for Data Warehouse uploads will be conducted by the Data Warehouse Partner which owns the data at the Partner’s own expense.

3. SAU is not responsible for ensuring the internal or network security of the Data Warehouse Partners or for any breaches of security occurring prior to the confirmed receipt of data from any Data Warehouse Partner.

3. Each Data Warehouse Partner is responsible for covering the costs and providing the personnel necessary to collect, format, and upload its own data into the Data Warehouse.

1. PROVISIONS FOR Data STORAGE

8. Ownership. All data shared in the Data Warehouse as part of this Agreement and any related agreements remains the property of the original source of that data. In addition, all Data Warehouse Partners who contributed data to a linked data set will share ownership of any findings derived from the data linkage. The Education Council is empowered to manage the dissemination of linked Data Warehouse Findings on behalf of these joint owners.

8. Access to Protected Information. Data covered under this Agreement shall not be disclosed, released, revealed, showed, sold, rented, leased, or loaned to any person or organization except as: (a) specified herein (see Provision 11, below); (b) approved in an executed Data-Sharing Agreement; (c) otherwise authorized in writing by the original data source; or (d) required by law. Access to Protected Information shall be limited to the minimum number of individuals necessary to achieve the purpose stated in this section and to those individuals on a need-to-know basis only. Each person who is authorized to access Protected Information shall sign Attachment A acknowledging that s/he shall comply with the restrictions within this Agreement on the uses and disclosure of such data.

8. Uploading of Additional Data. A Data Warehouse Partner may request permission to upload additional data sets into the Data Warehouse. The Data Warehouse system, for example, may have data linkage abilities which the Data Warehouse Partner lacks, or the Data Warehouse Partner may wish to store data in the warehouse in anticipation of a future research question and Data Draw-Down request.

2. A Data Warehouse Partner cannot upload such additional data sets without the written permission of the Data Warehouse Research Project Consultant, nor without the knowledge and cooperation of the Data Warehouse Data Steward.

2. The Data Warehouse Data Steward can choose to, but is not required to, help a Data Warehouse Partner with one-time or small-scale uploads of additional data. For larger-scale data uploads, the Data Warehouse Partner must work directly with the software provider who is housing the Data Warehouse.

2. If the software provider requires it, a Data Warehouse Partner uploading their own data may have to sign an additional agreement with, and pay additional fees to, the software provider. These arrangements, and the data uploaded and stored through these arrangements, do not fall under the governance of the Data Warehouse nor the terms of this Agreement. SAU and the other Data Warehouse Partners take no responsibility for the disposition of such additional data and are not responsible for providing the funding or staff support necessary to upload, maintain, or process these data.

8. Data Warehouse Security. SAU agrees to establish appropriate administrative, technical, and physical safeguards to protect the confidentiality of the data and to prevent unauthorized use or physical or electronic access to it, and report violations of this Agreement to the Education Council immediately upon discovery. Appropriate administrative, technical, and physical safeguards include, but are not limited to:

3. SAU must not save sensitive information on personal computers unless necessary to perform job duties. If sensitive information is stored on a personal computer, then all reasonable safeguards and security procedures shall be employed (as defined in Provision 9.4.2, below).

3. SAU users shall put in place reasonable safeguards and security procedures for its environment, including, but not limited to, password-protected computers; prohibiting password sharing among users; prohibiting unauthorized data downloads and distribution of data; requiring that users do not leave computer unattended, and/or set a timeout to lock an unattended computer; installation of antivirus software with current updates and a supported operating system with current patches and updates; requiring computer to be physically secured, such as in a locked office, desk, or car.

3. SAU shall provide information to internal staff on security policies and procedures, and on applicable state and federal legal requirements for protecting the privacy of individuals.

8. Data Breaches.

4. Discovery. Any suspicion of or discovery of an unauthorized release of Protected Information from the Data Warehouse must be reported immediately to the Data Warehouse Personnel or their organizational supervisors at both SAU and United Way of the Quad Cities Area.

4. External Security Breach. Upon receiving word of the suspected or proven access (virtual or physical) to the Data Warehouse itself by unauthorized individuals or organizations, SAU and Education Council will implement the following procedures:

1. The Data Warehouse Data Steward will initiate an immediate cessation of all Data Warehouse operations: no new data may be uploaded and no Data Warehouse Findings may be drawn down while this hold remains in effect.

1. The Data Warehouse Data Steward will immediately inform the third-party software provider who is housing the Data Warehouse of the breach. The software provider will seal off all access to the Data Warehouse functions and stored data, except access which is necessary for the Education Council to investigate the breach.

1. The Data Warehouse Research Project Consultant will inform all Data Warehouse Partners and Education Council members of the circumstances of the breach. Data Warehouse Partners, at this time, will each be able to initiate a hold on Protected Information, in accordance with Provision 9.6, below, which the Partner may keep in place even after the Data-Warehouse-wide hold is removed.

1. The Education Council will be responsible for investigating the fact, circumstances, extent, and perpetrators of the breach, and of providing SAU and all Data Warehouse Partners with regular, ongoing reports of the findings of this investigation.

1. Only once the source of the breach is identified and neutralized, to the satisfaction of both SAU and the Education Council, will normal Data Warehouse functions be allowed to resume.

4. Misuse of Protected Information. If at any time, any Data Warehouse Partner or any representative of that Data Warehouse Partner is suspected of or proved to have (a) had unapproved access to Protected Information or (b) was the source of the unauthorized release of Protected Information from the Data Warehouse, SAU and Education Council will implement the following procedures:

2. The Data Warehouse Data Steward will immediately block the Data Warehouse Partner’s access to the Data Warehouse system, on both an individual and organizational level.

2. The Data Warehouse Research Project Consultant will place an immediate suspension on the Data Warehouse Partner, in accordance with Provision 12.2, below.

2. The Data Warehouse Research Project Consultant will inform all Data Warehouse Partners and Education Council members of the circumstances of the breach. Data Warehouse Partners, at this time, will each be able to initiate a hold on Protected Information, in accordance with Provision 9.6, below, which the Data Warehouse Partner may keep in place even after the Data-Warehouse-wide hold is removed.

2. The Education Council will be responsible for investigating the fact, circumstances, extent, and perpetrators of the breach, and of providing SAU and all Data Warehouse Partners with regular, ongoing reports of the findings of this investigation.

2. If the Data Warehouse Partner organization is found to have disclosed Protected Information in violation of the terms of this Agreement, the Education Council is empowered to begin unilateral termination of that organization from the partnership, in accordance with Provision 12.4, below.

2. Only once the source of the breach is identified and neutralized, to the satisfaction of both SAU and the Education Council, will normal Data Warehouse functions be allowed to resume.

8. Data Warehouse Partner Hold on Protected Information. At any time, and for whatever reason, an individual Data Warehouse Partner may request an immediate hold on use of any of its own data which is stored in the Data Warehouse. This hold will also prevent the use of that Data Warehouse Partner’s data in any data linkages or Data Draw-Downs. This request must be communicated to any Data Warehouse Personnel or their organizational supervisors; the hold must be put in place within twenty-four (24) hours of this communication. This hold will last until the Data Warehouse Partner agrees to end it.

8. Destruction of Data. On the occasion of any single partner leaving or being terminated from the Data Warehouse project (see Provisions 12.3 and 12.4, below), or of the termination of the Data Warehouse project itself for any reason and in any manner (see Provision 14, below), SAU will:

6. Destroy all copies and records of the departing Data Warehouse Partner(s)’ contributed data within thirty (30) days, and remove those data from any linked data sets or cohorts being maintained in the Data Warehouse system. This obligation to destroy extends to the data stored electronically, in paper copies, or in any other fashion. Within thirty (30) days, SAU will certify in writing, to both the Education Council and the departing Data Warehouse Partner(s), that SAU has carried out this directive.

6. Confer with the company maintaining the database mainframe to ensure the deletion all primary data sets containing individually identifying information collected from the Data Warehouse Partner(s). The Data Warehouse Data Steward shall collect a certification in writing from the company that all copies of the data stored on servers, backup servers, backup media, or other media have been permanently erased or destroyed. The Data Warehouse Data Steward will share this certification with the Education Council and the departing Data Warehouse Partner(s) upon receipt.

1. PROCEDURES FOR Data DRAW-DOWNS. The main function of the Data Warehouse is to facilitate the creation of linked data sets, which match and/or correlate data on the same population from two or more data owners, for the purpose of answering specific research questions designed to improve outcomes and services for members of the Quad Cities community.

9. Who May Submit Data Draw-Down requests.

0. The Education Council may request Data Draw-Downs at any time. Note that this authority applies only to the Education Council as a body, and does not extend to any individual Education Council member or the organization he or she represents.

0. Any Data Warehouse Partner can request a Data Draw-Down in order to answer a specific research question, so long as the partner’s own data is to be included in the data linkage required to fulfill the request.

0. Any Data Warehouse Partner may make a Data Draw-Down request on behalf of an organization which is not a Data Warehouse Partner, so long as:

2. The Data Warehouse Partner who is presenting the request owns at least one of the data sets to be included in the data linkage required to fulfill the request.

10.1.3.2. The involvement of this non-Data-Warehouse Partner organization is overtly stated at the time of the Data Draw-Down request.

9. General Restrictions on Data Draw-Down Requests

1. Valid Research. Data Draw-Down requests which incorporate FERPA- or HIPAA-protected data must adhere to the general research guidelines presented in Attachment B and incorporated herein. In general, valid research questions include those which (a) help to pinpoint at-risk populations, (b) measure a degree of correlation between two separate indicators, or (c) evaluate the effectiveness of a local intervention (or to compare the effectiveness of two different intervention strategies one to the other).

1. Aggregate Data. The only Data Warehouse Findings released from the Data Warehouse will be Aggregate Findings, as defined in Provision 4.8.4, above, and governed by the restriction on “Individual Identifiability,” as outlined in Provision 10.5.3, below.

1. Temporary Holds and Suspensions. Note that any data which is on hold as part of an active investigation into a data breach (as outlined in Provision 9.5, above), or on hold by request of the Data Warehouse Partner which owns the data (as outlined in Provision 9.6, above), those data cannot be used in the creation of any data linkages while the hold remains in effect. All Data Draw-Down requests which would include data sets on hold will be suspended until the hold is removed. Similarly, if a Data Warehouse Partner organization is under Suspension (as outlined in Provision 12.2, below) for any reason, their data cannot be included in any Data Draw-Down until the matter is resolved to the satisfaction of all parties.

9. Data Draw-Down Requests Format. All Data Draw-Down requests must be in writing, in either hard copy or electronic media, and directed to the Data Warehouse Research Project Consultant at SAU. The request must contain all of the following information:

2. What the purpose of the Data Draw-Down request is. What research questions the Data Draw-Down will address. How the Data Warehouse Partner will make use of the Data Warehouse Findings.

2. Whether the organization needs the information for an Internal Data Release and/or a Public Data Release, as defined in Provision 4.8, above.

1. In the case of an Internal Data Release, the applicant must list any and all individuals who will have access to the Data Warehouse Findings.

1. In the case of a Public Data Release, the applicant must describe in detail what formats, and to which audiences, the Data Warehouse Findings will be disseminated.

2. Which data sets must be linked to generate the Data Warehouse Findings. At least one of these data sets must be under the ownership of the applicant organization.

2. Which population or subpopulations the applicant wants to research. Note that Data Draw-Downs can be for an entire population, a subpopulation, or a combination of the two. Subpopulations can be defined by such factors as demographics, geography, need indicators, or cohort membership.

2. Which specific data points the applicant wants linked, and which data sets those data points are stored in.

2. Which years’ data the applicant wants to research. Requests for multiple years are allowed.

2. Whether the Data Warehouse Partner would like this Data Draw-Down to be repeated in subsequent years, and if so, how many years they would like it repeated.

2. Whether the research question requires the creation of an ongoing cohort group within the Data Warehouse, to allow for the tracking of long-term impacts.

2. For any Data Draw-Down requests involving FERPA-protected data, the applicant must also demonstrate that the research will help improve educational outcomes for local students.

9. Approval Process. The Data Warehouse Research Project Consultant will grant or deny the request, or return it to the applicant asking for further information and/or setting special conditions which the organization must agree to before the request can be approved.

3. Upon receipt of a Data Draw-Down request, the Data Warehouse Research Project Consultant will inform all Data Warehouse Partners whose data will be included in the proposed linkage of the nature of the request, and secure permission from Data Warehouse Partners in those cases where such permission required by the terms of any agreement between that partner and the Data Warehouse project.

3. The Research Project Consultant will grant or deny a request based on the extent to which (a) the research question is a valid area of study, (b) the requested data linkages will not violate the confidentiality restrictions of the organizations that own the data sets which are to be linked, (c) the Data Warehouse Findings will not be used to publically identify individual organizations nor compare the performance of one organization’s work to another’s, in accordance with Provision 1.2, above, (d) the Data Warehouse raw data will be able to provide a statistically significant answer to the question, and (e) the request adheres to the conditions set in the various agreements which govern Data Warehouse operation.

3. The Data Warehouse Research Project Consultant is not required to consider a Data Draw-Down request within a specific timeframe.

3. The Data Warehouse Research Project Consultant is not required to provide reasons for the rejection of a specific request.

3. At each Education Council meeting, the Data Warehouse Research Project Consultant will present the Education Council with a list of all data requests which he or she has approved since the previous meeting.

3. Each Data Warehouse Partner’s data request will be considered on a case-by-case basis. The Research Project Consultant and the Education Council reserve the right to grant different levels of access to different Data Warehouse Partners.

3. An organization’s participation on the Education Council and/or contribution of data to the Data Warehouse in no way guarantees that the organization’s data requests will be approved.

3. Previously-obtained approval of a Data Draw-Down Request does not guarantee approval for additional draw-down requests made in the future, even if there are similarities between the two requests.

3. If the Research Project Consultant denies an applicant’s Data Draw-Down request, that applicant may bring the matter to the attention of the Education Council for review. The Education Council is not required to review these appeals. If the Education Council agrees to review the appeal, the Council will serve as a neutral party in the negotiation between the Data Warehouse Partner who made the original request and the SAU Data Warehouse Research Project Consultant.

9. Presentation of Data Warehouse Findings.

4. Once a Data Draw-Down has been completed and the Data Warehouse Research Project Consultant is satisfied with the validity of the Data Warehouse Findings (see Provision 7.2.1.4, above), those Data Warehouse Findings will be presented to the Data Warehouse Partner who made the original request.

4. At each Education Council meeting, the Data Warehouse Research Project Consultant will present a list of all Data Warehouse Findings derived from the Data Warehouse since the previous meeting. In those cases where such a presentation of Data Warehouse Findings would violate confidentiality or usage restrictions set by any of the owners of the data which was linked, the Data Warehouse Research Project Consultant will share information about what data sets were linked and what question they were linked to research, but not share the Data Warehouse Findings themselves.

4. Individual Identifiability. In any Data Draw-Down, any Data Warehouse Findings for a subset of the total population where that subset has fewer than 10 individuals will be withheld, to avoid the possibility of any individual being identifiable by inference. In such cases, the Data Warehouse Data Steward will inform the Data Warehouse Partner who requested the Data Draw-Down of the reason for this redaction, but not the number of individuals in the subset of the population which necessitated the redaction.

9. Maintenance of Data Linkages and Cohorts. Unless otherwise directed, the Data Warehouse Data Steward will retain all data linkages and cohort identifications undertaken to draw down data in response to a Data Draw-Down request. This will facilitate repetitions of the same measurements in the future, both for cross-verification and longitudinal comparisons, as well as research into long-term impacts of needs and interventions. Note, however, that the Data Warehouse Data Steward cannot repeat these measurements except in response to a Data Draw-Down request which has been approved by the Data Warehouse Research Project Consultant.

9. Repeated Linkages. If an approved Data Draw-Down request included repeated measurements over subsequent years, it is the responsibility of the Data Warehouse Data Steward to keep track of and fulfill these commitments.

1. PROVISIONS AND PROCEDURES FOR RELEASE OF DATA FINDINGS. All Data Warehouse Findings generated through the Data Warehouse will be categorized as either Internal Data Releases or Public Data Releases, based on the purpose of each Data Draw-Down and how the resulting Data Warehouse Findings are disseminated.

10. Internal Data Releases. This Provision outlines the policies and procedures for Internal Data Releases, as defined in Provision 4.8.2, above.

0. General Guidance. The main purpose of the Data Warehouse is to generate data for Internal Data Releases. The majority of the Data Draw-Down requests from the Education Council will be of this type, as the Education Council uses local, linked, aggregated, and segmented data to drive decision-making about community need and the impact of different interventions. Other likely Internal Data Release requests will come from:

0. Data Warehouse Partners who wish to compare different intervention models or to measure the impact of changes to an intervention’s design.

0. Community funders who wish to gauge the cost-effectiveness of specific interventions they are currently funding. Note that such funders cannot make Data Draw-Down requests unless they (a) are also already Data Warehouse Partners, as defined in Provision 4.1, above, or (b) the request is sponsored by a Data Warehouse Partner on their behalf, as outlined in Provision 10.1.3, above.

0. Dissemination and Use of Internal Data Releases. Internal Data Releases remain in the joint ownership and control of the Data Warehouse partnership itself, the owners of the various data sets which were linked to generate those Data Warehouse Findings, and the Data Warehouse Partner(s) who made the original Data Draw-Down request (as well as any non-Partner organizations on whose behalf the request was made).

1. The Data Warehouse Partner who made the original request may share the Data Warehouse Findings only with those individuals or organizations, and only in the manner and for the uses, specified in the approved Data Draw-Down request. If the Data Warehouse Partner wishes to share the Data Warehouse Findings with additional individuals or organizations, or use the Findings in additional ways, they must first receive approval from the Data Warehouse Research Project Consultant first, in accordance with Provision 11.1.3.2, below.

1. Data Warehouse Partners make Data Draw-Down requests with the understanding that any unapproved or unauthorized use or dissemination of Internal Data Releases could result in the immediate Suspension of the Data Warehouse Partner’s access to the Data Warehouse, in accordance with Provision 9.5.3, above, and/or unilateral termination from the Data Warehouse partnership, in accordance with Provision 12.4, below.

1. Data Warehouse Partners make Data Draw-Down requests with the understanding that the resultant Data Warehouse Findings will be shared with the Education Council as outlined in Provision 10.5.2, above, unless confidentiality restrictions and/or the conditions of any agreement governing the Data Warehouse project forbid it.

0. Public Release of Internal Data Findings. In general, Internal Data Releases are to be used only to drive and direct internal discussion about community need and the interventions best suited to meet those needs. However, once an Internal Data Release has been generated, it can be used as a Public Data Release, in accordance to the policies and restrictions outlined in Provision 11.2, below, if either of the following sets of conditions are met:

2. The Education Council approves, by majority vote, a Public Data Release of the Data Warehouse Finding, or

2. (a) A Data Warehouse Partner makes an official request to the Data Warehouse Research Project Consultant (using the format outlined in Provision 10.3, above), (b) the Data Warehou

· Web viewThe purpose of the Quad Cities Data Warehouse (the “Data Warehouse”) is to facilitate the creation and maintenance of a master regional data set of individual-level

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