- III. Operational Planning Elements
The Unified or Combined State Plan must include an Operational Planning Elements section that supports the State’s strategy and the system-wide vision described in Section II(c) above. Unless otherwise noted, all Operational Planning Elements apply to Combined State Plan partner programs included in the plan as well as to core programs. This section must include—
III. b. 6. D. Privacy Safeguards
Describe the privacy safeguards incorporated in the State’s workforce development system, including safeguards required by section 444 of the General Education Provisions Act (20 U.S.C. 1232g) and other applicable Federal laws.
Currently, each of the core programs under WIOA maintains its own management information system (MIS) and adheres to the standards and laws which are applicable to the population being served and the data being collected therein. Participants (or their legal guardians where applicable for those under 18 years of age) are asked to sign release of information waivers, as appropriate, and are advised of their right to decline to share their information outside of the program to which they are applying. Provision of information is voluntary except where such information is necessary to determine program eligibility.
Additionally, data-sharing agreements between core and optional partners will provide specific and explicit instructions as to which data can and cannot be shared between programs, and under which circumstances.
With respect to privacy safeguards related to the General Education Provisions Act and other applicable Federal laws, the Idaho Data Management Council (DMC) is a council that was established to make recommendation on the oversight and development of Idaho’s Educational Analytics System (EASI) and oversees the creation, maintenance and usage of said system, including safeguards for student data and privacy concerns.
The Idaho Department of Labor cooperates with the EASI through the Statewide Longitudinal Data System (SLDS) agreement, following Council and agency policies and procedures for secure data sharing.
The purpose of the EASI is to allow longitudinal tracking of students from preschool through all levels of the public education system (elementary, middle and high schools, college and graduate school) and into the workforce. To reflect this scope, the EASI is referred to as a P-20W system. This system will collect data from a variety of disparate source systems, including the K-12 system developed by the State Department of Education, the systems in use at the various postsecondary institutions, the State Department of Labor, the National Student Clearinghouse, and others, and will transform that data into a single, coherent structure on which longitudinal reporting and analysis can be performed.
The privacy of all student level data that is collected by the EASI is protected. A list of all data fields (but not the data within the field) collected by the EASI is publicly available. Only student identifiable data that is required by law is shared with the federal government.
In order to advise and make recommendation to OSBE on the implementation of the EASI, the DMC will report to OSBE through the Planning, Policy and Governmental Affairs Committee. The scope of responsibilities of the DMC includes the following:
- Data Standards and Quality
- Ensure that all data elements within the EASI are clearly and unambiguously defined and used consistently throughout the system.
- Ensure that the data within the EASI is as complete and accurate as possible and complies with the agreed upon definitions.
- Access and Security
- Establish parameters for security and encryption of data uploads, data storage, user roles and access, privacy protection, and appropriate use of data.
- Review and approve mechanisms (technical and procedural) for implementing the required security and access rights.
- Establish guidelines for responding to requests for data access by various stakeholders, including school, district and college/university staff, education researchers, and the public.
- Change Management and Prioritization
- Propose enhancements to the EASI , review enhancements proposed by other groups, and set priorities for the development of those enhancements.
- Review and approve or deny any proposed changes to existing functionality, data definitions, access and security policies, etc.
- Training and Communication
- Establish guidelines for training of EASI users, and review and approve specific training plans.
- Ensure adequate communication concerning the EASI. In each of these areas, the DMC shall develop policies and procedures for OSBE approval as appropriate.
Members of the Data Management Council include the Office of the State Board of Education, Idaho Department of Labor, Idaho State University, Career Technical Idaho Division of Career Technical Education, North Idaho College, University of Idaho, and the Idaho Department of Education.