The Arizona State System for Information on Student Transfer (ASSIST) is a database providing Arizona’s community colleges and universities longitudinal comparable data to research issues related to understanding of the transfer process, assessing the effectiveness of transfer policies, and reporting the completion rates to state and federal governments and other interested parties.
Since the ASSIST database contains information protected by the governing boards of Arizona’s community colleges and universities and state and federal law, this document outlines the security provisions to protect the privacy rights of the students whose records are in ASSIST. ASSIST is a project funded jointly by the State of Arizona and Arizona’s universities and community colleges.
The ASSIST security plan involves four parts:
- A joint resolution establishing ASSIST and designating the project’s principal agent.
- Rules for passing data to AZTransfer for the purpose of building ASSIST.
- Rules for passing data to participating institutions for conducting research.
- Policies and procedures governing the administration and use of ASSIST.
Adopting ASSIST Joint Resolution
The governing boards of the participating community colleges and universities adopted a joint resolution specifying: (1) that ASSIST will be used solely for researching issues related to transfer within Arizona, (2) that the AZTransfer Steering Committee (formerly APASC) is the responsible oversight committee, and AZTransfer its agent to create and administer the database, and (3) that ASSIST will be administered in a manner that protects the privacy rights of the students whose records are included. AZTransfer is a committee comprised of community college and university representatives responsible for administering Arizona’s transfer articulation model. (See ASSIST Joint Resolution.)
Passing Data to AZTransfer
Arizona’s community colleges and universities annually send student records to AZTransfer for inclusion in ASSIST. Matching records requires that individually identifiable data, such as SSN, name, and birthday, be available to AZTransfer. So that institutions do not violate FERPA when passing individually identifiable data to AZTransfer, AZTransfer signed an agreement assuming responsibility for enforcing the institution’s FERPA obligations, and protecting student privacy rights in ASSIST. The institutions that provide student record information to AZTransfer under the ASSIST project designate AZTransfer as an “other school official,” as that term is used in FERPA. Data are passed to AZTransfer via secured FTP processes or through registered mail. Once received, only designated employees at AZTransfer are authorized to work with the data, and the data are stored on a server behind a firewall accessible only to those employees.
Passing Data from AZTransfer to Participating Institutions
After matching student records, AZTransfer loads the data into a relational database on a server that is accessible through the web by user account and password. Personally identifying characteristics, such as SSN, student name, student address, and birthday, are excluded in database and never loaded onto this server. ASSIST assigns a new identifying number to each student, so that research involving individual records is possible without violating student anonymity. The database is structured so researchers can only access records of students from their institution and not another institution. Further, researchers authorized to access ASSIST are required to execute a nondisclosure agreement. This agreement obligates the researcher to protect the privacy rights of students in ASSIST, prohibits matching ASSIST records with local data, and prohibits the researcher from allowing a third party to use their account and password.
Policies and Procedures Governing Use
Participating institutions retain ownership and control over their data and approve all research involving ASSIST. Requests for information from ASSIST follow existing procedures and policies established by the community colleges and universities. Institutions designate the researchers authorized to access their data in ASSIST. AZTransfer trains these persons to use ASSIST, including the requirements imposed by FERPA and the ASSIST Security Plan. The agreement between AZTransfer and participating institutions precludes using ASSIST for operational purposes, or any other purpose not consistent with research or assessment. Also, the ASSIST Agreement prevents AZTransfer from granting access to persons other than those designated by the institution.