The Institute for Higher Education Policy has released its new report A Blueprint for Better Information: Recommendations for a Federal Postsecondary Student-Level Data Network. It's an interesting proposal, as with the College Transparency Act and previous recommendations for a national student database, it falls short in the usual areas. Primarily it ignores the states, particularly those with existing, longstanding systems in place. It is highly unlikely that most of those systems will go away with states relying solely on USED for data as there is no reason to believe that release of public data will be sooner than it is with aggregate data or that the  feds would produce the reports each state needs. Further, while it makes the point that "many institutions must calculate upward of 500 metrics" as part of their data submissions, won't they do this anyway to validate their files before submission? And many institutional reports are based within IPEDS structures, so I don't see this effort going away.

My friend Barmak Nassirian tweeted his concerns. I think they are well-placed, and while I don't necessarily agree with all he says, I think every point should be considered. Just the act of creating more data, better data, will not make things better - especially if it is not trusted as real.

For some time now, bemoaning the absence of a unit-record system has become an article of faith and the standard policy response on reform

— Barmak Nassirian (@BarmakN) October 18, 2017

You as should read the whole series of tweets.

So, if/as you read the report, consider the challenges and the potential value. I can't help but think we can do better than we do now at the federal level, but I also know that just because one presents data, there is no guarantee those data will be used to make any decision, let alone a good decision. But at least the possibility exists. I do think the privacy issues are real, but mostly I am concerned that states are left out of the discussion. I can envision just how messy it might get with institutions trying to ensure that individual records are consistent between SCHEV and USED, no matter how hard we work to make things parallel. Also, when you look at the list of data elements, that is a broad conceptual list - the actual list will be a bit longer.

Finally, did the authors of the report consider the European Union's General Data Protection Regulation? It is my understanding that institutions will have to gain Privacy Shield certification to be able to enroll EU students. I'm just beginning to look into this, so I really have no clue of the impact. It may be nothing, but it may create real challenges with sharing student records.

The General Data Protection Regulation Explained
http://er.educause.edu/articles/2017/8/the-general-data-protection-regulation-explained

GDPR: A Data Regulation to Watch
http://er.educause.edu/blogs/2017/8/gdpr-a-data-regulation-to-watch

Post-Brexit for UK:  https://techcrunch.com/2017/02/01/on-data-protection-brexit-means-mirroring-eu-rules-confirms-uk-minister/

Privacy Shield  - https://www.privacyshield.gov/article?id=My-Rights-under-Privacy-Shield .

Ultimately, I am not yet taking position. In general, I support the concept, and have since 1998, but I will wait to see how the College Transparency Act develops and whether legislation contemplates a vital role for the states and how privacy is addressed. Maybe Senators Wyden and Rubio will introduce an updated version of the Student Right-to-Know Before You Go Act. 

It's all exciting to watch.