Overview
The use of student financial aid data is restricted based on the Higher Education Act of 1965 (HEA). These restrictions limit the purposes for using student-specific financial aid data, and the disclosure of the identity of financial aid recipients. These restrictions are in addition to FERPA guidelines that apply to student data more broadly and to critical data storage guidelines from the Gramm-Leach-Bliley Act (GLBA). More information is in Appendices B, C, D, and E below.
Based on guidance from IU University Student Financial Aid and the National Association of Student Financial Aid Administrators (NASFAA), Institutional Analytics/Compliance & Reporting (IA) 1 makes student-level financial aid data available to IU financial aid staff and IU Institutional Analytics staff. Staff who have unitrecord access need to complete annually the IR FA Data User Agreement, shown below in Appendix A below.
Here are reporting guidelines that expand on the IR FA Data User Agreement:
1. Use the data for purposes of administering Federal Title IV, state, or institutional student financial aid programs, or programmatically (not individually) to improve processes that can promote student retention and graduation.
2. Use the data in aggregate whenever possible. When that is not possible, use the data in a way that obscures the identity of recipients.
3. When sharing data beyond your office, provide the minimum data needed to administer Federal Title IV, state, or institutional student financial aid programs or improve student outcomes without targeted, student-specific intervention. Here are some examples:
Here are reporting guidelines that expand on the IR FA Data User Agreement:
1. Use the data for purposes of administering Federal Title IV, state, or institutional student financial aid programs, or programmatically (not individually) to improve processes that can promote student retention and graduation.
2. Use the data in aggregate whenever possible. When that is not possible, use the data in a way that obscures the identity of recipients.
3. When sharing data beyond your office, provide the minimum data needed to administer Federal Title IV, state, or institutional student financial aid programs or improve student outcomes without targeted, student-specific intervention. Here are some examples:
a. The following is appropriate: Notate eligibility for state grants in student advising records to make advisors aware a student must pass 30 credits each year in order to maintain eligibility for the 21st Century Scholars award.
b. In IA Tableau reports, data are aggregated, and small cell sizes of < 11 are masked. Details for this are in a separate IR FA Data Technical Guide for Report Developers. Also, the Data Warehouse tables, views, and columns that are subject to these student privacy guidelines are listed in the Excel file IR FA Data Elements – Tables, Views, and Columns.
c. When providing an Excel data set, aggregated figures are provided whenever possible.
d. If unit-record data (by student) are requested, here are additional guidelines:
i. Leverage the IR Financial Aid Sharing Decision Tree for responding to inappropriate data requests.
ii. If exceptions are requested, consult a campus financial aid director or the University Financial Aid Director to discuss what is appropriate.
iii. Whenever possible, exclude personally identifiable information (PII), including combinations of data elements that would disclose the identity of recipients.
Since summer 2022, Institutional Analytics/Compliance & Reporting is the formal name for University Institutional Analytics (IA): https://iuia.iu.edu/index.html
Appendix A – Financial Aid Data User Agreement
The Department of Education’s Privacy Technical Assistance Center (PTAC) provides guidance on the use of student data in order to comply with the Family Educational Rights and Privacy Act (FERPA), Section 483(a)(3)(E) of the Higher Education Act (HEA) regarding students’ Free Application for Federal Student Aid (FAFSA) and aid information, and the Privacy Act.
De-identified, aggregate, descriptive statistics about program participants is a permitted use of FAFSA data, Institutional Student Information Record (ISIR) data, and related award information.
Under HEA restrictions, individual or personally identifiable information (PII) about FAFSA data and aid eligibility may only be used for the application, awarding, and administration of federal, state, and institutional aid programs.
Examples
Inappropriate:
Providing a list to facilitate contacting all Federal Pell Grant recipients to offer free tutoring, or discounted campus Counseling and Psychological Services (CAPS) appointments.
Acceptable alternative:
Advertise services to all students and mention that discounts are available for Federal Pell Grant recipients. Let the students disclose their status, directly.
Inappropriate:
Send names of O’Bannon Grant recipients with the Academic Honors incentive award to the Chancellor so she can congratulate them.
Acceptable alternative:
Disclose the percentage of O’Bannon Grant recipients with the bonus to highlight how the academic achievements of some students can make college more affordable.
Appropriate:
Notate eligibility for state grants in student advising records to make advisors aware that a student must pass 30 credits each year to maintain eligibility for the 21st Century Scholars award.
Additional Resources
• IR Financial Aid Data Sharing and Reporting Guide
• IR Financial Aid Data Sharing Decision Tree
• Data Sharing Decision Tree – NASFAA
• Protecting Student Privacy – US Department of Education
• Use of FAFSA Data to Administer Federal Programs
• PTAC guidance on Use of Financial Aid Information – US Department of Education
Please read, sign and date below, and return this PDF fillable form by email: uirr@iu.edu .
I acknowledge that the student financial aid data entrusted to me has more stringent federal privacy restrictions than other student data described in the IU Acceptable Use Agreement. I agree to share or provide only de-aggregated data with no personally identifiable information to requestors who require that data to fulfill the duties of their jobs. Personally identifiable data will only be shared with the express consent from a campus financial aid director or the University Financial Aid Director, for the purpose of the application, awarding, and administration of federal, state, and institutional aid programs, or other uses
expressly allowed by the U.S. Department of Education.