Big Data and Privacy–The White House Report

On May 1, 2014, the President’s Council of Advisors on Science and Technology (PCAST) released a report entitled Big Data and Privacy: A Technological Perspective.  (See “PCAST Releases Report on Big Data and Privacy.”) Education is specifically mentioned in the report, although briefly, and many of the observations and recommendations have direct implications for higher education administrators, especially those involved in Information technology.

There are two or three techniques that colleges and universities have relied upon for privacy protection which PCAST believes “do not now seem sufficiently robust to be a dependable basis for privacy protection where big data is concerned” (xi). These techniques include anonymization, the framework of notice and consent, and polices limiting collection and retention of data.  Of these, the area with the largest impact for higher education is anonymization, because it is the main technique underlying FERPA:

Anonymization . . . is not robust against near‐term future reidentification methods [and thus no longer] . . . a useful basis for policy. Unfortunately, anonymization is already rooted in the law, sometimes giving a false expectation of privacy where data lacking certain identifiers are deemed not to be personally identifiable information and therefore not covered by such laws as the Family Educational Rights and Privacy Act (FERPA). (p.39)

Anonymization (or de-identification), PCAST points out, “is increasingly easily defeated by the very techniques that are being developed for many legitimate applications of big data” (xi).

Another widely used technique, notice-and-consent, draws criticism because it “places the burden of privacy protection on the individual. . . . . The provider offers a complex, take‐it‐or‐leave‐it set of terms, while the user, in practice, can allocate only a few seconds to evaluating the offer” (xii). Rather, PCAST argues, the responsibility for personal data protection should rest with the provider rather than the user.

Also, there are problems with attempting to limit the collection and retention of data: there is the fact that data, once collected, may persist in unintended areas; that “big data” may include information other than the information targeted; and that archived datasets are of legitimate value to data collectors..

In keeping with its charge, PCAST did not recommend specific policy changes, merely indicating areas in which policy changes are needed.  It  does not attempt to provide solutions.  Consistent with that approach, the report is remarkably free from anything approaching  legal language,

In its Final Remarks, PCAST’s reaffirms the concept of privacy as “an important human value,” one which ought to be preserved and protected.   The implications for strategic planning in higher education would seem to be very large.  Privacy is reaffirmed as a desirable goal, but the techniques which higher education institutions are currently using  to ensure it will be rendered ineffective in the near future.  One can expect considerable debate in Congress and in the DOE, with new regulations eventually working their way into new accreditation requirements.

Online Programs, Looking Forward

Over the next few years we can expect colleges and universities to consolidate their online offerings into more formal degree and certificate programs.  Whereas the online courses at traditional schools often began as separate divisions or were under the aegis of the Continuing Education division, institutions are now recognizing that they need to fully incorporate their online and blended courses into their regular offerings.  Indeed, such a recognition is central to evaluations of online programs like the Sloan Consortium Scorecard.  And while some of the regional accrediting agencies have yet to incorporate such requirements in their standards, it is very likely that they will be moving in this direction.

Thus there is a relatively short window–we estimate five years, more or less–during which Higher Education Institutions will be re-evaluating their course offerings and grouping them into coherent programs.  In fact, many schools have already taken this step.  But this is a point in an institution’s development where wise and shrewd consultation can be particularly helpful.  There are many elements that go into successful strategic planning for this transition, including a thorough analysis of an institution’s strengths, assets, and market niche, as well as its needs, in terms of leadership, administrative support, technology resources, web-based student support, and faculty readiness and buy-in.

The early days of online teaching saw attempts to convert face-to-face courses directly to online, with very limited success.  As we gained more experience with this new medium, we came to understand what can be taken from the traditional model, and what needs to be rethought.  The same period saw increasing adoption of Teaching and Learning Centers, and the best of these offer excellent guidance for the process of rethinking and reconstructing individual courses.  The Professional and Organizational Development group has some good materials on pedagogically sound ways of structuring courses to take advantage of this new medium, and rubrics created by Quality Matters, CSU Chico, and U of Central Florida offer good self- or peer-to-peer evaluations, after the fact.  Designed by and for faculty, they make for good continuous-improvement pedagogical tools.

Still, course evaluation and improvement is not the same thing as institution-wide analysis of new online, hybrid, or distance programs.  Further, an awareness of where regional and professional accreditation is headed can enable the strategic reorganization to be proactive rather than reactive, so that the institution anticipates new requirements likely to come out of the reauthorization of the Higher Education Act.

In sum, the moment at which a college or university looks to develop its online courses into fully realized degree and certificate programs is one of the best opportunities for consultation with a firm which understands the full dimensions of the changes involved.  A consultation at the outset of a new program can ensure that the online/ distance degree or certification programs supplement and enhance an institutions face-to-face and hybrid offerings, and that the institution which emerges from the process is stronger than before, better prepared to serve its students now and in the future, and where faculty, administrators, and staff continue to find the satisfaction which drew them to higher education in the first place.

 I am indebted to Jane Courcy of Berry Dunn for discussions which led to this analysis.

edX Article

Quoted in the Zintro Blog: “Harvard and MIT’s big online move,” July 9, 2012, by Maureen Aylward.  The text of the quotation:

Glenn Everett, a higher education consultant, says that the motive behind edX is research. “The Harvard and MIT announcements emphasize the data that they will gather on how we learn, for application, online, and also in the classroom,” he says.  “They apparently intend to do some follow-up with the students, to learn not just how well they do on the exams, but how well they acquire and apply the learning months after the course has ended. And although they speak briefly of making the venture pay for itself through “modest fees” for certificates of course completion, Edx is apparently not driven by need for profit; they are not worried about “monetizing” the idea.”
Another, perhaps not-so-secondary motive, would seem to be establishing brand identity online for these residential schools, says Everett. “When asked what they have learned from other initiatives, Anant Agarwal, edX’s president, mentioned Khan Academy as ‘no. 1 out there’ in terms of innovation. One might surmise that Harvard and MIT hope for edX to have a Wikipedia-like impact in the area of free online courses,” he explains. “edX may have a significant impact in non-credit offerings, a staple of continuing education divisions at many colleges and universities. But Khan Academy was already showing where the future was heading. In the long term, the impact on student learning may be significant, but that depends entirely on quality of the research yet to be done—but at least it will be done.”