Guidelines for Protecting Data Sensitivity (GPDS)
Original Approved: 11/2/10. Updated on 5/9/16 Pg. 2
LEVEL I: In order to provide access to all, these data are posted
on the San Diego Community College District (SDCCD) web site
(research.sdccd.edu). Select data will also be available on the
San Diego Miramar College Institutional Research website
(http://www.sdmiramar.edu/institution/research). If a requestor of
research would like access to Level I data that are not already
available, the requestor should complete a Research Request
Form (RRF) and follow the RRF protocol delineated in the section
below under Level II data.
LEVEL II: Individuals must complete an Research Request Form
(RRF) available at the Miramar College Institutional Research
website. RRFs will be processed upon the signed approval by
the requestor’s supervisors or Department Chairs and School
Deans. Supervisors or Department Chairs and School Deans are
responsible for ensuring that data are being requested on a
legitimate need-to-know basis. Requestors who are new to the
process may meet with the Miramar College Research and
Planning Analyst. Although the requestor may specify a project
timeline, RRFs are prioritized based on the Miramar College
College-Wide Research Agenda. External requests, such as
those from the press, community, or outside agencies, are to be
routed through the Miramar College Office of Planning, Research,
& Institutional Effectiveness for appropriate processing.
LEVEL III: Access will be granted on a need-to-know basis.
Individuals who wish to gain access are required to read, print,
and sign the GPDS Statement of Responsibility. Individuals who
are granted access to Level III data shall be ethically bound to the
GPDS. In the event that the data requested are not deemed
“need-to-know”, the data request shall be fulfilled at a more
aggregated and appropriate level of data sensitivity.
LEVEL I, II: Data reports will be available in PDF format only
in order to protect data integrity.
LEVEL II: All data will be stored on a secure server.
Proprietary data will be stored on the Miramar College “G”
drive.
LEVEL III: Access shall be password protected. Passwords
will be given to individuals on a need-to-know basis. Data
Stewards shall take all precautions necessary to prevent
disclosure of highly sensitive data to individuals who have not
been granted access. Individuals who have not been granted
access shall under no circumstances seek to procure, view,
or share sensitive data. Failure to comply with these
precautions and restrictions shall meet with serious
consequences, as per
FERPA.
Data Stewards should take care to:
1) Protect the confidentiality of usernames and passwords.
2) Log off or sign out after visiting a password protected
Intranet or Internet site.
3) Avoid creating databases or applications that use Social
Security Numbers as identifiers.
4) Never send un-encrypted sensitive data via email.
5) Protect printed sensitive data by storing in locked desk,
drawer, or cabinet and never leave unattended on desk,
copier, FAX, or printer.
6) Dispose of sensitive data by shredding or returning to the
Research and Planning Analyst.
7) Physically protect devices that can be easily moved, such
as PDAs, laptops, and portable storage devices (e.g.,
memory sticks).
LEVELS I, II, and III: Data will
be:
1) Fairly and lawfully processed.
2) Processed for purposes
specified in RFF.
3) Accurate and relevant.
4) Handled with utmost concern
for data security. All aspects of
research, including formulation
of the research question,
sample selection, choice of
variables, and methodology,
should be carefully thought out
and planned by Data Stewards
(users) with the assistance of
the Research and Planning
Analyst.
LEVEL III: Highly sensitive data
should always be used on a
need-to-know basis. These data
should never be used for
commercial, private, personal,
or political purposes.
LEVELS I and II: The
Research and Planning
Analyst shall disseminate data
as deemed appropriate to
requestors who follow the
protocol for submitting an
RRF. Proprietary data shall be
disseminated only with
permission. Individuals are
obligated to respect all
copyright laws and give
appropriate credit.
Reproductions of data reports
should have all original titles,
footnotes, and supplemental
information intact and
unaltered.
LEVEL III: Highly sensitive
data will be disseminated by
the Research and Planning
Analyst on a need-to-know
basis only to requestors who
print and sign the GPDS
Statement of Responsibility.
All Level III data that are
disseminated by the Research
and Planning Analyst will be
considered confidential and
issues related to confidentiality
will be discussed with
requestors. Reproductions and
unauthorized dissemination of
Level III data are prohibited.
