Data Ownership and Management Policy
Effective date: October 27, 2015
Objective: The Forum on Education Abroad (“The Forum”) frequently conducts the activities such as but not limited to the following that may result in the collection of sensitive, personal or institutional identifiable information:
- Surveys of The Forum’s member institutions and their representatives
- The Critical Incident Database (CID)
- Quality Improvement Program (QUIP) reviews
- The Professional Certification Program
It is in the interest of The Forum to make certain data available to others in furtherance of The Forum’s mission and objectives, while using commercially reasonable efforts to protect the confidentiality of the participating individuals, institutions and any individuals or institutions identified in the responses provided. Thus, the purpose of this policy is to establish a protocol within The Forum for the accuracy, ownership, retention, accessibility and security of this data.
Data: Data shall be construed as all recorded information, regardless of medium, and all actual samples or examples that were created or gathered through The Forum’s data collection efforts and that could serve to influence or support a survey or research finding or conclusion. Data does not include such items as research papers cited, preliminary notes or paper drafts, reviews, or related communications, or items that are already the property of others. This definition is intended to characterize current norms, not to modify them.
Identifiable Information: Identifiable Information, also called Sensitive Information, is information that can be used on its own or with other information to identify, contact, or locate a single person or institution, or to identify an individual or institution in context.
The Forum: The Forum on Education Abroad.
The Forum Staff or Forum Staff or Staff: These terms refer to paid employees of The Forum on Education Abroad. They do not include Forum member institutions or their representatives, nor do they include volunteers, such as, but not limited to, members of the Forum Board, Forum Council or Forum Committees and Working Groups.
Outside Consultant or Contractor: A non-employee of The Forum who is paid by and under contract with The Forum to assist in some aspect of data collection or analysis. When contracted for assistance with research projects, this person must sign a Confidentiality Agreement not to use or disclose any of The Forum’s Data to which they have access except as expressly authorized by The Forum.
Confidentiality Agreement: A written agreement binding a person or entity to treat specific information as proprietary information and/or a trade secret, including a promise not to disclose the proprietary information and/or trade secret to others without proper authorization or as required by law.
Application & Responsibilities
The Forum on Education Abroad Data Ownership and Management Policy (set out in this document) applies to all data collection and research conducted by The Forum and its Staff, regardless of funding source, if any. For sponsored research, any relevant policies of the sponsor shall apply in addition to those provided here. Any apparent conflicts of policies are to be resolved in writing and approved by the President prior to accepting or entering an award, contract, or other binding agreement. If a conflict becomes apparent at a later date, the party who becomes aware must inform the other immediately and a resolution must be agreed upon in writing by all involved parties.
Period of Retention of Research Data and Records
Records of data containing Identifiable Information will be retained for a period of at least five (5) years after initial publication/dissemination of the survey results. The data shall be retained for a longer period as dictated by any applicable law, policy, or written agreement. If more than one minimum period of retention is deemed to apply, the data will be retained for the longest of these periods. Aggregate data and the publications that result from them may be retained by The Forum indefinitely.
Storage of Research Data and Records
All Data collected by The Forum is kept on password protected computers on the Dickinson College network and backed up according to Dickinson College’s network management protocols under a contractual agreement between The Forum and Dickinson College. Only Forum Staff with a “need to know” have access to Data collected by The Forum.
Security and Protection
Individual response data collected by The Forum will be assigned a unique personal identifier to be used for storage of information to ensure the confidentiality of the participant or participant institution’s information. Any publications or presentations prepared by The Forum will include only information about aggregate group data or fully anonymized individual comments in such a way that responses will not be identifiable to any individual institution or organization. The Forum will use commercially reasonable efforts to keep Identifiable Information confidential. All Data that constitutes confidential information of The Forum shall be marked conspicuously with the legend CONFIDENTIAL AND PROPRIETARY PROPERTY OF THE FORUM ON EDUCATION ABROAD. All Data shall also be marked with a copyright notice in the following form: Copyright 2017. The Forum on Education Abroad.
Removal or Movement of Data and Records
Forum Staff and only Forum Staff has the right to distribute Data to other parties as needed and under a binding Confidentiality Agreement with approval from The Forum’s President. Outside Consultants and other non-Staff parties will be required to return to the Forum Staff and/or verify their deletion of all copies of all Data associated with the project upon completion of their services in whatever form they exist.
Destruction of Records
Forum Staff will be responsible for destroying all paper and digital records at the appropriate time as outline in the sectioned “Period of Retention of Data and Records” above and documenting the action taken.
The Forum is the sole owner of the Data. Any agreement to the contrary requires approval from the President.
Collaborative Data Collection Projects
When Data collection projects are undertaken in collaboration with other individuals or institutions, ownership of Data must be established in a written agreement between or among the involved parties before a project begins.
Data shall be maintained in a manner that prevents alteration or that makes any and all alterations evident. If a datum is revised, the reason for revising it must be documented and dated. Electronic Data should be kept on a read-only medium, or in a read-only mode. The Forum should be able to document and justify any modification of the Data.
Only The Forum Staff shall have access to Data containing Identifiable Information. At The Forum Staff’s discretion, an Outside Consultant can be hired, under a Confidentiality Agreement, to assist in data analysis. In such a case, that individual may also be given access to unprocessed Data if necessary. Such agreements shall generally be of limited duration.
This policy is effective beginning October 27, 2015.
Anyone with questions regarding this policy can contact The Forum President.
Amendments to this policy must be approved by the President and the Audit Committee of the Forum Board.