DATA COLLECTION POLICY
The use of surveys and similar tools for the systematic collection of data and information from or about living persons entail certain rights and responsibilities. Users of both written and online data collection instrumentsmust protect those persons surveyed, who in turn should be aware of their rights and protections. Such tools shall be utilized only with proper authorization.
Note: The policies and guidelines in this document do not apply to official data collected and distributed by the Office of Institutional Research (OIR) or other offices on campus. These include surveys such as the Integrated Postsecondary Education Data System (IPEDS), and surveys done among institutions in common with Middlebury, such as the New England Small College Athetic Conference (NESCAC). Other surveys originate from a variety of organizations, such as publishers of guidebooks and journals. Data from many of these surveys are publicly available on the OIR website.
Responsibilities of data collectors
- Provide an explanation of the objectives of the data collection (hereafter called a "survey"), the procedures to be followed, the consequences of participation, and the risks and potential benefits
- Identify and include on the survey form the sponsoring College department or office
• Appropriate approvals of a College department or office must be secured in advance of distributing a survey • The survey form must include "contact information" (name, email, phone) should the respondents have any questions about the content of the form, or about the use and/or publication of survey results
- For research projects involving human subjects, determine if approval of the Institutional Review Board (IRB) is required. See: http://go.middlebury.edu/irb
see also below: Student, Faculty, and Academic Research
- Assure that those surveyed freely consent to participate
- Protect responsdents from risk of unreasonable harm, including any risks regarding confidentiality or privacy
- Respect the privacy of the respondents (see also: Personally Identifiable Information)
• Inform the respondents in advance if data collected will not be anonymous
- Protect confidential information received from respondents (see also: Personally Identifiable Information)
• Advise respondents in advance of any limits upon the collector's ability to ensure that the information will remain confidential (the extent to which data can be matched to the respondent)
- Inform the respondents if data and survey results will be published or distributed, including whether individual responses will appear in the published results
Rights of respondents:
- Privacy and confidendiality of respondents shall be respected
- Those surveyed as part of a research project shall be free to participate without being induced to respond
- Those surveyed as part of a research project shall be free to withdraw from active participation at any time with no risk to confidentiality, privacy, and without penalty or other loss
PERSONALLY IDENTIFIABLE INFORMATION
Personally identifiable information (PII) is information which can potentially be used to uniquely identify, contact, or locate a single person. Although individual piece of PII (such as your address) in itself may be public, a combination of PII elements can lead to invasion of individual privacy, information security, identity theft, and fraud.
- PII should be collected only as required in relation to the expressly stated purpose of research or a project
- PII relating to employees and students is selectively maintained and encoded on the College's administrative information system [Banner]. Such data may not be collected and retained elsewhere, including on personal computers, file servers, web or other internet servers.
- Certain PII should never be collected through a survey (category 2 in the table below), or only collected with explicit permission (category 3 in the table below), in order to protect the confidentiality of individual's academic records (for students/alumni) and financial information.
- Approvals shall be sought from Human Resources (for sensitive employee data) or the Dean of the College or Registrar's Office (for private student record information as defined by FERPA), or with approval of the Institutional Review Board (for academic/published research projects).
1. Directory information
- dates related to an individual (e.g., birthdate)
- email address
- telephone, cell phone numbers
- class year, course enrollment
- full face photos
2. Confidential/private information
-- never to be collected via survey:
- social security number
- bank account numbers
- driver license numbers
- health and insurance policy numbers
- biometric identifiers
3. Confidential/private information
-- requiring approval prior to collection:
- College ID number
- vehicle identification numbers
- salary, benefits, deduction information
- transcripts, grades, test scores
STUDENT, FACULTY, and RELATED ACADEMIC RESEARCH PROJECTS
Review and approval by the Institutional Review Board (http://go.middlebury.edu/irb ) is required for the conduct of original research if: personally identifiable information is collected or the researcher has access to private information AND the survey activity will lead to development of or contribution to generalizable knowledge, such as a published research report, article, newsletter, or book.
For example, IRB approval should be sought if the survey results will appear in a print or on-line publication, or dissemimated via a website, wiki, blog, or other internet accessible source. Student projects (including 500, 555, 600, 700 courses), even if conducted as part of the institutional curriculum, are subject to IRB guidelines if research using human subjects is involved. Student research projects, including senior and graduate theses, may be placed on the web as part of the College's institutional repository, or lead to publication. Hence, those including surveys are subject to IRB guidelines.
IRB review is not required if: no identifiable private information is collected surveys are conducted as part of assigned course work, exclusivly for instructional purposes, and results are not published.
ADMINISTRATIVE, EMPLOYEE, COMMITTEE, DEPARTMENTAL, STUDENT ORGANIZATION, AND OTHER PROJECTS
Individuals and student organizations seeking to collect data online not related to a specific course or faculty-sponsored research must receive sponsorship by an academic or administrative department or office of the College. Best practices in design and methodology should be followed in order to maintain integrity and trustworthiness of all data collection conducted on campus.
Various colleges committees, task forces, and other groups may collect data for reports, studies, planning, and other purposes. For each, the responsible group should seek appropriate approvals before conducting surveys. If the report includes data collected and maintained by the OIR, OIR staff must be consulted about data release and distribution.
- Data from surveys conducted by administrative offices, faculty committees, and other College committees are the property of the College.
- The group conducting a survey is responsible for managing and releasing the data collected.
- In most circumstances, individual respondents are not identified in survey results. Results should be provided in summary form.
- Summary results should be made available on request to persons who completed the survey.
- Reports on the results of surveys are generally made available to members of the College community who request them.
- Follow-up questions about survey summaries are answered at the discretion of the group conducting the survey.
- In some circumstances, data may be confidential and may not be made available publicly or to respondents. Any such limitation should be made clear to respondents at the time the survey is conducted, as well as within the report itself. When restrictions apply, publication and/or presentation of survey results must honor the stated restrictions.
- Data files from surveys are not made available except under special circumstances.
- Data files will be retained no longer than 2 years for surveys conducted by employees of the College; data from surveys conducted by students will be purged at the end of the following Fall or Spring semester following the execution of the survey.
The Office of Institutional Research [OIR] is responsible for official survey data related to Middlebury College See: http://go.middlebury.edu/instres
- The campus community should not be surveyed for information already collected by OIR.
- OIR should be notified of any research survey that is distributed to a significant portion of the campus population. The timing of surveys should not interfere the surveys conducted by OIR. The department or office sponsoring the survey should check with OIR in advance about research methodology, survey design, and timing.
ADMISSIONS, ALUMNI, PARENTS, FAMILY MEMBERS, AND OTHERS
The following are excluded from the category of original research under the purview of the Institutional Review Board.
- data gathering for the purposes of fundraising by the advancement office
- market research for the purposes of admissions recruiting
- recruiting efforts for faculty or staff
- statistical data collected for the management of institutional affairs
- attitudinal research of alumni, students, parents
However, any survey of members of the College's extended community may only take place following consultation, coordination and approval through the appropriate College office and, as required, the OIR. Examples:
|any survey that involves communication with:||requires coordination with the office of:|
|alumni and parents||College Advancement: Director of Constituent Records|
|faculty (current and retired)||Dean of Faculty; Provost|
|all students||Dean of the College|
|all employees (current and retired)||Human Resources|
|Language School students and faculty||Vice President for Language Schools, Bread Loaf and Graduate Programs|
|College Book Store customers||Director of Business Services|
|Attendees/supporters: athletic events||Director of Athletics|
|Attendees/subscribers:arts functions||Director of the Arts|
Failure to adhere to policies and guidelines relating to data collection will result in a written notification to the data collector and the associated College office listed above; access to the data collector account will be restricted by Library & Information Services, preventing use of the survey system, including access to past & current surveys, as well as the ability to create new surveys. Only upon appropriate review and approval by the College office will the account be re-activated by LIS.
USEFUL WEB LINKS
Office of Research Integrity, US Dept. of Health & Human Svcs. Office for Human Research Protections, US Dept. of Health & Human Svcs. Protection of Human Subjects, Federal Guidelines