Educational Data Requests

UC San Diego Skaggs School of Pharmacy and Pharmaceutical Sciences (SSPPS) Educational Data Request Guideline and Procedure

Purpose

To manage requests for data owned, stewarded, and maintained by the UC San Diego Skaggs School of Pharmacy and Pharmaceutical Sciences (SSPPS) in a manner that protects learner confidentiality and fosters the use for the improvement of our educational programs and educational research.

Overview

SSPPS provides a variety of services that include supporting a central repository of data available for use in program evaluation, educational research, quality improvement. Many departments and university administrators need access to graduate level data to complete their internal reports and to guide their decision-making process. When there is a need for graduate student school data, follow the guidance below, UC San Diego IRB Guidance for Researchers, and submit an online Data Request Form.

Related Confidentiality of Student Records

The disclosure of information from student records is governed by the Federal Family Educational Rights and Privacy Act (FERPA), by the State of California Educational Code, and by University of California policy.

Additionally, this guideline aligns with UC San Diego Disclosure of Information from Student Records and Office of the Registrar Guidelines and Protocols for Requesting Access to Restricted Student Data.

When reporting in aggregate, we follow a general rule of 10 to protect student identity. That is, upon filtering by particular criteria, if the student group displays fewer than 10 students, you should not report information for that group if that information will be available to those external to SSPPS.

Definitions

For the purpose of educational data requests, data are classified into the following categories:

1. Learner demographics: Includes descriptive data about learners (e.g., year in program, graduation date, age, UIM status, undergraduate institutions, etc.).
2. Learner performance: Includes learner academic achievement prior to, during, and post training (e.g., admission data, internal and external examination scores, assessment of learner performance etc.)
3. Program performance: Data on satisfaction with the SSPPS curriculum, programs, and faculty/non-faculty teaching (e.g., program, course, and faculty evaluations, AACP annual surveys etc.) and data from surveys and research conducted by SSPPS faculty and staff on programs that are not a part of routine program evaluation.

Procedure

1. Data Requests
   • All data requests must be made through an online Data Request Form.
   • All data requests must include all requested information including the reason the data is needed, type of data needed, and how the data will be secured.
2. Data Consultations
   • A member of the Data Request Team may require consultation in order to verify the use of the data.
   • Consultations will be required for all requests considered “High Risk”
   • These may include data request for de-identified or easily identifiable data, and requests from individuals without prior experience handling sensitive data.
   • Topics covered may include:
     • Clarification of the type of data requested.
     • Confirmation of the availability of data.
     • Review and clarification of data security and confidentiality requirements.
     • Clarification of intent of educational research.
     • Clarification of intent of continuous improvement work.
3. Data Security
   • Data must be stored in accordance with UC San Diego and UC minimum standards, guidelines and policies
   • All requestors must demonstrate understanding of the Family Educational Rights and Privacy Act (FERPA).
   • All requestors and staff releasing data to requesters must follow best practices for complying with FERPA and UC San Diego guidance for student record privacy and confidentiality.

     More information about UC San Diego Health Sciences and UC Systemwide Information Security and Privacy at:

     • UC Systemwide Electronic Information Security Policy
     • UC San Diego Health Sciences Office of Compliance
     • University of California San Diego Health Policies (UCSDHPs) Series 1-50
     • University of California Office of the President (UCOP) Privacy and Information Security Initiative
4. Access to Data
   The Data Request Team will provide access to educational data for which the SSPPS is the primary owner as permitted by School and University Policy. SSPPS retains the right to prioritize the fulfillment of data requests based on current priorities and the complexity of the request and to refuse any data requests.
   • Access to data will be provided for which SSPPS is the primary owner. When 3rd party data is requested to be incorporated into a data set, the requestor is responsible for securing access to the specified data.
   • The Data Request Team retains the right to prioritize the fulfillment of data requests based on current priorities and the complexity of the request and to refuse any data requests.
   • Current students cannot be granted access to any peer learner demographic or performance data, regardless of its format.
   • Access to program performance data and research conducted by the SSPPS on its curriculum and programs will require approval/support.
5. Research Data Requests
   • Approval by the UC San Diego Institutional Review Board (IRB) is required prior to the release of any data used for education research. Data requests can be made prior to IRB approval but data will only be released with IRB approval.  Please note that only SSPPS has the authority to grant requestors permission to use program data.
   • Any changes to the IRB protocol including changes to the research team membership (key personnel) must be shared promptly with the Data Request Team.
   • Any data sharing with investigators outside of UC San Diego must be approved by both the IRB and Data Request Team and comply with current University policies on data sharing.
   • Approval for access to data does not override restrictions described in UC San Diego Policies.
   • SSPPS reserves the right to refuse to release data that would compromise the school, its faculty,  and/or learners.

Data Request Review Process

1. Complete and submit a Data Request Form.
2. Receive a confirmation email request is received.
3. Allow up to 15 business days for completion of request.
4. An Assigned Analyst will review the request, verify IRB (if needed), and may email requester with questions.
5. The Assigned Analyst pulls and refines the data.
6. An Assigned Analyst validates the data file.
7. The Assigned Analyst emails requestor with data file via secure practices.
8. After reviewing the file, requestor can ask questions or request more data.
9. The Assigned Analyst completes request and saves final data file in SSPPS drive.

Clinical Data - Systemwide & UC San Diego Health:

• University of California Health Data Warehouse (UCHDW)

The Data Discovery Platform contains tools to allow researchers to query and analyze a HIPAA limited data set (LDS) generated from the UCHDW. Direct access possible rather than via ACTRI BMI team.

• Altman Clinical and Translational Research Institute (ACTRI) - Data Extraction Concierge Service (DECS)

DECS is the institutional provider of EHR data for research. Biomedical Informatics (BMI) offers data management and biomedical informatics services in support of clinical and translational research. BMI supports key applications including real-time cohort exploration (ACT, TriNetX), an electronic data capture system (REDCap), compliant clinical trial management systems, a biospecimen information management system (Velos), and Data Warehouses for Research (UCHDW) with data from over 1 million patients. Investigators receive data and analyze it in an ACTRI-managed secure research cloud through a personalized Virtual Research Desktop.

• Epic Cosmos

Available in future, UC San Diego currently testing. Epic will take deidentified clinical data points from Epic instances and form a high quality, representative, and integrated data set for researchers to study diseases and conditions at a national scale