The main purpose of community data sharing is to create a community-wide information system that supports interactions with many service providers to deliver a comprehensive, longitudinal perspective on each child, leveraging data and technology to provide better, faster, and continuously improved services. In Community Data Sharing Initiatives - Community Collaboratives - participants share information regarding the children they serve. It is essential to have a clear definition of how the sharing is managed and authorized and which information is shared. 

The Backbone Organization (Longitudinal Community Database) of the collaborative is the lead partner organization that is responsible for community agreements on data governance and data sharing, an agreed-upon approach to parent consent, collaborative goals, and the associated data set to be shared. This organization is responsible for Data Management Services: the “scoping” of data access for data sharing partners and users, defining the approach to mapping children between organizations, consent administration, and an approach to managing data quality. [e.g. duplicates]

• Legal Data Sharing - Community Agreement
• Organization & User Scoping 
• Child-Organization Mapping
• Consent Administration
• Data Quality

Data Users are partner organizations that are interested in accessing the Data Contributors’ child-related information either in aggregated, de-identified or identifiable format. The leverage the COMET Community Reporter. Commonly, Data Users are also Data Contributors, but not necessarily (e.g.: funding organizations like United Way, County, or City services).

• Aggregated & De-Identified Community Reports & Exports
• Geo-Coded Map Demographics
• Data For Program Evaluators
• Compare Your Organization To The Community
• Identifiable Data Reports & Exports, For Those With Proper Consent

COMET Operations

Data Contributors are partner organizations that directly interact with children and record child-driven information in COMET, or in their own operational database - Pass-thru Data Contributor -- that will be integrated into the data-sharing initiative. Another approach to contributing data is to provide program participation as a Roster Data Contributor through a list of your children (ID, last, first, DOB, gender). Note that contributors "own" the data they contribute in an explicit or implicit agreement of confidentiality [e.g.: Family Educational Rights & Privacy Act (FERPA)] with each child’s parent.

Data Contributors - Collected In COMET

• Community Organization Running Programs & Providing Support
• Funder Collecting Data From Multiple Service Providers
• School District SEL Program
• City Sending Data (Pass-Thru)

Data Contributors - Collected External To COMET

• Student Information Systems (SIS)
• Community-Based Organizations
• Government & Heath Systems

Parent Portal

Parent / Guardian involvement is key to a data-sharing initiative. COMET’s community data sharing solution supports parent approval of the sharing of their child’s data. Recording and leveraging parent consent is fundamental to a data-sharing initiative. 

• Parents Understand & Control Their Child's Data & Can See Their Child's Information, Including Assessment Results
• They Can Provide Input On Their Child & Communicate With Those Who Work With Them

Community Reporting 

COMET’s community data sharing solution is powered by our sophisticated reporting application - COMET Community Reporter, supporting aggregated and de-identified community reports and exports, geo-coded map demographic visualization, data for program evaluators, community comparison reports, and identifiable data reports and exports. 

• Aggregated reports: Typically, such reports may pull data from multiple Data Contributors and consolidate / aggregate accordingly. These reports are authorized through the data-sharing agreement between the service provider partners. 
• De-identified child-level reports or data extraction: Typically, these reports are used for research purposes. Records are de-identified meaning that they do not contain any data element that could identify a child (e.g.: name, ID, etc). These reports are authorized through data-sharing agreements between the service providers. 
• Identifiable child-level records: It is possible to report on identifiable child data, but this data sharing requires valid parent consent and clear authorization from the Data Contributor.

Only data sharing can enable outcome measurement across organizations. So, if an after-school program and a school want to measure if their collective work has a positive impact on school attendance and academic outcomes, and to determine which programs are effective and to fund, data sharing is essential.

Ideally, every community's child-serving organizations will share data and collaborate to improve common goals; realizing the vision of a comprehensive, longitudinal community database supported through the efforts of Partner Organizations that work together in a Community Data Sharing Initiative in which its children are thriving.

Ready to join a collaborative? Take our readiness quiz.

Original Posting 18.09.17

Stating concern for privacy, schools sometimes will not get involved in data sharing with community organizations or initiatives. Although permissible under federal law, the schools struggle with this change – whether from having an insular culture, resistance to change or a fear of increasing liability. The U.S. Department of Education is now providing guidance for how districts can work within the United States’ student-data-privacy law - the Family Educational Rights and Privacy Act (FERPA). They recommend that schools understand that integrated data system implementation is a multistep process. Each of the steps should be justified using the appropriate exception written into FERPA.

A few helpful concepts:

• "School Official" Exception: A provision that allows a district to share educational records with third parties as part of outsourcing a service that it lacks the capacity to perform itself, such as sharing identifiable records with an integrated data warehouse that links with other administrative data.
• "Studies" or "Audits and Evaluation" Exceptions: A provision where schools give permission for analysis of de-identified records from the data warehouse by approved researchers. Note that research projects must have an instructional benefit for the schools involved.
• Data Sharing Agreements: The process must include written agreements that detail all the terms of the relationships. School districts are responsible for protecting the education records they disclose.
• Parent Consent:  Records that have “identifiable” data that allows a child to receive appropriate interventions can’t be shared without parental consent. So if servicing the child to improve outcomes requires sharing of specific child records, a signed parent consent process must be implemented before this data is shared. Under FERPA, if the department is the legal guardian of the child, such as those in foster care or other court-ordered placements, then the department has the right to access their educational records.
• Security Protocols: Access to the data warehouse should be limited and school districts should generally have no access into individual records with the child’s data in this warehouse. They will receive information that has been aggregated where no child can be identified.  This aggregated information is also often shared with other participating organizations and agencies, often with a “Community Report Card” approach as part of a continuous improvement effort.

Here is a nice checklist from the U.S. Department of Education’s “Data-Sharing Tool Kit for Communities: How to Leverage Community Relationships While Protecting Student Privacy” - a resource full of good tips for school districts.

Getting Started: A Quick Checklist for the School

• Establish criteria in the annual notification of FERPA rights about who is a “school official” and what constitutes “legitimate educational interests.”
• Determine if the disclosure is to a school official who has a legitimate educational interest in the education records.
• Use reasonable methods to ensure that school officials obtain access to only those education records in which they have a legitimate educational interest.
• If outsourcing school services or functions to a third party, make sure your third party does the following:
  • Performs a service or function for which the school would otherwise use employees
  • Is under the direct control of the school regarding the use and maintenance of education records
  • Complies with the PII from education records use and re-disclosure requirements

COMET is pleased to support a number of communities in their data sharing efforts.  Check out our Community Data Sharing resource for more information. If you’re struggling to connect with your local school district, contact us. We have lots of experience working through these data sharing agreements.

Original Posting 02.05.18

...and by value, we mean necessity. If your programs are collecting data about the children and youth enrolled, you have hopes of sharing that data outside of your organization and you know parent consent is needed, here are some things to think about.

We work with a lot of organizations who collect data and ask us to help them understand how to share that data with another organization (a partner, a funder, a school district, etc.). We usually explain to them that the how of sharing the data is almost always doable. There is often time and cost involved but connecting two data sources is not an impossible task. There also need to be legal agreements in place to share data between the organizations (more on that topic here). However, often the hardest part which not everyone considers, is securing parent permission to share that data.

A few tips we’ve shared with customers related to parent permission include:

• Permission first. Secure parent permission to share data from the start. Include consent forms for data sharing with your sign-up /registration process and secure that permission up front. This saves you from having to go back later on and connect with parents one-by-one to get permission.
• Think ahead. If you’re going to ask for permission to share data, you need to be specific, but also think ahead. If two years from now you’re hoping to connect with the school district, ask for permission to share with them now. This saves you from having to go back and ask permission or amend your forms down the road.
• Be specific. Finally, you need to be specific about what data you’re going to share and who you are going to share it with. The language needs to be clear to the parents. A blanket consent to share any and all data with whomever you choose won’t work out well (at least, this what the lawyers tell us).

At COMET, we work with our customers to the best of our ability to help them through thinking about what parent consent they’ll need, how best to collect it and where to store that information. We can't advise on all of the legal requirements and we always encourage organizations to consult with their lawyer, but we can talk about the experiences we've had with others and we're happy to share sample agreements and recommendations.

If your organization is thinking about sharing data with other groups to help improve outcomes for kids, check out our Resources page for more materials on data sharing. 

Still have questions? Contact us!

Original Posting 16.01.19

One of the most exciting developments to come from COMET is happening - The COMET Parent Portal! We have a beta version in production and one special customer, GROW Rochester, who is in a pilot rollout phase. We also have secured funding to develop phase 2 of the portal with some exciting additional features - the ability for parents to complete assessments through the portal, a messaging system, the ability to view attendance records, and much more!

The COMET Team is really excited about this project. It's been in design over the last couple years, and now with the pilot we can begin to demonstrate that connecting with parents can make all the difference in the effectiveness of programs. We hope this parent portal will serve as one way for our customers to bridge the gap between home and school, or between home and afterschool. All the research and best practices agree, connecting with parents is critical and truly makes a difference.

We hope you're excited as we are. The parent portal isn't just a new population for us to connect with, we're focused on using new design and technology as well as mobile development, with lots more new things to come. For now, all we can say is that we're diligently working on it, but as timelines for a general rollout are developed we'll be sure to let all our customers know. In the meantime, connect with your Account Manager if you're interested in learning more ASAP - maybe we can arrange a sneak peek for you! Just email support@comet4children.com.