Five Reasons to Oppose NCES Participation in the Int’l Early Learning Study

Karen Effrem uncovered yet another governmental threat to the privacy of young children and their families – the National Center for Education Statistics’ proposed participation in an International Early Learning Study. Below is the comment on this proposal, submitted to the Federal Register by APP:

American Principles Project (APP) submits this comment in opposition to a proposal by the National Center for Education Statistics (NCES) to join the Organization for Economic Cooperation and Development (OECD) in conducting the International Early Learning Study (IELS).

As outlined in FR Doc No: 2016-29749, the IELS will focus on “young children and their cognitive and non-cognitive skills and competencies as they transition to primary school,” examining their “social emotional skills as well as cognitive skills; the relationship between children’s early learning and children’s participation in early childhood education and care (ECEC); [and] the role of contextual factors, including children’s individual characteristics and their home backgrounds and experiences, in promoting children’s growth and development . . . .”

In other words, through NCES the federal government intends to compile data about young children’s most personal and sensitive characteristics – their personalities and their “social emotional” development. APP opposes federal participation in this project for the reasons outlined below.

First, the federal government has no constitutional or statutory authority to engage in this research. The Constitution places all responsibility for education with the states and the people, not with the federal government. Especially objectionable is the federal government’s assumption of authority to examine – and perhaps set standards and norms for – young children’s attitudes, mindsets, dispositions, and values. It is difficult to imagine a more inappropriate use of any government resources, much less federal resources.

Second, this proposed study wastes yet more taxpayer money on something (government preschool) that has already been determined, in multiple studies, to be either useless or even harmful to children in the long run.

Third, experts in child development and mental health have warned that such standards and assessments of young children are highly subjective, especially when implemented by untrained teachers. Even worse is the possibility – or probability – that these unreliable assessments will be included in children’s permanent dossiers that are maintained in the state longitudinal databases (creation of which was incentivized by the federal government).

Fourth, participation in this international study, with its resulting compilation of highly personal student data, will threaten the privacy of young children and their families. The regulatory gutting of the Family Educational Rights and Privacy Act (FERPA) means that personally identifiable student data can now be disclosed to almost anyone in the world if the disclosure is rationalized by “evaluation” of an “education program.” So the unreliable assessments of children’s social and emotional states can be made available to an international organization (and presumably to agencies in the other participating countries) without even providing notice to parents, much less obtaining their consent. The inappropriateness of this should be self-evident.

Fifth, the federal government has proven itself incapable of securing the education data it already has. In late 2015 a hearing of the House Committee on Government Oversight and Reform revealed the shocking lack of student-data security throughout the U.S. Department of Education (USED). The problems encompass both lax controls over the people allowed access to sensitive data, as well as outdated technology and inadequate security to prevent unauthorized access.

The findings of the Office of the Inspector General (OIG) and the General Accounting Office illustrate why the federal government should not get its hands on any additional student data, especially such sensitive data as would be reported by the IELS:

  • Of the 97,000 account/users with access to student information (government employees and contractors), fewer than 20 percent have undergone a background check to receive a security clearance.
  • The security mechanisms protecting that data are grossly inadequate. As one OIG witness testified, “During our testing . . . OIG testers were able to gain full access to the Department’s network and our access went undetected by Dell [the vendor] and the Department’s Office of the Chief Information Officer.”
  • USED ignored repeated warnings from OIG that its information systems are vulnerable to security threats.

That the federal government should now consider adding to its data warehouse the extremely sensitive data of young children and their families is the height of arrogance and recklessness.

And finally, if data-security is this bad in the U.S. federal bureaucracy, it may be as bad or even worse in the other countries with which the data might be shared. American citizens should not have to worry that their children’s most personal data is circulating around the globe, with perhaps minimal protection.

For these reasons APP opposes participation by NCES in the International Early Learning Study and urges the new Administration to cancel this project.

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