Top of Page
Main

External Research Study and Data Policy

Section 203.4 | Board Report 19-1211-PO3 | Date Adopted December 11, 2019

Policy PDF  English

THE CHIEF EXECUTIVE OFFICER RECOMMENDS:

That the Chicago Board of Education (“Board”) amend Board Report 10-0728-PO1 the External Research Study and Data Policy.

The purpose of the December 2019 amendments are to address external research study and data needs, update the office responsible for handling requests and more accurately reflect the district mission and vision for research.

PURPOSE:

The Board recognizes that the District’s educational programs and services can benefit from academic study and study in the field of education. It is in the Board’s best interest to establish a policy in support of research endeavors when the findings and results of these studies will be shared with the Chicago Public Schools (“CPS”) to advance public education. This policy establishes the requirements for requesting authorization to conduct research in the Chicago Public Schools and/or to receive CPS data for research purposes and also establishes protocols to comply with federal and state laws regarding privacy of student records and the protection of pupils.

POLICY TEXT:

I. Applicability

This policy applies to individuals and entities who would like to conduct research activities in the Chicago Public Schools or who would like to receive and use Chicago Public Schools student data and/or staff data for research or evaluation purposes. This policy does not apply to requests made under the Freedom of Information Act (“FOIA”) which are addressed in the Board’s FOIA Policy.

II. Definitions

For purposes of this policy, the following definitions apply:

Board Contracted Research(er): Research conducted by individuals, organizations, or agencies not affiliated with the Board in accordance with their contract with the Board.

External Research(er): (1) independent research conducted by individuals, organizations, or agencies not affiliated with the Board; (2) research conducted by Board employees for personal purposes outside of their work duties during non-work hours, (e.g. research for the completion of a master’s thesis or doctoral dissertation or for any other personal purposes); or (3) educational product research conducted by a company or entity to study an educational product’s effectiveness for potential sale to the Chicago Public Schools.

Researcher: collectively refers to both Board Contracted Researchers and External Researchers.
Parent: natural, adoptive, foster or step-parent with guardianship rights, a legal guardian or a temporary custodian with whom the student resides and who has assumed legal responsibility for the student.
Research: various evaluation, measurement and inquiry activities that include, but are not limited to any of the following or any combination thereof: (1) the systematic investigation, including research development, testing and/or evaluation, designed to develop or contribute to general knowledge; (2) collecting and analyzing of information aimed at discovering new facts and their correct interpretation to draw conclusions; and (3) quantitative and qualitative study activities such as observations, interviews, case studies, ethnographic analysis, analysis of written materials, secondary analysis of data, achievement testing, surveys, experimental designs to examine causal relationships, product testing and analysis of cost and management records.

Student data: includes (1) personally-identifiable student level data, (2) de-identified student level data, and (3) aggregate level student data.

Staff data: includes (1) personally-identifiable staff level data, (2) de-identified staff level data, and (3) aggregate level staff data.

III. General Provisions

  1. Authorization: The Director of School Quality Measurement and Research (“SQMR”) or his/her designee shall approve or deny Researcher requests to conduct research in the Chicago Public Schools or receive CPS data as described in this Policy. SQMR may establish reasonable fees to charge Researchers for the review and evaluation of proposals and the compilation of data requested hereunder.
  2. No Right to Access: There is no right to access Chicago Public Schools students, staff or data related thereto for research purposes. Access may be granted when determined to be in the best interests of the Board. If access is granted, Researcher may only access schools, students, staff and data relevant to the research as approved by the SQMR.
  3. Guidelines: SQMR shall establish guidelines, standards and procedures for evaluating requests to conduct research in the Chicago Public Schools or to receive data for research purposes and generally for implementing the requirements of this Policy. Researchers shall comply with all requirements specified by SQMR in their guidelines, standards and procedures.
  4. Internal Research: Board employees who plan to conduct research as part of a work assignment or as part of their general job duties must obtain the prior approval of their supervisor prior to commencement of research activities.

IV. Proposals

  1. Board Contracted Research Proposals:
    1. Except as to research activities described in section IV.A.ii. below, Board Contracted Researchers who seek to conduct research activities in the Chicago Public Schools may not begin without first submitting the following materials to SQMR for approval:
      1. A draft copy of their proposed Board contract detailing the research activities, which includes:
        1. How the study will contribute to the profession of education and be of direct benefit to the Board;
        2. Description of the study’s design including but not limited to sample selection, instruments to be used, proposed research subjects and statistical analysis;
        3. Whether the study has obtained institutional review board approval, if needed; and
        4. Projected time and resource requirements for the Board, its employees and CPS students to participate in the study.
      2. Description of any student data that Researcher would like to collect and Board-held student data that the Researcher would like to receive for use in the research study;
      3. Description of any staff data that Researcher would like to collect and Board-held staff data that the Researcher would like to receive for use in the research study;
      4. Description and sample of Researcher’s notice and consent protocols for obtaining written consents from parents and all participants and how they are consistent with Section VI herein;
      5. How the Researcher plans to protect and maintain the privacy of students and participants in a study consistent with Section VI herein; and
      6. Such additional information as may be requested by SQMR
    2. Board Contracted Researchers who wish to conduct secondary analysis research only using existing Board-held data and that does not involve data collection in the Chicago Public Schools, must obtain prior SQMR approval and must submit the information and materials identified below to SQMR for consideration.
      1. How the study will contribute to the profession of education and be of direct benefit to the Board;
      2. Description of the research project;
      3. Description of the Board-held student and/or staff data that the Researcher would like to receive for use in the research project;
      4. Description of how the Researcher plans to protect and maintain the privacy of students and staff consistent with Section VI herein; and
      5. Any additional information as may be requested by SQMR.
  2. External Research Proposals:
    1. Except as to research activities described in Section IV.B.ii. below, External Researchers who seek to conduct research activities in the Chicago Public Schools may not begin without first submitting a proposal that contains the following to SQMR for approval:
      1. How the study will contribute to the profession of education and be of direct benefit to the Board;
      2. Description of the study’s design including but not limited to sample selection, instruments to be used, proposed research subjects and statistical analysis;
      3. Whether the study has obtained institutional review board approval, if needed;
      4. Projected time and resource requirements for the Board, its employees and CPS students to participate in the study;
      5. Whether the Researcher has the support of the Officer or Chief Officer responsible for the proposed subject area of the research study;
      6. Description and sample of Researcher’s notice and consent protocols for obtaining written consents from parents and all participants and how they are consistent with Section VI herein;
      7. How the Researcher plans to protect and maintain the privacy of students and participants in a study consistent with Section VI herein;
      8. Description of any student data that Researcher would like to collect and Board-held student data that the Researcher would like to receive for use in the research study;
      9. Description of any staff data that Researcher would like to collect and Board-held staff data that the Researcher would like to receive for use in the research study; and
      10. Such additional information as may be requested by SQMR.
    2. External Researchers who wish to conduct secondary analysis research only using existing Board-held data and that does not involve data collection in the Chicago Public Schools, must obtain prior SQMR approval and must submit the information and materials identified below to SQMR for consideration.
      1. How the study will contribute to the profession of education and be of direct benefit to the Board;
      2. Description of the research project;
      3. Description of the Board-held student and/or staff data that the Researcher would like to receive for use in the research project;
      4. Description of how the Researcher plans to protect and maintain the privacy of students and staff consistent with Section VI herein;
      5. Proof of consent for requests for personally-identifiable student level data or personally-identifiable staff level; and
      6. Such additional information as may be requested by SQMR.

V. Approval

  1. Notice of Approval or Acknowledgement. If a research proposal is approved, SQMR will issue a research approval letter to the Researcher. SQMR’s approval of a research proposal is limited to the study scope and methods outlined in the proposal or Board contract. Researcher must provide a copy of the research approval letter (or acknowledgement letter) to principals whose schools will be affected by the research project to notify them of SQMR’s project approval and, if applicable, the Board contract authorizing the research.
  2. Limited Approval. SQMR’s approval/acknowledgement of an external research study is conditional and subject to further approval by the school principal(s) and research subject(s) that form the basis for the proposed study. A principal may place restrictions on an External Researcher’s access to students and staff to minimize disruption to school activities.
  3. Modifications. If a Researcher wishes to modify the research scope, methods or materially change the research activities, the Researcher must obtain prior written approval of the modification from SQMR. For Board Contracted Researchers, this obligation shall exist in addition to any other requirements regarding project modifications that may be specified in their contract or memorandum of understanding.
  4. Duration. SQMR’s approval of an external research project will only be valid for a period of one year. If research activities extend beyond one year, the External Researcher must request approval for an extension from SQMR. SQMR’s approval of a Board Contracted Research project will be valid for the duration of the contract.

VI. Requirements

  1. Consent Forms: Prior to conducting research activities or collecting information from students or staff, the Researcher must obtain the prior written informed consent of participants or of a parent on behalf of a student. For students who are 18 or over, the Researcher must receive written informed consent from the student. Students under 18 years old cannot participate in research without the informed consent of a parent. Prior to obtaining personally-identifiable student level data, the Researcher must obtain written consent from the parent on behalf of a student or from the student who is 18 or over. All consent form must comply with state and federal laws and regulations regarding confidentiality of student records and the protection of study participants.
  2. Opportunity to Review Survey Assessment: Researcher must provide parents with notice of and the opportunity to review the survey/assessment instrument prior to being administered or distributed. A Researcher’s consent documents shall inform parents of their right to review surveys or materials created by an External Researcher prior to the time it is administered or distributed. Researcher shall be responsible for assuring that a parent’s request to review surveys or materials is granted in a reasonable manner and in a reasonable period of time.
  3. Research Subjects: Researchers must use independent research subjects in their studies. Researchers must not have a position of authority over proposed research subjects or have a conflict of interest with proposed research subjects.
  4. Data Requests: Researchers may not request data directly from schools or departments. All data requests must be submitted to SQMR for handling. Researchers may not receive data hereunder unless the Researcher provides SQMR with written evidence of compliance with the requirements of this policy. In particular, Researchers may not receive personally-identifiable student level data unless the Researcher also provides SQMR with written evidence that the parent or student, as appropriate, has consented to the release of student records.
  5. Data Security Agreement: To receive access to Board-held student level data or staff level data, Researcher must sign a Data Security Agreement or other agreement approved by the General Counsel that identifies requirements for the storage, use, maintenance, protection, dissemination and destruction of data provided hereunder. The Data Security Agreement must be signed by the Researcher for each research proposal approved by SQMR.
  6. Additional Requirements: SQMR may place additional conditions on an External Researcher as deemed necessary including but not limited to requirements related to insurance and criminal background checks. SQMR’s approval of an external research project may be withdrawn for any reason at any time.
  7. Completion of Study or Research: When the research study is completed, the Researcher must timely provide a copy of the final research results to SQMR. The Board reserves the right to use the information in the research report and research findings for educational programming or services, planning, solicitation of grants, staff development, and any other purposes to improve instruction or services to students of the Chicago Public Schools.

VII. Exception

Pursuant to Board Resolution 15-0225-RS1, the Chief Executive Officer is authorized to approve narrowly tailored, limited exceptions to the External Research Study and Data Policy that comply with state and federal laws when s/he deems the exception essential to further the District’s goals and priorities.

Policy References

Amends/Rescinds Amends 10-0728-PO1
Cross References 15-0225-RS1 and 12-0328-RS2 (Note: 15-0225-RS1 and 12-0328-RS2 modified the Research Study and Data Policy 10-0728-PO1); 10-0728-PO1; 09-0325-PO3; 07-1114-PO3
Legal References Family Educational Rights and Privacy Act of 1974, 20 U.S.C. §1232g; Protection of Pupil Rights Act, 20 U.S.C. §1232h; Illinois School Student Records Act, 105 ILCS 10/1 et seq.
Public Comment Pursuant to Board Rule 2-6 this Policy was subject to Public Comment from 9/27/19 -11/8/19 and adopted at the December 11, 2019 Board Meeting [Board Report 19-1211-PO3].

Policy and Procedures

1 N. Dearborn, 9th Floor
Chicago, IL 60602