Statement of Concern Regarding Data Matching
The undersigned members of the Massachusetts Statewide Adult Basic Education Performance Accountability Working Group are registering our concern over the implementation of a data matching system between the Department of Elementary and Secondary Education Adult and Community Learning Services and the Department of Revenue. We do not believe that this sort of data matching is a suitable solution to the provision of an accountability system for adult basic education.
There is a tremendous amount of data about individuals that is collected and stored by government agencies. This data, if different parts are brought together, provides an intensely detailed portrait of the activities of the individual. We feel that this is a violation of the privacy rights of the individual. Control of one's own personal data should remain in the hands of the individual to the greatest degree possible. Data matching gives this control to the government agencies rather than to the individual.
Data matching systems provide a significant potential for abuse. While the proposed system has been designed to protect the privacy of individuals by providing a blind match that does not return personal information to any agency this is not a guarantee for the future. Once the systems are in place to match data about individuals it is not unreasonable to expect that attempts will be made to expand the system. At this point a data matching system between ESE adult basic education records and Department of Revenue records does not exist creating it opens the door to potential misuse.
When the individuals asked to give up their personal data are some of the most vulnerable members of society, data matching is even more problematic. Individuals with power have some control over privacy of their information that is not available to people who do not have as much power.
The collection of data by the government is an even more central issue because the amount of data collected, processed and disseminated by other groups has increased dramatically. It is because data privacy in the private sector is currently not protected that it is even more important that the government does not participate in the construction of large data resources about individuals. The government should be assisting individuals in protecting their privacy rather than participating in the creation of information data banks.
We are aware that there are external influences on this decision. The United States Department of Education sees data matching as the best way to fulfill their requirements for reliable, valid and comparable data and the Massachusetts' Governor's office is requiring data matching for all adult education and training programs. However, for the PAWG, this issue is ultimately one of trade?offs. There is always tension between ease of data collection, accuracy of data collected and the individual rights involved in the collection of that data. In this case, data matching chooses the first two over the third. It is for all of these reasons that we do not think that the ESE should be involved in data matching.
Stacy Evans
Judy Titzel
Andy Nash
William Toller
Mina Reddy
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