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Suppression Policy for Disclosure Avoidance

Policy Statement – The MLDS Center will balance the mission to provide meaningful information to Maryland stakeholders with the need to protect individuals' privacy.

The MLDS Center provides comprehensive and valuable information to Maryland stakeholders about student outcomes to guide policy while implementing efforts to reduce the risk of inadvertent disclosure of information about individual students and workers.

Background – According to State law (see Ed. Art. § 24-703(h), Annotated Code of Maryland) only authorized staff of the Center may access de-identified data for analyses, research, and reporting. Further, research, reports, and responses to data requests may only contain aggregate data. Finally, data that may be identifiable based on the size or uniqueness of the population under consideration may not be reported in any form by the MLDS Center.

The MLDS Center also ensures compliance with other state and federal laws governing data in the MLDS. This includes compliance with:

  1. The federal Family Education Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R Part 99);
  2. The Maryland Public Information Act (Maryland Code, §4-101, et seq. of the General Provisions Article); and
  3. The Federal-State Unemployment Compensation Program (20 C.F.R. Part 603).

This policy establishes procedures for determining if data "may be identifiable based on the size or uniqueness of the population" and therefore must be suppressed. All aggregated data tables must undergo a suppression review by the MLDS Center Executive Director, or the Executive Director's designee, prior to the data tables being removed from the MLDS. For research and reporting purposes, under no circumstances are de-identified, individual-level data approved for removal from the system. This policy applies to descriptive statistics (e.g., where Ns and percentages are reported). Other statistical output (e.g., regression coefficients, p values) generally do not need to be suppressed.

Suppression Procedures – To ensure compliance with the requirement to suppress data that may be identifiable based on the size or uniqueness of the population under consideration and ensure that information about individual students and workers is not disclosed, the MLDS Center's baseline approach is to suppress any value less than 10. This approach will consider both actual values and derived values and apply disclosure avoidance techniques (such as complementary suppression and perturbation) necessary to ensure identifiable information is not disclosed. The procedures also allow for a Disclosure Review Advisory Board (DRAB) to relax this standard when the risk of disclosure is minimal and there is a need for more complete reporting.