Confidentiality Policy

Throughout the collection, storage, and reporting of survey data, the Office of Strategic Planning and Institutional Effectiveness takes seriously our responsibility for the confidentiality of our survey respondents.  The confidentiality policies and guidelines are outlined below for each aspect of our survey research projects. The policies outlined below do not apply to Course and Teacher Survey (CATS) process.

Collection of Data

All surveys administered by the Office of Strategic Planning and Institutional Effectiveness are confidential with few exceptions, listed below. Confidential means that office staff have access to information about who responded to a survey, but this information is never shared with anyone outside of the office. Confidential surveys allow OSPIE to combine survey responses with existing data from Villanova databases for further analysis.

Exceptions:

• Anonymous surveys.  When we specify that a survey is anonymous, it means that no one has any way of associating survey responses with an individual survey respondent. 
  
  • For paper surveys, this means that no names, student IDs, or any other personally identifying information will be asked for or collected. 
    
  • For web-based surveys, this means that the survey was designed using the anonymize feature of our survey software which disconnects survey responses from the IP address, location data, and personally identifying information of survey respondents. Using this feature, respondents are issued personalized links for invitation and reminder purposes, but the Office of Strategic Planning and Institutional Effectiveness has no way of knowing which respondent is associated with which response.
    
  • An anonymous survey could also mean that the survey is administered via a single link that anyone can access. Sometimes, anonymous surveys will ask for demographic information, such as race or gender. This information is used for aggregate analyses and reporting purposes only.
• Specific questions on a confidential survey, with respondent consent. In some instances, a department at Villanova may request contact information for a respondent in order to follow up on an experience mentioned in their survey. Within the survey, a question will specifically ask if it is acceptable for certain identifying information and survey answers to be shared with the department making such a request. Only the survey answers for which the respondent gives their consent will be shared, and the remainder of the survey answers will be kept confidential.
• Surveys with no promise of confidentiality. Sometimes, surveys will be administered that make no promise of confidentiality. In these instances, respondents will be made explicitly aware that the survey is not confidential and that survey responses may be associated with names or individuals. For example, if the Office of Strategic Planning and Institutional Effectiveness administers a survey to collect information from students to assist in the advising process, that information may be passed on to the program coordinator.
• Allegations of Title IX Violations. Title IX of the Education Amendments of 1972 requires that allegations of sexual harassment or violence be reported to the institution’s Title IX coordinator. If a member of the Office of Strategic Planning and Institutional Effectiveness reads a comment that indicates a violation of Title IX, the staff member is required to report it to Villanova’s Title IX coordinator.
• Comments that indicate a respondent poses a danger to themselves or others. If a member of the Office of Strategic Planning and Institutional Effectiveness reads a comment that threatens harm against anyone, we may pass such comments along to appropriate university staff for possible action.

Storage of Data

The Office of Strategic Planning and Institutional Effectiveness keeps all data in secure files and the original paper survey instruments are stored for a limited period of time in a locked/secured area. Data and databases are accessible only to the data base administrator and an assigned analyst/report writer. OSPIE administers surveys on behalf of the university to ensure the confidentiality/anonymity of Villanovan respondents. In rare cases, OSPIE may create a database of survey responses stripped of all individual identifiers and share it securely with a research team working on behalf of the university. These cases are always subject to the approval of the Executive Director of OSPIE.

If you are located in the European Union, under the General Data Protection Regulation (GDPR), you may have the right to (i) request access to and rectification or erasure of personal data, (ii) restrict or object to the processing of your data, (iii) in some cases, the right to receive or have your data transmitted in a portable format, and (iv) withdraw consent at any time. Please visit the university’s Website Privacy Policy for more information.

Reporting of Data

• For all data collected via web or paper surveys, all collected responses will be included in the analysis, even if the respondent did not reach the end or formally submit the survey.
• Copies of reports based on survey data are made available only with the approval of the committee, group, or office that commissioned the survey.
• Numeric data are grouped to prevent identification of any individual. Results for groups of respondents fewer than an established threshold are never reported when there is any risk of breach of confidentiality. If a group has fewer respondents than this threshold, those data will be merged with other groups or will not be reported. The response threshold is established based on the nature of the survey. For administrative research projects, the response threshold is ten. For evaluations of specific events and programs, the response threshold is five.
  
• For open ended responses, all comments are read and edited for grammar and coherence. Respondents will sometimes include the names of specific individuals or otherwise identifying information.  As comments are generally reported verbatim, below are the guidelines used to manage the distribution of comments.
  • All Office of Strategic Planning and Institutional Effectiveness sponsored surveys include a confidentiality statement in the survey invitation similar to the one below:
    • Your responses to this survey are confidential. The data will be collected by Villanova’s Office of Strategic Planning and Institutional Effectiveness and only summaries of numeric data will be reported. Any comments written in response to the open-ended questions are edited to eliminate any potentially identifying language, then reported verbatim to the office or committee that requested the survey. Original comments may also be sent to a key decision maker for review. If you are uncomfortable answering any particular question, please feel free to leave it blank.  Please reference our office’s full Confidentiality Policy for more information.
  • If the individual receiving the comments is a key decision maker and has a direct evaluative role to individuals or units mentioned in the comments, the comments are delivered verbatim. Examples of key decision makers include directors, deans, vice presidents, and vice provosts.
  • Examples of individuals that are not key decision makers include individual faculty, staff, and students.
  • If a comment needs to have pieces redacted, the following process is used:
    • Each comment is read to detect an individual’s name, position, or other identifying information.
    • If a name or position is found, the comment is evaluated to be positive or negative. If the comment is negative, the name or position is removed and replaced with [Name] or [Position] to indicate that something has been removed. The original comment is then placed into a separate report which may be shared confidentially and reviewed by a key decision maker.
    • If a member of Office of Strategic Planning and Institutional Effectiveness staff determines that potentially identifying language is used, the identifying components are removed and replaced with [Identifying] to indicate that something has been removed.  The original comment is then placed into a separate report which may be shared confidentially and reviewed by a key decision maker.
      • The Family Educational Rights and Privacy Act of 1974 (FERPA) defines personally identifiable information as information that can be used to distinguish or trace an individual’s identity.  This includes information that, alone or in combination, is linked or linkable to a specific respondent that would allow a reasonable person, who does not have personal knowledge of relevant circumstances, to identify a respondent with reasonable certainty.
  • Original comments are released with text in the document indicating that the document is confidential and should not be distributed. Redacted comments are shared at the discretion of the leader of the group or committee that commissioned the survey.
  • Comments can only be shared with members of Villanova.