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Disclosing Financial Aid Recipients

By Mark Mitchell posted 11-25-2014 04:04 PM

  
Frequently, the SSS by NAIS team gets specific questions from financial aid professionals seeking some best practice guidance on policy issues.  Here's one that came in recently about sharing lists of financial aid recipients outside of the financial aid office.

School:  "
I have a dilemma I hope you can give me some guidance on.  We have a new financial aid scholarship this year which is funded solely by donations from our faculty and staff.  The scholarship is intended for a student with financial need, who also meets some additional academic/citizenship criteria.  The scholarship committee, made up of 3 faculty representatives, wants me to provide them a list of aid recipients so they can bring names to their colleagues to choose the recipient. I have asked, instead, that they provide a short list of students who qualify based on the other criteria, prioritized, and the financial aid committee will then select the recipient.  If none on their list receives aid, we would ask for more names.  

The problem is that the scholarship committee is really wants me to provide the aid recipients list first.  I have provided the NAIS PGP's for Financial Aid as well as the statement on confidentiality from the school's financial aid policy manual that specifically states applicant names will not be divulged to teachers, but they are not taking 'no' for an answer.  Do you know of any further references or have any words of wisdom I can use to substantiate my stand on this?"

SSS:  Clearly, providing a list of financial aid recipients to this group (or any other outside of the financial aid committee) is a breach of the confidentiality of the need-based process and its applicants.  Since the faculty members are not part of the committee that determines students’ financial need, the specific family-by-family outcomes shouldn’t be shared in such an open way, particularly without the permission/knowledge of the families.                                  

It would seem to me that your internal policy about not divulging applicant names to teachers should be a sufficient argument, even if they don’t agree with it.  As school policy, you cannot not abide by that unless the head/board gets involved in changing the policy or establishing some rules for making exceptions.  If they don’t like the school policy or your approach to it, then the scholarship doesn’t get awarded.

In similar situations I’ve seen at other schools, the typical approach is to do what you suggest.  The committee or others provide a list of candidates to the financial aid office, who then selects the recipient(s) from that group as appropriate and notifies the committee who has been selected.  This way, the committee that sets the scholarship's academic criteria are ensured that the recipient has met the criteria and the committee that determines and safeguards financial need decisions protects the confidentiality of the pool, in keeping with existing school policy and best practice standards.  It really doesn’t have to be more complicated than that.  To select one scholarship recipient shouldn’t require compromising the confidentiality of the entire financial aid applicant pool.

Are there any references or notices given to parents about how the school will treat their fin aid info and outcomes?  Whether in the enrollment contract, financial aid letter, or policies listed on the website, any language you include that tells parents how the school keeps their fin aid related data/results confidential would be important to share.  It might help to remind/inform the scholarship committee that sharing the list violates what the school promises to parents, as well, which could open the door to liability issues, potentially.

If they insist and their way wins out (which should only happen if the head of school makes the decision to allow the list to be shared), you could take some measures to help insure that what you share doesn’t go beyond the committee.  For example, before you share the list of students, require each scholarship committee member to sign a confidentiality agreement that helps protect you and the financial aid program in case one of them divulges confidential information about an aid recipient, making them personally liable for any damages that result from breaches.  Even in that case, they shouldn’t share the list with other teachers or department chairs to choose someone.  They should keep it confined to ONLY committee members and sign off that that’s what they agree to do.  You could even suggest that the scholarship selection meeting must include you and that you would only show the roster/list on screen (not distribute the list to people in any way prior to the meeting) or that you would only provide the list on paper at the start of the meeting and collect/destroy the list when the meeting is over (even this is not 100% risk-free). 

There are some resources in the Content tab in School Portal related to confidentiality that might help.  When you log into your portal account, click “Content” in the top tab bar and type “confidentiality” in the search to find some material that address privacy and confidentiality issues. 


This is certainly an area where it's better to be safe than sorry when deciding whether to share financial aid applicant or recipient lists with others within the school, even when the intentions for its use are good.  Very few, if any, requests beyond the admission, financial aid, or business office really warrant the potential downsides of disclosing your aid recipients or applicants, even at a cursory level.  Families exercise a great deal of trust when submitting their aid application and the process works best when they believe that the information will only be seen and handled by the absolute fewest people who need to know it.

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