EAB financial aid optimization documents
It is a clone of this request.
| Submitted | Dec. 9, 2021 |
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Communications
From: Todd Feathers
To Whom It May Concern:
Pursuant to the Maryland Public Information Act, I hereby request the following records:
1) All financial aid descriptive analyses performed by EAB and provided to the university as described on page 46 of the attached contract for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built for the university by EAB, described on page 46 of the attached contract. This should include any documents describing the variables incorporated into the model(s) and how those variables are weighted, the model(s)' accuracy metrics (such as AUC), the model(s)' parameters, the machine learning techniques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the university provided to EAB in order for EAB to design its financial aid optimization model, as described on page 46 of the attached contract. Please note, I am not asking for any personally identifiable information about students. Rather, I'm asking for a copy of the dataset that excludes identifiable information such as student names and street addresses. This can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and statements of work, between the university and EAB regarding financial aid optimization services and/or enrollment optimization services.
I ask that all fees be waived as I am a journalist and intend to use the requested records to publish articles in the public interest. In the event you choose to impose fees, I request a detailed breakdown of the fees, including the hourly wage of each employee involved and an explanation justifying the employee hours required to fulfill the request.
Should you choose to reject this request or redact portions of it, I ask that you provide a detailed breakdown of the statutory exemptions and associated case law underlying your decision to withhold each/any portions from public review.
The requested documents will be made available to the general public, and this request is not being made for commercial purposes.
In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 calendar days, as the statute requires.
Sincerely,
Todd Feathers
From:
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (“UMBC”) has begun to process your request for records under the Public Information Act, Md. Code Ann., General Provisions Article (“GP”) Article, §§ 4-101 – 4-601 (“the Act”). This request, which was transmitted to UMBC via its electronic portal on December 12, 2021, was assigned reference number 2456689. Specifically, you seek “1) All financial aid descriptive analyses performed by EAB and provided to the university as described on page 46 of the attached contract for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built for the university by EAB, described on page 46 of the attached contract. This should include any documents describing the variables incorporated into the model(s) and how those variables are weighted, the model(s)' accuracy metrics (such as AUC), the model(s)' parameters, the machine learning techniques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the university provided to EAB in order for EAB to design its financial aid optimization model, as described on page 46 of the attached contract. Please note, I am not asking for any personally identifiable information about students. Rather, I'm asking for a copy of the dataset that excludes identifiable information such as student names and street addresses. This can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and statements of work, between the university and EAB regarding financial aid optimization services and/or enrollment optimization services.”
I write to inform you that it will take the University more than ten (10) working days to produce the records you’ve requested. In addition, I seek to provide you with the amount of time that UMBC anticipates it will take to locate, gather, review and produce the records, a discussion of fees that will be required for this disclosure, and an explanation as to why the University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid Optimization strategy; the most recent contract period ended in 2020. Additionally, item 3 of your request is considered proprietary under GP § 4-205(c)(4)(iv) and is therefore denied. Furthermore, your request appears to request data pulls without reference to a specific timeframe (ex. Academic year 2019-2020); is there a specific timeframe that you are seeking?
The University anticipates that it will be able to produce the records for your inspection within 30 calendar days. Please note, however, that UMBC may be obligated to request an extension of time pursuant to GP § 4-203(d). I do not yet know whether all of the records are subject to inspection, but, if any are to be withheld, the response will explain the reason for that. The Act, at Section 4-206, permits the University to charge for the search, preparation and reproduction of a public record, excluding the first two (2) hours. Of course, a more exact calculation will depend on the time to be expended and the actual hourly rates of the individual staff and attorneys who must conduct the review.
With regard to the amount of time required to produce the records you have requested, please be advised the Office of the General Counsel will be required to manage activities with the Office of Enrollment Management. The aforementioned functional areas have responsibilities, obligations, and work schedules that are separate from and in addition to the University’s requirements under the Act. Once the University has located and collected the records, legal counsel must review the records to determine whether they are, in whole or in part, exempt from disclosure under the Act. For example, there may be confidential commercial information at issue; consequently, the University must interface with the relevant entities and obtain their feedback to prepare a response. This interaction takes additional time.
If I can be of further assistance, please do not hesitate to contact me at morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--
Morgan Thomas
From:
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (“UMBC”) has begun to process your request for records under the Public Information Act, Md. Code Ann., General Provisions Article (“GP”) Article, §§ 4-101 – 4-601 (“the Act”). This request, which was transmitted to UMBC via its electronic portal on December 12, 2021, was assigned reference number 2456689. Specifically, you seek “1) All financial aid descriptive analyses performed by EAB and provided to the university as described on page 46 of the attached contract for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built for the university by EAB, described on page 46 of the attached contract. This should include any documents describing the variables incorporated into the model(s) and how those variables are weighted, the model(s)' accuracy metrics (such as AUC), the model(s)' parameters, the machine learning techniques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the university provided to EAB in order for EAB to design its financial aid optimization model, as described on page 46 of the attached contract. Please note, I am not asking for any personally identifiable information about students. Rather, I'm asking for a copy of the dataset that excludes identifiable information such as student names and street addresses. This can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and statements of work, between the university and EAB regarding financial aid optimization services and/or enrollment optimization services.”
I write to inform you that it will take the University more than ten (10) working days to produce the records you’ve requested. In addition, I seek to provide you with the amount of time that UMBC anticipates it will take to locate, gather, review and produce the records, a discussion of fees that will be required for this disclosure, and an explanation as to why the University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid Optimization strategy; the most recent contract period ended in 2020. Additionally, item 3 of your request is considered proprietary under GP § 4-205(c)(4)(iv) and is therefore denied. Furthermore, your request appears to request data pulls without reference to a specific timeframe (ex. Academic year 2019-2020); is there a specific timeframe that you are seeking?
The University anticipates that it will be able to produce the records for your inspection within 30 calendar days. Please note, however, that UMBC may be obligated to request an extension of time pursuant to GP § 4-203(d). I do not yet know whether all of the records are subject to inspection, but, if any are to be withheld, the response will explain the reason for that. The Act, at Section 4-206, permits the University to charge for the search, preparation and reproduction of a public record, excluding the first two (2) hours. Of course, a more exact calculation will depend on the time to be expended and the actual hourly rates of the individual staff and attorneys who must conduct the review.
With regard to the amount of time required to produce the records you have requested, please be advised the Office of the General Counsel will be required to manage activities with the Office of Enrollment Management. The aforementioned functional areas have responsibilities, obligations, and work schedules that are separate from and in addition to the University’s requirements under the Act. Once the University has located and collected the records, legal counsel must review the records to determine whether they are, in whole or in part, exempt from disclosure under the Act. For example, there may be confidential commercial information at issue; consequently, the University must interface with the relevant entities and obtain their feedback to prepare a response. This interaction takes additional time.
If I can be of further assistance, please do not hesitate to contact me at morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--
Morgan Thomas
From:
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (“UMBC”) has begun to process your request for records under the Public Information Act, Md. Code Ann., General Provisions Article (“GP”) Article, §§ 4-101 – 4-601 (“the Act”). This request, which was transmitted to UMBC via its electronic portal on December 12, 2021, was assigned reference number 2456689. Specifically, you seek “1) All financial aid descriptive analyses performed by EAB and provided to the university as described on page 46 of the attached contract for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built for the university by EAB, described on page 46 of the attached contract. This should include any documents describing the variables incorporated into the model(s) and how those variables are weighted, the model(s)' accuracy metrics (such as AUC), the model(s)' parameters, the machine learning techniques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the university provided to EAB in order for EAB to design its financial aid optimization model, as described on page 46 of the attached contract. Please note, I am not asking for any personally identifiable information about students. Rather, I'm asking for a copy of the dataset that excludes identifiable information such as student names and street addresses. This can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and statements of work, between the university and EAB regarding financial aid optimization services and/or enrollment optimization services.”
I write to inform you that it will take the University more than ten (10) working days to produce the records you’ve requested. In addition, I seek to provide you with the amount of time that UMBC anticipates it will take to locate, gather, review and produce the records, a discussion of fees that will be required for this disclosure, and an explanation as to why the University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid Optimization strategy; the most recent contract period ended in 2020. Additionally, item 3 of your request is considered proprietary under GP § 4-205(c)(4)(iv) and is therefore denied. Furthermore, your request appears to request data pulls without reference to a specific timeframe (ex. Academic year 2019-2020); is there a specific timeframe that you are seeking?
The University anticipates that it will be able to produce the records for your inspection within 30 calendar days. Please note, however, that UMBC may be obligated to request an extension of time pursuant to GP § 4-203(d). I do not yet know whether all of the records are subject to inspection, but, if any are to be withheld, the response will explain the reason for that. The Act, at Section 4-206, permits the University to charge for the search, preparation and reproduction of a public record, excluding the first two (2) hours. Of course, a more exact calculation will depend on the time to be expended and the actual hourly rates of the individual staff and attorneys who must conduct the review.
With regard to the amount of time required to produce the records you have requested, please be advised the Office of the General Counsel will be required to manage activities with the Office of Enrollment Management. The aforementioned functional areas have responsibilities, obligations, and work schedules that are separate from and in addition to the University’s requirements under the Act. Once the University has located and collected the records, legal counsel must review the records to determine whether they are, in whole or in part, exempt from disclosure under the Act. For example, there may be confidential commercial information at issue; consequently, the University must interface with the relevant entities and obtain their feedback to prepare a response. This interaction takes additional time.
If I can be of further assistance, please do not hesitate to contact me at morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--
Morgan Thomas
From: University Of Maryland Baltimore County
The following was sent via UMBC's PIA portal:
Dear Todd Feathers,
The University of Maryland, Baltimore County (“UMBC”) has begun to process
your request for records under the Public Information Act, Md. Code Ann.,
General Provisions Article (“GP”) Article, §§ 4-101 – 4-601 (“the Act”).
This request, which was transmitted to UMBC via its electronic portal on
December 12, 2021, was assigned reference number 2456689. Specifically,
you seek “1) All financial aid descriptive analyses performed by EAB and
provided to the university as described on page 46 of the attached contract
for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the
university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built
for the university by EAB, described on page 46 of the attached contract.
This should include any documents describing the variables incorporated
into the model(s) and how those variables are weighted, the model(s)'
accuracy metrics (such as AUC), the model(s)' parameters, the machine
learning techniques employed, and any validation or disparate impact
analyses performed.
4) A de-identified copy of the admissions and financial aid data the
university provided to EAB in order for EAB to design its financial aid
optimization model, as described on page 46 of the attached contract.
Please note, I am not asking for any personally identifiable information
about students. Rather, I'm asking for a copy of the dataset that excludes
identifiable information such as student names and street addresses. This
can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and
statements of work, between the university and EAB regarding financial aid
optimization services and/or enrollment optimization services.”
I write to inform you that it will take the University more than ten (10)
working days to produce the records you’ve requested. In addition, I seek
to provide you with the amount of time that UMBC anticipates it will take
to locate, gather, review and produce the records, a discussion of fees
that will be required for this disclosure, and an explanation as to why the
University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid
Optimization strategy; the most recent contract period ended in 2020.
Additionally, item 3 of your request is considered proprietary under GP §
4-205(c)(4)(iv) and is therefore denied. Furthermore, your request appears
to request data pulls without reference to a specific timeframe (ex.
Academic year 2019-2020); is there a specific timeframe that you are
seeking?
The University anticipates that it will be able to produce the records for
your inspection within 30 calendar days. Please note, however, that UMBC
may be obligated to request an extension of time pursuant to GP § 4-203(d).
I do not yet know whether all of the records are subject to inspection,
but, if any are to be withheld, the response will explain the reason for
that. The Act, at Section 4-206, permits the University to charge for the
search, preparation and reproduction of a public record, excluding the
first two (2) hours. Of course, a more exact calculation will depend on the
time to be expended and the actual hourly rates of the individual staff and
attorneys who must conduct the review.
With regard to the amount of time required to produce the records you have
requested, please be advised the Office of the General Counsel will be
required to manage activities with the Office of Enrollment Management.
The aforementioned functional areas have responsibilities, obligations, and
work schedules that are separate from and in addition to the University’s
requirements under the Act. Once the University has located and collected
the records, legal counsel must review the records to determine whether
they are, in whole or in part, exempt from disclosure under the Act. For
example, there may be confidential commercial information at issue;
consequently, the University must interface with the relevant entities and
obtain their feedback to prepare a response. This interaction takes
additional time.
If I can be of further assistance, please do not hesitate to contact me at
morganthomas@umbc.edu.
Regards,
--
*Morgan C. Thomas*
Assistant General Counsel
UMBC
Administration Building
1000 Hilltop Circle
9th Floor
Baltimore, MD 21250
Phone: 410-455-1354
Phone: 410-455-2870
Fax: 410-455-1713
http://www.umbc.edu/ogc
From: Todd Feathers
Thank you very much for your help. For the data pulls, you can limit the request to Jan. 1, 2018 until the date the university stopped using EAB's financial aid optimization services.
Todd
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following Maryland Public Information Act request, copied below, and originally submitted on Dec. 12, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: University Of Maryland Baltimore County
This email address is no longer accepting support requests.
If you need help or want to report an issue, please do the following:
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Thank you.
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Subject: RE: Maryland Public Information Act Request: EAB financial aid optimization documents
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University Of Maryland Baltimore County
PIA Office
Administration Building, 10th Floor
1000 Hilltop Circle
Baltimore, MD 21250
January 10, 2022
This is a follow up to a previous request:
To Whom It May Concern:
I wanted to follow up on the following Maryland Public Information Act requ=
est, copied below, and originally submitted on Dec. 12, 2021. Please let me=
know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
View request history, upload responsive documents, and report problems here:
https://www.muckrock.com/
rock.com%2Faccounts%2Flogin%2F%3Fnext%3D%252Faccounts%252Fagency_login%252F=
university-of-maryland-baltimore-county-31022%252Feab-financial-aid-optimiz=
ation-documents-122012%252F%253Femail%253DUMBCHelp%252540rt.umbc.edu&url_au=
th_token=3DAAEo5-0aUkb36FbwuQIt3By7JMQ%3A1n6njH%3AwgLVfos5Y8C5-O0ob-rEWpqqT=
tg
If prompted for a passcode, please enter:
••••••••
Filed via MuckRock.com
E-mail (Preferred): requests@muckrock.com
For mailed responses, please address (see note):
MuckRock News
DEPT MR 122012
411A Highland Ave
Somerville, MA 02144-2516
PLEASE NOTE: This request is not filed by a MuckRock staff member, but is b=
eing sent through MuckRock by the above in order to better track, share, an=
d manage public records requests. Also note that improperly addressed (i.e.=
, with the requester's name rather than "MuckRock News" and the department =
number) requests might be returned as undeliverable.
---
On Dec. 17, 2021:
Subject: RE: Maryland Public Information Act Request: EAB financial aid opt=
imization documents
Thank you very much for your help. For the data pulls, you can limit the re=
quest to Jan. 1, 2018 until the date the university stopped using EAB's fin=
ancial aid optimization services.
Todd
---
On Dec. 17, 2021:
Subject: Request #2456689
The following was sent via UMBC's PIA portal:
Dear Todd Feathers,
The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) has b=
egun to process
your request for records under the Public Information Act, Md. Code Ann.,
General Provisions Article (=E2=80=9CGP=E2=80=9D) Article, =C2=A7=C2=A7 4-1=
01 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D).
This request, which was transmitted to UMBC via its electronic portal on
December 12, 2021, was assigned reference number 2456689. Specifically,
you seek =E2=80=9C1) All financial aid descriptive analyses performed by EA=
B and
provided to the university as described on page 46 of the attached contract
for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the
university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built
for the university by EAB, described on page 46 of the attached contract.
This should include any documents describing the variables incorporated
into the model(s) and how those variables are weighted, the model(s)'
accuracy metrics (such as AUC), the model(s)' parameters, the machine
learning techniques employed, and any validation or disparate impact
analyses performed.
4) A de-identified copy of the admissions and financial aid data the
university provided to EAB in order for EAB to design its financial aid
optimization model, as described on page 46 of the attached contract.
Please note, I am not asking for any personally identifiable information
about students. Rather, I'm asking for a copy of the dataset that excludes
identifiable information such as student names and street addresses. This
can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and
statements of work, between the university and EAB regarding financial aid
optimization services and/or enrollment optimization services.=E2=80=9D
I write to inform you that it will take the University more than ten (10)
working days to produce the records you=E2=80=99ve requested. In addition, =
I seek
to provide you with the amount of time that UMBC anticipates it will take
to locate, gather, review and produce the records, a discussion of fees
that will be required for this disclosure, and an explanation as to why the
University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid
Optimization strategy; the most recent contract period ended in 2020.
Additionally, item 3 of your request is considered proprietary under GP =C2=
=A7
4-205(c)(4)(iv) and is therefore denied. Furthermore, your request appears
to request data pulls without reference to a specific timeframe (ex.
Academic year 2019-2020); is there a specific timeframe that you are
seeking?
The University anticipates that it will be able to produce the records for
your inspection within 30 calendar days. Please note, however, that UMBC
may be obligated to request an extension of time pursuant to GP =C2=A7 4-20=
3(d).
I do not yet know whether all of the records are subject to inspection,
but, if any are to be withheld, the response will explain the reason for
that. The Act, at Section 4-206, permits the University to charge for the
search, preparation and reproduction of a public record, excluding the
first two (2) hours. Of course, a more exact calculation will depend on the
time to be expended and the actual hourly rates of the individual staff and
attorneys who must conduct the review.
With regard to the amount of time required to produce the records you have
requested, please be advised the Office of the General Counsel will be
required to manage activities with the Office of Enrollment Management.
The aforementioned functional areas have responsibilities, obligations, and
work schedules that are separate from and in addition to the University=E2=
=80=99s
requirements under the Act. Once the University has located and collected
the records, legal counsel must review the records to determine whether
they are, in whole or in part, exempt from disclosure under the Act. For
example, there may be confidential commercial information at issue;
consequently, the University must interface with the relevant entities and
obtain their feedback to prepare a response. This interaction takes
additional time.
If I can be of further assistance, please do not hesitate to contact me at
morganthomas@umbc.edu.
Regards,
--=20
*Morgan C. Thomas*
Assistant General Counsel
UMBC
Administration Building
1000 Hilltop Circle
9th Floor
Baltimore, MD 21250
Phone: 410-455-1354
Phone: 410-455-2870
Fax: 410-455-1713
http://www.umbc.edu/ogc
---
On Dec. 17, 2021:
Subject: [Maryland Public Information Act Requests #2456689] Maryland Publi=
c Information Act Request [Correspondence]
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) has b=
egun to process your request for records under the Public Information Act, =
Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article, =
=C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This reque=
st, which was transmitted to UMBC via its electronic portal on December 12,=
2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the univer=
sity by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built =
for the university by EAB, described on page 46 of the attached contract. T=
his should include any documents describing the variables incorporated into=
the model(s) and how those variables are weighted, the model(s)' accuracy =
metrics (such as AUC), the model(s)' parameters, the machine learning techn=
iques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the univer=
sity provided to EAB in order for EAB to design its financial aid optimizat=
ion model, as described on page 46 of the attached contract. Please note, I=
am not asking for any personally identifiable information about students. =
Rather, I'm asking for a copy of the dataset that excludes identifiable inf=
ormation such as student names and street addresses. This can easily be don=
e by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and=
statements of work, between the university and EAB regarding financial aid=
optimization services and/or enrollment optimization services.=E2=80=9D
I write to inform you that it will take the University more than ten (10) w=
orking days to produce the records you=E2=80=99ve requested. In addition, I=
seek to provide you with the amount of time that UMBC anticipates it will =
take to locate, gather, review and produce the records, a discussion of fee=
s that will be required for this disclosure, and an explanation as to why t=
he University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid Optimizatio=
n strategy; the most recent contract period ended in 2020. Additionally, it=
em 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(4)(=
iv) and is therefore denied. Furthermore, your request appears to request d=
ata pulls without reference to a specific timeframe (ex. Academic year 2019=
-2020); is there a specific timeframe that you are seeking?
The University anticipates that it will be able to produce the records for =
your inspection within 30 calendar days. Please note, however, that UMBC m=
ay be obligated to request an extension of time pursuant to GP =C2=A7 4-203=
(d). I do not yet know whether all of the records are subject to inspection=
, but, if any are to be withheld, the response will explain the reason for =
that. The Act, at Section 4-206, permits the University to charge for the =
search, preparation and reproduction of a public record, excluding the firs=
t two (2) hours. Of course, a more exact calculation will depend on the tim=
e to be expended and the actual hourly rates of the individual staff and at=
torneys who must conduct the review.=20
With regard to the amount of time required to produce the records you have =
requested, please be advised the Office of the General Counsel will be requ=
ired to manage activities with the Office of Enrollment Management. The af=
orementioned functional areas have responsibilities, obligations, and work =
schedules that are separate from and in addition to the University=E2=80=99=
s requirements under the Act. Once the University has located and collecte=
d the records, legal counsel must review the records to determine whether t=
hey are, in whole or in part, exempt from disclosure under the Act. For exa=
mple, there may be confidential commercial information at issue; consequent=
ly, the University must interface with the relevant entities and obtain the=
ir feedback to prepare a response. This interaction takes additional time.=
=20=20
If I can be of further assistance, please do not hesitate to contact me at =
morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--=20
Morgan Thomas
---
On Dec. 17, 2021:
Subject: [Maryland Public Information Act Requests #2456689] Maryland Publi=
c Information Act Request [Correspondence]
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) has b=
egun to process your request for records under the Public Information Act, =
Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article, =
=C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This reque=
st, which was transmitted to UMBC via its electronic portal on December 12,=
2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the univer=
sity by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built =
for the university by EAB, described on page 46 of the attached contract. T=
his should include any documents describing the variables incorporated into=
the model(s) and how those variables are weighted, the model(s)' accuracy =
metrics (such as AUC), the model(s)' parameters, the machine learning techn=
iques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the univer=
sity provided to EAB in order for EAB to design its financial aid optimizat=
ion model, as described on page 46 of the attached contract. Please note, I=
am not asking for any personally identifiable information about students. =
Rather, I'm asking for a copy of the dataset that excludes identifiable inf=
ormation such as student names and street addresses. This can easily be don=
e by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and=
statements of work, between the university and EAB regarding financial aid=
optimization services and/or enrollment optimization services.=E2=80=9D
I write to inform you that it will take the University more than ten (10) w=
orking days to produce the records you=E2=80=99ve requested. In addition, I=
seek to provide you with the amount of time that UMBC anticipates it will =
take to locate, gather, review and produce the records, a discussion of fee=
s that will be required for this disclosure, and an explanation as to why t=
he University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid Optimizatio=
n strategy; the most recent contract period ended in 2020. Additionally, it=
em 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(4)(=
iv) and is therefore denied. Furthermore, your request appears to request d=
ata pulls without reference to a specific timeframe (ex. Academic year 2019=
-2020); is there a specific timeframe that you are seeking?
The University anticipates that it will be able to produce the records for =
your inspection within 30 calendar days. Please note, however, that UMBC m=
ay be obligated to request an extension of time pursuant to GP =C2=A7 4-203=
(d). I do not yet know whether all of the records are subject to inspection=
, but, if any are to be withheld, the response will explain the reason for =
that. The Act, at Section 4-206, permits the University to charge for the =
search, preparation and reproduction of a public record, excluding the firs=
t two (2) hours. Of course, a more exact calculation will depend on the tim=
e to be expended and the actual hourly rates of the individual staff and at=
torneys who must conduct the review.=20
With regard to the amount of time required to produce the records you have =
requested, please be advised the Office of the General Counsel will be requ=
ired to manage activities with the Office of Enrollment Management. The af=
orementioned functional areas have responsibilities, obligations, and work =
schedules that are separate from and in addition to the University=E2=80=99=
s requirements under the Act. Once the University has located and collecte=
d the records, legal counsel must review the records to determine whether t=
hey are, in whole or in part, exempt from disclosure under the Act. For exa=
mple, there may be confidential commercial information at issue; consequent=
ly, the University must interface with the relevant entities and obtain the=
ir feedback to prepare a response. This interaction takes additional time.=
=20=20
If I can be of further assistance, please do not hesitate to contact me at =
morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--=20
Morgan Thomas
---
On Dec. 17, 2021:
Subject: [Maryland Public Information Act Requests #2456689] Maryland Publi=
c Information Act Request [Correspondence]
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) has b=
egun to process your request for records under the Public Information Act, =
Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article, =
=C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This reque=
st, which was transmitted to UMBC via its electronic portal on December 12,=
2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the univer=
sity by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built =
for the university by EAB, described on page 46 of the attached contract. T=
his should include any documents describing the variables incorporated into=
the model(s) and how those variables are weighted, the model(s)' accuracy =
metrics (such as AUC), the model(s)' parameters, the machine learning techn=
iques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the univer=
sity provided to EAB in order for EAB to design its financial aid optimizat=
ion model, as described on page 46 of the attached contract. Please note, I=
am not asking for any personally identifiable information about students. =
Rather, I'm asking for a copy of the dataset that excludes identifiable inf=
ormation such as student names and street addresses. This can easily be don=
e by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and=
statements of work, between the university and EAB regarding financial aid=
optimization services and/or enrollment optimization services.=E2=80=9D
I write to inform you that it will take the University more than ten (10) w=
orking days to produce the records you=E2=80=99ve requested. In addition, I=
seek to provide you with the amount of time that UMBC anticipates it will =
take to locate, gather, review and produce the records, a discussion of fee=
s that will be required for this disclosure, and an explanation as to why t=
he University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid Optimizatio=
n strategy; the most recent contract period ended in 2020. Additionally, it=
em 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(4)(=
iv) and is therefore denied. Furthermore, your request appears to request d=
ata pulls without reference to a specific timeframe (ex. Academic year 2019=
-2020); is there a specific timeframe that you are seeking?
The University anticipates that it will be able to produce the records for =
your inspection within 30 calendar days. Please note, however, that UMBC m=
ay be obligated to request an extension of time pursuant to GP =C2=A7 4-203=
(d). I do not yet know whether all of the records are subject to inspection=
, but, if any are to be withheld, the response will explain the reason for =
that. The Act, at Section 4-206, permits the University to charge for the =
search, preparation and reproduction of a public record, excluding the firs=
t two (2) hours. Of course, a more exact calculation will depend on the tim=
e to be expended and the actual hourly rates of the individual staff and at=
torneys who must conduct the review.=20
With regard to the amount of time required to produce the records you have =
requested, please be advised the Office of the General Counsel will be requ=
ired to manage activities with the Office of Enrollment Management. The af=
orementioned functional areas have responsibilities, obligations, and work =
schedules that are separate from and in addition to the University=E2=80=99=
s requirements under the Act. Once the University has located and collecte=
d the records, legal counsel must review the records to determine whether t=
hey are, in whole or in part, exempt from disclosure under the Act. For exa=
mple, there may be confidential commercial information at issue; consequent=
ly, the University must interface with the relevant entities and obtain the=
ir feedback to prepare a response. This interaction takes additional time.=
=20=20
If I can be of further assistance, please do not hesitate to contact me at =
morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--=20
Morgan Thomas
---
On Dec. 9, 2021:
Subject: Maryland Public Information Act Request: EAB financial aid optimiz=
ation documents
To Whom It May Concern:
Pursuant to the Maryland Public Information Act, I hereby request the follo=
wing records:
1) All financial aid descriptive analyses performed by EAB and provided to =
the university as described on page 46 of the attached contract for EAB's f=
inancial aid optimization services.
2) All aggregated data analysis reports or documents provided to the univer=
sity by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built =
for the university by EAB, described on page 46 of the attached contract. T=
his should include any documents describing the variables incorporated into=
the model(s) and how those variables are weighted, the model(s)' accuracy =
metrics (such as AUC), the model(s)' parameters, the machine learning techn=
iques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the univer=
sity provided to EAB in order for EAB to design its financial aid optimizat=
ion model, as described on page 46 of the attached contract. Please note, I=
am not asking for any personally identifiable information about students. =
Rather, I'm asking for a copy of the dataset that excludes identifiable inf=
ormation such as student names and street addresses. This can easily be don=
e by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and=
statements of work, between the university and EAB regarding financial aid=
optimization services and/or enrollment optimization services.
I ask that all fees be waived as I am a journalist and intend to use the re=
quested records to publish articles in the public interest. In the event yo=
u choose to impose fees, I request a detailed breakdown of the fees, includ=
ing the hourly wage of each employee involved and an explanation justifying=
the employee hours required to fulfill the request.
Should you choose to reject this request or redact portions of it, I ask th=
at you provide a detailed breakdown of the statutory exemptions and associa=
ted case law underlying your decision to withhold each/any portions from pu=
blic review.
The requested documents will be made available to the general public, and t=
his request is not being made for commercial purposes.
In the event that there are fees, I would be grateful if you would inform m=
e of the total charges in advance of fulfilling my request. I would prefer =
the request filled electronically, by e-mail attachment if available or CD-=
ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I loo=
k forward to receiving your response to this request within 10 calendar day=
s, as the statute requires.
Sincerely,
Todd Feathers
View request history, upload responsive documents, and report problems here:
https://www.muckrock.com/
rock.com%2Faccounts%2Flogin%2F%3Fnext%3D%252Faccounts%252Fagency_login%252F=
university-of-maryland-baltimore-county-31022%252Feab-financial-aid-optimiz=
ation-documents-122012%252F%253Femail%253DUMBCHelp%252540rt.umbc.edu&url_au=
th_token=3DAAEo5-0aUkb36FbwuQIt3By7JMQ%3A1n6njH%3AwgLVfos5Y8C5-O0ob-rEWpqqT=
tg
If prompted for a passcode, please enter:
••••••••
Filed via MuckRock.com
E-mail (Preferred): requests@muckrock.com
For mailed responses, please address (see note):
MuckRock News
DEPT MR 122012
411A Highland Ave
Somerville, MA 02144-2516
PLEASE NOTE: This request is not filed by a MuckRock staff member, but is b=
eing sent through MuckRock by the above in order to better track, share, an=
d manage public records requests. Also note that improperly addressed (i.e.=
, with the requester's name rather than "MuckRock News" and the department =
number) requests might be returned as undeliverable.
--a17981769d0164e137bbcf638883f20e7fc837785aca61d9caae2614d3ee
Content-Transfer-Encoding: quoted-printable
content-type: text/html; charset="utf-8"
X-RT-Original-Encoding: utf-8
<p><br>University Of Maryland Baltimore County<br>PIA Office<br>Administrat=
ion Building, 10th Floor<br>1000 Hilltop Circle<br>Baltimore, MD 21250</p>
<p>January 10, 2022</p>
<p>This is a follow up to a previous request:</p>
<p>To Whom It May Concern:</p>
<p>I wanted to follow up on the following Maryland Public Information Act r=
equest, copied below, and originally submitted on Dec. 12, 2021. Please let=
me know when I can expect to receive a response.</p>
<p>Thanks for your help, and let me know if further clarification is needed=
.</p>
<p>View request history, upload responsive documents, and report problems h=
ere:<br>https://www.muckrock.com/
www.muckrock.com%2Faccounts%2Flogin%2F%3Fnext%3D%252Faccounts%252Fagency_lo=
gin%252Funiversity-of-maryland-baltimore-county-31022%252Feab-financial-aid=
-optimization-documents-122012%252F%253Femail%253DUMBCHelp%252540rt.umbc.ed=
u&url_auth_token=3DAAEo5-0aUkb36FbwuQIt3By7JMQ%3A1n6njH%3AwgLVfos5Y8C5-=
O0ob-rEWpqqTtg</p>
<p>If prompted for a passcode, please enter:<br>••••••••</p>
<p>Filed via MuckRock.com<br>E-mail (Preferred): 122012-35454644@requests.m=
uckrock.com</p>
<p>For mailed responses, please address (see note):<br>MuckRock News<br>DEP=
T MR 122012<br>411A Highland Ave<br>Somerville, MA 02144-2516</p>
<p>PLEASE NOTE: This request is not filed by a MuckRock staff member, but i=
s being sent through MuckRock by the above in order to better track, share,=
and manage public records requests. Also note that improperly addressed (i=
.e., with the requester's name rather than "MuckRock News" a=
nd the department number) requests might be returned as undeliverable.</p>
<p>---</p>
<p>On Dec. 17, 2021:<br>Subject: RE: Maryland Public Information Act Reques=
t: EAB financial aid optimization documents<br>Thank you very much for your=
help. For the data pulls, you can limit the request to Jan. 1, 2018 until =
the date the university stopped using EAB's financial aid optimization=
services.</p>
<p>Todd<br>---</p>
<p
>On Dec. 17, 2021:<br>Subject: Request #2456689<br>The following was sent=
via UMBC's PIA portal:</p>
<p>Dear Todd Feathers,</p>
<p>The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) ha=
s begun to process<br>your request for records under the Public Information=
Act, Md. Code Ann.,<br>General Provisions Article (=E2=80=9CGP=E2=80=9D) A=
rticle, =C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D).<br>=
This request, which was transmitted to UMBC via its electronic portal on<br=
>December 12, 2021, was assigned reference number 2456689. Specifically,<b=
r>you seek =E2=80=9C1) All financial aid descriptive analyses performed by =
EAB and<br>provided to the university as described on page 46 of the attach=
ed contract<br>for EAB's financial aid optimization services.</p>
<p>2) All aggregated data analysis reports or documents provided to the<br>=
university by EAB as described on page 49 of the attached contract.</p>
<p>3) Documentation of the financial aid optimization statistical model bui=
lt<br>for the university by EAB, described on page 46 of the attached contr=
act.<br>This should include any documents describing the variables incorpor=
ated<br>into the model(s) and how those variables are weighted, the model(s=
)'<br>accuracy metrics (such as AUC), the model(s)' parameters, t=
he machine<br>learning techniques employed, and any validation or disparate=
impact<br>analyses performed.</p>
<p>4) A de-identified copy of the admissions and financial aid data the<br>=
university provided to EAB in order for EAB to design its financial aid<br>=
optimization model, as described on page 46 of the attached contract.<br>Pl=
ease note, I am not asking for any personally identifiable information<br>a=
bout students. Rather, I'm asking for a copy of the dataset that exclu=
des<br>identifiable information such as student names and street addresses.=
This<br>can easily be done by removing those columns from the spreadsheet.=
</p>
<p>5) All other contract documents, including memorandums of understanding =
and<br>statements of work, between the university and EAB regarding financi=
al aid<br>optimization services and/or enrollment optimization services.=E2=
=80=9D</p>
<p>I write to inform you that it will take the University more than ten (10=
)<br>working days to produce the records you=E2=80=99ve requested. In addit=
ion, I seek<br>to provide you with the amount of time that UMBC anticipates=
it will take<br>to locate, gather, review and produce the records, a discu=
ssion of fees<br>that will be required for this disclosure, and an explanat=
ion as to why the<br>University is unable to produce the records more quick=
ly.</p>
<p>Please note, UMBC no longer works with EAB on its Financial Aid<br>Optim=
ization strategy; the most recent contract period ended in 2020.<br>Additio=
nally, item 3 of your request is considered proprietary under GP =C2=A7<br>=
4-205(c)(4)(iv) and is therefore denied. Furthermore, your request appears<=
br>to request data pulls without reference to a specific timeframe (ex.<br>=
Academic year 2019-2020); is there a specific timeframe that you are<br>see=
king?</p>
<p>The University anticipates that it will be able to produce the records f=
or<br>your inspection within 30 calendar days. Please note, however, that =
UMBC<br>may be obligated to request an extension of time pursuant to GP =C2=
=A7 4-203(d).<br>I do not yet know whether all of the records are subject t=
o inspection,<br>but, if any are to be withheld, the response will explain =
the reason for<br>that. The Act, at Section 4-206, permits the University =
to charge for the<br>search, preparation and reproduction of a public recor=
d, excluding the<br>first two (2) hours. Of course, a more exact calculatio=
n will depend on the<br>time to be expended and the actual hourly rates of =
the individual staff and<br>attorneys who must conduct the review.</p>
<p>With regard to the amount of time required to produce the records you ha=
ve<br>requested, please be advised the Office of the General Counsel will b=
e<br>required to manage activities with the Office of Enrollment Management=
.<br>The aforementioned functional areas have responsibilities, obligations=
, and<br>work schedules that are separate from and in addition to the Unive=
rsity=E2=80=99s<br>requirements under the Act. Once the University has loc=
ated and collected<br>the records, legal counsel must review the records to=
determine whether<br>they are, in whole or in part, exempt from disclosure=
under the Act. For<br>example, there may be confidential commercial inform=
ation at issue;<br>consequently, the University must interface with the rel=
evant entities and<br>obtain their feedback to prepare a response. This int=
eraction takes<br>additional time.</p>
<p>If I can be of further assistance, please do not hesitate to contact me =
at<br>morganthomas@umbc.edu.</p>
<p>Regards,</p>
<p>-- </p>
<p>*Morgan C. Thomas*<br>Assistant General Counsel<br>UMBC<br>Administratio=
n Building<br>1000 Hilltop Circle<br>9th Floor<br>Baltimore, MD 21250<br>Ph=
one: 410-455-1354<br>Phone: 410-455-2870<br>Fax: 410-455-1713<br>http://www=
.umbc.edu/ogc<br>---</p>
<p>On Dec. 17, 2021:<br>Subject: [Maryland Public Information Act Requests =
#2456689] Maryland Public Information Act Request [Correspondence]<br>Ticke=
t <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 ></p>
<p>Last Update From Ticket:</p>
<p>Dear Todd Feathers,</p>
<p>The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) ha=
s begun to process your request for records under the Public Information Ac=
t, Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article=
, =C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This req=
uest, which was transmitted to UMBC via its electronic portal on December 1=
2, 2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.</p>
<p>2) All aggregated data analysis reports or documents provided to the uni=
versity by EAB as described on page 49 of the attached contract.</p>
<p>3) Documentation of the financial aid optimization statistical model bui=
lt for the university by EAB, described on page 46 of the attached contract=
. This should include any documents describing the variables incorporated i=
nto the model(s) and how those variables are weighted, the model(s)' a=
ccuracy metrics (such as AUC), the model(s)' parameters, the machine l=
earning techniques employed, and any validation or disparate impact analyse=
s performed.</p>
<p>4) A de-identified copy of the admissions and financial aid data the uni=
versity provided to EAB in order for EAB to design its financial aid optimi=
zation model, as described on page 46 of the attached contract. Please note=
, I am not asking for any personally identifiable information about student=
s. Rather, I'm asking for a copy of the dataset that excludes identifi=
able information such as student names and street addresses. This can easil=
y be done by removing those columns from the spreadsheet.</p>
<p>5) All other contract documents, including memorandums of understanding =
and statements of work, between the university and EAB regarding financial =
aid optimization services and/or enrollment optimization services.=E2=80=9D=
</p>
<p>I write to inform you that it will take the University more than ten (10=
) working days to produce the records you=E2=80=99ve requested. In addition=
, I seek to provide you with the amount of time that UMBC anticipates it wi=
ll take to locate, gather, review and produce the records, a discussion of =
fees that will be required for this disclosure, and an explanation as to wh=
y the University is unable to produce the records more quickly.</p>
<p>Please note, UMBC no longer works with EAB on its Financial Aid Optimiza=
tion strategy; the most recent contract period ended in 2020. Additionally,=
item 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(=
4)(iv) and is therefore denied. Furthermore, your request appears to reques=
t data pulls without reference to a specific timeframe (ex. Academic year 2=
019-2020); is there a specific timeframe that you are seeking?</p>
<p>The University anticipates that it will be able to produce the records f=
or your inspection within 30 calendar days. Please note, however, that UMB=
C may be obligated to request an extension of time pursuant to GP =C2=A7 4-=
203(d). I do not yet know whether all of the records are subject to inspect=
ion, but, if any are to be withheld, the response will explain the reason f=
or that. The Act, at Section 4-206, permits the University to charge for t=
he search, preparation and reproduction of a public record, excluding the f=
irst two (2) hours. Of course, a more exact calculation will depend on the =
time to be expended and the actual hourly rates of the individual staff and=
attorneys who must conduct the review. </p>
<p>With regard to the amount of time required to produce the records you ha=
ve requested, please be advised the Office of the General Counsel will be r=
equired to manage activities with the Office of Enrollment Management. The=
aforementioned functional areas have responsibilities, obligations, and wo=
rk schedules that are separate from and in addition to the University=E2=80=
=99s requirements under the Act. Once the University has located and colle=
cted the records, legal counsel must review the records to determine whethe=
r they are, in whole or in part, exempt from disclosure under the Act. For =
example, there may be confidential commercial information at issue; consequ=
ently, the University must interface with the relevant entities and obtain =
their feedback to prepare a response. This interaction takes additional tim=
e. </p>
<p>If I can be of further assistance, please do not hesitate to contact me =
at morganthomas@umbc.edu.<br>Regards,</p>
<p>Morgan C. Thomas, Esq.</p>
<p>-- <br>Morgan Thomas<br>---</p>
<p>On Dec. 17, 2021:<br>Subject: [Maryland Public Information Act Requests =
#2456689] Maryland Public Information Act Request [Correspondence]<br>Ticke=
t <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 ></p>
<p>Last Update From Ticket:</p>
<p>Dear Todd Feathers,</p>
<p>The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) ha=
s begun to process your request for records under the Public Information Ac=
t, Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article=
, =C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This req=
uest, which was transmitted to UMBC via its electronic portal on December 1=
2, 2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.</p>
<p>2) All aggregated data analysis reports or documents provided to the uni=
versity by EAB as described on page 49 of the attached contract.</p>
<p>3) Documentation of the financial aid optimization statistical model bui=
lt for the university by EAB, described on page 46 of the attached contract=
. This should include any documents describing the variables incorporated i=
nto the model(s) and how those variables are weighted, the model(s)' a=
ccuracy metrics (such as AUC), the model(s)' parameters, the machine l=
earning techniques employed, and any validation or disparate impact analyse=
s performed.</p>
<p>4) A de-identified copy of the admissions and financial aid data the uni=
versity provided to EAB in order for EAB to design its financial aid optimi=
zation model, as described on page 46 of the attached contract. Please note=
, I am not asking for any personally identifiable information about student=
s. Rather, I'm asking for a copy of the dataset that excludes identifi=
able information such as student names and street addresses. This can easil=
y be done by removing those columns from the spreadsheet.</p>
<p>5) All other contract documents, including memorandums of understanding =
and statements of work, between the university and EAB regarding financial =
aid optimization services and/or enrollment optimization services.=E2=80=9D=
</p>
<p>I write to inform you that it will take the University more than ten (10=
) working days to produce the records you=E2=80=99ve requested. In addition=
, I seek to provide you with the amount of time that UMBC anticipates it wi=
ll take to locate, gather, review and produce the records, a discussion of =
fees that will be required for this disclosure, and an explanation as to wh=
y the University is unable to produce the records more quickly.</p>
<p>Please note, UMBC no longer works with EAB on its Financial Aid Optimiza=
tion strategy; the most recent contract period ended in 2020. Additionally,=
item 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(=
4)(iv) and is therefore denied. Furthermore, your request appears to reques=
t data pulls without reference to a specific timeframe (ex. Academic year 2=
019-2020); is there a specific timeframe that you are seeking?</p>
<p>The University anticipates that it will be able to produce the records f=
or your inspection within 30 calendar days. Please note, however, that UMB=
C may be obligated to request an extension of time pursuant to GP =C2=A7 4-=
203(d). I do not yet know whether all of the records are subject to inspect=
ion, but, if any are to be withheld, the response will explain the reason f=
or that. The Act, at Section 4-206, permits the University to charge for t=
he search, preparation and reproduction of a public record, excluding the f=
irst two (2) hours. Of course, a more exact calculation will depend on the =
time to be expended and the actual hourly rates of the individual staff and=
attorneys who must conduct the review. </p>
<p>With regard to the amount of time required to produce the records you ha=
ve requested, please be advised the Office of the General Counsel will be r=
equired to manage activities with the Office of Enrollment Management. The=
aforementioned functional areas have responsibilities, obligations, and wo=
rk schedules that are separate from and in addition to the University=E2=80=
=99s requirements under the Act. Once the University has located and colle=
cted the records, legal counsel must review the records to determine whethe=
r they are, in whole or in part, exempt from disclosure under the Act. For =
example, there may be confidential commercial information at issue; consequ=
ently, the University must interface with the relevant entities and obtain =
their feedback to prepare a response. This interaction takes additional tim=
e. </p>
<p>If I can be of further assistance, please do not hesitate to contact me =
at morganthomas@umbc.edu.<br>Regards,</p>
<p>Morgan C. Thomas, Esq.</p>
<p>-- <br>Morgan Thomas<br>---</p>
<p>On Dec. 17, 2021:<br>Subject: [Maryland Public Information Act Requests =
#2456689] Maryland Public Information Act Request [Correspondence]<br>Ticke=
t <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 ></p>
<p>Last Update From Ticket:</p>
<p>Dear Todd Feathers,</p>
<p>The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) ha=
s begun to process your request for records under the Public Information Ac=
t, Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article=
, =C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This req=
uest, which was transmitted to UMBC via its electronic portal on December 1=
2, 2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.</p>
<p>2) All aggregated data analysis reports or documents provided to the uni=
versity by EAB as described on page 49 of the attached contract.</p>
<p>3) Documentation of the financial aid optimization statistical model bui=
lt for the university by EAB, described on page 46 of the attached contract=
. This should include any documents describing the variables incorporated i=
nto the model(s) and how those variables are weighted, the model(s)' a=
ccuracy metrics (such as AUC), the model(s)' parameters, the machine l=
earning techniques employed, and any validation or disparate impact analyse=
s performed.</p>
<p>4) A de-identified copy of the admissions and financial aid data the uni=
versity provided to EAB in order for EAB to design its financial aid optimi=
zation model, as described on page 46 of the attached contract. Please note=
, I am not asking for any personally identifiable information about student=
s. Rather, I'm asking for a copy of the dataset that excludes identifi=
able information such as student names and street addresses. This can easil=
y be done by removing those columns from the spreadsheet.</p>
<p>5) All other contract documents, including memorandums of understanding =
and statements of work, between the university and EAB regarding financial =
aid optimization services and/or enrollment optimization services.=E2=80=9D=
</p>
<p>I write to inform you that it will take the University more than ten (10=
) working days to produce the records you=E2=80=99ve requested. In addition=
, I seek to provide you with the amount of time that UMBC anticipates it wi=
ll take to locate, gather, review and produce the records, a discussion of =
fees that will be required for this disclosure, and an explanation as to wh=
y the University is unable to produce the records more quickly.</p>
<p>Please note, UMBC no longer works with EAB on its Financial Aid Optimiza=
tion strategy; the most recent contract period ended in 2020. Additionally,=
item 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(=
4)(iv) and is therefore denied. Furthermore, your request appears to reques=
t data pulls without reference to a specific timeframe (ex. Academic year 2=
019-2020); is there a specific timeframe that you are seeking?</p>
<p>The University anticipates that it will be able to produce the records f=
or your inspection within 30 calendar days. Please note, however, that UMB=
C may be obligated to request an extension of time pursuant to GP =C2=A7 4-=
203(d). I do not yet know whether all of the records are subject to inspect=
ion, but, if any are to be withheld, the response will explain the reason f=
or that. The Act, at Section 4-206, permits the University to charge for t=
he search, preparation and reproduction of a public record, excluding the f=
irst two (2) hours. Of course, a more exact calculation will depend on the =
time to be expended and the actual hourly rates of the individual staff and=
attorneys who must conduct the review. </p>
<p>With regard to the amount of time required to produce the records you ha=
ve requested, please be advised the Office of the General Counsel will be r=
equired to manage activities with the Office of Enrollment Management. The=
aforementioned functional areas have responsibilities, obligations, and wo=
rk schedules that are separate from and in addition to the University=E2=80=
=99s requirements under the Act. Once the University has located and colle=
cted the records, legal counsel must review the records to determine whethe=
r they are, in whole or in part, exempt from disclosure under the Act. For =
example, there may be confidential commercial information at issue; consequ=
ently, the University must interface with the relevant entities and obtain =
their feedback to prepare a response. This interaction takes additional tim=
e. </p>
<p>If I can be of further assistance, please do not hesitate to contact me =
at morganthomas@umbc.edu.<br>Regards,</p>
<p>Morgan C. Thomas, Esq.</p>
<p>-- <br>Morgan Thomas<br>---</p>
<p>On Dec. 9, 2021:<br>Subject: Maryland Public Information Act Request: EA=
B financial aid optimization documents<br>To Whom It May Concern:</p>
<p>Pursuant to the Maryland Public Information Act, I hereby request the fo=
llowing records:</p>
<p>1) All financial aid descriptive analyses performed by EAB and provided =
to the university as described on page 46 of the attached contract for EAB&=
#x27;s financial aid optimization services.</p>
<p>2) All aggregated data analysis reports or documents provided to the uni=
versity by EAB as described on page 49 of the attached contract.</p>
<p>3) Documentation of the financial aid optimization statistical model bui=
lt for the university by EAB, described on page 46 of the attached contract=
. This should include any documents describing the variables incorporated i=
nto the model(s) and how those variables are weighted, the model(s)' a=
ccuracy metrics (such as AUC), the model(s)' parameters, the machine l=
earning techniques employed, and any validation or disparate impact analyse=
From: University Of Maryland Baltimore County
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (“UMBC”) has processed your request for records under the Public Information Act, Annotated Code of Maryland, General Provisions (“GP”) Article, § 4-101 et seq. (“the PIA”). This request, which was transmitted to UMBC via its electronic portal on December 12, 2021, was assigned reference number 2456689. Specifically, you seek “1) All financial aid descriptive analyses performed by EAB and provided to the university as described on page 46 of the attached contract for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built for the university by EAB, described on page 46 of the attached contract. This should include any documents describing the variables incorporated into the model(s) and how those variables are weighted, the model(s)' accuracy metrics (such as AUC), the model(s)' parameters, the machine learning techniques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the university provided to EAB in order for EAB to design its financial aid optimization model, as described on page 46 of the attached contract. Please note, I am not asking for any personally identifiable information about students. Rather, I'm asking for a copy of the dataset that excludes identifiable information such as student names and street addresses. This can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and statements of work, between the university and EAB regarding financial aid optimization services and/or enrollment optimization services.”
As communicated to you via email on December 17, 2021, once the University locates and collects the records, legal counsel must review the records to determine whether they are, in whole or in part, exempt from disclosure under the Act. For example, there may be confidential commercial information at issue. As a result of that review, items 1,2,3, and 4 are considered proprietary under GP § 4-205(c)(4)(iv) and are therefore denied.
Responsive records not exempt from disclosure can be found here: https://umbc.box.com/s/bracphd4exsd0tmqy2epy68fjtv29djz. UMBC expended less than two hours in responding to your request, so there will be no charge to you pursuant to GP § 4-206.
If I can be of further assistance, please do not hesitate to contact me at morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--
Morgan Thomas
From: Todd Feathers
Hello Morgan,
Thank you very much for your help with this.
I'd like to request some clarification regarding your denial. The specific section of law you cite, GP § 4-205(c)(4)(iv), as justification for withholding the records states that records custodians are not required to "release an electronic record in a format that would jeopardize or compromise the security or integrity of the original record or of any proprietary software in which the record is maintained."
Could you please explain how any of the records I've requested would "jeopardize or compromise the security or integrity" of any software system?
I've received responsive records to identical requests from other schools. The documents are simple spreadsheets and PDFs of presentations given to university officials—there's nothing in there that would jeopardize any software or system.
I look forward to your response,
Todd
From: University Of Maryland Baltimore County
This email address is no longer accepting support requests.
If you need help or want to report an issue, please do the following:
1. Check the FAQs at http://www.umbc.edu/faq or myUMBC Help (https://my.umbc.edu
/help)
2. Submit an RT ticket via myUMBC Help
3. Call the Technology Support Center (TSC) at 410.455.3838
4. Visit the TSC in the Library on the 1st floor, between the security gates and
Retriever Learning Center (RLC).
If you are a non-UMBC user and don't have a myUMBC UserName (e.g. bob123) or
a CampusID (e.g. XY12345), you may request help by contacting the Technology
Support Center at 410-455-3838. Our hours of operation can be found at:
Thank you.
University Of Maryland Baltimore County
PIA Office
Administration Building, 10th Floor
1000 Hilltop Circle
Baltimore, MD 21250
January 18, 2022
This is a follow up to a previous request:
Hello Morgan,
Thank you very much for your help with this.
I'd like to request some clarification regarding your denial. The specific section of law you cite, GP § 4-205(c)(4)(iv), as justification for withholding the records states that records custodians are not required to "release an electronic record in a format that would jeopardize or compromise the security or integrity of the original record or of any proprietary software in which the record is maintained."
Could you please explain how any of the records I've requested would "jeopardize or compromise the security or integrity" of any software system?
I've received responsive records to identical requests from other schools. The documents are simple spreadsheets and PDFs of presentations given to university officials—there's nothing in there that would jeopardize any software or system.
I look forward to your response,
Todd
View request history, upload responsive documents, and report problems here:
https://www.muckrock.com/
If prompted for a passcode, please enter:
••••••••
Filed via MuckRock.com
E-mail (Preferred): requests@muckrock.com
For mailed responses, please address (see note):
MuckRock News
DEPT MR 122012
411A Highland Ave
Somerville, MA 02144-2516
PLEASE NOTE: This request is not filed by a MuckRock staff member, but is being sent through MuckRock by the above in order to better track, share, and manage public records requests. Also note that improperly addressed (i.e., with the requester's name rather than "MuckRock News" and the department number) requests might be returned as undeliverable.
---
On Jan. 18, 2022:
Subject: [Maryland Public Information Act Requests #2456689] Maryland Public Information Act Request [Correspondence]
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (“UMBC”) has processed your request for records under the Public Information Act, Annotated Code of Maryland, General Provisions (“GP”) Article, § 4-101 et seq. (“the PIA”). This request, which was transmitted to UMBC via its electronic portal on December 12, 2021, was assigned reference number 2456689. Specifically, you seek “1) All financial aid descriptive analyses performed by EAB and provided to the university as described on page 46 of the attached contract for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built for the university by EAB, described on page 46 of the attached contract. This should include any documents describing the variables incorporated into the model(s) and how those variables are weighted, the model(s)' accuracy metrics (such as AUC), the model(s)' parameters, the machine learning techniques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the university provided to EAB in order for EAB to design its financial aid optimization model, as described on page 46 of the attached contract. Please note, I am not asking for any personally identifiable information about students. Rather, I'm asking for a copy of the dataset that excludes identifiable information such as student names and street addresses. This can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and statements of work, between the university and EAB regarding financial aid optimization services and/or enrollment optimization services.”
As communicated to you via email on December 17, 2021, once the University locates and collects the records, legal counsel must review the records to determine whether they are, in whole or in part, exempt from disclosure under the Act. For example, there may be confidential commercial information at issue. As a result of that review, items 1,2,3, and 4 are considered proprietary under GP § 4-205(c)(4)(iv) and are therefore denied.
Responsive records not exempt from disclosure can be found here: https://umbc.box.com/s/bracphd4exsd0tmqy2epy68fjtv29djz. UMBC expended less than two hours in responding to your request, so there will be no charge to you pursuant to GP § 4-206.
If I can be of further assistance, please do not hesitate to contact me at morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--
Morgan Thomas
---
On Jan. 10, 2022:
Subject: Your UMBC technical support request
This email address is no longer accepting support requests.
If you need help or want to report an issue, please do the following:
1. Check the FAQs at http://www.umbc.edu/faq or myUMBC Help (https://my.umbc.edu
/help)
2. Submit an RT ticket via myUMBC Help
3. Call the Technology Support Center (TSC) at 410.455.3838
4. Visit the TSC in the Library on the 1st floor, between the security gates and
Retriever Learning Center (RLC).
If you are a non-UMBC user and don't have a myUMBC UserName (e.g. bob123) or
a CampusID (e.g. XY12345), you may request help by contacting the Technology
Support Center at 410-455-3838. Our hours of operation can be found at:
Thank you.
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Subject: RE: Maryland Public Information Act Request: EAB financial aid optimization documents
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University Of Maryland Baltimore County
PIA Office
Administration Building, 10th Floor
1000 Hilltop Circle
Baltimore, MD 21250
January 10, 2022
This is a follow up to a previous request:
To Whom It May Concern:
I wanted to follow up on the following Maryland Public Information Act requ=
est, copied below, and originally submitted on Dec. 12, 2021. Please let me=
know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
View request history, upload responsive documents, and report problems here:
https://www.muckrock.com/
rock.com%2Faccounts%2Flogin%2F%3Fnext%3D%252Faccounts%252Fagency_login%252F=
university-of-maryland-baltimore-county-31022%252Feab-financial-aid-optimiz=
ation-documents-122012%252F%253Femail%253DUMBCHelp%252540rt.umbc.edu&url_au=
th_token=3DAAEo5-0aUkb36FbwuQIt3By7JMQ%3A1n6njH%3AwgLVfos5Y8C5-O0ob-rEWpqqT=
tg
If prompted for a passcode, please enter:
••••••••
Filed via MuckRock.com
E-mail (Preferred): requests@muckrock.com
For mailed responses, please address (see note):
MuckRock News
DEPT MR 122012
411A Highland Ave
Somerville, MA 02144-2516
PLEASE NOTE: This request is not filed by a MuckRock staff member, but is b=
eing sent through MuckRock by the above in order to better track, share, an=
d manage public records requests. Also note that improperly addressed (i.e.=
, with the requester's name rather than "MuckRock News" and the department =
number) requests might be returned as undeliverable.
---
On Dec. 17, 2021:
Subject: RE: Maryland Public Information Act Request: EAB financial aid opt=
imization documents
Thank you very much for your help. For the data pulls, you can limit the re=
quest to Jan. 1, 2018 until the date the university stopped using EAB's fin=
ancial aid optimization services.
Todd
---
On Dec. 17, 2021:
Subject: Request #2456689
The following was sent via UMBC's PIA portal:
Dear Todd Feathers,
The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) has b=
egun to process
your request for records under the Public Information Act, Md. Code Ann.,
General Provisions Article (=E2=80=9CGP=E2=80=9D) Article, =C2=A7=C2=A7 4-1=
01 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D).
This request, which was transmitted to UMBC via its electronic portal on
December 12, 2021, was assigned reference number 2456689. Specifically,
you seek =E2=80=9C1) All financial aid descriptive analyses performed by EA=
B and
provided to the university as described on page 46 of the attached contract
for EAB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the
university by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built
for the university by EAB, described on page 46 of the attached contract.
This should include any documents describing the variables incorporated
into the model(s) and how those variables are weighted, the model(s)'
accuracy metrics (such as AUC), the model(s)' parameters, the machine
learning techniques employed, and any validation or disparate impact
analyses performed.
4) A de-identified copy of the admissions and financial aid data the
university provided to EAB in order for EAB to design its financial aid
optimization model, as described on page 46 of the attached contract.
Please note, I am not asking for any personally identifiable information
about students. Rather, I'm asking for a copy of the dataset that excludes
identifiable information such as student names and street addresses. This
can easily be done by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and
statements of work, between the university and EAB regarding financial aid
optimization services and/or enrollment optimization services.=E2=80=9D
I write to inform you that it will take the University more than ten (10)
working days to produce the records you=E2=80=99ve requested. In addition, =
I seek
to provide you with the amount of time that UMBC anticipates it will take
to locate, gather, review and produce the records, a discussion of fees
that will be required for this disclosure, and an explanation as to why the
University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid
Optimization strategy; the most recent contract period ended in 2020.
Additionally, item 3 of your request is considered proprietary under GP =C2=
=A7
4-205(c)(4)(iv) and is therefore denied. Furthermore, your request appears
to request data pulls without reference to a specific timeframe (ex.
Academic year 2019-2020); is there a specific timeframe that you are
seeking?
The University anticipates that it will be able to produce the records for
your inspection within 30 calendar days. Please note, however, that UMBC
may be obligated to request an extension of time pursuant to GP =C2=A7 4-20=
3(d).
I do not yet know whether all of the records are subject to inspection,
but, if any are to be withheld, the response will explain the reason for
that. The Act, at Section 4-206, permits the University to charge for the
search, preparation and reproduction of a public record, excluding the
first two (2) hours. Of course, a more exact calculation will depend on the
time to be expended and the actual hourly rates of the individual staff and
attorneys who must conduct the review.
With regard to the amount of time required to produce the records you have
requested, please be advised the Office of the General Counsel will be
required to manage activities with the Office of Enrollment Management.
The aforementioned functional areas have responsibilities, obligations, and
work schedules that are separate from and in addition to the University=E2=
=80=99s
requirements under the Act. Once the University has located and collected
the records, legal counsel must review the records to determine whether
they are, in whole or in part, exempt from disclosure under the Act. For
example, there may be confidential commercial information at issue;
consequently, the University must interface with the relevant entities and
obtain their feedback to prepare a response. This interaction takes
additional time.
If I can be of further assistance, please do not hesitate to contact me at
morganthomas@umbc.edu.
Regards,
--=20
*Morgan C. Thomas*
Assistant General Counsel
UMBC
Administration Building
1000 Hilltop Circle
9th Floor
Baltimore, MD 21250
Phone: 410-455-1354
Phone: 410-455-2870
Fax: 410-455-1713
http://www.umbc.edu/ogc
---
On Dec. 17, 2021:
Subject: [Maryland Public Information Act Requests #2456689] Maryland Publi=
c Information Act Request [Correspondence]
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) has b=
egun to process your request for records under the Public Information Act, =
Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article, =
=C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This reque=
st, which was transmitted to UMBC via its electronic portal on December 12,=
2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the univer=
sity by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built =
for the university by EAB, described on page 46 of the attached contract. T=
his should include any documents describing the variables incorporated into=
the model(s) and how those variables are weighted, the model(s)' accuracy =
metrics (such as AUC), the model(s)' parameters, the machine learning techn=
iques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the univer=
sity provided to EAB in order for EAB to design its financial aid optimizat=
ion model, as described on page 46 of the attached contract. Please note, I=
am not asking for any personally identifiable information about students. =
Rather, I'm asking for a copy of the dataset that excludes identifiable inf=
ormation such as student names and street addresses. This can easily be don=
e by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and=
statements of work, between the university and EAB regarding financial aid=
optimization services and/or enrollment optimization services.=E2=80=9D
I write to inform you that it will take the University more than ten (10) w=
orking days to produce the records you=E2=80=99ve requested. In addition, I=
seek to provide you with the amount of time that UMBC anticipates it will =
take to locate, gather, review and produce the records, a discussion of fee=
s that will be required for this disclosure, and an explanation as to why t=
he University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid Optimizatio=
n strategy; the most recent contract period ended in 2020. Additionally, it=
em 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(4)(=
iv) and is therefore denied. Furthermore, your request appears to request d=
ata pulls without reference to a specific timeframe (ex. Academic year 2019=
-2020); is there a specific timeframe that you are seeking?
The University anticipates that it will be able to produce the records for =
your inspection within 30 calendar days. Please note, however, that UMBC m=
ay be obligated to request an extension of time pursuant to GP =C2=A7 4-203=
(d). I do not yet know whether all of the records are subject to inspection=
, but, if any are to be withheld, the response will explain the reason for =
that. The Act, at Section 4-206, permits the University to charge for the =
search, preparation and reproduction of a public record, excluding the firs=
t two (2) hours. Of course, a more exact calculation will depend on the tim=
e to be expended and the actual hourly rates of the individual staff and at=
torneys who must conduct the review.=20
With regard to the amount of time required to produce the records you have =
requested, please be advised the Office of the General Counsel will be requ=
ired to manage activities with the Office of Enrollment Management. The af=
orementioned functional areas have responsibilities, obligations, and work =
schedules that are separate from and in addition to the University=E2=80=99=
s requirements under the Act. Once the University has located and collecte=
d the records, legal counsel must review the records to determine whether t=
hey are, in whole or in part, exempt from disclosure under the Act. For exa=
mple, there may be confidential commercial information at issue; consequent=
ly, the University must interface with the relevant entities and obtain the=
ir feedback to prepare a response. This interaction takes additional time.=
=20=20
If I can be of further assistance, please do not hesitate to contact me at =
morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--=20
Morgan Thomas
---
On Dec. 17, 2021:
Subject: [Maryland Public Information Act Requests #2456689] Maryland Publi=
c Information Act Request [Correspondence]
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) has b=
egun to process your request for records under the Public Information Act, =
Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article, =
=C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This reque=
st, which was transmitted to UMBC via its electronic portal on December 12,=
2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the univer=
sity by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built =
for the university by EAB, described on page 46 of the attached contract. T=
his should include any documents describing the variables incorporated into=
the model(s) and how those variables are weighted, the model(s)' accuracy =
metrics (such as AUC), the model(s)' parameters, the machine learning techn=
iques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the univer=
sity provided to EAB in order for EAB to design its financial aid optimizat=
ion model, as described on page 46 of the attached contract. Please note, I=
am not asking for any personally identifiable information about students. =
Rather, I'm asking for a copy of the dataset that excludes identifiable inf=
ormation such as student names and street addresses. This can easily be don=
e by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and=
statements of work, between the university and EAB regarding financial aid=
optimization services and/or enrollment optimization services.=E2=80=9D
I write to inform you that it will take the University more than ten (10) w=
orking days to produce the records you=E2=80=99ve requested. In addition, I=
seek to provide you with the amount of time that UMBC anticipates it will =
take to locate, gather, review and produce the records, a discussion of fee=
s that will be required for this disclosure, and an explanation as to why t=
he University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid Optimizatio=
n strategy; the most recent contract period ended in 2020. Additionally, it=
em 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(4)(=
iv) and is therefore denied. Furthermore, your request appears to request d=
ata pulls without reference to a specific timeframe (ex. Academic year 2019=
-2020); is there a specific timeframe that you are seeking?
The University anticipates that it will be able to produce the records for =
your inspection within 30 calendar days. Please note, however, that UMBC m=
ay be obligated to request an extension of time pursuant to GP =C2=A7 4-203=
(d). I do not yet know whether all of the records are subject to inspection=
, but, if any are to be withheld, the response will explain the reason for =
that. The Act, at Section 4-206, permits the University to charge for the =
search, preparation and reproduction of a public record, excluding the firs=
t two (2) hours. Of course, a more exact calculation will depend on the tim=
e to be expended and the actual hourly rates of the individual staff and at=
torneys who must conduct the review.=20
With regard to the amount of time required to produce the records you have =
requested, please be advised the Office of the General Counsel will be requ=
ired to manage activities with the Office of Enrollment Management. The af=
orementioned functional areas have responsibilities, obligations, and work =
schedules that are separate from and in addition to the University=E2=80=99=
s requirements under the Act. Once the University has located and collecte=
d the records, legal counsel must review the records to determine whether t=
hey are, in whole or in part, exempt from disclosure under the Act. For exa=
mple, there may be confidential commercial information at issue; consequent=
ly, the University must interface with the relevant entities and obtain the=
ir feedback to prepare a response. This interaction takes additional time.=
=20=20
If I can be of further assistance, please do not hesitate to contact me at =
morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--=20
Morgan Thomas
---
On Dec. 17, 2021:
Subject: [Maryland Public Information Act Requests #2456689] Maryland Publi=
c Information Act Request [Correspondence]
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 >
Last Update From Ticket:
Dear Todd Feathers,
The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) has b=
egun to process your request for records under the Public Information Act, =
Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article, =
=C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This reque=
st, which was transmitted to UMBC via its electronic portal on December 12,=
2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.
2) All aggregated data analysis reports or documents provided to the univer=
sity by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built =
for the university by EAB, described on page 46 of the attached contract. T=
his should include any documents describing the variables incorporated into=
the model(s) and how those variables are weighted, the model(s)' accuracy =
metrics (such as AUC), the model(s)' parameters, the machine learning techn=
iques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the univer=
sity provided to EAB in order for EAB to design its financial aid optimizat=
ion model, as described on page 46 of the attached contract. Please note, I=
am not asking for any personally identifiable information about students. =
Rather, I'm asking for a copy of the dataset that excludes identifiable inf=
ormation such as student names and street addresses. This can easily be don=
e by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and=
statements of work, between the university and EAB regarding financial aid=
optimization services and/or enrollment optimization services.=E2=80=9D
I write to inform you that it will take the University more than ten (10) w=
orking days to produce the records you=E2=80=99ve requested. In addition, I=
seek to provide you with the amount of time that UMBC anticipates it will =
take to locate, gather, review and produce the records, a discussion of fee=
s that will be required for this disclosure, and an explanation as to why t=
he University is unable to produce the records more quickly.
Please note, UMBC no longer works with EAB on its Financial Aid Optimizatio=
n strategy; the most recent contract period ended in 2020. Additionally, it=
em 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(4)(=
iv) and is therefore denied. Furthermore, your request appears to request d=
ata pulls without reference to a specific timeframe (ex. Academic year 2019=
-2020); is there a specific timeframe that you are seeking?
The University anticipates that it will be able to produce the records for =
your inspection within 30 calendar days. Please note, however, that UMBC m=
ay be obligated to request an extension of time pursuant to GP =C2=A7 4-203=
(d). I do not yet know whether all of the records are subject to inspection=
, but, if any are to be withheld, the response will explain the reason for =
that. The Act, at Section 4-206, permits the University to charge for the =
search, preparation and reproduction of a public record, excluding the firs=
t two (2) hours. Of course, a more exact calculation will depend on the tim=
e to be expended and the actual hourly rates of the individual staff and at=
torneys who must conduct the review.=20
With regard to the amount of time required to produce the records you have =
requested, please be advised the Office of the General Counsel will be requ=
ired to manage activities with the Office of Enrollment Management. The af=
orementioned functional areas have responsibilities, obligations, and work =
schedules that are separate from and in addition to the University=E2=80=99=
s requirements under the Act. Once the University has located and collecte=
d the records, legal counsel must review the records to determine whether t=
hey are, in whole or in part, exempt from disclosure under the Act. For exa=
mple, there may be confidential commercial information at issue; consequent=
ly, the University must interface with the relevant entities and obtain the=
ir feedback to prepare a response. This interaction takes additional time.=
=20=20
If I can be of further assistance, please do not hesitate to contact me at =
morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--=20
Morgan Thomas
---
On Dec. 9, 2021:
Subject: Maryland Public Information Act Request: EAB financial aid optimiz=
ation documents
To Whom It May Concern:
Pursuant to the Maryland Public Information Act, I hereby request the follo=
wing records:
1) All financial aid descriptive analyses performed by EAB and provided to =
the university as described on page 46 of the attached contract for EAB's f=
inancial aid optimization services.
2) All aggregated data analysis reports or documents provided to the univer=
sity by EAB as described on page 49 of the attached contract.
3) Documentation of the financial aid optimization statistical model built =
for the university by EAB, described on page 46 of the attached contract. T=
his should include any documents describing the variables incorporated into=
the model(s) and how those variables are weighted, the model(s)' accuracy =
metrics (such as AUC), the model(s)' parameters, the machine learning techn=
iques employed, and any validation or disparate impact analyses performed.
4) A de-identified copy of the admissions and financial aid data the univer=
sity provided to EAB in order for EAB to design its financial aid optimizat=
ion model, as described on page 46 of the attached contract. Please note, I=
am not asking for any personally identifiable information about students. =
Rather, I'm asking for a copy of the dataset that excludes identifiable inf=
ormation such as student names and street addresses. This can easily be don=
e by removing those columns from the spreadsheet.
5) All other contract documents, including memorandums of understanding and=
statements of work, between the university and EAB regarding financial aid=
optimization services and/or enrollment optimization services.
I ask that all fees be waived as I am a journalist and intend to use the re=
quested records to publish articles in the public interest. In the event yo=
u choose to impose fees, I request a detailed breakdown of the fees, includ=
ing the hourly wage of each employee involved and an explanation justifying=
the employee hours required to fulfill the request.
Should you choose to reject this request or redact portions of it, I ask th=
at you provide a detailed breakdown of the statutory exemptions and associa=
ted case law underlying your decision to withhold each/any portions from pu=
blic review.
The requested documents will be made available to the general public, and t=
his request is not being made for commercial purposes.
In the event that there are fees, I would be grateful if you would inform m=
e of the total charges in advance of fulfilling my request. I would prefer =
the request filled electronically, by e-mail attachment if available or CD-=
ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I loo=
k forward to receiving your response to this request within 10 calendar day=
s, as the statute requires.
Sincerely,
Todd Feathers
View request history, upload responsive documents, and report problems here:
https://www.muckrock.com/
rock.com%2Faccounts%2Flogin%2F%3Fnext%3D%252Faccounts%252Fagency_login%252F=
university-of-maryland-baltimore-county-31022%252Feab-financial-aid-optimiz=
ation-documents-122012%252F%253Femail%253DUMBCHelp%252540rt.umbc.edu&url_au=
th_token=3DAAEo5-0aUkb36FbwuQIt3By7JMQ%3A1n6njH%3AwgLVfos5Y8C5-O0ob-rEWpqqT=
tg
If prompted for a passcode, please enter:
••••••••
Filed via MuckRock.com
E-mail (Preferred): requests@muckrock.com
For mailed responses, please address (see note):
MuckRock News
DEPT MR 122012
411A Highland Ave
Somerville, MA 02144-2516
PLEASE NOTE: This request is not filed by a MuckRock staff member, but is b=
eing sent through MuckRock by the above in order to better track, share, an=
d manage public records requests. Also note that improperly addressed (i.e.=
, with the requester's name rather than "MuckRock News" and the department =
number) requests might be returned as undeliverable.
--a17981769d0164e137bbcf638883f20e7fc837785aca61d9caae2614d3ee
Content-Transfer-Encoding: quoted-printable
content-type: text/html; charset="utf-8"
X-RT-Original-Encoding: utf-8
<p><br>University Of Maryland Baltimore County<br>PIA Office<br>Administrat=
ion Building, 10th Floor<br>1000 Hilltop Circle<br>Baltimore, MD 21250</p>
<p>January 10, 2022</p>
<p>This is a follow up to a previous request:</p>
<p>To Whom It May Concern:</p>
<p>I wanted to follow up on the following Maryland Public Information Act r=
equest, copied below, and originally submitted on Dec. 12, 2021. Please let=
me know when I can expect to receive a response.</p>
<p>Thanks for your help, and let me know if further clarification is needed=
.</p>
<p>View request history, upload responsive documents, and report problems h=
ere:<br>https://www.muckrock.com/
www.muckrock.com%2Faccounts%2Flogin%2F%3Fnext%3D%252Faccounts%252Fagency_lo=
gin%252Funiversity-of-maryland-baltimore-county-31022%252Feab-financial-aid=
-optimization-documents-122012%252F%253Femail%253DUMBCHelp%252540rt.umbc.ed=
u&url_auth_token=3DAAEo5-0aUkb36FbwuQIt3By7JMQ%3A1n6njH%3AwgLVfos5Y8C5-=
O0ob-rEWpqqTtg</p>
<p>If prompted for a passcode, please enter:<br>••••••••</p>
<p>Filed via MuckRock.com<br>E-mail (Preferred): 122012-35454644@requests.m=
uckrock.com</p>
<p>For mailed responses, please address (see note):<br>MuckRock News<br>DEP=
T MR 122012<br>411A Highland Ave<br>Somerville, MA 02144-2516</p>
<p>PLEASE NOTE: This request is not filed by a MuckRock staff member, but i=
s being sent through MuckRock by the above in order to better track, share,=
and manage public records requests. Also note that improperly addressed (i=
.e., with the requester's name rather than "MuckRock News" a=
nd the department number) requests might be returned as undeliverable.</p>
<p>---</p>
<p>On Dec. 17, 2021:<br>Subject: RE: Maryland Public Information Act Reques=
t: EAB financial aid optimization documents<br>Thank you very much for your=
help. For the data pulls, you can limit the request to Jan. 1, 2018 until =
the date the university stopped using EAB's financial aid optimization=
services.</p>
<p>Todd<br>---</p>
<p
>On Dec. 17, 2021:<br>Subject: Request #2456689<br>The following was sent=
via UMBC's PIA portal:</p>
<p>Dear Todd Feathers,</p>
<p>The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) ha=
s begun to process<br>your request for records under the Public Information=
Act, Md. Code Ann.,<br>General Provisions Article (=E2=80=9CGP=E2=80=9D) A=
rticle, =C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D).<br>=
This request, which was transmitted to UMBC via its electronic portal on<br=
>December 12, 2021, was assigned reference number 2456689. Specifically,<b=
r>you seek =E2=80=9C1) All financial aid descriptive analyses performed by =
EAB and<br>provided to the university as described on page 46 of the attach=
ed contract<br>for EAB's financial aid optimization services.</p>
<p>2) All aggregated data analysis reports or documents provided to the<br>=
university by EAB as described on page 49 of the attached contract.</p>
<p>3) Documentation of the financial aid optimization statistical model bui=
lt<br>for the university by EAB, described on page 46 of the attached contr=
act.<br>This should include any documents describing the variables incorpor=
ated<br>into the model(s) and how those variables are weighted, the model(s=
)'<br>accuracy metrics (such as AUC), the model(s)' parameters, t=
he machine<br>learning techniques employed, and any validation or disparate=
impact<br>analyses performed.</p>
<p>4) A de-identified copy of the admissions and financial aid data the<br>=
university provided to EAB in order for EAB to design its financial aid<br>=
optimization model, as described on page 46 of the attached contract.<br>Pl=
ease note, I am not asking for any personally identifiable information<br>a=
bout students. Rather, I'm asking for a copy of the dataset that exclu=
des<br>identifiable information such as student names and street addresses.=
This<br>can easily be done by removing those columns from the spreadsheet.=
</p>
<p>5) All other contract documents, including memorandums of understanding =
and<br>statements of work, between the university and EAB regarding financi=
al aid<br>optimization services and/or enrollment optimization services.=E2=
=80=9D</p>
<p>I write to inform you that it will take the University more than ten (10=
)<br>working days to produce the records you=E2=80=99ve requested. In addit=
ion, I seek<br>to provide you with the amount of time that UMBC anticipates=
it will take<br>to locate, gather, review and produce the records, a discu=
ssion of fees<br>that will be required for this disclosure, and an explanat=
ion as to why the<br>University is unable to produce the records more quick=
ly.</p>
<p>Please note, UMBC no longer works with EAB on its Financial Aid<br>Optim=
ization strategy; the most recent contract period ended in 2020.<br>Additio=
nally, item 3 of your request is considered proprietary under GP =C2=A7<br>=
4-205(c)(4)(iv) and is therefore denied. Furthermore, your request appears<=
br>to request data pulls without reference to a specific timeframe (ex.<br>=
Academic year 2019-2020); is there a specific timeframe that you are<br>see=
king?</p>
<p>The University anticipates that it will be able to produce the records f=
or<br>your inspection within 30 calendar days. Please note, however, that =
UMBC<br>may be obligated to request an extension of time pursuant to GP =C2=
=A7 4-203(d).<br>I do not yet know whether all of the records are subject t=
o inspection,<br>but, if any are to be withheld, the response will explain =
the reason for<br>that. The Act, at Section 4-206, permits the University =
to charge for the<br>search, preparation and reproduction of a public recor=
d, excluding the<br>first two (2) hours. Of course, a more exact calculatio=
n will depend on the<br>time to be expended and the actual hourly rates of =
the individual staff and<br>attorneys who must conduct the review.</p>
<p>With regard to the amount of time required to produce the records you ha=
ve<br>requested, please be advised the Office of the General Counsel will b=
e<br>required to manage activities with the Office of Enrollment Management=
.<br>The aforementioned functional areas have responsibilities, obligations=
, and<br>work schedules that are separate from and in addition to the Unive=
rsity=E2=80=99s<br>requirements under the Act. Once the University has loc=
ated and collected<br>the records, legal counsel must review the records to=
determine whether<br>they are, in whole or in part, exempt from disclosure=
under the Act. For<br>example, there may be confidential commercial inform=
ation at issue;<br>consequently, the University must interface with the rel=
evant entities and<br>obtain their feedback to prepare a response. This int=
eraction takes<br>additional time.</p>
<p>If I can be of further assistance, please do not hesitate to contact me =
at<br>morganthomas@umbc.edu.</p>
<p>Regards,</p>
<p>-- </p>
<p>*Morgan C. Thomas*<br>Assistant General Counsel<br>UMBC<br>Administratio=
n Building<br>1000 Hilltop Circle<br>9th Floor<br>Baltimore, MD 21250<br>Ph=
one: 410-455-1354<br>Phone: 410-455-2870<br>Fax: 410-455-1713<br>http://www=
.umbc.edu/ogc<br>---</p>
<p>On Dec. 17, 2021:<br>Subject: [Maryland Public Information Act Requests =
#2456689] Maryland Public Information Act Request [Correspondence]<br>Ticke=
t <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 ></p>
<p>Last Update From Ticket:</p>
<p>Dear Todd Feathers,</p>
<p>The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) ha=
s begun to process your request for records under the Public Information Ac=
t, Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article=
, =C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This req=
uest, which was transmitted to UMBC via its electronic portal on December 1=
2, 2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.</p>
<p>2) All aggregated data analysis reports or documents provided to the uni=
versity by EAB as described on page 49 of the attached contract.</p>
<p>3) Documentation of the financial aid optimization statistical model bui=
lt for the university by EAB, described on page 46 of the attached contract=
. This should include any documents describing the variables incorporated i=
nto the model(s) and how those variables are weighted, the model(s)' a=
ccuracy metrics (such as AUC), the model(s)' parameters, the machine l=
earning techniques employed, and any validation or disparate impact analyse=
s performed.</p>
<p>4) A de-identified copy of the admissions and financial aid data the uni=
versity provided to EAB in order for EAB to design its financial aid optimi=
zation model, as described on page 46 of the attached contract. Please note=
, I am not asking for any personally identifiable information about student=
s. Rather, I'm asking for a copy of the dataset that excludes identifi=
able information such as student names and street addresses. This can easil=
y be done by removing those columns from the spreadsheet.</p>
<p>5) All other contract documents, including memorandums of understanding =
and statements of work, between the university and EAB regarding financial =
aid optimization services and/or enrollment optimization services.=E2=80=9D=
</p>
<p>I write to inform you that it will take the University more than ten (10=
) working days to produce the records you=E2=80=99ve requested. In addition=
, I seek to provide you with the amount of time that UMBC anticipates it wi=
ll take to locate, gather, review and produce the records, a discussion of =
fees that will be required for this disclosure, and an explanation as to wh=
y the University is unable to produce the records more quickly.</p>
<p>Please note, UMBC no longer works with EAB on its Financial Aid Optimiza=
tion strategy; the most recent contract period ended in 2020. Additionally,=
item 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(=
4)(iv) and is therefore denied. Furthermore, your request appears to reques=
t data pulls without reference to a specific timeframe (ex. Academic year 2=
019-2020); is there a specific timeframe that you are seeking?</p>
<p>The University anticipates that it will be able to produce the records f=
or your inspection within 30 calendar days. Please note, however, that UMB=
C may be obligated to request an extension of time pursuant to GP =C2=A7 4-=
203(d). I do not yet know whether all of the records are subject to inspect=
ion, but, if any are to be withheld, the response will explain the reason f=
or that. The Act, at Section 4-206, permits the University to charge for t=
he search, preparation and reproduction of a public record, excluding the f=
irst two (2) hours. Of course, a more exact calculation will depend on the =
time to be expended and the actual hourly rates of the individual staff and=
attorneys who must conduct the review. </p>
<p>With regard to the amount of time required to produce the records you ha=
ve requested, please be advised the Office of the General Counsel will be r=
equired to manage activities with the Office of Enrollment Management. The=
aforementioned functional areas have responsibilities, obligations, and wo=
rk schedules that are separate from and in addition to the University=E2=80=
=99s requirements under the Act. Once the University has located and colle=
cted the records, legal counsel must review the records to determine whethe=
r they are, in whole or in part, exempt from disclosure under the Act. For =
example, there may be confidential commercial information at issue; consequ=
ently, the University must interface with the relevant entities and obtain =
their feedback to prepare a response. This interaction takes additional tim=
e. </p>
<p>If I can be of further assistance, please do not hesitate to contact me =
at morganthomas@umbc.edu.<br>Regards,</p>
<p>Morgan C. Thomas, Esq.</p>
<p>-- <br>Morgan Thomas<br>---</p>
<p>On Dec. 17, 2021:<br>Subject: [Maryland Public Information Act Requests =
#2456689] Maryland Public Information Act Request [Correspondence]<br>Ticke=
t <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 ></p>
<p>Last Update From Ticket:</p>
<p>Dear Todd Feathers,</p>
<p>The University of Maryland, Baltimore County (=E2=80=9CUMBC=E2=80=9D) ha=
s begun to process your request for records under the Public Information Ac=
t, Md. Code Ann., General Provisions Article (=E2=80=9CGP=E2=80=9D) Article=
, =C2=A7=C2=A7 4-101 =E2=80=93 4-601 (=E2=80=9Cthe Act=E2=80=9D). This req=
uest, which was transmitted to UMBC via its electronic portal on December 1=
2, 2021, was assigned reference number 2456689. Specifically, you seek =E2=
=80=9C1) All financial aid descriptive analyses performed by EAB and provid=
ed to the university as described on page 46 of the attached contract for E=
AB's financial aid optimization services.</p>
<p>2) All aggregated data analysis reports or documents provided to the uni=
versity by EAB as described on page 49 of the attached contract.</p>
<p>3) Documentation of the financial aid optimization statistical model bui=
lt for the university by EAB, described on page 46 of the attached contract=
. This should include any documents describing the variables incorporated i=
nto the model(s) and how those variables are weighted, the model(s)' a=
ccuracy metrics (such as AUC), the model(s)' parameters, the machine l=
earning techniques employed, and any validation or disparate impact analyse=
s performed.</p>
<p>4) A de-identified copy of the admissions and financial aid data the uni=
versity provided to EAB in order for EAB to design its financial aid optimi=
zation model, as described on page 46 of the attached contract. Please note=
, I am not asking for any personally identifiable information about student=
s. Rather, I'm asking for a copy of the dataset that excludes identifi=
able information such as student names and street addresses. This can easil=
y be done by removing those columns from the spreadsheet.</p>
<p>5) All other contract documents, including memorandums of understanding =
and statements of work, between the university and EAB regarding financial =
aid optimization services and/or enrollment optimization services.=E2=80=9D=
</p>
<p>I write to inform you that it will take the University more than ten (10=
) working days to produce the records you=E2=80=99ve requested. In addition=
, I seek to provide you with the amount of time that UMBC anticipates it wi=
ll take to locate, gather, review and produce the records, a discussion of =
fees that will be required for this disclosure, and an explanation as to wh=
y the University is unable to produce the records more quickly.</p>
<p>Please note, UMBC no longer works with EAB on its Financial Aid Optimiza=
tion strategy; the most recent contract period ended in 2020. Additionally,=
item 3 of your request is considered proprietary under GP =C2=A7 4-205(c)(=
4)(iv) and is therefore denied. Furthermore, your request appears to reques=
t data pulls without reference to a specific timeframe (ex. Academic year 2=
019-2020); is there a specific timeframe that you are seeking?</p>
<p>The University anticipates that it will be able to produce the records f=
or your inspection within 30 calendar days. Please note, however, that UMB=
C may be obligated to request an extension of time pursuant to GP =C2=A7 4-=
203(d). I do not yet know whether all of the records are subject to inspect=
ion, but, if any are to be withheld, the response will explain the reason f=
or that. The Act, at Section 4-206, permits the University to charge for t=
he search, preparation and reproduction of a public record, excluding the f=
irst two (2) hours. Of course, a more exact calculation will depend on the =
time to be expended and the actual hourly rates of the individual staff and=
attorneys who must conduct the review. </p>
<p>With regard to the amount of time required to produce the records you ha=
ve requested, please be advised the Office of the General Counsel will be r=
equired to manage activities with the Office of Enrollment Management. The=
aforementioned functional areas have responsibilities, obligations, and wo=
rk schedules that are separate from and in addition to the University=E2=80=
=99s requirements under the Act. Once the University has located and colle=
cted the records, legal counsel must review the records to determine whethe=
r they are, in whole or in part, exempt from disclosure under the Act. For =
example, there may be confidential commercial information at issue; consequ=
ently, the University must interface with the relevant entities and obtain =
their feedback to prepare a response. This interaction takes additional tim=
e. </p>
<p>If I can be of further assistance, please do not hesitate to contact me =
at morganthomas@umbc.edu.<br>Regards,</p>
<p>Morgan C. Thomas, Esq.</p>
<p>-- <br>Morgan Thomas<br>---</p>
<p>On Dec. 17, 2021:<br>Subject: [Maryland Public Information Act Requests =
#2456689] Maryland Public Information Act Request [Correspondence]<br>Ticke=
t <URL: https://rt.umbc.edu/Ticket/Display.html?id=3D2456689 ></p>
<p>Last Update From Ticket:</p>
<p>Dear Todd Feathers,</p>
From: Todd Feathers
Hello Morgan,
Thank you very much for your help with this.
I'd like to request some clarification regarding your denial. The specific section of law you cite, GP § 4-205(c)(4)(iv), as justification for withholding the records states that records custodians are not required to "release an electronic record in a format that would jeopardize or compromise the security or integrity of the original record or of any proprietary software in which the record is maintained."
Could you please explain how any of the records I've requested would "jeopardize or compromise the security or integrity" of any software system?
I've received responsive records to identical requests from other schools. The documents are simple spreadsheets and PDFs of presentations given to university officials—there's nothing in there that would jeopardize any software or system.
I look forward to your response,
Todd
From: University Of Maryland Baltimore County
Ticket <URL: https://rt.umbc.edu/Ticket/Display.html?id=2456689 >
Last Update From Ticket:
Good evening Todd,
I can absolutely provide more context for the basis of the denial. Before addressing your specific request(s), it is important to note that Exhibit B, Section 4.2 (page 8) of the EAB Contract for Consultant Services (“EAB Contract”) provided to you on January 18, 2022 explicitly states that “EAB owns all right, title and interest in and to all Deliverables (excluding any Client Data and Client Materials therein), as well as all products and services, including all hardware, systems, software and other intellectual property EAB uses to provide services and furnish Deliverables hereunder…. [UMBC] may not (a) provide the Deliverables to any third party….”
Furthermore, in Exhibit A, Section 2 (page 7) of the EAB Contract, “Deliverables” are described as:
• Financial Aid Descriptive Analysis by program
• Live simulation model
• Award simulation and aid policy development counsel
• Tactical counsel for implementation of the aid policy
• Monitoring of admits and awards
For ease of reading, I will address each part of your request in order.
1) All financial aid descriptive analyses performed by EAB and provided to the university as described on page 46 of the attached contract for EAB's financial aid optimization services.
This information is specifically listed in the EAB Contract as a Deliverable, which UMBC may not provide to any third party. In this regard, GP § 4-205(c)(1)(iii)(1-3) requires the University to deny confidential and protected information. Consistent with caselaw, UMBC will not disseminate information provided under the assurances of privacy, and particularly when it has been marked or clearly communicated as confidential or proprietary. Food Mktg. Inst. v. Argus Leader Media, 139 S. Ct. 2356, 2366 (2019).
Furthermore, financial aid descriptive analyses performed by EAB are a direct result and product of their proprietary software. Even if the University is not required to deny, under GP § 4-205(c)(4)(iv), the University can choose not to release this information in a format that would somehow compromise the security or integrity of the original record or proprietary software. Page 46 of the document you linked and referenced in your request to the University, which is labeled “Scope of Services: Financial Aid Optimization Services,” describes the descriptive analyses as follows:
“a. Services include the development of an extensive database from the combined admissions and financial aid data we acquire from you.
b. From this database, we build a descriptive analysis which illustrates the behavior of the admitted student cohort for the most recently recruited classes, as a group and by segments.
c. The descriptive analysis provides a review of the composition of the admitted student cohort, by segment, and how such responded to offers of grant aid.”
It is UMBC’s position that sharing the descriptive analyses would reveal too much about the innerworkings of EAB’s business, EAB’s proprietary software, and the content provided from the software, and thus denies this portion of your request.
2) All aggregated data analysis reports or documents provided to the university by EAB as described on page 49 of the attached contract.
Page 49 of the document you linked and referenced in your request to the University, which is labeled “Scope of Services: Financial Aid Optimization Services,” describes the aggregated data analysis reports or documents as follows:
“EAB may aggregate or analyze student-level and institutional-level data across Organization cohorts to enhance the Program(s). EAB may provide these insights from such analysis to Organization in various forms, for example, benchmarking Organization’s performance against a group of peer institutions, which may include data at the individual student level. EAB may also use such information to optimize and improve the efficacy of the Program(s) relative to individual students, such as modifying communication strategies based on student-level or parent-level behavior across all of EAB's interactions with such individual.”
These reports and documents are Deliverables created and owned by EAB to enhance the Program(s). This could include, but may not be limited to, the following Deliverables categories specifically stated in the EAB Contract:
• Live simulation model
• Award simulation and aid policy development counsel
• Tactical counsel for implementation of the aid policy
• Monitoring of admits and awards
For the reasons stated for the denial of part 1 of your request, part 2 of the request is also denied.
3) Documentation of the financial aid optimization statistical model built for the university by EAB, described on page 46 of the attached contract. This should include any documents describing the variables incorporated into the model(s) and how those variables are weighted, the model(s)' accuracy metrics (such as AUC), the model(s)' parameters, the machine learning techniques employed, and any validation or disparate impact analyses performed.
The University notified you in its communication to you on December 17, 2021, that this information is deemed proprietary and would thus be denied.
Page 46 of the document you linked and referenced in your request to the University, which is labeled “Scope of Services: Financial Aid Optimization Services,” describes The Price Optimization Model as follows:
“a. Services also include the results from a statistically-driven live simulation model.
b. Built into the model is the capacity to simulate financial aid packages for individual students, including add-on or stacked awards.
c. In addition to customizing award strategy, this model is capable of showing the results of admitting more or less students from individual cells, or “buckets,” in Organization’s matrix.
d. The simulation model allows manually adjusting yield expectations by cell.
e. Award simulation and aid policy development counsel
f. Tactical counsel for implementation of the aid policy”
For the reasons stated for the denial of sensitive information in part 1 of your request, and applied to part 2 of your request, part 3 of the request is also denied.
4) A de-identified copy of the admissions and financial aid data the university provided to EAB in order for EAB to design its financial aid optimization model, as described on page 46 of the attached contract. Please note, I am not asking for any personally identifiable information about students. Rather, I'm asking for a copy of the dataset that excludes identifiable information such as student names and street addresses. This can easily be done by removing those columns from the spreadsheet.
Upon further review, part 4 of your request was denied in error. De-identified spreadsheets provided by UMBC to EAB are available for your review in the existing Box folder: https://umbc.box.com/s/bracphd4exsd0tmqy2epy68fjtv29djz.
5) All other contract documents, including memorandums of understanding and statements of work, between the university and EAB regarding financial aid optimization services and/or enrollment optimization services.
This information has been provided to you. Please note that I have provided information to you via a Box folder, which is our general practice for fulfilling PIAs. Should this be an issue and you prefer that I use the MuckRock portal, please don’t hesitate to communicate that.
Should you disagree with this finding, you have remedial options available. First, you may seek judicial review of this decision in accordance with GP Section 4-362. Second, you may seek assistance from the Public Access Ombudsperson under GP Section 4-1B-01 et seq.
If you have further questions, please feel free to contact me at morganthomas@umbc.edu.
Regards,
Morgan C. Thomas, Esq.
--
Morgan Thomas
-
2456689
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