EAB financial aid optimization documents
| Submitted | Dec. 7, 2021 |
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Communications
From: Todd Feathers
To Whom It May Concern:
Pursuant to the Arizona Public Records Law, 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.
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 business days.
Sincerely,
Todd Feathers
From: Northern Arizona University
Please fill out and return the attached form and we will begin processing your request. Thank you.
NAU Communications
From: Todd Feathers
Hello,
Please find the completed form attached.
Todd
From: Northern Arizona University
Todd,
NAU is continuing to work diligently on both of your requests. We will be back in touch when we have additional information. Thank you.
NAU Communications
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following Arizona Public Records Law request, copied below, and originally submitted on Dec. 7, 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: Northern Arizona University
We are continuing to work on this request and will respond as soon as possible. Thank you.
NAU Communications
From: Northern Arizona University
Todd,
As you know, we are in receipt of your public records requests, which seek extensive, detailed, and largely confidential information attendant to NAU’s contract with EAB. After review and analysis, NAU has determined that the requests are untenable. For the reasons below, NAU is not releasing the requested records.
The first three requests seek information that is subject to a statutory exemption from Arizona’s public inspection law and is not in the best interests of the State to release. The requested information is not available to the public and deemed confidential under NAU’s properly approved contract with EAB; EAB provided the information to NAU pursuant to the terms of the contract (as you acknowledge in your request); and, the agreement itself includes sufficient information for the public to understand the nature of the contracted work. See A.R.S. 15-1640(A)(1)(c); see also A.R.S. 15-1640(A)(1)(b) (exempting from Arizona’s public inspection law “[i]nformation or intellectual property that is not available to the public and that is…[d]eveloped by…independent contractors working with a university or third parties collaborating with a university, if the disclosure of this data or material would be contrary to the best interests of this state”).
The fourth request, in effect, asks NAU to create a spreadsheet of aggregated (and “de-identified” or redacted) information that does not otherwise exist. NAU is not obligated to do so. See, e.g., American Civil Liberties Union v. Ariz. Dep’t of Child Safety, 240 Ariz. 142, 148, 377 P.3d 339, 345 (App. 2016) (“Arizona’s public records law does not require an agency to tally and compile previously untallied and un-compiled information or data to respond to a public records request.”). The request is also unduly burdensome, and any ordinary presumption favoring disclosure is overcome by “(1) the resources and time it [would] take to locate, compile, and redact the requested materials; (2) the volume of materials requested; and (3) the extent to which compliance with the request w[ould] disrupt [NAU]’s ability to perform its core functions.” Hodai v. City of Tucson, 239 Ariz. 34, 43, 365 P.3d 959, 968 (App. 2016); see also London v. Broderick, 206 Ariz. 490, 493, 80 P.3d 769, 772 (2003) (explaining that “sometimes the benefits of public disclosure must yield to the burden imposed on…the government itself by disclosure.”).
Thank you.
NAU Communications
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