EAB financial aid optimization documents

To Whom It May Concern:

Pursuant to the Ohio Open 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

Hello,

I'm following up to confirm that you've received this request. Thank you!

Todd

Hello Shelly,

I'm following up on my public records request (copied below), which I submitted on Dec. 7. I think it may have gone to the wrong person, so I just want to make sure you folks have it and are processing it.

Thank you!

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To Whom It May Concern:

Pursuant to the Ohio Open 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

Hello Shelly,

Thank you very much for your help with this request.

The presence of potentially exempt information in a document does not preclude the entire record from disclosure. Even if the requested records do contain exempt information, the records custodian must still produce the documents with the minimal possible redactions. Records custodians are also "required to give the requester an explanation, including legal authority, for each denial," as explained by the Attorney General's Sunshine Laws Manual (https://www.ohioattorneygeneral.gov/Files/Publications-Files/Publications-for-Legal/Sunshine-Laws-Publications/2021-Sunshine-Manual.aspx).

As stated in my original request, I ask that if you intend to withhold documents responsive my request, in whole or in part, that you provide the statutorily required explanation and legal justification for the denial or redactions. Your assertion that "We believe that the requested materials contain trade secrets and/or other proprietary information" does not constitute an explanation for the legal authority under which you are seeking to withhold these records. Specifically, you have not offered any evidence that the records in question meet either of the two tests required for information to be designated a "trade secret" under R.C. 1333.61(D).

I'd be happy to discuss this request over the phone if it's helpful.

Thank you again,
Todd