Child welfare predictive analytics systems

To Whom It May Concern:

Pursuant to the Rhode Island Access to Public Records Act, I hereby request the following records:

1) Contracts with any company, nonprofit, or other entity that currently provides software to the department that includes predictive analytics models for child welfare (i.e., models designed to identify home placement risk, abuse risk, human trafficking risk, etc.). This should include contracts for CCWIS or comparable systems that include predictive models as well as project descriptions for any models created in-house.

2) Data dictionaries for all child welfare predictive models used by the department, including those provided by outside entities as well as in-house models. Data dictionaries are documents commonly created for predictive models and databases. They describe the categories of data that are inputs (age, gender, etc.) and outputs (risk level, etc.) of predictive models. They are equivalent to headers on a spreadsheet, and do not include actual data.

3) A list of all memorandums of understanding (MOUs) and/or data sharing agreements with state or local agencies for the provision of data that is incorporated into the department's child welfare predictive models. Should the department not maintain a list of these MOUs, I will accept copies of the MOUs themselves.

4) Any differential impact assessments, validation studies, or comparable documents that describe the accuracy of child welfare predictive models used by the department. This should include any documents that describe common measures of predictive accuracy, such as area under the curve (AUC).

5) All department policies, employee manuals, and guidelines describing how employees can and/or should use child welfare predictive models.

6) All governance board, committee, or outside expert reviews assessing the efficacy of the department's proposed or current child welfare predictive models.

Should you have questions regarding any aspect of this request, please don't hesitate to contact me.

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 employ 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.

I would prefer the request be filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you very much for your help, and I look forward to receiving your response to this request within 10 business days, as the statute requires.

Sincerely,

Todd Feathers

Hello,

I am writing to appeal the Rhode Island Department of Children, Youth and Families' denial of my public records request for documents related to its child welfare predictive analytics models. I submitted the request on April 30, 2021, and received the rejection letter from DCYF on June 11, 2021.

In that letter, DCYF states that it does use predictive analytics models developed in-house. However, DCYF, also claims that those records are not public records, stating in full:

"RI DCYF’s Division of Performance Improvement Data Analytics and Evaluation unit performs
statistical analysis including predictive analytic models that test for factors that predict child
welfare outcomes. RI DCYF does not use a software that auto generates or machine learning
predictive models. The records requested are not state agency public records in accordance with
Rhode Island General Law 38-2-2(4), and therefore, these are not records maintained or kept on
file by the Department of Children Youth and Families, the state agency in accordance with
Rhode Island General Law 38-2-3(a). RI DCYF has no public records pertaining to predictive
analytic software."

DCYF does not explain how the records pertaining to its in-house models aren't public records. The agency seems to have misconstrued the request to apply only to models that are part of software. However, only the first portion of my request--for contracts with outside vendors--references software. The rest of my request applies to documents related to any predictive models, whether they be part of software or not.

My request also clearly states that I am seeking records pertaining to predictive analytics models developed by agencies themselves. DCYF's acknowledgement that it creates these models is evidence enough that the requested records exist and are public records.

I ask that you instruct the agency to provide the responsive records in a timely manner, as required by the law.

Thank you very much for your assistance.

Sincerely,
Todd Feathers