Approved by: Ethics and Compliance Leadership Committee (ECLC)
History: Issued November 27, 2012; Revised August 17, 2015, January 21, 2016
Responsible Official: Office of Institutional Research
Claremont McKenna College strives to maintain the highest quality institutional data, so that it may accurately and consistently represent itself to both internal and external audiences. This policy regulates how institutional data and related statistics are created, maintained, and audited, and defines the roles of all parties involved in communicating institutional data. At CMC, data construction and reporting responsibility is shared among individual departments, Institutional Research, Public Affairs and Communications, and the Ethics and Compliance Leadership Committee.
Entities Covered by this Policy
T. Colleen Wynn
Assistant VP for Institutional Research & Assessment
Data and surveys covered by this policy - Specific figures and calculations that are reported annually, both internally and externally, including federal and local reporting, and guidebooks and college rankings. Several examples are available on the Institutional Research website: the Fact Sheet, CDS, and Enrollment Statistics. Basic or general facts that are well-known and publicly available, e.g. the College was founded in 1946 and CMC is a highly-selective institution, can be reported without the additional procedures set forth in this policy.
- While no individual office at CMC “owns” institutional data, each department at CMC is responsible for the accuracy, quality, and integrity of institutional data apropos of that office. For example, Admission is accountable for application information; Financial Aid for grant, scholarship, and loan information; Treasurer for billing and financial information, etc.
- Each department will maintain a current and comprehensive list of surveys to which it reports institutional statistics and/or specific data elements. Offices must share their survey inventory with Institutional Research, for inclusion in CMC’s master survey inventory.
- Departments maintain written internal procedures which document how institutional data is gathered, verified, and reported. These procedures should be reviewed and updated every two years. At a minimum, these procedures must include:
a. Reasonable independent review: An independent review of survey responses may be performed within a department or by colleagues in a related office.
b. VP sign-off: The Vice President responsible for the office issuing survey responses must verify that procedures for separation of duties and independent review have been appropriately followed prior to submitting any survey responses. The VP’s “sign-off” may be recorded either on paper or electronically, as part of the auditable record of each survey. In the event that a VP is unable to fulfill this responsibility, the Chief Compliance Officer may perform this function or temporarily delegate it to another responsible staff member.
c. Auditable records: All survey responses and underlying data must be maintained for at least 5 years, to allow auditing by both internal and external reviewers. Departments will maintain survey instructions, annotated supporting data files, and methodologies for each survey response.
d. A documented separation of duties: No single individual may control data collection and the data reporting process. If a department lacks the staff resources to separate these duties, it must propose an alternate procedure to be approved by the Ethics and Compliance Leadership Committee (ECLC).
e. IR Review: Institutional Research must receive survey responses for review at least two weeks prior to survey submission deadlines. Departments which require an exception to this requirement may request an exception from the Director of Institutional Research. The Director of IR will report requests to the ECLC, so that CMC might identify departments which require additional support to adhere to these procedures.
Institutional Research (IR) Responsibilities
- Institutional Research serves as the primary source for accurate, consistent, definition-driven data about Claremont McKenna College. IR provides analysis of general institutional data in consultation with various stakeholders, supports internal decision-making, and maintains compliance with internal and external reporting requirements. IR serves as a resource for best practices in data construction and provides assistance with data-related projects to other offices within the College. In keeping with these responsibilities, IR must review survey responses, identify and resolve any data discrepancies, and approve surveys for submission. In the unlikely event that IR cannot resolve a data discrepancy with the responsible department, it will refer discrepancies to the President’s Executive Cabinet (PEC) for resolution.
- IR serves as the primary contact for surveys seeking general information or information pertaining to multiple departments at CMC, such as IPEDS. For surveys specific to a particular department, such as VSE, the responsible department serves as the primary contact and Institutional Research serves as the secondary contact; provided the survey allows for a secondary contact.
- IR makes the most commonly requested data elements available on its website so that those completing surveys, replying to inquiries, or placing institutional data in publications will have easy access to verified data and related definitions.
Public Affairs and Communications (PAC) Responsibilities
- PAC is responsible for promoting the College and responding to media inquiries.
- PAC oversees all marketing and communications materials at CMC including: the CMC Website, undergraduate and graduate admission marketing materials and brochures, financial aid and career services brochures, the CMC Magazine, Presidential communications, and news releases.
- In fulfilling these responsibilities, PAC will maintain written internal procedures to document the fact-checking process for any institutional communication materials prior to printing or publication. In addition to direct fact checking with responsible departments or offices, PAC will include a separate cross-check with IR when institutional data is included in its materials.
Additional Questions and Information
1. What about list serves and sharing information with other colleagues and professional organizations, which will not be made publicly available?
Before sharing any information that has not been through the formal approval process, it is wise to confirm that the organization or listserv requesting the information has a statement of understanding about data sharing, which should cover appropriate use and limiting third-party access, at a minimum.
2. Who reviews promotional materials for individual departments?
Promotional materials should be reviewed by Public Affairs and Communications before printing and/or publishing. Because PAC includes a separate cross-check with IR, it is not necessary for departments to send the information to IR separately, but it may expedite the process.
3. Is unofficial data subject to the same procedures set forth in this policy?
Whenever possible, it is best to use reviewed and approved figures for reporting. If that is not an option, it may also work well to use a more general figure, e.g. CMC typically enrolls about 1,300 students. Once a specific number is reported either internally or externally, it can be picked up and spread quickly and also difficult to correct in multiple locations, if it changes, e.g. the number of admitted applicants is around 600 on March 1st but generally increases in May.