Student Data Policy

Effective Date: To Be Determined | Date Issued: August 26, 2025 | Last Version: August 14, 2025

Policy Summary

  1. Local staff must use TDLWD’s student data management system for recording student data and must complete required training and acceptable use form; staff who leave AE must have system access removed on their last workday.
  2. Student data must be entered within 10 business days of its collection.
  3. Students must complete registration and application forms; minors must have an approval form; SSNs are encouraged but not required; students must provide citizenship/immigration status documentation.
  4. Students must be assigned activity codes as applicable.
  5. Students’ program attendance hours must be recorded.
  6. Students’ TABE and CASAS assessment scores must be recorded.
  7. Students’ measurable skill gains must be recorded and accompanying documents uploaded.
  8. Students’ career plans must be uploaded as applicable.
  9. Local staff must follow data privacy requirements outlined in FERPA and handle sensitive student information and documents appropriately.

Revisions Summary

  • Added driver’s license to the list of documents for citizenship and immigration status verification.

Policy

1. Data Management System and Training

Local AE providers must record student data in TDLWD’s student data management system. If paper records are collected for any student data elements, those elements must be manually entered into the data system. Paper records must be stored in physical files or digitally saved (e.g., via uploading to the data system) for verification purposes. Once paper records are digitally saved, they can either be stored or shredded.

TDLWD is responsible for maintaining records in the data system—local staff must not delete these records.

All staff who will use the data system to enter or retrieve student data must first complete the required TDLWD AE Student Data Management System Basics training.1 This training is offered virtually periodically throughout the program year, and a recorded version is available via TDLWD’s learning management system. Local providers must keep record of staff who complete the training via an internal tracking method or a record of attendance in TDLWD’s learning management system.

Local staff must also read and sign the State of Tennessee Acceptable Use Policy – User Agreement Acknowledgment to be granted access to the system.

Local staff who leave employment with the local provider must have their system access removed by the close of business of their last workday.

2. Data Entry Timeliness

Local staff must enter student data within 10 business days of its collection (or when documentation becomes available). Specifically, the following student data elements must abide by the 10-day-window requirement:

  • Intake information
  • Activity codes
  • Attendance hours
  • Pre-tests and post-tests
  • Measurable skill gains
  • Career plans

3. Intake Information

A. Registration and Application

To enroll in a local AE program, a student must be registered in the data management system and complete an enrollment application. To complete the registration and application, students are required to provide their name, contact information, date of birth, and various demographics and statuses. The exact information required is listed in the TDLWD Adult Education Student Registration Form. Local providers can use this form as-is or develop their own (including digital), but all required information must be collected from the student.

Local staff must then enter the student’s information and date of enrollment into the data system. Copies of the forms completed by students must be kept for data verification purposes (either paper or digital).

B. Approval Form for Minors

Students who are 16 or 17 years old must have their parent or guardian sign the student registration form and an approval form that certifies the student is not enrolled in school or has been unenrolled, and allows for the student’s enrollment in AE. Local AE staff must have this form completed at the time of enrollment and maintain a copy of the form for data verification purposes (either paper or digital).

C. SSNs and Photo ID’s

Social Security Numbers (SSNs), while listed on the registration/application form, are not required to be owned or disclosed by students. The exception is if a student chooses to use their social security card to verify citizenship or immigration status (see Section D, below). However, SSNs are needed for “data matching”, an automatic process used to efficiently retrieve students' high school equivalency exam scores and future postsecondary and employment outcomes. Thus, students should be strongly encouraged to provide their SSNs during registration. Social security cards must not be requested or photocopied—students can simply write their SSN on the registration form.

If a student does not provide an SSN, local staff must generate a “pseudo ID number” in the data system.

Photo ID’s (such as a driver’s license or booking sheet) must not be required to be owned or shown by students as part of registration. The exception is if a student chooses to use photo ID to verify citizenship or immigration status (see Section D, below). However, local staff may request to view photo ID as necessary to verify spelling of the student’s name or to verify residency if required by local policy. Local staff should also encourage students to have photo ID if they are going to take the HiSET or GED exam—students must show photo ID for admission to HiSET or GED testing. Photo ID’s must not be photocopied or retained in student records.

D. Citizenship and Immigration Status Verification

Students must provide one of the following documents that verifies citizenship or immigration status:

  • Driver’s license (from Tennessee or any other state or territory NOT excluded2)
  • REAL ID license or card (from any state or territory)
  • U.S. social security card
  • U.S. birth certificate
  • U.S. passport or passport card
  • Permanent resident card (Form I-551 or “green card”)
  • Foreign passport or visa with temporary Form I-551
  • Foreign passport with Form I-94 or I-94A
  • Employment Authorization Document (Form I-766 or “work permit”)
  • U.S. Citizen ID card (Form I-197)
  • Identification Card for Use of Resident Citizen (Form I-179)
  • Native American tribal document
  • Other documents that might be specifically held by refugees, asylees, parolees, and other immigrants3

When receiving a document, local staff must briefly review it for authenticity and validity, scan it into an electronic file, and return it to the student. Staff must then upload the digital file to the student’s profile in the student data management system as soon as possible. After documents are uploaded to the data system, staff must use appropriate methods for destroying sensitive personally identifiable information (PII) in paper files and securely deleting sensitive electronic PII.

4. Activity Codes

To be accurately tracked and reported, students must be assigned the activity code(s) in the data system corresponding to the services they receive and the dates they receive them. These codes include:

  • AE1 – Adult Education: The “catch-all” code for each student, regardless of the services they receive.
  • A03 – Corrections Education: For justice-involved students who are in a correctional institution or are required to attend a Day Reporting Center (DRC).
  • A04 – Integrated Education and Training (IET): For students in an approved IET program.
  • A05 – Workplace Learning: For students in an approved workplace learning program.
  • A06 – Pre-Apprenticeship: For students in an approved pre-apprenticeship program.
  • A08 – Postsecondary Pathway: For students in an approved postsecondary pathway program.
  • A10 – Jail Tablet User: For justice-involved students in a correctional institution who are using the TDLWD Workforce-Reentry tablets for AE activities.
  • A11 – Career Plan: For students who have established a career plan with a career coach.
  • ALP – Alternative Placement: For students who are exempt from formal TABE or CASAS pre- and post-testing.

Local staff must assign the activity codes when entering a student’s intake information and whenever the student begins participating in any additional services. When a student is no longer participating in a given activity, local staff must ensure the activity code closes.

5. Attendance Hours

Local staff must record students' program attendance hours in the data system. Attendance must be entered to correspond with the student’s assigned class and date of attendance, or the student’s distance education activity and date of completion. Hours may be recorded rounding up to the quarter-hour (e.g., 2 hours and 5 minutes of attendance is recorded as 2¼ hours). Copies of attendance records are not required to be kept and will not be monitored, including past records.

6. Pre-Tests & Post-Tests

For students who are not exempt from TABE or CASAS pre- and post-testing, local staff must record their TABE and CASAS testing information in the data system. This includes test subjects, forms, scores, and dates. Copies of the student’s test results must be kept for data verification purposes (either paper, digital, or via the TABE DRC Insight or CASAS TOPSpro online systems).

7. Measurable Skill Gains

Local staff must record certain information in the data system in order to count student measurable skill gains (MSG) and for data verification purposes. The required information for each type of MSG is below.

  • MSG Type 1a – Level gain via pre- and post-testing: Local staff must record the student’s TABE or CASAS assessment scores in the data system via the “Assessments” ribbon. An MSG will automatically be recorded based on the scores entered.
  • MSG Type 1b – Level gain via credits: For adult high school students who earn enough credits to move to 11th- or 12th-grade status (as determined by the local school district) – local staff must upload the student’s transcript and indicate the MSG in the data system via the “MSG” ribbon.
  • MSG Type 1c – Level gain via entry into postsecondary or training: For students who enroll in postsecondary education or training (after already being enrolled in AE) – local staff must upload the student’s proof of enrollment and indicate the MSG in the data system via the “MSG” ribbon.
  • MSG Type 1d – Level gain via passing HSE subtest: For students who pass one or more of the five required HSE subtests (math, reading, writing, science, or social studies) – local staff must indicate the MSG in the data system via the “MSG” ribbon. Scores are verified in the “Assessments” or “High School Equivalency” ribbons.
  • MSG Type 2 – Diploma: For students who earn a high school equivalency diploma – local staff must upload the student’s unofficial transcript and indicate the MSG in the data system via the “Credentials” ribbon or ensure scores are in the “High School Equivalency” ribbon. For students who earn a regular high school diploma – local staff must upload the student’s official transcript or diploma and indicate the MSG in the data system via the “Credentials” ribbon.
  • MSG Type 3 – Postsecondary transcript or report card: For IET students in a postsecondary program – local staff must upload the student’s transcript or report card and indicate the MSG in the data system via the “MSG” ribbon.
  • MSG Type 4 – Progress toward milestones: Most likely for workplace learning or IET students, and milestones are established with an employer or training provider – local staff must upload evidence of the student’s progress toward established milestones and indicate the MSG in the data system via the “MSG” ribbon.
  • MSG Type 5 – Passage of exam or progress in attaining skills: Most likely for IET students, and generally the result of passing a technical occupational skills assessment or earning an industry credential – local staff must upload the student’s exam results or evidence of progress in gaining occupational skills and indicate the MSG in the data system via the “MSG” ribbon.

8. Career Plans

For students who work with their career coach to establish career plans, local staff must upload their career plan in the data system.

9. FERPA and Data Privacy

Local AE providers must ensure compliance with the provisions outlined in the Family Educational Rights and Privacy Act (FERPA). FERPA requires local providers to protect students' PII (e.g., name, contact info, SSN, etc.) and education records (e.g. registration info, attendance, assessment scores, credentials, etc.). This information must be kept secure and not shared with anyone that isn’t allowed under FERPA, unless the student (or guardian) gives written permission.

In general, local staff may disclose student educational data to the following parties without needing further permission and without needing to keep record of the disclosure:

  • The student or their guardian.
  • AE staff.
  • A minor student’s school district.
  • A student’s court-appointed authorities (including probation/parole officers and Department of Children’s Services officials).
  • Partner educational or workforce programs.
  • Educational institutions where the student wants to enroll.

Students (or their guardian) must sign the “authorization for release of confidential information” section of the student registration form. This ensures the student (or guardian) is informed of and consents to how their data will be used.

Documents that verify students’ citizenship and immigration status also contain sensitive PII. To ensure that sensitive PII is handled appropriately, local staff must:

  • Ensure PII is not transmitted to unauthorized users and all PII transmitted through e-mail or stored electronically is encrypted.
  • Never store PII on personally owned devices, at off-site locations (e.g., an employee’s home), or on personal email accounts.
  • Use appropriate methods for destroying sensitive PII in paper files and securely deleting sensitive electronic PII.

In addition, local program leaders must advise all staff who have access to PII of the confidential nature of the information, the safeguards required to protect the information, and the civil and criminal sanctions for noncompliance with such safeguards.

Governance

Local program directors are responsible for disseminating this policy to their staff members, and for providing staff with associated training, checking for understanding, enforcing compliance, and seeking technical assistance from TDLWD staff as necessary. Program directors should also establish internal data quality review processes to ensure timeliness and accuracy of data entry.

To ensure compliance with this policy, TDLWD staff will review student data entered in the data system, verification documents (e.g., registration forms, test results, transcripts, etc.), paper documents, and data security practices.

Student Registration Form

1 This training requirement only applies to staff who are new to using the data system as of the effective date of this policy.
2 Excluded states include: California, Colorado, Connecticut, Delaware, Hawaii, Illinois, Maryland, Massachusetts, Minnesota, Nevada, New Jersey, New Mexico, New York, Oregon, Rhode Island, Utah, Vermont, Virginia and Washington. Driver’s licenses from these states do NOT qualify for eligibility.
3 This list is non-exhaustive. Additional examples of acceptable documents, including images of what the various documents look like, can be found on the Form  I-9 Acceptable Documents webpage.