Early Childhood Integrated Data System.
What changed between versions
New subdivision (a)(3) adds a purpose for the data system: providing linked data to conduct audits and evaluations of federal- or state-supported early childhood programs, enforce legal requirements, and create deidentified datasets for accountability and public purposes, subject to HIPAA, FERPA, CMIA, and the Information Practices Act.
The former subdivision (c) requiring the department to establish memoranda of understanding for data sharing with eight specific entities (Department of Rehabilitation, Child Support Services, Housing and Community Development, EDD, Student Aid Commission, Chancellor of California Community Colleges, Office of the Surgeon General, and California State Library) is entirely removed.
Data collection is replaced with a narrower data ingestion mandate limited to nine specified administrative systems: Credentialing Automation System for Education, California Statewide Assignment Accountability System, Accreditation Data System, California Longitudinal Pupil Achievement Data System, Migrant Student Information Network, After School Support and Information System, California Preschool Data Collection System, Child Development Management Information System, and Preschool Language Information System.
The finding that the system will connect early childhood data directly to the California Cradle-to-Career Data System is softened to state that data may be used in the future to support that system through subsequent legislation.
A two-phase data ingestion process is established. Phase 1 uses personally identifiable information only for initial record linking in a highly secure environment under a separation principle (PII kept separate from service information). Phase 2 strips identifying information after probabilistic matching, leaving only an encrypted linkage key and source record identifiers pushed to a separate analytic environment.
All data made available for analysis must be deidentified and presented as summary data or in the aggregate (rates, percentages, averages). Personally identifiable information may not be analyzed or used for any purpose other than the linking described in Phase 1.
A new provision states that the section shall not be construed as requiring state entities to collect new data; instead, entities are urged to furnish existing data to answer specific questions about early learning and care experiences, workforce, and needs.
Memoranda of understanding are replaced with data-sharing agreements that must capture shared intent, data-sharing purposes, specifications, and methodologies meeting all applicable state and federal privacy laws. A new requirement states that only reviewed and approved uses of data by the originating state entity shall be allowed.
A new requirement (E)(vi) mandates that the data system be developed in a manner that complies with all applicable privacy laws.
The annual legislative report is expanded to require specific recommendations for ongoing community interest-holder engagement and recommendations regarding the permanent governance structure, including sustained oversight, data privacy protections, and technical evolution of the system.
The stakeholder engagement plan is renamed an interest-holder engagement plan and must now outline a process to consider and respond to public input. The task force's data sharing facilitation role is expanded from two purposes to three, adding enabling ongoing evaluation for accountability and transparency.
