The Council on Governmental Relations (COGR), representing 200 U.S. research universities and institutes, submitted detailed comments to the National Science Foundation (NSF) regarding the proposed NSF-77 Data Analytics Application Suite, as outlined in the NSF’s recent System of Records Notice (SORN) under the Privacy Act of 1974. COGR acknowledges the importance of balancing federal interests in research integrity and security while minimizing administrative burdens on the research community. While recognizing the potential benefits of efficient data analytics like NSF-77, COGR raises significant concerns about the SORN's vagueness and lack of transparency, particularly regarding the tool’s purposes, data sources, guidelines for use, individual access and amendment mechanisms, and compliance with specific Privacy Act requirements.
COGR’s primary critique is that the NSF SORN does not adequately inform affected individuals about how their data will be used, shared, or corrected, failing both the spirit and letter of the Privacy Act. Specific issues include insufficient justification for using third-party data sources rather than collecting information directly from individuals, lack of detail on how data quality and relevance will be assured, and overly broad language regarding the sharing and usage of collected data. Moreover, COGR finds the mechanisms provided for individuals to access or amend their records to be unacceptably slow and burdensome, especially given the possible professional consequences of erroneous information. The Council recommends increased transparency around the "rules of the road" governing NSF-77 operations, proactive researcher access to their data prior to proposal submission, and limiting retroactive data reviews to align with evolving disclosure requirements. In sum, COGR urges NSF to revise its SORN to incorporate greater clarity, opportunity for public comment, and practical procedures that both uphold privacy protections and support the essential open nature of scientific collaboration.
This letter provides comments regarding to NSF concerning its Privacy Act notice of a new system of records that describes the use of a data analytics tool to analyze information collected from researcher disclosures.
