; (bb) include transfer flags and course and credit data to allow the State to run initial degree audits for institutions; (cc) include all postsecondary educational institutions in the State, including public, private nonprofit, and private for-profit institutions; and (dd) have in place mechanisms to share data across institutions, systems, and States; (II) the capacity of the agency governing the State's longitudinal system to respond to data requests accurately and in a timely manner; and (III) the State's plan to protect student privacy with respect to data in the State longitudinal data system and comply with section 444 of the General Education Provisions Act (commonly referred to as the Family Educational Rights and Privacy Act of 1974 ); or (ii) the State's plan to develop such administrative capacity as part of the activities carried out under the grant. (d) Award basis and priority The Secretary shall award grants under this section to States based on the quality of the applications submitted under subsection (c). In awarding grants under this section, the Secretary shall give priority to applications from States— (1) that do not have, as of the time of the application, statewide policies or statewide initiatives in place to retroactively award associate's degrees to students