Maintaining Confidentiality of Data and Clearing Release of Research Output

• Absolutely no data and/or research results may leave the facilities without being examined and approved by the CES Disclosure Officer or a designated RDC Administrator.  This applies especially to confidential information on individuals, households, establishments, and firms – including microdata; sensitive identifiers such as names and addresses; and the presence or absence of an establishment, firm, household, or individual person in a survey.
• CES releases approved research output only electronically; we do not release output in paper form.
• Handwritten notes may not be removed from the RDC. Handwritten notes should be treated as confidential materials.  If you want notes released, type them up and request disclosure review. Do not put undisclosed results (from memory) into any email, even to Census Bureau employees and even if you think they would pass disclosure review.
• You must not discuss individual respondents or specific results that have not been cleared — in your research papers; via email, phone, or fax; or in casual conversation — with persons outside Census Bureau facilities.  This includes discussion with other project researchers with Special Sworn Status when you are not in a secure Census Bureau facility (e.g., inside the RDC). Qualitative discussions are allowed under certain conditions.  For more about these conditions, talk to your RDC Administrator and review the Researcher Handbook.
• Even revealing that an entity is in the data is a disclosure. In IRS terms, this is revealing the fact-of-filing.
• The Census Bureau considers it important not only to avoid disclosure of confidential information, but also to avoid the perception of disclosure.  If respondents perceive that their confidential data is being or will be disclosed, they will be less likely to participate in Census Bureau data collections, whether or not there is any actual disclosure.
• The parameters in certain disclosure rules themselves are confidential.  Revealing these rules is considered a disclosure and violators will be dealt with accordingly.  This policy is explained in the section, “Disclosure Analysis” of the Researcher Handbook.

It is your responsibility to protect the data:

• You must meet with the RDC administrator at the beginning of your project to discuss confidentiality and security policies and procedures.
• Use data only as authorized, only for project-related purposes. Confidential Census data may be used only for purposes authorized by the U.S. Census Bureau, and IRS data may be used only for purposes authorized by the Internal Revenue Code. Casual browsing of confidential data is illegal. For more detail about protecting IRS data, see Title 26, Appendix B, U.S. Code.
• Keep the RDC secure at all at all times.
  • • Make sure the door is secured whenever you leave.
    • Store confidential data in a secure, enclosed cabinet when not in use.
    • Ensure that listings and computer screens with confidential data are never visible to visitors or other non-authorized users.
    • Close your thin client session when you leave.
• Dispose of all confidential data properly.  Shred or lock up project-related materials when you are not using them.
• All RDC printers are configured to place the following watermark on all printouts:  “Disclosure Prohibited – Title 13 U.S.C. and Title 26 U.S.C.”  If the label or watermark does not appear, please report this to your RDC Administrator immediately.
• The creation of any printout with FTI must be recorded in one of the CES FTI Printout and Disposal Logs.  Ask your RDC administrator where the log is located.  The destruction (shredding) of any printout with FTI must also be logged.  NOTE: only printouts with actual FTI need to be recorded in the logs.  FTI printouts that need to be logged are those printouts for economic and SSA projects only that would not pass disclosure (even if you do not submit it for disclosure).  If you are in doubt, log it.
• Results must fall within the scope of the approved project.  CES will not release results that are determined to be outside the scope of the approved project topic.  If your research idea has changed or you have a new research idea, contact your RDC Administrator to discuss whether or not the new research falls within the scope of the approved project.
• The release of “intermediate output” (i.e., output that you know will not appear in a publication) is STRONGLY DISCOURAGED.  Producing intermediate output for examination inside the RDC is not problematic – removing it, however, can be.  Since intermediate output often consists of detailed tables of preliminary descriptive statistics, or large numbers of similarly specified regression models, often based on ‘thin’ samples, releasing this type of output can increase disclosure risk for several reasons.  For example, releasing similar tables based on changing samples (adding or dropping small numbers of observations) causes complementary disclosure problems, since comparison of the released data tables may reveal information on who is in the sample as well as their characteristics.
• CES requires projects to emphasize model output rather than tabular output.  Tabular output typically consists of small one- or two-dimensional tables of variables that describe the samples that appear in the models.  CES will not approve removal of large tabulations that were not explicitly described in the approved proposal.  Moreover, review of large amounts of tabular output requires significant resources on the part of Census Bureau staff and will be sent to the Disclosure Review Board for review.
• You must provide the appropriate documentation and prepare files as described in the section “Preparing Files for Disclosure Avoidance Review”.  Inappropriately documented or formatted requests will simply be NOT APPROVED, and another request will need to be submitted.
• It takes time to conduct disclosure analysis, and you must account for this in your project planning.  CES will not make rushed clearance decisions for events such as conference deadlines or the end of a project.  Inform your RDC Administrator as soon as you know you will need release of research output, and the approximate date you will need the output.
  • Plan to meet, as early as possible, with your RDC Administrator and/or the reviewer of your clearance request. This will minimize learning time on both sides, avoid costly misunderstandings, and speed approval of your clearance requests.
  • For a typical release of output, we recommend allowing for 3 weeks from the date of submission to receipt of the final cleared file(s) – this includes NCHS and AHRQ review of output.  Properly documented and formatted files can help to minimize the agency review time.
  • For a typical release of programs or research notes, we recommend allowing for 3 business days for receipt of cleared program files. Please see the section, “Clearing Other Files – Programs and Research Notes” for more information about having these files released.
  • Review times can be longer in certain cases; e.g., if the output has to go to the Census Bureau’s Disclosure Review Board (DRB) or if there is a large amount of output being requested.
• You must use a standard disclaimer on all research papers and reports that indicates that your views/results do not represent the opinions or views of the Census Bureau.  Your research products are not considered official Census Bureau data products since they do not undergo an official Census Bureau review to ensure that they meet certain Bureau standards.  The disclaimer may be modified to fit the number of authors and to include disclaimer information regarding other organizations. Please check with your RDC Administrator to see if there are any RDC specific acknowledgements that should be included.  The disclaimer follows:

Researcher_Handbook – Chapter 3 offers a detailed description of the disclosure review process and requirements.  All researchers must read this prior to requesting the release of output.

Federal Committee on Statistical Methodology– This site contains information on FCSM activities, and links to information on confidentiality and disclosure analysis, including conferences and working groups.

American Statistical Association Committee on Privacy and Confidentiality– This site contains information on committee activities, and links to information on confidentiality and disclosure analysis, including conferences and working groups.