PRINCIPLE 3

Trust Among the Public and Data Providers

Federal statistical agencies must have the trust of those whose information they obtain.

NEARLY every day of the year, individuals, household members, businesses, state and local governments, and other organizations provide information about themselves when requested by federal statistical agencies. Without the cooperation of these data providers, federal statistical agencies could produce very little useful statistical information.

Some information provided is required by law or regulation for government tax and transfer programs, such as reports of employers’ wages to state employment security agencies or payments to program beneficiaries. A small number of federal statistical surveys are so important that participation is mandatory. But most of the data come from the voluntary cooperation of respondents. In all cases, the willing cooperation of data providers reduces costs and likely promotes accuracy (see National Academies of Sciences, Engineering, and Medicine [NASEM, 2016b; National Research Council [NRC], 1995b, 2004a).

Because virtually every person, household, business, state or local government, and organization is the subject of some federal statistics, public trust is essential for the continued effectiveness of federal statistical agencies. Individuals and entities providing data directly or indirectly to federal statistical agencies must trust that the agencies will appropriately handle and protect their information. Implicitly and explicitly, they expect the following:

• the agency’s computer systems will not be hacked and their information taken;

• their information will not be accessed and used by others for nonstatistical purposes;
• the statistical agency has a legitimate need for each piece of information it is requesting;
• the statistical agency will use their information for creating useful statistics;
• the statistical agency will not release or publish their information in identifiable form;
• the statistical agency will control who is allowed to see and access their information; and
• the statistical agency will evaluate and update its systems for using and protecting data providers’ information to take account of new information needs and new threats to privacy.

Federal statistical agencies not only have legal and ethical obligations that require them to fulfill these expectations, they also have the obligation to effectively communicate how they fulfill them. Consistent ethical conduct on the part of a statistical agency is critical for obtaining the trust of the general public and of data providers, whether those providers are individuals, organizational entities, or custodians of administrative records. Statistical agencies should coordinate and collaborate with each other to ensure that their communications and internal practices are clear and consistent to strengthen the trust of data providers who may interact with more than one agency (see Practice 7).

Data providers must trust that the information the agency seeks is important for the government to collect and is being collected in a competent manner, for the good of the larger society, and only for the purposes that the agency has described. To engender trust, a statistical agency should also respect the privacy of data providers in other ways and ensure that each individual’s consent to respond to a survey is given knowingly and with full information. Agencies should describe the intended and likely future uses of the data being collected, the data’s relevance for important public purposes, and the extent of confidentiality protection that will be provided. Agencies should minimize the intrusiveness of questions and the effort needed to respond to them, and they should seek administrative or other nonsurvey sources to fulfill needs consistent with each agency’s requirements for information (see Practices 5 and 8).

Trust among data providers also requires that an agency treat respondents with courtesy in appreciation for their time (see NASEM, 2016b).

The mission of federal statistical agencies is to produce statistical information that aggregates the data provided by individuals, businesses, or other entities. These agencies pledge to use the information they collect only for statistical purposes, not to provide individual records for any administrative, regulatory, or judicial use, and to make every effort to protect the confidentiality of individual information in the data they make available for public use. This pledge is supported by many statistical agencies’ individual statutes as well as the Confidential Information Protection and Statistical Efficiency Act (CIPSEA) of 2018 (see Appendix A).

Data providers must be able to trust that a statistical agency will scrupulously honor its pledge of confidentiality and will fulfill the expectations noted above. Earning this trust, however, goes beyond what the agency is simply required to do by law, and recognizes that there are many potential threats, some outside the control of the statistical agency, that the agency must anticipate and guard against. In the world of “big data,” agencies must guard against the use of external data to re-identify information provided by individuals. Agencies must consistently innovate in privacy-protecting technologies to protect—to the extent possible—against re-identification of individual records in statistical data products (see NASEM, 2017b, 2017d; and Practice 8).

When data are obtained from the administrative records of other federal, state, or local government agencies or other third-party providers, the same requirements of trust building apply to justify their cooperation.³ Provider organizations need to trust that their records are important and legitimate for a statistical agency to obtain, that their own restrictions on data access will be honored, and that the statistical agency will make every effort to minimize their burden in responding.

An effective statistical agency has policies and practices to instill the highest possible commitment to professional ethics among its staff and builds a culture of confidentiality of its data. When issues arise or

___________________

³ See OMB Memorandum M-14-06 in Appendix A, which asserts the legitimacy and benefits of use of administrative data from other federal agencies for statistical agency purposes. It also provides guidance for best practices and procedures to engender mutual respect and trust and facilitate such data sharing.

guidance is unclear, it must be able to rely on its staff to keep this culture and resist unethical actions as contrary to the ethical principles of their profession and the ethical requirements for their agency to merit public trust (see Practices 3 and 4).

Practices That Are Particularly Relevant for Principle 3