U.S. Department of State Information Quality Guidelines

Information Quality Guidelines

October 2002
Released by the Office of the Legal Adviser

These guidelines are based upon and implement Office of Management and Budget (OMB) Final Guidelines issued on February 22, 2002 (67 FR 8451-8460). The OMB guidelines were issued pursuant to Section 515 of the Treasury and General Government Appropriations Act for FY 2001 (Public Law 106-554; HR 5658). In response to the legislation and OMB Guidelines, the Department identifies the following policies and procedures for ensuring and maximizing the quality, objectivity, utility, and integrity of information disseminated by the Department; and it hereby establishes additional procedures for affected persons to seek and obtain correction of information maintained and disseminated by the Department within the United States that does not comply with standards set out in the OMB guidelines and these guidelines. These guidelines represent Department goals, policies or procedures; they have no legal effect and do not create any legal rights or obligations.

I. Procedures for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Prior to Dissemination

The OMB guidelines define "quality" as an encompassing term comprising utility, objectivity, and integrity. The standards of utility and objectivity relate to the preparation of materials for dissemination and are therefore grouped together, while "integrity" refers to the protection of information and is treated separately below. The Department will promote the dissemination of information that meets the standards of quality, utility, objectivity and integrity set forth in these guidelines and will incorporate information quality criteria into information dissemination practices.

Objectivity and Utility of Information

2. Many of the Department’s policies and procedures are set out in the Foreign Affairs Manual (FAM) and the Foreign Affairs Handbook (FAH), as well as other forms of internal Department guidance. The quality control procedures followed by the Department vary with the nature of the information and the manner of its distribution. While the Department has detailed procedures applicable to official statements by Department personnel and agents to non-U.S. Government audiences, the following guidelines focus on procedures for the "dissemination" of "information," as those terms are defined herein. Accordingly, procedures specifically applicable to forms of communication outside the scope of these guidelines, such as those for correspondence or press releases, among others, are not included.

3. The Department’s quality control system for information dissemination is based generally on the "action" and "clearance" processes, by which the Department makes certain decisions, including decisions on the content and manner of the Department’s information dissemination. These processes place responsibility for action upon an action office, while ensuring that the information and opinions of other offices are brought to bear on the proposed action. The action office is encouraged to consult widely on proposed disseminations of information, with all offices having a substantial interest in the proposed action being given a right of clearance. Where appropriate, substantive input also is sought from other U.S. Government agencies, foreign governments, non-government organizations, and the public.

4. Responsibility for an "action" relating to the dissemination of information begins with an "action office," which assigns an "action officer," typically the principal drafter. Normally, the action officer consults informally with officers in other interested offices before preparing information for dissemination.

5. The action officer’s role includes:

a. Preparing an action document after consulting the necessary materials and people, including government and non-government sources, as appropriate;

b. Determining clearance points;

c. Making the initial determination as to where the final decision shall be made;

d. Obtaining clearances; and

e. Overcoming delays and, if necessary, presenting the matter to higher authority.

6. Clearances on information for dissemination generally are obtained from any office within the Department or any other agency within the U.S. Government that has a substantive interest in the information. If an office designated for clearance disagrees with information drafted for dissemination and differences cannot be resolved at that level, then the matter is raised to a higher level Department official.

7. In addition to the formal requirement for clearances by offices with substantial interests at stake, action officers may also seek advice from other offices having a collateral interest in the subject matter. For example, an office that has useful information or views to contribute, but whose field of responsibility is not vitally affected by the proposed action, may be consulted on information proposed for dissemination, even where it need not clear the draft.

8. Where there are significant differences in views within the Department concerning a proposed information dissemination, those differences would be discussed and may be documented and explained, and offices asked to clear the document. After reasonable efforts have been made to resolve substantive differences, superior officers are informed of the dissenting views and make the necessary decisions.

9. While the "action" and "clearance" processes are general requirements for a range of information dissemination actions, there are specific procedures for certain categories of information dissemination. For example, the Assistant Secretary of the Bureau of Public Affairs is responsible for approving official public remarks and testimony by Assistant Secretaries as well as statements prepared for Department personnel making official appearances before the media or general public to give formal interviews, speeches, or remarks. The same requirement applies to unofficial speaking, writing, or teaching activities that are of official concern. Department statements, speeches released to the press, and media interviews also are cleared by the Bureau of Public Affairs. Where Department personnel speak or write unofficially on topics of official interest, the Department of Public Affairs reviews any prepared materials and requires the presenter to clearly represent that the views are personal to the presenter and not necessarily those of the Department.

10. The Bureau of Public Affairs also approves journals, magazines, periodicals, books, pamphlets, leaflets, and similar substantive hard-copy publications of the Department, as well as all information published on the Department’s website, after clearances are obtained from other appropriate Department offices.

11. The Department also controls the quality of disseminated information through limits on who may speak on behalf of the Department. For example, comments to the press may be made only by the Secretary, an Under Secretary, the Assistant Secretary for Public Affairs/Department Spokesman or Deputy Spokesman, authorized personnel of the Office of Press Relations, or other Department officials cleared to deliver such statements by the Bureau of Public Affairs. Even within this constraint, Department officials need clearance from Public Affairs for official public appearances.

12. Conclusion: The Department maximizes the quality of the information it disseminates, in terms of objectivity and utility, first by looking for input from a range of sources and perspectives, to the extent practicable, and second by subjecting draft materials to a review process involving as many Department offices as may be in a position to offer constructive input, and other USG agencies as appropriate. Where the Department intends to disseminate influential scientific, financial or statistical information, clearance is first obtained from the agency or agencies of the U.S. Government primarily responsible for developing such information.

Often, the Department disseminates reports or other statements based on observations and analysis of activities of foreign governments and current events. In preparing such documentation, the Department utilizes input from multiple sources, such as: foreign governments, non-governmental organizations and public comment; and the Department attempts to corroborate all information received. In instances where statements cannot be corroborated adequately, those statements are accompanied by attribution to the source, wherever practicable, to assist the reader in assessing their credibility. Where the Department disseminates conclusions concerning foreign governments or other international actors or current conditions in foreign countries, effort is made to identify the facts or events upon which the conclusions are based, to the extent appropriate.

B. Integrity of Information

1. "Integrity" refers to the security of information--protection of the information from unauthorized access or revision--to prevent information from being compromised through corruption or falsification.

2. Within the Department, the Chief Information Officer (CIO) has Department-wide oversight responsibility for the integrity of information. That role includes developing and maintaining an information security program promoting effective implementation and maintenance of information security policies, procedures, and control techniques throughout the Department, as well as training, overseeing and assisting Department personnel with significant information security related responsibilities. Under the CIO, the Bureau of Information Resource Management (IRM) develops, implements, and maintains new computer software and hardware systems and provides operational support for systems and system users.

3. Under the oversight of, and assisted by, the CIO, senior Department officials (for each Bureau, at the level of the Office of Assistant Secretary) are primarily responsible and accountable for the integrity of information within their bureaus. On a day-to-day basis, the responsibilities are carried out by the managers of networks, systems and applications. These technical personnel assess and manage the information security risks associated with the operations and assets for programs and systems within their control. In that capacity, the technical personnel determine the levels of information security appropriate to protect such operations and assets and periodically test and evaluate information security controls and techniques.

4. Computer security is a shared responsibility of the Chief Information Officer (CIO) and Diplomatic Security, with the CIO being the senior officer with ultimate responsibility for approving all new policies. The CIO generally oversees security operations related to the Department-wide information resources management and systems; whereas, Diplomatic security typically is more focused on developing information security policies. However, both of the Bureaus, Information Resource Management and Diplomatic Security, engage in policy development and planning.

Section II. Requests for Correction of Information Publicly Disseminated by the Department of State

The Department works continuously to be responsive to users of its information and to improve Department information products. The public is welcome at any time to contact the Department with comments, questions or other concerns by calling (202) 647-6575 or send email through the Department’s website at http://contact-us.state.gov, which includes links to the main web site at http://state.gov and topical subsections.

For questions about individual passports, relevant information is available through the Department web site at: http://travel.state.gov/passport_services.html or by telephone at 1-900-225-5674 (TDD: 1-900-225-7778) (a toll call) or 1-888-362-8668 (TDD 1-888-498-3648) (a flat fee will be charged) or by writing to: Bureau of Consular Affairs Passport Services, Rm. 6811, Washington, D.C. 20520. For visa questions, contact the Department by e-mail at usvisa@state.gov or see the Department’s web site for information for foreign nationals visiting or emigrating to the United States or for U.S. citizens seeking visas to travel abroad. Foreign nationals needing information about visiting or immigrating to the United States should contact: Public Inquiries, Visa Services, U.S. Department of State, Washington, DC 20522-0106; Tel: 202-663-1225.

In some cases, a bureau may disseminate a study, analysis, or other information in connection with the issuance of a notice of proposed rulemaking or other action that involves well-established procedures for obtaining, considering, and responding to comments from the public. In most cases, comments concerning the quality of the disseminated information can be addressed through these procedures, such as by responding to a request for correction of the information in the preamble to a final rule. However, in unusual circumstances, it would be appropriate for a bureau to address and respond to such comments pursuant to these guidelines before issuing the final rule. For example, the procedures of these guidelines should be used if the commenter has shown a reasonable likelihood of suffering actual harm if the comment is not resolved before the issuance of the final action and the bureau determines that resolving the matter pursuant to these guidelines will not unduly delay the final action.

The procedures set forth below do not affect any of the above options or other existing procedures for questions, concerns and public comments directed to the Department. The following "information quality" procedures are available for "affected" persons who seek to correct information publicly disseminated by the Department. The procedures apply to information disseminated by the Department on or after October 1, 2002, even if the original dissemination occurred prior to that date:

1. Persons seeking to utilize procedures available under the statute and these guidelines to correct information affecting them that was publicly disseminated by the Department should complete the Data Quality Act form at http://dataquality.state.gov/.

3. These guidelines apply only to requests submitted in the form of a Request for Correction of Public Information or other requests prepared and submitted in accordance with these guidelines that explicitly reference these guidelines and generally include the essential information identified in the Request for Correction. With respect to any such request, the Department may decide not to apply these guidelines if the Department determines:

(a) it is not submitted by an affected person, as that term is defined in these guidelines;

(b) it does not involve the correction of publicly disseminated information of the Department of State, as those terms are defined in these guidelines;

(c) the information requested in the Request for the Correction of Public Information has not been provided in sufficient detail to determine the problem, or;

(d) application of the guidelines would not advance material interests of the requester, the general public, or the Department.

4. If the Department determines that a request is not covered by these guidelines, then it may so advise the requester and/or it may respond to the requester consistent with standard Department procedures for public comments, which vary depending upon the form and substance of the communication.

5. For requests processed under these guidelines, the office reviewing the request will give the request due consideration, including a review of the disseminated information at issue and other materials, as appropriate. Where the reviewing office determines that the information publicly disseminated by the Department was incorrect and a response appropriate, in light of these guidelines, it may consider corrective measures, as appropriate, recognizing the potential implications for the requester, the United States, and the Department, without disrupting agency processes.

6. In determining whether a response to a request for correction is appropriate, the reviewing office may take the following factors into consideration:

(a) Whether the statements challenged by the requester fall within the scope of "information" that has been "disseminated" by the Department, as those terms are defined in these guidelines;

(b) Whether the requester is "affected" by the information at issue, as that term is defined in these guidelines;

(c) Whether the requester has provided the information requested on the Request For The Correction of Publicly Disseminated Information;

(d) The timeliness and importance of the information involved; and

(e) The nature and extent of the request and the public benefit of making the requested correction.

Where the Department determines that a response under these guidelines is not appropriate, it may so advise the requester and/or it may respond to the requester consistent with standard Department procedures for public comments, which vary depending upon the form and substance of the communication.

7. In most cases, where response under these guidelines is appropriate, the Department aims to respond within sixty (60) days of receipt of the request. The requester should be notified if additional time is required, the reasons why the additional time is needed and the estimated time to complete. Department responses will describe the disposition of the request, including any corrective action taken or pending.

8. Subject to applicable law, rules and regulations, corrective measures may include, without limitation, personal contacts via letter or telephone, form letters, press releases or postings on the Department website to correct a widely disseminated error or address a frequently raised request. Corrective measures, where appropriate, should be designed to provide reasonable notice to affected persons of any corrections made.

Section III. Procedures for Requesting Reconsideration

1. The following procedures are available to an affected person who has filed a Request for Correction of Public Information in accordance with Section II, above; who received notice from the Data Quality Coordinator of the disposition of the request; and who believes that the Department did not take appropriate corrective action. Requests determined by the Department to fall outside of the guidelines (see Section II, paragraph 4, above) and requests determined not to be appropriate for response under these guidelines (see Section II, paragraph 7, above) may not be reconsidered under these provisions. These procedures apply to information disseminated by the Department on or after October 1, 2002 even if the original dissemination occurred prior to that date.

2. To request reconsideration, a copy of the previously submitted Request for the Correction of Public Information must be resubmitted, with Section IV "Requests for Reconsideration" completed. Resubmission should be made to the Data Quality Coordinator by e-mail, fax or mail using the contact information in Section II, paragraph 1, above. Requests for Reconsideration must be submitted within thirty (30) days of the date of the Department’s notification to the requester of disposition of the underlying request for correction.

3. Requests for reconsideration, for which these procedures are available, in accordance with paragraph 1 of this Section, will be forwarded to the appropriate Office of the Assistant Secretary, generally within the Bureau responsible for the disseminated information.

4. The Office of the Assistant Secretary may delegate to any Deputy Assistant Secretary (DAS), including an Acting DAS, or to another person of equivalent or higher rank, responsibility for responding to a request for reconsideration; provided that the designee did not decide the underlying request for correction. Where such a delegation is made, the designee will assume all responsibilities of the Office of the Assistant Secretary set out in these guidelines.

5. The Office of the Assistant Secretary or designee receiving the request for reconsideration should apply the same standards and procedures applicable to requests for correction, as set out in Section II, above.

6. In most cases, where a response is appropriate, the Department aims to issue decisions on requests for reconsideration within sixty (60) days of receipt of the request. The requester will be notified if additional time is required to resolve the request, the reason the time is needed and the estimated time of completion. The requester will be informed by the Data Quality Coordinator of the disposition of the request, including any action taken or pending. The Department will give reasonable notice allowing affected persons to learn of any corrections made.

Section IV. Definitions

1. "Affected" persons are those who may personally benefit or be harmed by the disseminated information, e.g., (a) persons seeking to address information about themselves or about other persons to whom they are directly related or publicly associated; and (b) persons that may reasonably be expected to experience significant adverse impact to their financial interests as a result of the information deficiency.

2. "Dissemination" means Department initiated or sponsored distribution of information within the United States to the general public (see 5 CFR 1320.3(d) "Conduct or Sponsor"). Dissemination does not include distributions of information or other materials that are:

(a) intended for government employees or agency contractors or grantees (for example: directories, staffing information, internal manuals; cables);

(b) intended for U.S. Government agencies;

(c) produced in responses to requests for agency records under the Freedom of Information Act, the Privacy Act, the Federal Advisory Committee Act or similar law;

(d) correspondence or other communication limited to individuals (examples include questions or concerns about individual passports, visas, adoptions, missing persons, applications for employment, or federal benefits) or to other persons, as defined in paragraph 7, below;

(e) distributed to the press as a summary of a recent event or Department action;

(f) archival records; public filings; responses to subpoenas or compulsory document productions; or

(g) intended to be limited to adjudicative processes. These guidelines do not impose any additional requirements on agencies during adjudicative proceedings and do not provide parties to such adjudicative proceedings any additional rights of challenge or appeal.

3. "Influential," when used in the phrase "influential scientific, financial, or statistical information," refers to a narrow category of information with respect to which an agency can reasonably determine that dissemination will have a clear and substantial impact on important public policies or important private sector decisions. To be considered influential, information must be based on objective and quantifiable data that constitute a principal basis for substantive policy positions adopted by the Department. Any influential information to be disseminated by the Department is reviewed for quality by the agency within the U.S. Government primarily responsible for developing such information. Where circumstances deem it appropriate, the Department supports including in disseminated information the identity of the U.S. Government agency or international organization originating any cited influential information.

4. "Information," for purposes of these guidelines, including the administrative mechanism described in Sections II and III, above, means any communication or representation of knowledge such as facts or data, in any medium or form, including textual, numerical, graphic, cartographic, narrative, or audiovisual forms. This definition does not include:

(a) statements of U.S. foreign policy, including official explanations of, positions on, and responses to, international events;

(b) statements reporting or interpreting actions of foreign governments and other international actors, including evaluations of foreign government compliance with international law, custom or practice or U.S. or international sanctions;

(c) statements, the modification of which might cause harm to the national security, including harm to the national defense or foreign relations of the United States;

(d) opinion or exercise of judgment, where the presentation makes clear that the statements are subjective, rather than facts or objective determinations by the Department; however, any underlying information published by the Department upon which the opinion or judgment is based may be subject to these guidelines. For example, recommendations on foreign travel constitute an exercise of judgment, rather than objective "information," and are not covered by these guidelines; however, facts alleged as the basis for the recommendations may be covered by these guidelines;

(e) information originated by, and attributed to, non-Department sources, provided the Department does not expressly rely upon it. Examples include: information originated by other U.S.G. agencies or non-U.S.G. sources and duly attributed in reports prepared and disseminated by the Department; hyperlinks on the Department’s website to information that others disseminate; and reports of advisory committees and international organizations published on a Department website;

(f) Foreign government information, including:

(1) statements provided to the United States Government by a foreign government or governments, an international organization of governments, or any element thereof;
(2) statements produced by the United States pursuant to, or as a result of, a joint arrangement with a foreign government or governments, or an international organization of governments, or any element thereof;

(g) materials covered by the United States Information and Educational Exchange Act of 1948 (the Smith-Mundt Act) 22 USC Sec. 1461-1a (Ban on domestic activities);

(h) statements related solely to the internal personnel rules and practices of the Department and other materials produced for Department employees, contractors, agents or alumni;

(i) descriptions of the agency, its responsibilities and its organizational components;

(j) testimony of Department officials before courts, administrative bodies, or Congress with respect to materials otherwise disseminated;

(k) investigatory material compiled pursuant to U.S. law or for law enforcement purposes in the United States or abroad; or

(l) statements which are, or which reasonably may be expected to become, the subject of litigation, whether before a U.S. or foreign court or in an international arbitral or other dispute resolution proceeding.

5. "Integrity" refers to the security of information -- protection of the information from unauthorized access or revision, to prevent the information from being compromised through corruption or falsification.

6. "Objectivity" denotes whether disseminated information is being presented in an accurate, clear, complete, and unbiased manner, including background information where warranted by the circumstances, and whether as a matter of substance, is accurate, reliable and unbiased.

7. "Person" means an individual, partnership, association, corporation, business trust, or legal representative, an organized group of individuals, a regional, national, State, territorial, tribal, or local government or branch thereof, or a political subdivision of a State, territory, tribal, or local government or a branch of a political subdivision, or an international organization;

8. "Quality" is an encompassing term comprising utility, objectivity, and integrity.

9. "Utility" refers to the usefulness of the information to its intended users, including the public.

2. Requests submitted to the Data Quality Coordinator as described above that are processed under these guidelines will be assigned a reference number and receipt will be acknowledged by the Data Quality Coordinator. Typically, requests raising substantive issues will be forwarded to the bureau within the Department responsible for the subject area.

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