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Minimize Paperwork Burden and Protect Privacy

A priority of CDC is ensuring the information collection burden is minimized when questionnaires, surveys, interviews, reports, and other data collections are requested of the public. There also is a commitment to the quality, practical utility, and public health importance of any data collected through a CDC sponsored activity. The Office of Management and Budget (OMB) review and approval process as required by the Paperwork Reduction Act (PRA) further ensures that CDC adheres to this commitment.

Office of Management and Budget Paperwork Reduction Act Clearance

OMB PRA clearance is required to conduct federally sponsored data collections. The Paperwork Reduction Act (44 U.S.C. 3501 et seq.) of 1995 grants authority to OMB to review and approve federally sponsored data collections involving ten (10) or more respondents. The implementing regulations for the PRA can be found in 5 CFR 1320. The purpose of the Paperwork Reduction Act is to ensure that the federal government is not duplicative in paperwork requests made to the public and that the paperwork is necessary to government business.

In order for CDC programs to conduct data collections, a request to do so must be submitted to OMB. The request consists of a statement explaining the purpose, use, the burden to the respondent completing the questionnaire, form, survey, etc., and statistical validity of the data collection; a copy of the law and/or statutes which authorizes the data collection; and all data collection instruments. Documents such as consent forms, letters, and telephone scripts are also included in the request to OMB.

In addition, those outside of CDC must be given the opportunity to provide input on the planned data collection prior to submitting the request for OMB PRA clearance. To solicit this input, a 60-day Federal Register Notice (FRN) is published to give the general public the opportunity to comment. The comments must be considered and noted in the OMB PRA request for clearance.

A second notice is published in the Federal Register to notify the public that the request for OMB PRA clearance had been officially submitted.

Once a planned data collection has received OMB PRA clearance, the project may begin. CDC must monitor the burden hours to ensure they are properly utilized, not exceeded, and that any underusage is reported during the data collection portion of the project. A summary of this information across the agency is submitted by CDC to OMB in the annual Information Collection Budget report.

Any changes to the project (e.g., to the data collection instrument, to the number or type of respondents, to the burden hours or methods) must be reported and all changes must be approved by OMB before they can be implemented.

Privacy Protection

The Privacy Act (5 U.S.C. 552a) is a federal law that protects the privacy of individually identifiable information when records are maintained by a federal agency in a system of records. It is the policy of CDC to safeguard the privacy of individuals to the fullest extent possible while at the same time permitting disclosure of records necessary to fulfill the mission of CDC and to provide simplicity and ease for individuals who seek notification and access to personally identifiable record systems as granted by the Act.

For CDC sponsored data collections that require OMB PRA clearance, a Privacy Act review must be done as part of the request for OMB PRA clearance.

The request is reviewed to assess whether personal data is being collected that will be retrieved by the name of the individual or by a unique identifying number or characteristic. Consent documents and introductory advisements are also reviewed to determine whether the Privacy Act requirements are met. The requirements include: informing respondent as to authority for data collection, ensuring participation is voluntary, explaining effects of non-participation, and describing with whom identifiable data will be shared.

In addition, Section 208 of the E-Government Act of 2002 requires that a Privacy Impact Assessment (PIA) be done on all identifiable data collections. This includes when initiating, consistent with the PRA, a new electronic collection of information for 10 or more persons (excluding federal government employees being asked work related questions) that is collected by electronic means or analyzed, stored or managed in an electronic system. This information must be included in every request for OMB PRA clearance.

Frequently Asked Questions

HHS Information Collection / Paperwork Reduction Act Website

CDC/ATSDR Privacy Act System Notices – Systems of Records Notices (SORNs)

Page last reviewed: June 23, 2008
Page last modified: April 1, 2008
Content source: Office of the Chief Science Officer (OCSO)