Section I. Procedures for Ensuring and Maximizing the Quality, Objectivity, Utility and Integrity of Information Prior to Dissemination
OPM will maximize 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 under the circumstances, and second by subjecting draft materials to a review process involving as many OPM program offices as may be in a position to offer constructive input, as well as other offices within other Federal agencies.
In the OMB Governmentwide Guidelines, "quality" is defined as an encompassing term comprising utility, objectivity and integrity.
Objectivity and Utility of Information
As defined in Section IV below, "objectivity" is a measure of whether disseminated information is "accurate, clear, complete and unbiased;" "utility" refers to the usefulness of the information to its intended audience. OPM is committed to disseminating reliable and useful information. Before disseminating information, OPM staff will subject such draft information to a review process. It is the primary responsibility of the OPM program office drafting information intended for dissemination to pursue the most knowledgeable and reliable sources reasonably available to confirm the objectivity and utility such information.
Much of the information OPM disseminates consists of or is
based on information submitted to OPM by other Federal
agencies. OPM expects that these agencies will subject
information submitted to OPM to adequate quality control
measures. In drafting the material to be disseminated, the
program office will review and verify the data submitted by
the agencies, as necessary and appropriate.
In seeking to assure the "objectivity" and
"utility" of the information it disseminates, OPM
will follow a basic clearance process coordinated by the
program offices drafting information intended for dissemination.
The quality control process places responsibility for action upon
the program offices. The program offices will consult with all
other program offices throughout OPM having substantial interest
or expertise in the material proposed to be disseminated. Where
appropriate, substantive input will be sought from other Government
agencies, non-government organizations and the public.
The program office will consider the uses of the information from
both the perspective of OPM and the public. When it is determined
that the transparency of information is relevant for assessing the
information's usefulness from the public's perspective, the program
office will ensure that transparency is appropriately addressed.
When the program office determines that the information it will
disseminate is influential scientific, financial or statistical
information, extra care will be taken to include a high degree of
transparency about data and methods to meet the OMB Governmentwide
Guidelines' requirement for the reproducibility of such information.
In determining the appropriate level of transparency, the program
office will consider the types of data that can practicably be subjected
to a reproducibility requirement given ethical, feasibility, and
confidentiality constraints. OPM will assure reproducibility for
those kinds of original and supporting data according to commonly
accepted scientific, financial, or statistical standards. In making
these determinations, the program office will apply especially rigorous
robustness checks to hold analytical results to an even higher standard
than original data and document what checks have been undertaken.
The program office responsible for the dissemination of information
will consider steps such as the following to assure the "objectivity"
and "utility" of the information to be disseminated:
Preparing a draft of the document after consulting the necessary parties, including Government and non-government sources, as appropriate;
Determining necessary internal and external clearance points;
Determining where the decision to disseminate the information shall be made;
Determining whether peer review would be appropriate, and if necessary, coordinating such review; and
Hard-copy public dissemination of information and all information published on OPM’s website shall occur only after clearances are obtained from all appropriate program offices, and as appropriate, the Office of the Director.
The quality control procedures followed by OPM will vary with the nature of the information and the manner of its distribution.
These 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 (covering information that OPM has disseminated elsewhere), among others, are not included.
Integrity of Information
"Integrity" refers to the security of information, protection of the information from unauthorized, unanticipated or unintentional modification, to prevent information from being compromised through corruption or falsification.
Computer security is the responsibility of the Chief Information Officer. The Office of the Chief Information Officer (OCIO) oversees matters relating to information integrity, including the design and implementation of the security architecture for OPM, periodic audits of security architecture components and review and approval of changes to the technical baseline. OPM's Information Technology (IT) Security Policy, procedures and controls are risk-based, cost-effective and incorporated into the lifecycle planning of every IT investment. Additionally, OCIO and program offices assess risks to systems and implement appropriate security controls; review annually the security of systems; and develop plans to remediate all security weaknesses found in independent evaluations and other security audits and reviews, such as integrity issues.
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