An Introduction
to the Census Bureau’s
Privacy Impact Assessments (PIA)
An important function of the Federal government’s Executive Branch is collecting
information to administer programs authorized by the U.S. Congress. For the U.S. Census
Bureau, this means collecting high quality information, or data, to meet the nation’s
statistical needs as identified by Congress through its budgetary and policy decisions. Data
collection and associated activities that turn raw data into meaningful statistical information
are undertaken most efficiently through the use of information technology or, simply,
telecommunication and computer hardware and software. The Census Bureau honors the privacy
of America’s people and businesses by asking only what is needed to fulfill our mission
and protects the confidentiality of the information collected through state-of-the-art technology.
Title 13 U.S.C., a Federal law, provides strong confidentiality protections for all individual
information collected by the Census Bureau. The Census Bureau constantly pursues new procedures,
technologies and methodologies to safeguard individual data. Census Bureau employees are
explicitly prohibited by Title 13 from revealing confidential Census Bureau information for
any purpose. Violating this law is a Federal crime with serious penalties, including a prison
sentence of up to five years and a $250,000 fine.
The Census Bureau has created a gold standard of federal privacy and confidentiality programs
grounded in federal statute and professional ethical codes. Additionally, we continue to employ
the latest technology and techniques to bolster this protection. The Census Bureau is committed
to ensuring that public trust is priority number one in our every activity as the leading source
of quality statistics describing America’s people and our economy. In addition, the Census
Bureau scrutinizes all the data that we collect so that we only collect data that are necessary.
The E-Government Act of 2002 requires federal agencies to conduct PIAs when developing or
significantly modifying information technology (IT) systems or information collections.
Consistent with the objectives of the E-Government Act and to ensure the continued trust of
our constituency, the Census Bureau publicly releases the PIAs it prepares.
The Census Bureau PIAs are labeled as "Data Stewardship/Privacy Impact Assessments"
(DS/PIAs). At the Census Bureau, privacy, confidentiality, disclosure avoidance and security
are key components of data stewardship. The Census Bureau’s DS/PIAs bolster our data
stewardship program, as well as recently adopted Privacy Principles and a host of supporting
policies. These principles and policies help us carry out our mission to collect high quality
data and meet our legal requirements to ensure that individually identified data are kept
confidential and are not used to affect the rights, privileges, or benefits of the individuals
or businesses whose data contribute to products. These protections apply whether information
is obtained directly from an individual or a business, or from an administrative source.
The DS/PIAs offer the Census Bureau an opportunity to affirm that it is using its legal and
policy protections to ensure that, in fact, data are being collected and used in a manner
that emphasizes our commitment to honoring privacy and protecting confidentiality while
ensuring useful statistical data products for the nation. The Census Bureau embraces this
opportunity to examine each of its major programs.
Why do we conduct DS/PIAs?
The federal government has a long history of responding to public concern about the
information it collects and how it is handled as expressed in legislation such as the
Freedom of Information Act, the Privacy Act, and the Computer Matching Act. The most
recent federal law meant to prescribe ethical standards relating to the collection,
processing, and maintaining of identified data about respondents is the E-Government
Act of 2002 (Public Law 107-347, 44 U.S.C., Ch 36).
One purpose of the E-Government Act is to ensure that no collection, storage, access,
use, or dissemination of identifiable respondent information occurs that is not needed
or permitted. The Act applies to both identifiable data about both people and businesses.
The tool required by the Act to accomplish these ends is the PIA. PIAs are agency reviews
of how collected information is handled by the agency. The reviews are program analyses
that determine whether the data collected are protected in a manner consistent with
Federal standards for privacy and security.
While the E-Government Act speaks to information collection, the Executive Branch
concurrently developed its additional PIA requirements linked to responsibilities of
the Office of Management and Budget (OMB) for funding information technology. OMB
Circular A-11 and OMB Exhibit 300, "Capital Asset Plan and Business Case,"
require PIAs to be prepared for and approved by OMB for every new information
technology funding request.
How Do I read a DS/PIA?
For each program, the DS/PIA asks a series of questions about procedures and activities
as well as the application of current policy. Each question is related to one of the four
privacy principles. Risk points are assigned based on responses that reveal potential
privacy threats. Mitigation points are assigned based on responses that document the
application of current policies and procedures that are designed to reduce privacy
threats. An overall score indicates whether the program poses minimal, average, or
excessive risk after the mitigation activities are taken into account.
The first three sections of each of the 20 DS/PIAs are the same, and include an
introduction and user guide, including a glossary. The glossary is a crucial component
to understanding the unique aspects of specialized terms. For example, the definition
of DS/PIA explains that DS/PIAs typically cover privacy, confidentiality, security,
and data use, not just "privacy," which has a more narrow definition, also
provided in the glossary.
The next section of the DS/PIA, which is the DS/PIA Instrument (the assessment tool),
is specific to each program. Each assessment is organized around the four Privacy
Principles: 1) mission necessity, 2) openness, 3) respectful treatment of respondents,
and 4) protection of confidentiality. The following section, the System Write-up,
describes the IT system to which the program is linked and how the IT Security Office
determined the risk level of the system. The final two sections, the Data Sensitivity
Worksheet, and the Activity Sensitivity Worksheet, compute the sensitivity levels of
the program, based on the answers provided in the assessment.
We hope that your review of our DS/PIAs yields a better understanding of our efforts
to respect your privacy, protect your personal information and limit its use while
ensuring that we produce the highest quality statistics for America. Should you have
any questions or concerns about the contents of these DS/PIAs please contact us at
DIR.Privacy.Office@census.gov.
Media inquires should be directed to Mark.Tolbert.III@census.gov |