INFORMATION
QUALITY GUIDELINES
I.
Purpose and Scope
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The
Selective Service System (hereafter identified as the
SSS) is publishing these guidelines to ensure and maximize
the quality, objectivity, utility, and integrity of specific
types of information it disseminates, as required by section
515(a) of the Treasury and Government Appropriations Act
for Fiscal Year 2001, Pub. L. No. 106-554, ' 515, 114
Stat. 2763, 2763A-153 (2000), reprinted at 44 U.S.C.A.
' 3516 Historical and Statutory Notes ("Data Quality Act").
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The
purpose of this document is to describe the SSS' policy
and procedures for reviewing and substantiating the quality
of information before it is disseminated to the public,
and to describe the SSS' administrative mechanisms allowing
affected persons to seek and obtain, where appropriate,
correction of information disseminated that does not comply
with the Office of Management and Budget (OMB) Guidelines,
Guidelines for Ensuring and Maximizing the Quality,
Objectivity, Utility, and Integrity of Information Disseminated
by Federal Agencies, 66 FR 49718 (Sept. 28, 2001)
(interim final guidelines), and 67 FR 369 (Jan. 3, 2002)
(final guidelines), corrected, 67 FR 5365 (Feb. 5, 2002),
reprinted correcting errors, 67 FR 8452 (Feb. 22, 2002),
or the SSS' final Information Quality Guidelines, which
will be issued October 1, 2002.
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These
guidelines apply only to information disseminated by the
SSS as defined in these guidelines. Other information
distributed by the SSS that is not addressed by these
guidelines may be subject to other SSS policies and correction
procedures.
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This
document provides guidance to SSS staff and informs the
public of the SSS' policies and procedures. These guidelines
are not rules or regulations. They are not legally enforceable
and do not create any legal rights or impose any legally
binding requirements or obligations on the SSS or the
public. Nothing in these guidelines affects any otherwise
available judicial review of SSS action. The SSS will
correct information that does not meet its guidelines
or those of OMB based on the significance and impact of
the correction. Any decisions regarding a particular case,
matter or action will be made based on applicable statutes,
regulations and requirements. Interested parties are free
to raise questions and objections regarding the substance
of the guidelines and the appropriateness of using them
in a particular situation. The SSS will consider whether
or not the guidelines are appropriate in that situation.
Factors such as imminent threats to public health or homeland
security, statutory or court-ordered deadlines, or other
time constraints, may limit or preclude applicability
of these guidelines.
II.
Definitions
For
purposes of these guidelines, the following definitions apply:
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Affected
person means anyone (including a group, organization or
corporation as defined in the Paperwork Reduction Act)
who may benefit or be harmed by the publicly disseminated
information, including those who are seeking to correct
information about themselves and those who use the information.
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Complaint
refers to a written communication to the SSS that includes
enough information so that the SSS can readily determine
the specific information dissemination product the complaining
party believes needs correcting, how the complaining party
is affected by the information dissemination product sought
to be corrected, the sections of these guidelines or the
OMB Guidelines the complaining party believes have
not been followed, what resolution the complaining party
would like, and how to get in contact with the comment
writer.
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Data
are the basic or underlying elements of information. All
information dissemination products covered by these guidelines
are based upon data. Additionally, covered information
dissemination products may contain analysis of the data
and conclusions drawn from this analysis.
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Dissemination
means SSS-initiated or sponsored distribution of information
to the public. Dissemination does not include distribution
limited to government employees or agency contractors
or grantees; intra- or inter-agency use or sharing of
government information; responses to requests for agency
records under the Freedom of Information Act, the Privacy
Act, or other similar laws; correspondence with individuals
or persons; archival records; other non-scientific/non-statistical
general, procedural, or organizational information; and
public filings, subpoenas, or adjudicative processes.
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Influential,
when used in the phrase "influential scientific, financial,
or statistical information," means that the SSS can reasonably
determine that dissemination of the information will have
or does have a clear and substantial impact on important
public policies or important private sector decisions.
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Information
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 includes information
disseminated from an Internet page, but does not include
the provision of hyperlinks to information that others
disseminate. This definition does not include opinions
where the presentation makes it clear that what is being
offered is someone's opinion rather than an official view.
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Information
dissemination product means any book, paper, map, machine-readable
material, audiovisual production, or other documentary
material regardless of physical form or characteristic
that is covered by these guidelines and disseminated to
the public as an expression of an official SSS position.
This definition can include electronic documents, CD-ROMs,
or web pages.
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Integrity
refers to the security of information - protection of
the information from unauthorized access or revision to
ensure that the information is not compromised through
corruption or falsification.
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Non-scientific/non-statistical
general, procedural, or organizational information includes
but is not limited to:
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Agency press releases,
fact sheets, press conferences, or similar communications
(in any medium) that announce, support the announcement,
or give public notice of information that the SSS has
disseminated elsewhere
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Fact
sheets and brochures
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Speeches/Remarks/Presentations
and their accompanying visual materials
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Listings
of:
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Licensees,
registrations, fees paid
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Phone
directories
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Job
openings
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Transcriptions
or minutes (video, audio, or print) of meetings
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Glossaries
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Links
to non-SSS sites
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Standards
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FAQ's
e.
Organizational descriptions
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Organization
charts
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Budget
submittals
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Strategic
and performance plans
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Descriptions
of laws, regulations, rules that underpin SSS activities
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Biographies
f.
Applications, standards, and help products
g. Forms (for printing or on-line filing)
h. Database search results
i. How-to-file materials
j. Fee information
k. Electronic comment filings
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Objectivity involves
two distinct elements, presentation and substance. In
a substantive sense objectivity involves a focus on ensuring
accurate, reliable, and unbiased information. In addition,
data should have full, accurate, transparent documentation
and error sources affecting data quality should be identified
and disclosed to users. In a scientific, financial, or
statistical context, substantive objectivity means that
the original and supporting data shall be generated, and
the analytic results shall be developed, using sound statistical
and research methods. Presentational objectivity involves
a focus on ensuring clarity, accuracy, completeness, and
reliability.
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Quality
is a term encompassing utility, objectivity, and integrity.
Therefore, the guidelines sometimes refer to these statutory
terms, collectively, as "quality."
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Reproducibility
means that the information is capable of being substantially
reproduced, subject to an acceptable degree of imprecision.
For information judged to have more influence or important
impact, the degree of imprecision that is tolerated is
reduced. With respect to analytic results, "capable of
being substantially reproduced" means that independent
analysis of the original or supporting data using identical
methods would generate similar analytic results, subject
to an acceptable degree of imprecision or error.
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Transparency
refers to practices of describing the data and methods
used in developing an information dissemination product
in a way that it would be possible for an independent
re-analysis to occur by a qualified individual or organization.
Transparency does not require that information be disclosed
where disclosure would result in harm to other compelling
interests such as privacy, trade secrets, intellectual
property, confidentiality protections, or public safety.
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Utility
refers to the usefulness of the information to its intended
users, including the public. In assessing the usefulness
of information that the SSS disseminates to the public,
the SSS will consider the uses of the information not
only from the perspective of the SSS but also from the
perspective of the public.
III.
Pre-Dissemination Information Review and Substantiation Process
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Beginning
October 1, 2002, the following process will apply to information
dissemination products distributed by the SSS to ensure
and maximize the quality, objectivity, utility, and integrity
of the information. The information dissemination products
covered by these guidelines include reports prepared for
Congress or required by legislation, such as the annual
reports of services.
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Information
exempt from these guidelines includes information associated
with public filings, subpoenas, or adjudicative processes;
non-scientific/non-statistical general, procedural, or
organizational information; information that is not initiated
or sponsored by the SSS; information that expresses personal
opinions rather than formal agency views; information
for the primary use of federal employees (inter- or intra-agency),
contractors, or grantees; responses to requests made under
the Freedom of Information Act, the Privacy Act, the Federal
Advisory Committee Act, or similar laws; agency correspondence;
archival records; trade secrets, intellectual property,
confidential data or information; and non-routine or emergency
public safety information.
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For
each information dissemination product covered by these
guidelines every Office shall conduct a pre-dissemination
review using the standards below:
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Quality
will be demonstrated through the incorporation of a
methodological section or appendix that describes, at
a minimum, the design and methods used during the creation,
collection, and processing of the data; the compilation
and/or analysis of the data; and the pre-release review
of the information dissemination product for clarity,
completeness, accuracy, and reliability.
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Objectivity
will be demonstrated by including in the information
dissemination product's methodology section or appendix
a discussion of other scientifically, financially, or
statistically responsible and reliable alternative views
and perspectives, if these alternative views or perspectives
are not already noted in other sections of the information
dissemination product.
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Utility
will be demonstrated by the responsible Office incorporating
into the methodology section or appendix examples of
the use of the information dissemination product. These
examples could include, but are not limited to, listing
of the legislation requiring the information dissemination
product or the specific request for the information
dissemination product.
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Integrity
is demonstrated by the SSS' routine, day-to-day compliance
across all operations and processes with relevant data
protection and security sections of applicable statues
and regulations and therefore does not have to be specifically
addressed in information dissemination products covered
by these guidelines.
IV.
The Complaint and Appeals Process
1.
Filing a Complaint.
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Affected
persons may seek timely correction of information dissemination
products maintained and distributed by the SSS that
do not comply with the SSS' or OMB's guidelines by completing
the Data Quality Comment form that will be found, beginning
October 1, 2002, at Data
Quality Comment Form. This form can be
submitted electronically by clicking on the link found
at the end of the form, or by printing a copy and mailing
it to the Selective Service System, National Headquarters,
ATTN: Public and Congressional Affairs Office, Arlington,
Virginia, 22209-2425.
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Initial
Correction Request.
1)
Any person affected by the information SSS publicly disseminates,
as intended by Section 515, may request the timely correction
of that information.
2)
Any "affected person" may submit a timely request for
correction to the Office of the Director of SSS, who will
direct the request to the appropriate Directorate Head
for consideration.
3)
The request for correction under Section 515 and these
guidelines must
·
Be in writing;
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Clearly explain how the person is an "affected person,"
as defined by these guidelines;
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Clearly identify the information dissemination product
that needs to be corrected for failure to meet SSS or
OMB standards;
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Clearly identify the information within that product
alleged to be incorrect;
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Suggest and explain appropriate corrective action, including
the justifications for the changes or other remedial
actions being sought;
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Identify the comment writer and how to contact him or
her; and
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Be clearly marked "Information Correction Request" and
addressed to: Selective Service System, National Headquarters,
ATTN: Public and Congressional Affairs Office, Arlington,
Virginia, 22209-2425. The request can also be emailed
to information@sss.gov.
4)
If the information disseminated by SSS and contested by
an affected person was previously disseminated by another
Federal agency in virtually identical form, then the complaint
should be directed to the originating agency.
5) Once an Information
Correction Request has been received, it is SSS' intention
for the Office Director (OD) to respond within 60 days,
beginning at the time of SSS receipt. The OD may extend
the response period for an additional 30 days if: the
OD determines an extension is appropriate, and promptly
provides the requestor the reasons why more time is needed.
Such reasons may include the need to review multiple records
encompassed by a single request, or the need to consult
with other Federal agencies that have a substantial interest
in the information at issue and the change being sought.
In cases where the SSS disseminates a study, analysis,
or other information prior to the final SSS action or
information product, requests for correction will be considered
prior to the final SSS action or information product in
those cases where the SSS has determined that an earlier
response would not unduly delay issuance of the SSS action
or information product and the complainant has shown a
reasonable likelihood of suffering actual harm from the
SSS' dissemination if the SSS does not resolve the complaint
prior to the final SSS action or information product.
6) Once received, the
OD shall initially determine whether the request meets
threshold requirements for standing, such as whether the
request:
a.
Is timely;
b. Is from an "affected person," as defined in these
guidelines;
c. Is appropriately directed to SSS;
d. Alleges errors in information subject to correction
(i.e., implicates information" as defined in these guidelines);
or
e. Reasonably describe
(1) the information source,
(2) the information alleged to be
incorrect; and
(3) a suggested remedy, including
justifications for
the remedy
being sought.
f. Contains information from the comment writer to facilitate
his or her contact for response.
7) If the OD determines
the request does not satisfy one or more of the threshold
requirements for standing, the OD will respond to the
requester explaining why the request was deficient. If
the request was deficient due to an insufficient description
of the disseminated information source or the information
alleged to be incorrect, as a matter of discretion the
OD may advise the requester what additional clarification
is required and provide a reasonable time for a proper
clarification to be submitted. Otherwise, the OD
shall determine whether the request for correction has
merit, as well as the type of remedy that is most appropriate
for the alleged error at issue, if proven. Given
the multiple types of information that may be involved,
as well as the wide range in possible levels of the information's
importance, a great variety of remedies may be appropriate.
The OD has discretion to implement the requester's suggested
remedy, or to choose another remedy the OD deems most
appropriate in the given circumstances. The OD will respond
to the affected person with an explanation of the decisions
that were made on both the error at issue and the remedy,
if any, selected to address it.
2.
Complaint Resolution.
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A
determination will be made within 60 days of receipt
of the complaint on whether correction is warranted..
If the request requires more than 60 calendar days to
resolve, the SSS will inform the complainant that more
time is required and indicate the reason why and an
estimated decision date.
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The
decision on appropriate corrective action will be based
upon the nature and timeliness of the information dissemination
product involved and such factors as ;the significance
of the correction on the use of the information dissemination
product and the magnitude of the correction. Inconsequential,
trivial, or frivolous complaints may require no response
at all. If corrective action is warranted, the correction
will occur within 60 days of this notification to the
complaining party.
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If
a correction is warranted, the appropriate Office handling
the complaint will respond to the complaint in a manner
appropriate to the nature and extent of the complaint.
Examples of appropriate responses include personal contacts
via letter or telephone, form letters, errata notices,
press releases, or mass mailings that correct a widely
disseminated error or address a frequently raised complaint.
3.
Right to Appeal.
If
the person who requested correction does not agree with
the initial decision (including corrective action, if
any), the person may file an application for review by
the SSS within 30 days of the date of the notification
of action on the complaint or the corrective action. Applications
for review must be submitted in writing to the SSS, Office
of the Director, National Headquarters, Arlington, Virginia,
22209-2425. E-mail copies of the written appeal may be
sent, beginning October 1, 2002, to Information@sss.gov.
The
written appeal must include a copy of the original complaint
and the response thereto, and an explanation of how the
initial resolution of the complaint or the corrective
action was contrary to the SSS' or OMB's information quality
guidelines.
Applications
for review will be resolved within 60 days. The SSS will
respond to all requests for appeals within 60 calendar
days of receipt. If the request requires more than 60
calendar days to resolve, the SSS will inform the complainant
that more time is required and indicate the reason why
and an estimated decision date. The SSS, in appropriate
cases, may deny an application for review without providing
reasons.
V.
Reporting Requirements
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On
an annual fiscal-year basis, the SSS shall submit a report
to the Director of OMB providing information (both quantitative
and qualitative, where appropriate) on the number and
nature of complaints received regarding compliance with
OMB guidelines, and how such complaints were resolved.
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The
report shall be submitted no later than January 1 of each
following year.
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The
first report shall be submitted by January 1, 2004.
VI.
Effective Dates
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Pre-dissemination
review under section III, above, shall apply to information
dissemination products that the SSS first disseminates
on or after October 1, 2002.
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The
administrative mechanisms noted in section IV shall apply
only to information dissemination products that the SSS
disseminates on or after October 1, 2002, regardless of
when the SSS first disseminated the information.
VII.
Information Quality Correspondence
At this
time, SSS has received no information quality correction
requests; however, SSS will update this page if it receives
any requests.
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