OMB Appendix F HSIS Westat Confidentiality Pledges

Appendix F

Westat Confidentiality Pledges

WESTAT, INC.

EMPLOYEE OR CONTRACTOR'S ASSURANCE OF CONFIDENTIALITY OF SURVEY DATA

Statement of Policy

Westat is firmly committed to the principle that the confidentiality of individual data obtained through Westat surveys must be protected. This principle holds whether or not any specific guarantee of confidentiality was given at time of interview (or self-response), or whether or not there are specific contractual obligations to the client. When guarantees have been given or contractual obligations regarding confidentiality have been entered into, they may impose additional requirements which are to be adhered to strictly.

Procedures for Maintaining Confidentiality

1. All Westat employees and field workers shall sign this assurance of confidentiality. This assurance may be superseded by another assurance for a particular project.

2. Field workers shall keep completely confidential the names of respondents, all information or opinions collected in the course of interviews, and any information about respondents learned incidentally during field work. Field workers shall exercise reasonable caution to prevent access by others to survey data in their possession.

3. Unless specifically instructed otherwise for a particular project, an employee or field worker, upon encountering a respondent or information pertaining to a respondent that s/he knows personally, shall immediately terminate the activity and contact her/his supervisor for instructions.

4. Survey data containing personal identifiers in Westat offices shall be kept in a locked container or a locked room when not being used each working day in routine survey activities. Reasonable caution shall be exercised in limiting access to survey data to only those persons who are working on the specific project and who have been instructed in the applicable confidentiality requirements for that project.

Where survey data have been determined to be particularly sensitive by the Corporate Officer in charge of the project or the President of Westat, such survey data shall be kept in locked containers or in a locked room except when actually being used and attended by a staff member who has signed this pledge.

5. Ordinarily, serial numbers shall be assigned to respondents prior to creating a machine-processible record and identifiers such as name, address, and Social Security number shall not, ordinarily, be a part of the machine record. When identifiers are part of the machine data record, Westat's Manager of Data Processing shall be responsible for determining adequate confidentiality measures in consultation with the project director. When a separate file is set up containing identifiers or linkage information which could be used to identify data records, this separate file shall be kept locked up when not actually being used each day in routine survey activities.

6. When records with identifiers are to be transmitted to another party, such as for keypunching or key taping, the other party shall be informed of these procedures and shall sign an Assurance of Confidentiality form.

7. Each project director shall be responsible for ensuring that all personnel and contractors involved in handling survey data on a project are instructed in these procedures throughout the period of survey performance. When there are specific contractual obligations to the client regarding confidentiality, the project director shall develop additional procedures to comply with these obligations and shall instruct field staff, clerical staff, consultants, and any other persons who work on the project in these additional procedures. At the end of the period of survey performance, the project director shall arrange for proper storage or disposition of survey data including any particular contractual requirements for storage or disposition. When required to turn over survey data to our clients, we must provide proper safeguards to ensure confidentiality up to the time of delivery.

8. Project directors shall ensure that survey practices adhere to the provisions of the U.S. Privacy Act of 1974 with regard to surveys of individuals for the Federal Government. Project directors must ensure that procedures are established in each survey to inform each respondent of the authority for the survey, the purpose and use of the survey, the voluntary nature of the survey (where applicable) and the effects on the respondents, if any, of not responding.

PLEDGE

I hereby certify that I have carefully read and will cooperate fully with the above procedures. I will keep completely confidential all information arising from surveys concerning individual respondents to which I gain access. I will not discuss, disclose, disseminate, or provide access to survey data and identifiers except as authorized by Westat. In addition, I will comply with any additional procedures established by Westat for a particular contract. I will devote my best efforts to ensure that there is compliance with the required procedures by personnel whom I supervise. I understand that violation of this pledge is sufficient grounds for disciplinary action, including dismissal. I also understand that violation of the privacy rights of individuals through such unauthorized discussion, disclosure, dissemination, or access may make me subject to criminal or civil penalties. I give my personal pledge that I shall abide by this assurance of confidentiality.

Signature Print Name Date

WESTAT

DATA COLLECTOR CODE OF CONDUCT

AND

ASSURANCE OF CONFIDENTIALITY

Westat is committed to the collection of high quality, independent, and unbiased data. These Performance Standards and Assurance of Confidentiality define the principles that are at the foundation of our data collection. By following these principles, we assure clients, researchers, educators, business leaders, and policymakers that they can have confidence in the data we collect.

The basic principles guiding Westat data collection are:

I. Ethics

• Data collectors have an obligation to the public, respondents, clients, and Westat to collect data according to study procedures.

• Respondents, who are individuals or institutions that participate in our studies, are to be provided with the information about the basic elements of a study as set forth in survey materials.

• Respondents are to be treated with respect and their concerns are to be addressed promptly, openly, and courteously.

• Data collectors are to maintain high standards of personal conduct and perform their job in a manner that will not harm, humiliate, or mislead respondents.

• Data collectors have an obligation to submit time and expense information that accurately reflects the work performed.

II. Technical Performance

• Data collectors are to follow the study protocol and procedures as specified in the study manual, at training, and in post training memos.

• Data collectors are to complete data collection and administrative activities accurately and on schedule.

• Data collectors are to return all study materials and equipment (in good condition) to Westat at the end of the study.

• Data collectors are to submit work that is valid and conforms to the quality requirements for the study.

III. Work Style

• Data collectors are to perform their work as effectively as possible and in such a way as to meet the goals set for the study.

• Data collectors are to accept responsibility for the quality of the data they collect and the work they complete.

• Data collectors are to demonstrate commitment, initiative, consistency, and organization in their approach to work.

• Data collectors are to display a professional attitude and appearance during the conduct of their work.

• Data collectors are to communicate professionally and effectively with clients, respondents, and other employees.

• Data collectors are to work effectively with the project team.

IV. Confidentiality

A. Policy on Confidentiality of Survey Data

Westat is firmly committed to the principle that the privacy of respondents and the confidentiality of individual data obtained through Westat surveys must be protected. This principle holds whether or not any specific guarantee of confidentiality was given at time of data collection, or whether or not there are specific contractual obligations to the client. When guarantees have been given or contractual obligations regarding confidentiality have been entered into, they may impose additional requirements, which are to be adhered to strictly.

B. Protecting the Privacy and Rights of Survey Participants

Successful survey research depends upon the cooperation of respondents. Data collectors are expected to gain cooperation using the methods described at training sessions or by their supervisor. For example, data collectors should explain the survey carefully and accommodate respondent time preferences wherever practical.

Data collectors are also to respect the privacy and property of respondents. They must not engage in any selling or promotion of products or services or in any other activity unrelated to the survey. If the data collector or the respondent suffers damage or injury to person or property in the course of the data collector’s activities, Westat must be notified promptly.

C. Procedures for Maintaining Confidentiality

All Westat employees and data collectors shall sign this agreement of confidentiality. This agreement may be superseded by another agreement for a particular project.

Data collectors shall keep completely confidential the names and addresses of respondents, all information or opinions collected in the course of interviews, and any information learned incidentally about individual respondents, responding organizations, or the places and organization where respondents work and live. Data collectors shall exercise care to prevent access by others to survey data in their possession.

Unless specifically instructed otherwise for a particular project, an employee or data collector, upon encountering a respondent or information pertaining to a respondent that s/he knows personally, shall immediately terminate the activity and contact her/his supervisor for instructions.

As a data collector on the Tracking Head Start Impact Study Participants Beyond 8^th Grade, I agree to follow the principles and guidelines listed above. I understand that my performance will be evaluated using these criteria, as well as project-specific requirements detailed in the study manual, at training, in post training memos or as otherwise directed by my supervisor or Westat generally.

I give my personal pledge that I shall abide by all policies on privacy and confidentiality. I will keep completely confidential all information arising from surveys concerning individual respondents to which I gain access. I will not discuss, disclose, disseminate, or provide access to survey data and identifiers except as authorized by Westat for a particular contract. I will devote my best efforts to ensure that there is compliance with the required procedures by personnel whom I supervise.

I understand that violation of this pledge will result in disciplinary action, up to and including dismissal. I also understand that violation of the privacy rights of individuals through unauthorized discussion, disclosure, dissemination, or access may make me subject to criminal or civil penalties. A copy of this document has been provided to me.

Signature _______________________________ Date ____________________________