SUPPORTING STATEMENT – PART A
[U.S. Census Bureau and U.S. Bureau of Economic Analysis]
Data Security Requirements for Accessing Confidential Data
OMB Control No. [0607-NEW]
The Foundations for Evidence-Based Policymaking Act of 2018 (44 U.S.C. 3583) mandates that the Director of the Office of Management and Budget (OMB) establish a standard application process (SAP) for requesting access to certain confidential data assets. The SAP is to be a process through which agencies, the Congressional Budget Office, State, local, and Tribal governments, researchers, and other individuals, as appropriate, may apply to access confidential data assets held by a federal statistical agency or unit for the purposes of developing evidence. The SAP Portal is to be a single web-based common application designed to collect information from individuals requesting access to confidential data assets from federal statistical agencies and units. In late 2022, the National Center for Science and Engineering Statistics (NCSES), in its role as the SAP PMO, published a 60-day Federal Register Notice (87 FR 53793) and 30-day Federal Register Notice (87 FR 66754) announcing plans to collect information through the SAP Portal. This collection request was submitted to the Office of Management and Budget as a Common Form in late 2022; the OMB control number for SAP Portal information collection is 3145-0271 and the expiration date is 12/31/2025.
When an application for confidential data is approved through the SAP Portal, the U.S. Census Bureau and the U.S. Bureau of Economic Analysis will collect information to fulfill their statutory confidentiality and data security requirements. This is a required step before providing the individual with access to confidential microdata for the purpose of evidence building. The U.S. Census Bureau’s and the U.S. Bureau of Economic Analysis’s confidentiality and data security forms and other paperwork, along with the corresponding security protocols, allow the U.S. Census Bureau and the U.S. Bureau of Economic Analysis to maintain careful controls on confidentiality, as required by law. This collection will occur outside of the SAP Portal. On November 10, 2022, the U.S. Census Bureau and the U.S. Bureau of Economic Analysis published a 60-day Federal Register Notice (87 FR 67865) announcing plans for this collection.
This submission requests approval to collect information from individuals to fulfill the U.S. Census Bureau’s and the U.S. Bureau of Economic Analysis’s statutory confidentiality and data security requirements. This request is from the U.S. Census Bureau and the U.S. Bureau of Economic Analysis within the Department of Commerce.
Title III of the Foundations for Evidence-Based Policymaking Act of 2018 (hereafter referred to as the Evidence Act) mandates that OMB establish a Standard Application Process (SAP) for requesting access to certain confidential data assets. Specifically, the Evidence Act requires OMB to establish a common application process through which agencies, the Congressional Budget Office, State, local, and Tribal governments, researchers, and other individuals, as appropriate, may apply for access to certain confidential data assets collected, accessed, or acquired by a statistical agency or unit. This new process will be implemented while maintaining stringent controls to protect confidentiality, as required by the law governing the data-owning agency.
Data collected, accessed, or acquired by statistical agencies and units is vital for developing evidence on the characteristics and behaviors of the public and on the operations and outcomes of public programs and policies. This evidence can benefit the stakeholders in the programs, the broader public, and policymakers and program managers at the local, State, Tribal, and National levels. The many potential benefits of access to data for evidence building notwithstanding, the U.S. Census Bureau and the U.S. Bureau of Economic Analysis are required by the law governing their activities to uphold controls to protect the confidentiality of the data they collect.
The SAP Portal is a web-based application to allow individuals to request access to confidential data assets from federal statistical agencies and units. The objective of the SAP Portal is to broaden access to confidential data for the purposes of evidence building and reduce the burden of applying for such access. Once an individual’s application in the SAP Portal has received a positive determination by the data-owning agency, the data-owning agency(ies) or unit(s) will begin the process of collecting information to fulfill their statutory confidentiality and data security requirements.
The paragraphs below outline the process for the U.S. Census Bureau and U.S. Bureau of Economic Analysis to collect information fulfilling their confidentiality and data security requirements, as required by their statutory confidentiality requirements.
In the instance of a positive determination for an application requesting access to a U.S. Census Bureau and/or U.S. Bureau of Economic Analysis-owned confidential data asset, the U.S. Census Bureau and/or the U.S. Bureau of Economic Analysis will contact the applicant(s) to initiate the process of collecting information to fulfill their statutory confidentiality and data security requirements. This collection may include any or all of the following information from applicant(s):
Form BC-1759, Special Sworn Status – U.S. Census Bureau
Fair Credit Release – U.S. Census Bureau
Selective Service Form – U.S. Census Bureau
Foreign National Residence History – U.S. Census Bureau
Initial Information Sheet – U.S. Census Bureau
Researcher Semi-Annual Contact Information and Travel History Update – U.S. Census Bureau
Form I-9, Employment Eligibility Verification (OMB No. 1615-0047) – U.S. Census Bureau
OF-306, Declaration for Federal Employment (OMB No. 3206-0182) – U.S. Census Bureau
SF85P, Questionnaire for Public Trust Positions (OMB No. 3206 0258) – U.S. Census Bureau
Sworn Statement (Affirmation) of Nondisclosure for Consultant to BEA – U.S. Bureau of Economic Analysis
Annual Census Bureau Data Handling University Training, including:
Data Stewardship & Controlled Unclassified Information (CUI)
Title 13 Awareness Course
Title 26 Awareness Training
Cybersecurity Awareness & Protection Course
Annual Census Bureau Records Management Training
Annual Bureau of Economic Analysis Title 26 Awareness Training
Annual Bureau of Economic Analysis Data Stewardship and IT Security Training
Annual Bureau of Economic Analysis Records Management 101 Training
Annual Bureau of Economic Analysis Active Shooter Training
Annual Bureau of Economic Analysis Employees Safety Training
Form CD-591, Department of Commerce Personal Identity Verification (PIV) Request, was included in the 30-day FRN, but has been removed because the form is not completed by the applicant.
This collection is authorized by 13 U.S.C. Sections 9 and 23(c) for the U.S. Census Bureau; 22 U.S.C. Section 3104 and 15 C.F.R. Part 80 for the Bureau of Economic Analysis.
The Paperwork Reduction Act (PRA) seeks to maximize the usefulness of information created, collected, maintained, used, shared, and disseminated by or for the federal government while also ensuring the greatest possible public benefit from such information. The PRA moreover mandates that the disposition of information by or for the federal government complies with the privacy and confidentiality statutes that apply to the particular data asset. The U.S. Census Bureau’s and the U.S. Bureau of Economic Analysis’s data security forms ensure that the U.S. Census Bureau and the U.S. Bureau of Economic Analysis are compliant with PRA requirements.
Data collected, accessed, or acquired by statistical agencies and units is vital for developing evidence on conditions, characteristics, and behaviors of the public and on the operations and outcomes of public programs and policies. Access to confidential data on businesses, households, and individuals from federal statistical agencies and units enables agencies, the Congressional Budget Office, State, local, and Tribal governments, researchers, and other individuals to contribute evidence-based information to research and policy questions on economic, social, and environmental issues of national, regional, and local importance. This evidence can benefit the stakeholders in the programs, the broader public, as well as policymakers and program managers at the local, State, Tribal, and National levels.
Many applicants will be academic research faculty or students at U.S. universities or other types of research institutions. Other applicants are likely to include analysts at eligible nonprofit organizations and research groups in U.S. Government organizations (Federal, State, local, and Tribal). Scientific research typically results in papers presented at scientific conferences and published in peer-reviewed academic journals, working paper series, monographs, and technical reports. The scientific community at large benefits from the additions to knowledge resulting from research with statistical agencies and units’ data. Results inform both scientific theory and public policy and can assist agencies in carrying out their missions.
Once approved, applicants using confidential data can provide insights on how statistical agencies and units may improve the quality of the data collected or acquired; identify shortcomings of current data collection programs and data processing methods; document new data needs; and develop methods to address survey nonresponse or improve statistical weights.
The U.S. Census Bureau and/or the U.S. Bureau of Economic Analysis will contact individuals whose approved applications are requesting access to the U.S. Census Bureau’s and/or the U.S. Bureau of Economic Analysis’s confidential data via an encrypted messaging and file sharing system. Applicants complete the U.S. Census Bureau’s and/or the U.S. Bureau of Economic Analysis’s required forms and resubmit through an encrypted messaging and file sharing system.
The U.S. Census Bureau and the U.S. Bureau of Economic Analysis are required by law to maintain careful controls on confidentiality and limit disclosure risk. Their forms are required for each approved research project to ensure minimal disclosure risk of the U.S. Census Bureau’s and/or the U.S. Bureau of Economic Analysis’s confidential data. The Census Bureau coordinates with the Office of Personnel Management system on background investigations and collects the minimum amount of information needed for the current background investigation and to ensure the project researchers’ continued residency in the United States. The Census Bureau and the U.S. Bureau of Economic Analysis do not duplicate work on security forms. These forms are necessary for the U.S. Census Bureau and/or the U.S. Bureau of Economic Analysis to place the applicant(s) in a trusted category and protect the confidentiality of the data they collect.
Small businesses or their representatives may choose to participate in this voluntary collection of information. The burden of this collection does not represent a significant barrier to participation from small businesses and is not large enough to pose significant costs to respondents, including small businesses.
The U.S. Census Bureau and the U.S. Bureau of Economic Analysis require and collect information for their security forms from all individuals who will access data and view output that has not been cleared for disclosure review. Less frequent collection would compromise the U.S. Census Bureau's and the U.S. Bureau of Economic Analysis’s ability to secure their confidential data.
There are no special circumstances.
On November 10, 2022, the U.S. Census Bureau and the U.S. Bureau of Economic Analysis published a notice in the Federal Register (87 FR 67865) inviting the public and other federal agencies to comment on plans to submit this request. The U.S. Census Bureau and the U.S. Bureau of Economic Analysis received 0 comment(s).
No payments or gifts are given to applicants requesting access to U.S. Census Bureau and U.S. Bureau of Economic Analysis data.
All personal identifiers are protected under the Privacy Act of 1974 and the U.S. Census Bureau’s and the U.S. Bureau of Economic Analysis’s privacy practices.
Any sensitive questions are necessary for the U.S. Census Bureau and/or the U.S. Bureau of Economic Analysis to place the applicant(s) in a trusted category and protect the confidentiality of the data they collect.
The amount of time to complete the forms and other paperwork that comprise the U.S. Census Bureau’s and the U.S. Bureau of Economic Analysis’s confidentiality and security requirements will vary based on the confidential data assets requested. To obtain access to U.S. Census Bureau and/or U.S. Bureau of Economic Analysis confidential data assets, it is estimated that the average time to complete and submit the U.S. Census Bureau’s and the U.S. Bureau of Economic Analysis’s data security forms and other paperwork is 45 minutes for the U.S. Census Bureau and 12 minutes for the U.S. Bureau of Economic Analysis. This estimate does not include the time needed to complete and submit an application within the SAP Portal. All efforts related to SAP Portal applications occur prior to and separate from the U.S. Census Bureau’s and the U.S. Bureau of Economic Analysis’s effort to collect the information required by statute and data security requirements. In addition, annual trainings are required to obtain and maintain a security clearance. It is estimated that the average time to complete the Census Bureau’s Data Handling University and Records Management Training is 300 minutes, and the average time to complete Bureau of Economic Analysis training is 180 minutes.
In a given year, the expected number of applications in the SAP Portal that receive a positive determination from the U.S. Census Bureau and/or the U.S. Bureau of Economic Analysis may vary. Overall, per year, the U.S. Census Bureau and the U.S. Bureau of Economic Analysis estimate they will collect information for 260 application submissions that received a positive determination within the SAP Portal. The U.S. Census Bureau or the U.S. Bureau of Economic Analysis estimate that the total burden for the collection of information for over the course of the three-year OMB clearance will be about 10,503 hours and, as a result, an average annual burden of 3,501 hours.
Type of submission: forms and paperwork required to meet statutory and security requirements
Average submission time: 192 minutes for the U.S. Bureau of Economic Analysis and 345 minutes for the U.S. Census Bureau; This estimate includes completion of paperwork and training requirements.
Annual number of security form submissions: 640 submissions
Total burden hours over the three-year OMB clearance: 3 years x [time to complete security forms] x [number of approved applications] = 10,503 hours
Annual burden hours over the three-year OMB clearance: 10,503 hours/3 years = 3,501 hours
The total cost to applications requesting access to the U.S. Census Bureau and the U.S. Bureau of Economic Analysis data for the 10,503 total burden hours is estimated to be $368,655.
This estimate is based on an estimated median annual salary of $73,000 per applicant.1 Assuming a 40-hour workweek and a 52-week salary, this annual salary translates to an hourly salary of $35.10. Over the three-year OMB clearance period, the average annual cost to the public for the U.S. Census Bureau’s and the U.S. Bureau of Economic Analysis’s forms is estimated to be $122,885.
Not applicable. The U.S. Census Bureau and the U.S. Bureau of Economic Analysis do not impose any fees, charges, or costs to individuals submitting the U.S. Census Bureau’s and the U.S. Bureau of Economic Analysis’s forms.
We estimate the average annual cost to the Federal Government for the collection and review of U.S. Census Bureau and U.S. Bureau of Economic Analysis documents to be approximately $1.59 million per year for Fiscal Years 2023, 2024, and 2025. These figures are based on required contractual and staff resources necessary to collect and review documents given the expected annual number of submitted applications.
Not applicable.
The information provided by applicants to the U.S. Census Bureau and the U.S. Bureau of Economic Analysis is received on an ongoing basis and is not subject to any schedule. Because applications requesting access to U.S. Census Bureau and U.S. Bureau of Economic Analysis data are voluntary, applicants provide information voluntarily and at their discretion.
The U.S. Census Bureau plans to display the OMB control number and expiration date for this information collection request on the following instruments: Foreign National Residence History, Initial Information Sheet, and Researcher Semi-Annual Contact Information and Travel History Update. The forms included in this request that have already been approved by OMB for other agencies will display their existing OMB control numbers and expiration dates.
There are no exceptions.
B. Collections of Information Employing Statistical Methods
Not applicable. Because applications requesting access to U.S. Census Bureau and U.S. Bureau of Economic Analysis data are voluntary, this information collection will not employ statistical methods.
1Applicant salary estimates were based on annual median salary estimates for employed college graduates using data from the 2019 National Survey of College Graduates.
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