OMB M-19-18: Federal Data Strategy - A Framework for Consistency

EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C.

20503

June 4, 2019
M-19-18

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MEMORANDUM FOR THE HEADS OF E :ECUTIVE DEPARTMENTS AND AGENCIES
FROM:

Russell T. Vought
Acting Director

SUBJECT:

Federal Data Strategy - A Framework for Consistency

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New tools, technologies, and norms are creating opportunity to use data to bolster the Federal
Government's mission delivery, service design, and tax-dollar stewardship for the public. In
order to leverage these opportunities, the Government must address consistency in skills,
interoperability, and best practices in how agencies use and manage data.
This memorandum establishes a Federal Data Strategy (Strategy) as a framework of operational
principles and best practices that help agencies deliver on the promise of data in the 21 st century.
Through consistent data infrastructure and practices, the Strategy will enable Government to
fully leverage data as a strategic asset by supporting strong data governance and providing the
protection and security that the American people, businesses, and partners deserve.
Purpose & Overview
This Strategy enables agencies-and Government as an enterprise-to use and manage Federal
data to serve the American people, including the critical twin goals of getting optimal value
from our data assets and of protecting security, privacy, and confidentiality. It provides a
common set of data principles and best practices in implementing data innovations that drive
more value for the public. 1 The Strategy complements statutory requirements2 and 0MB
information policy and guidance, 3 and incorporates relevant changes proposed by agency and
public comments received in response to M-19-01: Request for Agency Feedback on the Federal
Data Strategy.

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Federal data drives the U.S. economy and civic engagement and there is virtually no policy or program decision facing a federal agency that

would not benefit from the use of data. This Strategy will enable the government and the public to harness the value of federal and federally­
sponsored data by increasing accessibility and use to support public and private decision-making, accountability, commercialization, innovation,
and public use.
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Including the Paperwork Reduction Act, the E-Government Act of 2002, the Privacy Act of 1974, the Federal Information Security
Modernization Act of 2014 (FISMA), the Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA), the Freedom of
Information Act, the Information Quality Act, the Federal Records Act, and the Foundations for Evidence-Based Policymaking Act of 2018,
among others.
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lncludin~ 0MB Circular A-130 Managing Information as a Strategic Resource, among others.

The Strategy is comprised ofthree components to guide Federal data management and use:
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Mission Statement: The mission statement articulates the intent and core purpose of the
Strategy.
Principles: The principles serve as motivational guidelines in the areas of Ethical
Governance, Conscious Design, and Learning Culture. They include concepts from
existing frameworks, such as protecting personally identifiable information, managing
information as an asset, carrying out fundamental responsibilities of a Federal statistical
agency, and building Federal evidence.
Practices: The practices guide agencies in leveraging the value of data by Building a
Culture that Values Data and Promotes Public Use; Governing, Managing, and
Protecting Data; and Promoting Efficient and Appropriate Data Use.

Mission Statement

The mission of the Federal Data Strategy is to leverage the full value of Federal data for mission,
service, and the public good by guiding the Federal Government in practicing ethical
govern8:nce, conscious design, and a learning culture.
Principles

The principles are organized in three categories that reflect core concepts carried throughout the
Strategy and should inform agencies in developing and executing all aspects of the data lifecycle.
The following principles are intended to guide federal and federally-sponsored data management
activities, be they programmatic, statistical, or mission-support.
Etltical Governance
1. Uphold .Ethics: Monitor and assess the implications of federal data practices for the
public. Design checks and balances to protect and serve the public good.
2. Exercise Responsibility: Practice effective data stewardship and governance. Employ
sound data security practices, protect individual privacy, maintain promised
confidentiality, and ensure appropriate access and use.
3. Promote Transparency: Articulate the purposes and uses of federal data to engender
public trust. Comprehensively document processes and products to inform data providers
and users.
Conscious Design
4. Ensure. Relevance: Protect the quality and integrity of the data. Validate that data are
appropriate, accurate, objective, accessible, useful, understandable, and timely.
5. Harness Existing Data: Identify data needs to inform priority research and policy
questions; reuse data if possible and acquire additional data if needed.
6. Anticipate Future Uses: Create data framework thoughtfully, considering fitness for use
by others; plan for reuse and build in interoperability from the start.
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7. Demonstrate Responsiveness: Improve data collection, analysis, and dissemination with
ongoing input from users and stakeholders. The feedback proces~ is cyclical; establish a
baseline, gain support, collaborate, and refine continuously .
. Learning Culture
8. Invest in Learning: Promote a culture of continuous and collaborative learning with and
about data through ongoing investment in data infrastructure and human resources ..
9. Develop Data Leaders: Cultivate data leadership at all levels of the federal workforce by
investing in training and development about the value of data for mission, service, and
the public good.
10. Practice Accountability: Assign responsibility, audit data practices, document and learn
from results, and make needed changes.
Practices
The practices are organized in three categories that reflect the importance of aligning data
management with data usage in order to answer critical Federal Government questions and meet
stakeholder needs. By prioritizing data uses, the Federal Government can derive more.value from
otherwise unanticipated or secondary uses of data assets, and more strategically execute data
management improvements. Specifically, the practice categories are: .

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Building a Culture that Values Data and Promotes Public Use (practices 1-10)
Governing, Managing, and Protecting Data (practices 11-26)
Promoting Efficient and Appropriate Data Use (practices 27-39)

The importance of protecting individual privacy is integrated and emphasized throughout the
Strategy. While the Strategy establishes an overarching framework for data, the practices reflect
further consideration of the Fair Information Practice Principles (FIPPs). 4 The FIPPs are a
collection of widely accepted principles that agencies should use when evaluating information
systems, processes, programs, and activities that affect individual privacy. The FIPPs are not
requirements; rather, they are principles that should be applied by each agency according to the
agency's particular mission and privacy program requirements. The precise expression of the
FIPPs has varied over time and in different contexts. However, the FIPPs retain a consistent set
of core principles that are broadly relevant to agencies' information management practices, and
hence their concepts have been integrated throughout the practices.
Building a Culture that Values Data and Promotes Public Use
Practices 1-10 derive value by articulating data uses for agency decision-making and
accountability and supporting commercialization, innovation, and public use. To improve data

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Privacy Act of 1974, 5 U.S.C. § 552a, as amended. The FIPPs are a set of eight principles that are rooted in the tenets of the Privacy Act of 1974.

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management, agencies should consider potential uses of data and the benefits of those uses for
answering key agency questions and meeting stakeholder needs. To derive value from these
potential uses, agencies need leadership champions, management buy-in, and staff capacity to
conduct the data driven decision-making cycle that prioritizes the informative value of data.
When using data to answer key questions and address stakeholder needs, agencies should use
data sources that are the most fit for the particular purpose. When allocating resources, agencies
should prioritize data that identifies problems, informs solutions, and provides transparency for
results delivered. Agencies shall:
1. Identify Data Needs to Answer Key Agency Questions: Use the learning agenda5
process to identify and prioritize the agency's key questions and the data needed to
answer them.
2. Assess and Balance the Needs of Stakeholders: Identify and engage stakeholders
throughout the data lifecycle to identify stakeholder needs and to incorporate stakeholder
feedback into government priorities to maximize entrepreneurship, innovation, scientific
dis_covery, economic growth, and the public good.
3. Champion Data Use: Leaders set an example, incorporating data in decision-making and
targeting resources to maximize the value of data for decision-making, accountability,
and the public good.
4. Use Data to Guide Decision-Making: Effectively, routinely, transparently, and
appropriately use data in policy, planning, and operations to guide decision-making;
share the data and analyses behind those decisions.
5. Prepare to Share: Assess and proactively address the procedural, regulatory, legal, and
cultural barriers to sharing data within and across federal agencies, as well as with
external partners.
6. Convey Insights from Data: Use a range of communication tools and techniques to
effectively present insights from data to a broad set of audiences.
7. Use Data to Increase Accountability: Align operational and regulatory data inputs with
performance measures and other outputs to help the public to understand the results of
federal investments and to support informed decision-making and rule-making.
8. Monitor and Address Public Perceptions: Regularly assess and address public
confidence in the value, accuracy, objectivity, and privacy protection of federal data to
make strategic improvements, advance agency missions, and improve public messages
about planned and potential uses of federal data.
9. Connect Data Functions Across Agencies: Establish communities of practice for
common agency data Junctions (e.g. data management, access, analytics, informatics, and
user support) to promote efficiency, collaboration, and coordination.
10. Provide Resources Explicitly to Leverage Data Assets: Ensure that sufficient human
and financial resources are available to support data driven agency decision-making,
accountability and the ability to spur commercialization, innovation, and public use.

5 Also known as evidence-building plans, such as in the Foundations for Evidence-based Policymaking Act of 2018.

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Governing, Managing, and Protecting Data
Practices 11-26 derive value from data by bringing leaders with diverse perspectives and
expertise together to plan for using the data appropriately and responsibly. A data governance
structure helps agencies use data to answer important questions while meeting legal and ethical
requirements essential to maintaining public trust, including protecting privacy and ensuring
confidentiality. Agency questions and user needs should drive specific governance, management,
and data protection priorities. Data governance and management also allow agencies to assess
data quality and the agency's capacity to acquire, ·manage, protect and use data to address
mission priorities, as well as to prioritize data investments. A broad spectrum of leaders and skill
sets within and across agencies will be key to successful implementation of these practices, and
inter-agency collaboration will be essential for consistency across the government. Agencies
shall:
11. Prioritize Data Governance: Ensure there are sufficient authorities, roles,
organizational structures, policies, and resources in place to transparently support the
management, maintenance; and use of strategic data assets.
12. Govern Data to Protect Confidentiality and Privacy: Ensure there are sufficient
authorities, roles, organizational structures, policies, and resources in place to provide
appropriate access to confidential data and to maintain public trust and safeguard privacy.
13. Protect Data Integrity: Emphasize state-of-the-art data security as part of Information
Technology security practices for every system that is refreshed, architected, or replaced
to address current and emerging threats; foster innovation and leverage new technologies
to maintain protection.
14. Convey Data Authenticity: Disseminate data sets such that their authenticity is
discoverable and verifiable by users throughout the information lifecycle, consistent with
open data practices, and encourage appropriate attribution from users.
15. Assess Maturity: Evaluate the maturity of all aspects of agency data capabilities to
inform priorities for strategic resource investment.
16. Inventory Data Assets: Maintain an inventory of data assets with sufficient
completeness, quality, and metadata to facilitate discovery and collaboration in support of
answering key agency questions and meeting stakeholder needs.
17. Recognize the Value of Data Assets: Assign value to data assets based on maturity, key
agency questions, stakeholder feedback, and applicable law and regulation to
appropriately prioritize and document resource decisions.
18. Manage with a Long View: Include data investments in annual capital planning
processes and associated guidance to ensure appropriated funds are being used efficiently
to leverage data as a strategic long-term asset.
19. Maintain Data Documentation: Store up-to-date and comprehensive data
documentation in accessible repositories to facilitate use and document quality, utility,
and provenance in support of informing key agency questions and meeting stakeholder
needs.
20. Leverage Data Standards: Adopt or adapt, cre·ate as needed, and implement data
standards within relevant communities of interest to maximize data quality and facilitate
use, access, sharing, and interoperability.

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21. Align Agreements with Data Management Requirements: Establish terms and
conditions for contracts, grants, cooperative agreements, and other agreements that meet
data management requirements for processing, storage, access, transmission, and
disposition.
22. Identify Opportunities to Overcome Resource Obstacles: Coordinate with
stakeholders to identify mutually-acceptable cost recovery, shared service, or partnership
opportunities to enable data access while conserving available resources to meet user
· needs.
23. Allow Amendment: Establish clear.procedures to allow members of the public to access
and amend federal data about themselves, as appropriate and in accordance with federal
laws, regulations and policies, in order to safeguard privacy, reduce potential harm from
inaccurate data, and promote transparency.
24. Enhance Data Preservation: Preserve federal data in accordance with applicable law,
regulation, policy, approved schedules, arid mission relevance.
25. Coordinate Federal Data Assets: Coordinate and share data assets across federal
agencies to advance progress on shared and similar objectives, fulfill broader federal
information needs; and reduce collection burden.
26. Share Data Between State, Local, and Tribal Governments and Federal Agencies:
Facilitate data sharing between state, local, and tribal governments and the Federal
Government, where.relevant and appropriate and with proper protections, particularly for
programs that are federally funded and locally administered, to enable richer analyses for
more informed decision-making.

Promoting Efficient and Appropriate Data Use
Practices 27-40 derive value from data by providing access to data resources, promoting
appropriate use of data resources, and providing guidance on approaches• for data augmentation.
Access to data resources includes practices related to sharing data assets, including open data and
tiered access to protected data, disclosure review, and interoperability of federal data. Use of data
resources includes practices related to data documentation, emerging technologies for protecting
confidential data, and federal data expertise. Data augmentation includes practices related to data
quality, metadata standards, and secure data linkage. Agency leadership and practitioners within
programs will be key to these activities, many of which involve working across agencies and
with experts across industry. Agencies shall:
27. Increase Capacity for Data Management and Analysis: Educate and empower the
federal workforce by investing in training, tools, communities, and other opportunities to
expand capacity for critical data-related activities such as. analysis and evaluation, data·
management, and privacy protection.
28. Align Quality with Intended Use: Data likely to inform important public policy or
private sector decisions must be of appropriate utility, integrity, and objectivity.
29. Design Data for Use and Re-Use: Design new data collections with the end uses and
users in mind to ensure that data are necessary and of high enough quality to meet
planned and future agency and stakeholder needs.
30. Communicate Planned and Potential Uses of Data: Review data collection procedures
to update and improve how planned and future uses of data are communicated, promoting
· public trust through transparency.
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31. Explicitly Communicate Allowable Use: Regularly employ descriptive metadata that
provides clarity about access and use restrictions for federal data, explicitly recognizes
and safeguards applicable intellectual property rights, conveys attribution as needed, and
optimizes potential. value to stakeholders to maximize appropriate legal use.
32. Harness Safe Data Linkage: Test, review, and deploy data linkage and analysis tools
that use secure and privacy-protective technologies to address key agency questions and
meet stakeholder needs while protecting privacy.
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33. Promote Wide Access: Promote equitable and appropriate access to data in open,
machine-readable form and through multiple mechanisms, including through both federal
and non-federal providers, to meet stakeholder needs while protecting privacy,
confidentiality, and proprietary interests.
34. Diversify Data Access Methods: Invest in the creation and usability of multiple tiers of
access to make data as accessible as possible while minimizing privacy risk and
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protecting confidentiality.
35. Review Data Releases for Disclosure Risk: Review federal data releases to the public to
assess and minimize the risk of re-identification, consistent with applicable laws and
policies, and publish reviews to promote transparency and public trust.
36. Leverage Partnerships: Create and sustain partnerships that facilitate innovation with
commercial, academic, and other partners to advance agency mission and maximize
economic opportunities, intellectual value, and the public good.
37. Leverage Buying Power: Monitor needs and systematically leverage buying power for
private-sector data assets, services, and infrastructure to promote efficiency and reduce
federal costs.
38. Leverage Collaborative Computing Platforms: Periodically review and optimize the
use of modern collaborative computing platforms to minimize costs, improve
performance, and increase use.
39. Support Federal Stakeholders: Engage with relevant agencies to share expert
· knowledge of data assets, promote wider use, improve usability and quality, and meet
mission goals.
40. Support Non-Federal Stakeholders: Engage with industry, academic, and other non­
federal users of data to share expert knowledge of data assets, promote wider use,
improve usability and quality, and advance innovation and commercialization.
Agency Requirements, Resources, and Points of Contact
Agencies shall implement the Strategy by adhering to the requirements of annual government­
wide Action Plans (hereinafter "Action Plans"). Action Plans will identify and prioritize
practice-related steps for a given year, along with target timeframes and responsible entities. This
approach allows for continuous innovation with focused, measured progress, along with
opportunities to improve and adapt plans for future actions. In addition to Action Plans, 0MB
· may assess agency progress in implementing the Strategy through any of its existing ove_rsight
and coordination mechanisms. 6

6 Including, but not limited to: Capital Planning Guidance, the President's Management Agenda Cross-Agency Priority Goals and Strategic
. Reviews, the President's Budget development process, review of information collection requests under the Paperwork Reduction Act, and review
ofSystems of Records Notices under the Privacy Act.

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Strategy.data.gov will be the hub for Federal Data Strategy implementation guidance and will
include updates, action steps, and living resources for agencies to implement the Federal Data
Strat~gy. It will also serve as the platform for continued stakeholder feedback on the Federal
Data Strategy. 0MB requests agency comment on the draft 2019-2020 Federal Data Strategy
Action Plan available at Strategy.data.gov by July 5, 2019. Questions should be directed to

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