Attachment H Westat Confidentiality Pledge

Appendix H: Westat Confidentiality Pledge
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may be superseded by another assurance for a particular project.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.

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