NASS Data Security Requirements for Accessing Confidential Data

National Agriculture Statistics Service
(NASS)

Data Access Security
The NASS mission is to provide timely,
accurate, and useful statistics in service to
U. S. agriculture.
According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person is not required to respond to a
collection of information unless it displays a valid OMB control number. The valid OMB number is xxxx-xxxx. The time required to
complete this information collection is estimated to average 20 minutes per response, including the time for reviewing instructions,
searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.

Outline of Presentation
• Laws governing NASS authority for data
collections
• Data Access locations, rules, and procedures
• NASS disclosure review

NASS Authority to Collect Data
• Title 7, U.S. Code, Sec. 2276 – Confidentiality
of Information - Agriculture Title - 1985
• Confidential Information Protection and
Statistical Efficiency Act (CIPSEA) of 2018, Title
III of the Evidence Act.

Confidentiality
• Confidential information refers to information
collected from an individual or establishment that
– could be used to publicly identify respondents
– was collected under a restriction about sharing the
information with others.

• Confidential information may be referred to as
restricted data, identifiable data, data from in-house
files, or personally identifiable information (PII)
• Confidential information includes direct and indirect
identifiers. Indirect are those that would identify
individuals when combined with other data.

Confidential Information Protection
and Statistical Efficiency Act
(CIPSEA)
• How does CIPSEA Support Confidentiality?
– All data are collected under a pledge of confidentiality.
– It strengthens protection of statistical data for all
federal government surveys.
– Penalties for disclosure increased to Class E felony – 5
years in prison and/or $250,000 fine.
– It permits the designation of sworn agents to access
for exclusively statistical purposes.
• Sworn agents have the same responsibility to protect data as
employees.

Statistical Purpose Defined
Statistical purposes
– Description, estimation, or analysis of the characteristics of
groups, without identifying individuals or organizations
that comprise such groups
Statistical purposes do NOT include:
– Use of information in an identifiable form that affects the
rights, privileges, or benefits of a respondent
– Use of data for administrative purposes such as
compliance with Federal regulations
– Access to confidential information in response to a
Freedom of Information Act (FOIA) request

Respondent Protection
• NASS conducts the large majority of surveys
on a voluntary basis, however the Census of
Agriculture is the primary exception, since it is
mandatory.
• It is critical for NASS to maintain the trust of
respondents so they will complete NASS
surveys.
• Low response rates decrease the quality of
survey data and increase the costs.

Data AccessLocations for Agents
• Virtual Data Enclave (fee based)

NASS Access
• NASS will facilitate access to a virtual data
enclave with the approved data uploaded.
• Sworn agents must read and understand the
contents of the Data Lab Handbook.
• NASS employee or representative will assist
with questions regarding the operations of the
enclave.

Rules and Procedures
• Sworn agents using the virtual Data Enclave are
only permitted to access from an approved U.S.
location, cleared by a virtual site inspection.
• All sworn agents must receive confidentiality
training, sign an ADM-43 Data Confidentially and
User Attestation forms. These forms bind sworn
agents to the specific limitations for access and
mandatory codes of conduct.
• All sworn agents are prohibited from the
reproduction of any data or analysis including
photography, screen clipping, or any other form
of replication or reproduction.

Disclosure Review
• Anything to be removed from virtual data
enclave must be reviewed by NASS for
disclosure risk.
• NASS will review summaries and analysis for
disclosure concerns and will apply
suppressions where necessary.
• Anything that does not pass disclosure review
cannot be released for public use or be used
in any publications.

Disclosure Rules
• Threshold Rule: Every cell must be computed
from a minimum of five (5) unweighted
observations.
• Dominance Rules: All cells are checked for
dominance. There are two rules used depending
on the circumstances.
• (n,k), top n producers represent more than k percent
• P-percent, no one can approximate the largest producer to
within p percent.

Dominance rule values are kept administratively
confidential to give added protection.

Disclosure Review
• All cells failing the threshold or dominance
rule must be suppressed and are considered a
primary suppression.
• Complimentary cells must also be suppressed
to prevent the deriving of primary suppressed
cells.

Disclosure Reviews
• A complete list of the requirements for a
disclosure review can be found in the Data Lab
Handbook.
• All files in a disclosure review request are
reviewed as a unit.
• Incomplete disclosure review requests will be
rejected, and resubmission will be necessary.
• NASS recommends allowing at least 30 days to
process each disclosure review request.

Requirements for Disclosure
Reviews
• The requirements for each disclosure review
must include
–
–
–
–
–

The program code used to generate results
A list of variables used in the analysis
A description of all modeling techniques used
Visualizations must include underlying data
All summary statistics must be weighted and be
accompanied by
• Total weighted and unweighted number of contributing
records for each summarized cell
• Unweighted values from each of the top two contributing
records for each summarized cell

Disclosure Review
Using Weights
• All summary statistics including aggregated
totals and means must be weighted.
• NASS will not authorize the release of record
level values (e.g., maximums or minimums)
• NASS strongly encourages but does not
require the use of weights for modeling
purposes unless intended for publishing.

Closing Comments
• Confidentiality is the key to maintaining the
trust and the cooperation of respondents.
– And it is the LAW!

• As a sworn agent, confidentiality is your
responsibility.

Quiz

1. Confidential Information Protection and Statistical Efficiency Act (CIPSEA) permits designation of
sworn agents to perform analysis for exclusively statistical purposes excluding which one of the
following:
a) Description of the characteristics of groups without identifying individuals or organizations
that comprise such groups
b) Estimation of the characteristics of groups without identifying individuals or organizations
that comprise such groups
c) Analysis of the characteristics of groups without identifying individuals or organizations that
comprise such groups
d) Use of information in an identifiable form that affects the rights, privileges of such groups
e) None of the above
2. The NASS mission is to provide timely, accurate, and useful statistics in service to U. S.
agriculture.
a) True
b) False
3. Sworn agents using the virtual Data Enclave are permitted to access data from any location,
including outside the United States.
a) True
b) False
4. Disclosure review requests may
a)
b)
c)
d)

Take up to 30 days
Be rejected if incomplete
Require resubmission, if rejected
All of the above

5. Anything to be removed from virtual data enclave must be reviewed by NASS for disclosure risk.
a) True
b) False

6. NASS will review summaries and analysis for disclosure concerns and will apply suppressions
where necessary. Anything that does NOT pass disclosure review
a)
b)
c)
d)

Cannot be released for public use or be used in any publications
May be published to a limited audience
Can be released with accompanying disclaimers
None of the above

7. All sworn agents must
a)
b)
c)
d)
8.

receive confidentiality training
sign an ADM 43 Data Confidentially form
sign an ADM 44 User attestation form
all of the above

The signed forms bind sworn agents to the specific limitations for access and mandatory codes
of conduct.
a) True
b) False

9. All sworn agents are prohibited from the reproduction of any data or analysis including
a)
b)
c)
d)

photography
screen clipping
any other form of replication or reproduction
all of the above

10. Sworn agents must read and understand the contents of the Data Lab Handbook.
a) True
b) False