1 Information Quality Act

Purpose- after this course you will be able to… define what is the Information Quality Act define what is the Information Quality Act describe what data are affected by the Act describe what data are affected by the Act describe Objectivity, Utility, and Integrity of BLM data describe Objectivity, Utility, and Integrity of BLM data describe Transparency and reproducibility of BLM data describe Transparency and reproducibility of BLM data explain the BLM process for handling requests for correction of information explain the BLM process for handling requests for correction of information 2

3 Public Law Section 515 of the Treasury and General Government Appropriations Act for FY 2001 Section 515 of the Treasury and General Government Appropriations Act for FY 2001

4 Information Quality Act Requires federal agencies to publish their "Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information" that they disseminate

Information Quality Act Sometimes mistakenly called the ‘Data Quality Act’ Sometimes mistakenly called the ‘Data Quality Act’ Does not require data to be of a certain quality, only requires Federal Agencies be able to say what is known about the quality of disseminated data Does not require data to be of a certain quality, only requires Federal Agencies be able to say what is known about the quality of disseminated data 5

6 Information Quality Act Further requires that agencies report annually on the number and nature of complaints received and the steps that were taken to resolve them Further requires that agencies report annually on the number and nature of complaints received and the steps that were taken to resolve them Also requires agencies to establish mechanisms for receiving requests for correction of information Also requires agencies to establish mechanisms for receiving requests for correction of information

7 What information is covered by the Act? Information must be disseminated Information must be disseminated Either published or publicly available on or after October 1, 2002 Either published or publicly available on or after October 1, 2002

8 What information is covered by the Act? Agency Sponsored Agency Sponsored Agency creates and uses this data or has decided to use this data Agency creates and uses this data or has decided to use this data Could include third party data if it is used for agency decision-making and/or can be considered “endorsed” by the agency Could include third party data if it is used for agency decision-making and/or can be considered “endorsed” by the agency

9 What information is not covered? Party-to-Party transactions Party-to-Party transactions Internet hyperlinks and other references Internet hyperlinks and other references Opinions Opinions Press release, fact sheets, press conferences or similar communications in any medium Press release, fact sheets, press conferences or similar communications in any medium Public filings of information Public filings of information Dissemination of information by an agency- employed scientist, grantee, or contractor Dissemination of information by an agency- employed scientist, grantee, or contractor

10 What information is not covered? Testimony and other submissions to Congress Testimony and other submissions to Congress Inadvertent or unauthorized disclosure of information intended only for inter-agency and/or intra-agency use of communication Inadvertent or unauthorized disclosure of information intended only for inter-agency and/or intra-agency use of communication Correspondence with individuals Correspondence with individuals Records covered by other laws, including FOIA, Privacy Act, etc. Records covered by other laws, including FOIA, Privacy Act, etc. Archived records Archived records

BLM Influential Information When information is defined as influential, there is an added level of scrutiny afforded this information, to include the need to ensure it is reproducible. When information is defined as influential, there is an added level of scrutiny afforded this information, to include the need to ensure it is reproducible. At BLM, influential information is that which is expected to have a clear and substantial impact at the national level for major public and private policy decisions as they relate to Federal public lands and resources issues. At BLM, influential information is that which is expected to have a clear and substantial impact at the national level for major public and private policy decisions as they relate to Federal public lands and resources issues. 11

BLM Influential Information For the purposes of the BLM Information Quality Guidelines, BLM will generally consider the following classes of information to be influential, and, to the extent that they contain scientific, financial, or statistical information, that information will adhere to a higher standard of quality. For the purposes of the BLM Information Quality Guidelines, BLM will generally consider the following classes of information to be influential, and, to the extent that they contain scientific, financial, or statistical information, that information will adhere to a higher standard of quality. Information disseminated in support of top BLM actions (i.e., substantive notices, policy documents, studies, guidance) that demand the ongoing involvement of the Director's officeInformation disseminated in support of top BLM actions (i.e., substantive notices, policy documents, studies, guidance) that demand the ongoing involvement of the Director's office Information used in cross-bureau issues that have the potential to result in major cross-bureau policies and highly controversial information that is used to advance the BLM's priorities.Information used in cross-bureau issues that have the potential to result in major cross-bureau policies and highly controversial information that is used to advance the BLM's priorities. 12

13 Objectivity, Utility, & Integrity Objectivity - Objectivity - process under which the data is collected and maintained Utility - Utility - usefulness of the information to the intendedusers Integrity Integrity - protections against unauthorized tampering

14 How Is Data Objective ? Objectivity is achieved by using the same procedures to collect, verify, record, maintain, and archive data for each occurrence Objectivity is achieved by using the same procedures to collect, verify, record, maintain, and archive data for each occurrence Ensures that no possible bias exists Ensures that no possible bias exists Procedures must be “Transparent” Procedures must be “Transparent” Procedures must be “Reproducible” Procedures must be “Reproducible”

15 How to Define Transparency Identify: Identify: the source the source assumptions employed assumptions employed analytical methods employed analytical methods employed statistical procedure involved statistical procedure involved Identify/use commonly accepted standards Identify/use commonly accepted standards Document what you did Document what you did

16 How to Define Reproducibility If anyone follows the process the agency used, it will get the same result If anyone follows the process the agency used, it will get the same result An agency is not required to duplicate the process if challenged and is not compelled to run the process to certify that it can be duplicated An agency is not required to duplicate the process if challenged and is not compelled to run the process to certify that it can be duplicated An agency needs to be prepared to explain the process and must ensure that the process was followed in all cases An agency needs to be prepared to explain the process and must ensure that the process was followed in all cases

17 How Is Utility of Data Determined? Based on the relevance of data to the analysis being performed Based on the relevance of data to the analysis being performed Information Quality Act Guidelines - data’s usefulness to the public (Data must have a perceived public benefit) Information Quality Act Guidelines - data’s usefulness to the public (Data must have a perceived public benefit) Must be a connection between strategic mission requirements and data collected/maintained by an agency Must be a connection between strategic mission requirements and data collected/maintained by an agency Intent to eliminate collection and retention of extraneous data Intent to eliminate collection and retention of extraneous data

18 Data From External Sources Agencies must disclose what they know of the quality of the data Agencies must disclose what they know of the quality of the data Transparency and reproducibility standards apply to external information Transparency and reproducibility standards apply to external information Agency can be challenged on “third party data” under the Information Quality Act Agency can be challenged on “third party data” under the Information Quality Act

19 Third Party Data Challenge The response should be to inform the party that possesses the data about the concern and notify the complainant The response should be to inform the party that possesses the data about the concern and notify the complainant While the agency is not responsible for correcting the data, they can be held responsible for relying on the data for decision-making purposes While the agency is not responsible for correcting the data, they can be held responsible for relying on the data for decision-making purposes

20 Data Integrity Integrity refers to the protection of information from unauthorized access or revision, to ensure that the information is not compromised through corruption or falsification Integrity refers to the protection of information from unauthorized access or revision, to ensure that the information is not compromised through corruption or falsification Access and security controls must be sufficient to prevent contamination of the data Access and security controls must be sufficient to prevent contamination of the data

21 “Environmental attorneys should be aware of the DQA and the newly-implemented data quality guidelines from each federal agency. One important reason for this is that it may serve the best interest of a client to file a petition with an agency such as the Environmental Protection Agency, Federal Energy Regulatory Commission, U.S. Fish & Wildlife, Department of the Interior, Office of Surface Mining Reclamation and Enforcement, Bureau of Land Management, or the Bureau of Indian Affairs, challenging the utility, objectivity or integrity of information that agency has disseminated.” “Federal Agencies Subject to Data Quality Act” Susan Bisong, January 10, 2003

22 Request for Correction of Information Who may request a correction of information? Must be an “affected person” Defined as: anyone who may use, be benefited by, or be harmed by the disseminated information

23 Correction Request Contents Specific reference to the information being challenged. Specific reference to the information being challenged. Statement specifying why the complainant believes the information fails to satisfy the standards in the BLM, the DOI or OMB guidance. Statement specifying why the complainant believes the information fails to satisfy the standards in the BLM, the DOI or OMB guidance. How a complainant is affected by the challenged information. The complainant may include suggestions for correcting the challenged information, but that is not mandatory. How a complainant is affected by the challenged information. The complainant may include suggestions for correcting the challenged information, but that is not mandatory. Contact information of the person filing the complaint request for the purpose of responding to the challenge initiated by the individual. Contact information of the person filing the complaint request for the purpose of responding to the challenge initiated by the individual.

Process Diagram for Handling Complaints

BLM Information Quality Page _in_Footer/data_quality.html _in_Footer/data_quality.html A request for correction of information covered by these guidelines should first be filed with the office that disseminated the information. That office has sixty (60) days within which to respond. If any member of the public wishes to challenge that office’s response, they may do so in writing to: Assistant Director, Information Resources Management, Bureau of Land Management 1849 C Street, NW Washington, DC A request for correction of information covered by these guidelines should first be filed with the office that disseminated the information. That office has sixty (60) days within which to respond. If any member of the public wishes to challenge that office’s response, they may do so in writing to: Assistant Director, Information Resources Management, Bureau of Land Management 1849 C Street, NW Washington, DC

Summary The Information Quality Act and the resulting BLM guidelines are intended to ensure that any information disseminated by the BLM will be high quality, accurate, useable information. The Information Quality Act and the resulting BLM guidelines are intended to ensure that any information disseminated by the BLM will be high quality, accurate, useable information. 26