Purpose- after this course you will be able to… define what is the Information Quality Act describe what data are affected by the Act describe Objectivity, Utility, and Integrity of BLM data describe Transparency and reproducibility of BLM data explain the BLM process for handling requests for correction of information
Public Law 106-554 Section 515 of the Treasury and General Government Appropriations Act for FY 2001
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’ 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
Information Quality Act • Also requires agencies to establish mechanisms for receiving requests for correction of information • Further requires that agencies report annually on the number and nature of complaints received and the steps that were taken to resolve them
What information is coveredby the Act? • Information must be disseminated • Either published or publicly available on or after October 1, 2002
What information is coveredby the Act? • Agency Sponsored • 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
What information is not covered? • Party-to-Party transactions • Internet hyperlinks and other references • Opinions • Press release, fact sheets, press conferences or similar communications in any medium • Public filings of information • Dissemination of information by an agency-employed scientist, grantee, or contractor
What information is not covered? • Testimony and other submissions to Congress • Inadvertent or unauthorized disclosure of information intended only for inter-agency and/or intra-agency use of communication • Correspondence with individuals • Records covered by other laws, including FOIA, Privacy Act, etc. • 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. 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.
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. • 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 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.
Objectivity, Utility, & Integrity Objectivity - process under which the data is collected and maintained Utility - usefulness of the information to the intended users Integrity- protections against unauthorized tampering
How Is Data Objective ? • 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 • Procedures must be “Transparent” • Procedures must be “Reproducible”
How to Define Transparency • Identify: • the source • assumptions employed • analytical methods employed • statistical procedure involved • Identify/use commonly accepted standards • Document what you did
How to Define Reproducibility • 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 needs to be prepared to explain the process and must ensure that the process was followed in all cases
How Is Utility of Data Determined? • 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) • Must be a connection between strategic mission requirements and data collected/maintained by an agency • Intent to eliminate collection and retention of extraneous data
Data From External Sources • Agencies must disclose what they know of the quality of the data • Transparency and reproducibility standards apply to external information • Agency can be challenged on “third party data” under the Information Quality Act
Third Party DataChallenge • 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
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 • Access and security controls must be sufficient to prevent contamination of the data
“Federal Agencies Subject to Data Quality Act” Susan Bisong, January 10, 2003 “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.”
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
Correction Request Contents • 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. • 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.
Process Diagram for Handling Complaints http://www.blm.gov/wo/st/en/National_Page/Notices_used_in_Footer/data_quality.html
BLM Information Quality Page http://www.blm.gov/wo/st/en/National_Page/Notices_used_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 Management1849 C Street, NWWashington, DC 20240
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.