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Information Quality ActInformation Quality Act

Purpose- after this course Purpose- after this course you will be able to…you will be able to…

define what is the Information Quality Actdefine 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 describe Objectivity, Utility, and Integrity of

BLM dataBLM data describe Transparency and reproducibility describe Transparency and reproducibility

of BLM dataof BLM data explain the BLM process for handling explain the BLM process for handling

requests for correction of informationrequests for correction of information

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Public Law 106-554Public Law 106-554

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

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Information Quality ActInformation 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 ActInformation Quality Act

Sometimes mistakenly called the Sometimes mistakenly called the ‘Data Quality Act’‘Data Quality Act’

Does not require data to be of a Does not require data to be of a certain quality, only requires certain quality, only requires Federal Agencies be able to say Federal Agencies be able to say what is known about the quality of what is known about the quality of disseminated datadisseminated data

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Information Quality ActInformation Quality Act

Further requires that Further requires that agencies report annually agencies report annually on the number and nature on the number and nature of complaints received of complaints received and the steps that were and the steps that were taken to resolve themtaken to resolve them

Also requires agencies to establish Also requires agencies to establish mechanisms for receiving requests for mechanisms for receiving requests for correction of information correction of information

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What information is coveredWhat information is coveredby the Act?by the Act?

Information must be disseminatedInformation must be disseminated

Either published or publicly available Either published or publicly available on or after October 1, 2002 on or after October 1, 2002

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What information is coveredWhat information is coveredby the Act?by the Act?

Agency SponsoredAgency Sponsored

Agency creates and uses this data or Agency creates and uses this data or has decided to use this datahas decided to use this data

Could include third party data if it is Could include third party data if it is used for agency decision-making used for agency decision-making and/or can be considered “endorsed” and/or can be considered “endorsed” by the agencyby the agency

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What information is What information is notnot covered?covered?

• Party-to-Party transactionsParty-to-Party transactions

• Internet hyperlinks and other referencesInternet hyperlinks and other references

• OpinionsOpinions

• Press release, fact sheets, press conferences Press release, fact sheets, press conferences or similar communications in any mediumor similar communications in any medium

• Public filings of informationPublic filings of information

• Dissemination of information by an agency-Dissemination of information by an agency-employed scientist, grantee, or contractoremployed scientist, grantee, or contractor

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What information is What information is notnot covered? covered?

• Testimony and other submissions to CongressTestimony and other submissions to Congress

• Inadvertent or unauthorized disclosure of Inadvertent or unauthorized disclosure of information intended only for inter-agency information intended only for inter-agency and/or intra-agency use of communicationand/or intra-agency use of communication

• Correspondence with individualsCorrespondence with individuals

• Records covered by other laws, including Records covered by other laws, including FOIA, Privacy Act, etc.FOIA, Privacy Act, etc.

• Archived recordsArchived records

BLM Influential InformationBLM Influential Information

When information is defined as influential, there When information is defined as influential, there is an added level of scrutiny afforded this is an added level of scrutiny afforded this information, to include the need to ensure it is information, to include the need to ensure it is reproducible.reproducible.

At BLM, At BLM, influential information influential information is that which is is that which is expected to have a clear and substantial impact expected to have a clear and substantial impact at the national level for major public and private at the national level for major public and private policy decisions as they relate to Federal public policy decisions as they relate to Federal public lands and resources issues. lands and resources issues.

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BLM Influential InformationBLM Influential Information

For the purposes of the BLM Information Quality For the purposes of the BLM Information Quality Guidelines, BLM will generally consider the following Guidelines, BLM will generally consider the following classes of information to be influential, and, to the extent classes of information to be influential, and, to the extent that they contain scientific, financial, or statistical that they contain scientific, financial, or statistical information, that information will adhere to a higher information, that information will adhere to a higher standard of quality. standard of quality. • Information disseminated in support of top BLM actions (i.e., Information disseminated in support of top BLM actions (i.e.,

substantive notices, policy documents, studies, guidance) that substantive notices, policy documents, studies, guidance) that demand the ongoing involvement of the Director's office demand the ongoing involvement of the Director's office

• Information used in cross-bureau issues that have the potential Information used in cross-bureau issues that have the potential to result in major cross-bureau policies and highly controversial to result in major cross-bureau policies and highly controversial information that is used to advance the BLM's priorities.information that is used to advance the BLM's priorities.

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Objectivity, Utility, & IntegrityObjectivity, Utility, & Integrity

ObjectivityObjectivity - - process under which the data is collected

and maintained

UtilityUtility - - usefulness of the information to

the intendedusers

IntegrityIntegrity - protections against unauthorized

tampering

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How Is Data Objective ?How Is Data Objective ?

Objectivity is achieved by using the same Objectivity is achieved by using the same procedures to collect, verify, record, procedures to collect, verify, record, maintain, and archive data for each maintain, and archive data for each occurrenceoccurrence

Ensures that no possible bias existsEnsures that no possible bias exists

Procedures must be “Transparent”Procedures must be “Transparent”

Procedures must be “Reproducible”Procedures must be “Reproducible”

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How to Define TransparencyHow to Define Transparency Identify:Identify:

• the sourcethe source• assumptions employedassumptions employed• analytical methods employedanalytical methods employed

• statistical procedure involvedstatistical procedure involved

Identify/use commonly accepted standardsIdentify/use commonly accepted standards

Document what you didDocument what you did

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How to Define ReproducibilityHow to Define Reproducibility If anyone follows the process the agency If anyone follows the process the agency

used, it will get the same resultused, it will get the same result An agency is An agency is notnot required to duplicate the required to duplicate the

process if challenged and is process if challenged and is notnot compelled to compelled to run the process to certify that it can be run the process to certify that it can be duplicatedduplicated

An agency needs to be prepared An agency needs to be prepared to explain the process and must to explain the process and must ensure that the process was ensure that the process was followed in all casesfollowed in all cases

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How Is Utility of Data Determined?How Is Utility of Data Determined?

Based on the Based on the relevancerelevance of data to the analysis of data to the analysis being performedbeing performed

Information Quality Act Guidelines - data’s Information Quality Act Guidelines - data’s usefulness to the public (Data must have a usefulness to the public (Data must have a perceived public benefit)perceived public benefit)

Must be a connection between strategic mission Must be a connection between strategic mission requirements and data collected/maintained by requirements and data collected/maintained by an agencyan agency

Intent to eliminate collection and retention of Intent to eliminate collection and retention of extraneous dataextraneous data

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Data From Data From External SourcesExternal Sources

Agencies must disclose what they know of Agencies must disclose what they know of the quality of the datathe quality of the data

Transparency and reproducibility standards Transparency and reproducibility standards apply to external informationapply to external information

Agency can be challenged on “third party Agency can be challenged on “third party data” under the Information Quality Act data” under the Information Quality Act

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Third Party DataThird Party DataChallengeChallenge

The response should be to inform the party The response should be to inform the party that possesses the data about the concern that possesses the data about the concern and notify the complainantand notify the complainant

While the agency is not responsible for While the agency is not responsible for correcting the data, they can be held correcting the data, they can be held responsible for relying on the data for responsible for relying on the data for decision-making purposesdecision-making purposes

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Data IntegrityData Integrity

Integrity refers to the protection of Integrity refers to the protection of information from unauthorized access information from unauthorized access or revision, to ensure that the or revision, to ensure that the information is not compromised information is not compromised through corruption or falsificationthrough corruption or falsification

Access and security controls must be Access and security controls must be sufficient to prevent contamination of sufficient to prevent contamination of the datathe data

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“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 Federal Agencies Subject to Data Quality Act”Data Quality Act”

Susan Bisong, January 10, 2003

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Request for Correction of Request for Correction of InformationInformation

Who may request a correction of Who may request a correction of information?information?

Must be an “affected person”Must be an “affected person”

Defined as: anyone who may use, be Defined as: anyone who may use, be benefited by, or be harmed by the benefited by, or be harmed by the

disseminated informationdisseminated information

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Correction Request ContentsCorrection Request Contents • Specific reference to the information being Specific reference to the information being challenged. challenged.

• Statement specifying why the complainant Statement specifying why the complainant believes the information fails to satisfy the believes the information fails to satisfy the standards in the BLM, the DOI or OMB guidance. standards in the BLM, the DOI or OMB guidance.

• How a complainant is affected by the challenged How a complainant is affected by the challenged information. The complainant may include information. The complainant may include suggestions for correcting the challenged suggestions for correcting the challenged information, but that is not mandatory. information, but that is not mandatory.

• Contact information of the person filing the Contact information of the person filing the complaint request for the purpose of responding complaint request for the purpose of responding to the challenge initiated by the individual. to the challenge initiated by the individual.

Process Diagram for Handling Process Diagram for Handling ComplaintsComplaints

Challenge to the Quality of

Disseminated Information

Specific reference to the challenged information

Statement specifying false information

Statement justifying interests (affects)

Contact Information

BLM Local Office Receives Complaint

BLM provides Notification of

Receipt w/in 10 days

BLM Local Office Evaluates Complaint

(w/in 60 days of receipt)

Determine if Complaint has

Merit

Complainant notified

Complainant notified

Take reasonable steps to withdraw

informationDetermine if

Information will be corrected

YES

NO

YES

Appeal to AD-500, then Director

Complainant dissatisfied with

disposition

YES

http://www.blm.gov/wo/st/en/National_Page/Notices_used_in_Footer/data_quality.html

BLM Information Quality PageBLM 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 A request for correction of information covered by these guidelines should first be filed with the office that guidelines should first be filed with the office that disseminated the information. That office has sixty (60) disseminated the information. That office has sixty (60) days within which to respond. If any member of the public days within which to respond. If any member of the public wishes to challenge that office’s response, they may do so wishes to challenge that office’s response, they may do so in writing to: in writing to:

Assistant Director, Information Resources Management, Assistant Director, Information Resources Management, Bureau of Land ManagementBureau of Land Management1849 C Street, NW1849 C Street, NWWashington, DC 20240Washington, DC 20240

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SummarySummary

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

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