Information Quality

OMB M-19-15 is in effect

Ensuring the Quality of the Information Disseminated by the Department

The Department's Information Quality Guidelines are in accordance with the provisions of the Treasury and General Government Appropriations Act (P.L. 106-554), and OMB government-wide guidance. The administrative correction mechanisms outlined in the guidelines apply to information disseminated by the Department on or after October 1, 2002, regardless of when it was first disseminated. These Guidelines provide policy and procedural guidance to agency staff and inform the public about agency policies and procedures for making corrections to published information.

Information Quality and Peer Review Disclaimer

References

OMB Guidelines for Information Dissemination

The Department components below have published information quality guidelines.

Executive Office of Immigration Review
Office of Justice Programs
Office of Justice Programs/Bureau of Justice Statistics
Office of the Inspector General

DOJ Information Quality Guidance

Introduction and Purpose

This Guidance provides the standards for Department of Justice (DOJ)-wide information quality, as required under the Information Quality Act (IQA) and related guidelines.[1]? Senior Leadership Offices and Heads of Components (SLOs & HoCs) are responsible for the quality of the information they produce and disseminate to the public.?

The information in this document is intended as guidance for the SLOs & HoCs.? It is not regulation, is not legally enforceable, and does not create any legal rights or impose any legally binding requirements or obligations on DOJ or the public.? Nothing in this guidance affects any otherwise available judicial review of the agency’s actions.? This Guidance does not override other compelling interests such as privacy, trade secrets, intellectual property, and other confidential protections.

Oversight / Management Responsibility

OMB Memorandum M-19-15 requires agencies to maximize the quality, objectivity, utility, and integrity of information disseminated to the public, and define mechanisms for redress by affected parties, where appropriate.?

In response, SLOs & HoCs will use this guidance to:

  1. Pre-Dissemination Practices.? Establish SLO & HoC information pre-dissemination practices that include:
  • Establishing ?a basic standard of quality for information maintained and disseminated by the SLO & HoC.
  • Establishing information quality procedures for their SLO & HoC, as necessary, and apply the procedures before disseminating SLO & HoC information.
  1. Request for Correction.? Establish a process for the public to seek timely correction of information maintained and disseminated by the SLO & HoC that does not comply with OMB, DOJ, or SLO & HoC guidelines. ?
  2. Reporting.? Report on SLO & HoC IQA practices to JMD as required for OMB reporting.

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Influential Information

SLOs & HoCs will identify and provide additional scrutiny for “influential” information. SLOs & HoCs may designate certain classes of information as "influential" in the context of their specific programs. Absent such designations, SLOs & HoCs will determine whether information is influential on a case-by-case basis, using the principles articulated in this Guidance.

Influential information is scientific, financial, or statistical information expected to have a genuinely clear and substantial impact at the national level, or on major public and private policy decisions as they relate to federal justice issues. A clear and substantial impact is one that has a high probability of occurring. The "influential" designation is intended to be applied to information only when clearly appropriate. SLOs & HoCs will not designate information products or types of information as influential on a regular or routine basis.

General Exemptions

Except for those categories of information exempted (see below), this Guidance applies to all information disseminated by DOJ, and DOJ-initiated or sponsored dissemination of information by DOJ grantees, contractors, or cooperators on or after October 1, 2002, regardless of when the information was first disseminated. ?This Guidance applies not only to information that DOJ generates, but also to information that other parties provide to DOJ that DOJ disseminates publicly. ??This Guidance does not override other compelling interests, including, but not limited to, privacy, trade secrets, intellectual property, and other confidential protections.?? Additionally, this Guidance does not apply when the agency's presentation makes it clear that the material offered is someone's opinion rather than fact or the agency's views.?

Pre-Dissemination Practices

SLOs & HoCs will conduct pre-dissemination reviews of their information products that incorporate the following requirements.

  • Quality.? During the reviews, consider the level of quality for each type of product it disseminates, based on the utility, objectivity, and integrity of the information.? Utility refers to the how users might use the data, whether for its intended use or other purposes. SLOs & HoCs ensure the utility of the information by continuously monitoring information needs and developing new information sources by revising existing methods, models, and information products. Objectivity refers to whether the disseminated information is accurate, reliable, and unbiased as a matter of presentation and substance. SLOs & HoCs will ensure objectivity by using reliable data sources, sound analytic techniques, and document methods and data sources. Finally, SLOs & HoCs will maintain the integrity of information, ensuring it is protected from unauthorized access, corruption, or revision.?
  • Peer Review of Influential Information.? When using scientific information, including third-party data or models, ensure compliance with the requirements of OMB’s Information Quality Bulletin for Peer Review.[2] When conducting peer review, SLOs & HoCs will ask reviewers to evaluate the objectivity of the underlying data and the sensitivity of the agency’s conclusions to analytic assumptions. When influential information that has been peer reviewed changes significantly (e.g., as a result of the peer reviewer comments, additional agency analysis, or further consideration) the SLO & HoC will conduct a second peer review.
  • Information Protection.? While prioritizing increased access to data and analytical frameworks used to generate information, ensure compliance with statutory, regulatory, and Department policy requirements for protections of data security, privacy and confidentiality, proprietary data, and the confidentiality of business, law enforcement, and national security information.? Ensure that all interests in privacy and confidentiality are protected, and any disclosure of personally identifiable information (PII) takes place pursuant to applicable statutory, regulatory, and Department policy requirements.? Any questions relating to appropriate disclosure of PII should be coordinated with the Department’s Senior Agency Official for Privacy, the Chief Privacy and Civil Liberties Officer (CPCLO), consistent with DOJ policy.?
  • Options for Wider Access.? Explore methods that provide wider access to datasets while reducing the risk of improper disclosures of PII.? Tiered access[3] offers promising ways to make data widely available while applying protections for security, privacy, confidentiality, and ensuring appropriate access and use.?
  • Statistical Information.? Engage in statistical activities[4] that are transparent and based on sound statistical methods.? Transparency is a broad concept, which can include a clear description of the methods, data sources, assumptions, outcomes, limitations, and related information to?permit a data user to understand how the statistical information product was designed or produced.? Sound statistical activities and methods generate information (data and analysis) for a statistical purpose[5] that is accurate, reliable, and unbiased.? Procedures to promote sound statistical activities and methods will cover the planning of statistical data systems, the collection of statistical data, and the processing of statistical data (including analysis).? Transparency refers to a clear description of the methods, data sources, assumptions, outcomes, limitations, and related information to permit a data user to understand how the statistical information was designed or produced.
  • Scientific Information.? Ensure documented methods used on the same data set achieve consistent results. Communicate transparently by “including a clear explication of underlying assumptions; accurate contextualization of uncertainties; and a description of the probabilities associate with both optimistic and pessimistic projections, including best-case and worst-case scenarios.”[6]??
  • Program, Regulatory and Administrative Information.? Establish procedures for clearly documenting and communicating the quality of program, regulatory, or administrative information that has potential for secondary use (aka secondary analysis), or other use.? For questions relating to authorized or unauthorized secondary uses or analysis of information that includes PII, SLOs and HoCs should coordinate with Senior Component Officials for Privacy, subject to approval by the CPLO, in order to ensure privacy requirements are met, and risks are managed.
  • Program, Regulatory and Administrative Information.? Establish procedures for clearly documenting and communicating the quality of program, regulatory, or administrative information that has potential for authorized secondary use, (aka secondary analysis).? For secondary analysis that includes PII, components should coordinate with the Senior Component Officials for Privacy, subject to approval by the CPCLO, to mitigate risks to individual privacy.
  • Non-Government Information.? When using non-government sources[7] to create influential information that represents SLO & HoC views, communicate to the public sufficient information on the characteristics of the data and analysis, including its scope, generation protocols, and any other information necessary to allow the public to reproduce the SLO & HoC’s conclusions.
  • Cross Agency Information.? When making information originally collected or developed by other Federal agencies available to the public in a cross-agency dissemination, clearly communicate to the public the quality of the information contributed by DOJ.?
  • Information Aggregation. ?Account for the ”mosaic effect” of information aggregation, which occurs when the information in an individual dataset, in isolation, may not pose a risk of identifying an individual but when combined with other available information could pose such a risk.
  • Transparent Communication.? Provide the public with documentation about each dataset released to allow data users to determine the fitness of the data for the purpose for which third parties may consider using.? Such documentation can include the strengths and weaknesses of the data, analytical limitations, security requirements, and processing options.
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Request for Correction

SLOs & HoCs will allow the public to submit a Request for Correction (RFC) when disseminated information does not comply with OMB, DOJ, and SLO & HoC policy, guidelines, and procedures. ?SLOs & HoCs will process the request in accordance with the below.

  • 120 Calendar Day Response.? Respond to RFCs within 120 calendar days of receipt, or obtain concurrence from the requester to an extension.
  • RFC Review.? Conduct a thorough review of the information being challenged, the processes that were used to create and disseminate the information and the conformity of the information and processes with OMB, DOJ and SLO & HoC policy, guidelines, and procedures. Provide a point-by-point response addressing data quality arguments in the RFC.? Do not opine on the requestor’s or the Department’s policy position. Determine whether a correction is warranted, and, if so, what corrective action to take.?? The corrective action will be determined by the nature and timeliness of the information and factors, such as the significance and magnitude of the error. ?DOJ is not required to change or alter the content or status of information simply based on the receipt of a RFC.
  • Legal and OMB Review.? Before releasing responses to the requestor, complete all appropriate internal review, and share the draft response with OMB for its assessment of compliance with OMB guidance.
  • Request for Reconsideration.? The requestor may file a Request for Reconsideration within 45 calendar days from the date that DOJ transmitted its decisions from the original RFC. ?The same agency personnel who opined during the RFC process will not participate in deciding a Request for Reconsideration.? Requestors will be aware they bear the "burden of proof" with respect to the necessity for correction as well as with respect to the type of correction they seek. ?DOJ will base its decision on the merits of the information provided by the requestor and may be unable to process, in a timely manner or at all, requests that omit one or more of the requested elements. ?DOJ will not attempt to contact the requestor to obtain additional information.

Reporting

SLOs & HoCs will report on their information quality practices as required for OMB reporting.? This includes reporting on downstream uses of their information collection systems as required by OMB in the Information Collection Request under the Paperwork Reduction Act (PRA).

Additional Exemptions for Categories of Information

The following non-exhaustive list, desribes context in which information may be ?disseminated that are exempted from this Guidance.?

  1. Limited to government employees or agency contractors or grantees unless the agency represents the information as, or uses the information in support of, an official agency position, or the grantee is disseminating the information at the request of the agency, or the grant requires agency approval of the information request
  2. Intra-or inter-agency use or sharing of government information
  3. Responses to requests for agency records under the Freedom of Information Act, the Privacy Act of 1974, the Federal Advisory Committee Act or other similar law
  4. Distribution limited to correspondence with individuals or persons
  5. Press releases fact sheets, press conferences or similar communications (in any medium) that announce, support or give public notice of information in DOJ
  6. Information relating to subpoenas, or adjudicative processes
  7. Archival records disseminated by federal agency libraries or similar federal data repositories
  8. Congressional testimony and other submissions to Congress containing information that DOJ has previously provided to the public; and
  9. Procedural, operational, policy and internal manuals prepared for the management and operations of DOJ that are not primarily intended for public dissemination
  10. Non-public information, including information incorrectly/inadvertently disclosed Civil, criminal, and administrative information for investigations or proceedings

Requester Information?

To obtain consideration, requesters will provide the following information:

  • Statement that the Request for Correction of information is submitted under DOJ’s Information Quality Guidance.
  • Requestor contact information, including the name, mailing address, telephone number, fax number (if any), email address (if any), and organization affiliation (if any) of the person requesting the correction.
  • Specific description of information to correct - the name of the DOJ report or data product, the date of issuance or other identifying information such as the URL of the web page, and a detailed description that clearly identifies the specific information contained the report or data product for which a correction is being sought
  • Explanation of noncompliance with OMB and/or DOJ Information Quality Guidance – the explanation will describe how the information is incorrect or fails to meet either the OMB or DOJ information quality guidelines.
  • Explanation of the impact of the alleged error. Provide an explanation that specifies how the alleged error harms or how a correction would benefit the requestor.
  • Recommendation and justification for how the information will be corrected – provide an explanation that gives the requestor’s specific recommendations for how the information will be corrected and that describes the requestor’s position for why DOJ will adopt the recommendation.
  • Supporting documentary evidence – provide supporting documentary evidence, such as comparable data or research results on the same topic to assist in evaluating the merits of the request.

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[1] See Treasury and General Government Appropriations Act, 2001, Pub. L. No. 106-554 § 515(a) (2000) (as codified at 44 U.S.C. § 3516 note); Improving Implementation of the Information Quality Act, Office of Mgmt. & Bud., OMB Memorandum No. M-19-15 (April 24, 2019) (available at:? www.whitehouse.gov/wp-content/uploads/2019/04/M-19-15.pdf); Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies, 67 Fed. Reg. 8452 (OMB Feb. 22. 2002) (available at

www.federalregister.gov/documents/2002/02/22/R2-59/guidelines-for-ensuring-and-maximizing-the-quality-objectivity-utility-and-ingrity-of-information).

[2] See Issuance of OMB’s “Final Information Quality Bulletin for Peer Review,” Office of Mgmt. & Bud. Memorandum No. M-05-03 (Dec. 16, 2004) (available at:? https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/2005/m05-03.pdf).

[3] Tiered Access refers to the creation of multiple versions of a single dataset with varying levels of specific and protection.? One of the advantages of tiered access is that data users, who wish to conduct activities with a statistical purpose, do not need to obtain special authorization to access versions of the data in the least restricted tiers, enabling them to conduct research while maintaining protection requirements.

[4] The term “statistical activities”-- (A) means the collection, compilation, processing, or analysis of data for the purpose of describing or making estimates concerning the whole, or relevant groups or components within, the economy, society, or the natural environment; and (B) includes the development of methods or resources that support those activities, such as measurement methods, models, statistical classifications, or sampling frames.? 44 U.S.C. § 3561(10).

[5] The term “statistical purpose”-- (A) means the description, estimation, or analysis of the characteristics of groups, without identifying the individuals or organizations that comprise such groups; and (B) includes the development, implementation, or maintenance of methods, technical or administrative procedures, or information resources that support the purposes described in subparagraph (A). Id. at (12).

[6] John P. Holdren, Office of Sci. & Tech. Pol’y, Memorandum for the Heads of Executive Departments and Agencies, Scientific Integrity, (Dec. 17, 2010), at 2 (available at:?obamawhitehouse.archives.gov/sites/default/files/microsites/ostp/scientific-integrity-memo-12172010.pdf).

[7] Examples of non-government sources include: scientific research published in peer review journals; data submitted by industry or non-government organizations in response to Requests for Information; information generated by state, local, tribal, or international governments; web scraping exercises; data purchased from the private sector; and data generated by sensors and satellites.?

Updated September 25, 2019

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