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Appendix E3-C: Policy and Sensitivity Review Checklist for Division and Office Chiefs

This checklist should be used to determine the suitability for publication and release of Census Bureau information products.

If the answer to any of the following questions is “yes,” then the information product proposed for publication/release must not be released until the issue raised by the question has been resolved appropriately.

  1. Is the information product inconsistent with the Census Bureau’s mission?
  2. Would publication/release of the information product compromise the Census Bureau’s ability to perform its mission?
  3. Does the information product express views on or discuss any of the following topics in an inappropriate manner or in a way that is inconsistent with laws, Commerce Department policies, or Census Bureau policies?
    1. Laws, regulations, Federal Register notices, court cases, congressional testimony, or policy statements or decisions pertaining to the Commerce Department or the Census Bureau.

      Examples include:
      • Sections of the Commerce Department’s Code of Federal Regulations.
      • Chapters of the Census Bureau’s Policies and Procedures Manual.
      • Census Bureau’s Data Stewardship Policies.
      • Census Bureau’s Information Technology Security Policies and Regulations.
    2. The Freedom of Information Act or the Privacy Act.
    3. Matters that are currently being investigated by Congress.
    4. Issues relating to privacy, confidentiality, data security, or access to and use of administrative records (including any issues related to personally or business identifiable information or data breaches).
    5. Budget/appropriations issues.
    6. Any issue that is politically sensitive or that has been the subject of recent news articles, correspondence, hearings, or current or potential lawsuits.

      Examples of sensitive issues include:
      • Current poverty estimates.
      • Concerns about the American Community Survey (ACS).
      • Concerns about Local Update of Census Addresses Program (LUCA).
      • Concerns about the enumeration of sensitive populations (racial or ethnic populations, immigrants, the homeless, or Group Quarter’s (GQ) populations such as prisoners, residents of nursing homes, or college students).
      • Concerns about the enumeration of overseas Americans.
      • Concerns about statistical sampling or adjustment of decennial census counts.
    7. Sensitive historical issues like the internment of Japanese Americans or statistical adjustment of the decennial census.
  4. Is it possible that release of the information product will affect any national policy issues related to the topics it discusses?
  5. Does the information product discuss matters related to sharing confidential Title 13 and/or Title 26 information/data in a way that suggests the sharing is inconsistent with laws, Census Bureau policies, or IRS policies?
  6. Does the information product suggest or imply that the Census Bureau may be cooperating in any way with an enforcement, regulatory, or administrative activity of another government agency?
    • An example would be a discussion of providing tabulations of public-use data to a federal law enforcement agency. It would be acceptable to discuss the Census Bureau’s policy to encourage the agency to perform the tabulations and to inform the agency that any tabulations provided by the Census Bureau are subject to public disclosure.
  7. Does the information product discuss specific contract/acquisitions issues or information in a manner that improperly discloses commercial proprietary information or trade secrets?
  8. Does the information product single out a particular group or category of individuals to receive special treatment, consideration, or recognition (e.g., identifying key partners who contributed to the decennial census effort) in a manner that might compromise the Census Bureau’s ability to perform its mission?
  9. Does the information product contain any subject matter or language that might be deemed offensive, insensitive, or inappropriate?
  10. Does the information product lack the disclaimer (if required) indicating that the information product represents the author’s views (on statistical, methodological, technical, or operational issues) and does not necessarily represent the position of the Census Bureau? (Statistical Quality Standard E2, Reporting Results, specifies when the disclaimer is required.)

  11. Note: If the disclaimer is required but missing, the author must add it before the information product may be published or released.

Page Last Revised - October 8, 2021
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