Purpose: The purpose of this standard is to ensure that information products released by the Census Bureau receive the appropriate reviews required to ensure they are of high quality and do not disclose protected information or administratively restricted information. This standard also ensures that plans to participate at public events are reviewed and approved.

Scope: The Census Bureau’s statistical quality standards apply to all information products released by the Census Bureau and the activities that generate those products, including products released to the public, sponsors, joint partners, or other customers. All Census Bureau employees and Special Sworn Status individuals must comply with these standards; this includes contractors and other individuals who receive Census Bureau funding to develop and release Census Bureau information products.

In particular, this standard applies to the review and approval of:

• Information products, including internal information products that are subsequently released to the public.
• Participation at public events.

Note: Information products (e.g., professional papers, presentations, or other materials) prepared by a Census Bureau employee that pertain to the Census Bureau’s programs, policies or operations and are related to the employee’s job or area of expertise, are covered by this standard, even if prepared on the employee’s own time, without the use of Census Bureau resources or support. See Department Administrative Order (DAO) 219-1, Section 11, Non-Official Public Communications.

Exclusions:
In addition to the global exclusions listed in the Preface, this standard does not apply to:

• Information products prepared or delivered by Census Bureau employees, but which are not related to programs, policies, or operations of the Department of Commerce or the Census Bureau. (Census Bureau employees or Special Sworn Status individuals, who want to include their Census Bureau affiliation as biographical information in the communication, should obtain guidance from the Office of Analysis and Executive Support.)

Key Terms: Census Bureau publications, custom tabulations, direct comparison, disclosure, implied comparison, information products, participation, policy view, public event, and working papers.

Requirement E3-1: All Census Bureau information products must be reviewed before release to ensure that disclosure avoidance techniques necessary to prevent unauthorized release of protected information or administratively restricted information have been implemented completely and correctly. Information protected by federal law (e.g., Title 13, Title 15, and Title 26) and by the Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA) is covered by this requirement. (Statistical Quality Standard S1, Protecting Confidentiality, addresses disclosure avoidance techniques.)

Sub-Requirement E3-1.1: The Census Bureau’s Disclosure Review Board (DRB) procedures must be followed for information products that use data protected by Title 13 to prevent unauthorized release of protected information or administratively restricted information, particularly personally identifiable information or business identifiable information. (See the DRB Intranet Web site for further guidance and procedures.)

Requirement E3-2: To maintain the Census Bureau’s position as unbiased and neutral with regard to policy and political issues, employees must submit an Event Participation Approval Form, through their Division Chief, to the Chief, International Relations Office, to receive approval to participate in public events within the United States, except for the conferences noted below. Appendix E3-A contains the Event Participation Approval Form. See the Census Bureau’s Intranet Web page on participation at public events for further information.

Definitions:

1. A “public event” means that the event is open to the general public, including events that require a registration fee.
2. “Participation” means that the employee takes an active role in the event.

Examples of the types of activities that constitute participation and require an Event Participation Approval Form include:

• Presenting a paper or poster at a professional association conference.
• Organizing and/or chairing a session at a professional association conference.
• Acting as a discussant.
• Serving as a panelist.
• Giving a seminar or workshop at colleges, universities, the Washington Statistical Society, or other organizations.
• Making a presentation as an expert member of a working group or other group.
• Staffing a Census Bureau-sponsored booth at a professional association conference or at a trade show.
• Conducting Foreign Trade Division export compliance seminars on the Foreign Trade Regulations and electronic export reporting for U.S. exporters.

Examples of the types of activities that do not constitute participation and do not require an Event Participation Approval Form include:

• Attending a conference or seminar as a member of the audience only.
• Participating in corporate recruiting sponsored by the Human Resources Division, including conducting information sessions and other presentations at colleges or universities.

Examples of events that are not public and do not require an Event Participation Approval Form include:

• Attending a meeting with a survey sponsor.
• Attending private planning meetings for cooperation between statistical agencies.
• Attending meetings sponsored by the Census Bureau to elicit input from survey users.
• Presenting a Center for Statistical Research and Methodology seminar at the Census Bureau.

Notes:

1. The Event Participation Approval Form is not needed for the following conferences:
   • Joint Statistical Meetings (JSM) of the American Statistical Association (ASA)
   • American Association of Public Opinion Research (AAPOR)
   • International Conference on Establishment Surveys (ICES)
   • Population Association of America (PAA)
   • American Economics Association
   • International Statistical Institute (ISI)
   • Association of American Geographers (AAG)
2. Multiple employees that participate in the same session of a conference need submit only one form.
3. Contact the Chief of the International Relations Office regarding attendance at international events or for questions regarding whether an Event Participation Form must be submitted

Requirement E3-3: All information products must undergo review and receive approval before they are released to the public, to sponsors, or to other customers. Sub-Requirements E3-3.1 through E3-3.5 describe the types and levels of review needed.

Examples of information products covered by this requirement include, but are not limited to:

• News releases.
• Census Bureau publications (i.e., information products that the program’s Associate Director has reviewed and approved and the Census Bureau has affirmed their content).
• Working papers (e.g., technical papers and division reports intended for release to the public).
• Professional papers (e.g., journal articles, book chapters, conference papers, poster sessions, and written discussant comments).
• Research reports used to guide decisions about Census Bureau programs.
• Abstracts.
• Presentations at public events, such as seminars or conferences. (See Requirement E3-4 for additional requirements for presentations.)
• Handouts for distribution at public events.
• Data sets (e.g., public-use files) and their associated documentation.
• Tabulations, including custom tabulations, estimates, and their associated documentation.
• Statistical graphs, figures, and thematic maps.

Notes:

1. Drafts of information products to be released for limited circulation (e.g., professional papers) outside the Census Bureau are subject to the requirements for a supervisory review as stated in Sub-Requirement E3-3.1. The other reviews (i.e., content/subject matter, statistical, and policy) are not required unless the supervisor determines that the product needs any of those reviews.
2. While not a statistical quality requirement, Census Bureau Policy requires that the Chief of the Demo-Econ Media Relations Branch in the Public Information Office (PIO) be informed of any information products or other materials being prepared for public use. (See the Census Bureau Policies and Procedures Manual, Chapter B-13 – Clearance and Release of Public Information Materials, for further guidance and procedures.)

Sub-Requirement E3-3.1: All information products must undergo a supervisory review and receive approval.

1. The following table specifies who must perform the supervisory review and approval.



Type of Information Product	Supervisory Reviewers
Census Bureau publications	Author’s immediate supervisor Author’s Division or Office Chief Associate Director of the program releasing the information product
News releases	Author’s immediate supervisor Author’s Division or Office Chief Associate Director of the program releasing the information product Associate Director for Communications
All other information products	Author’s immediate supervisor Author’s Division or Office Chief

2. The supervisory reviewer must verify that the following requirements have been met.
   
   All information products
   
   1. The content of the information product is technically and factually correct.
   2. All mandated disclosure avoidance procedures have been followed.
   3. The provisions for reviewing and releasing information products in any data-use agreements have been followed.
   4. The information product complies with the Census Bureau’s statistical quality standards.
   5. If the information product is a draft to be released for limited circulation outside the Census Bureau, it must include a disclaimer that states the draft is still under review and is not for distribution.
      
      All information products containing text
      
   6. No policy views are expressed in the information product.
   7. No personal views are expressed in Census Bureau publications or news releases.
   8. Only personal views on statistical, methodological, technical, or operational issues are expressed in information products other than Census Bureau publications and news releases.
   9. A disclaimer is included on the title page in all information products except as noted below.  The author may determine the wording of the disclaimer as long as it indicates that any views expressed are those of the author and not necessarily those of the Census Bureau.  An example of a disclaimer is: “Any views expressed are those of the author(s) and not necessarily those of the U.S. Census Bureau.”
      

      Note: The disclaimer is not needed for:

      • Census Bureau publications, new releases, abstracts, and handouts for advisory committee meetings.
      • Information products that are distributed internally.
      • Information products that have been reviewed and approved by the Associate Director as not needing a disclaimer because the documents do not contain personal views (e.g., working papers).
      • Presentation slides, unless they will be distributed as handouts or published (e.g., in conference proceedings).
   10. The information is presented logically and any results follow from the data and the analysis.
   11. Any anomalous findings are addressed appropriately.
   12. Correct grammar is used.
   13. Presentation slides use the required Census Bureau PowerPoint template found on the Customer Liaison Marketing and Services Office (CLMSO) Intranet Web site. (Note: This is a Census Bureau Corporate Identity Standard.)
       
       

       Notes:

       1. When the author is a Division or Office Chief, the supervisory reviewer is the author’s Associate Director. When the author is a higher-level manager than a Division or Office Chief, the supervisory review is waived.
       2. When the author is a Senior Technical (ST) employee, the supervisory reviewer is the Chief of the Center for Statistical Research and Methodology.

Sub-Requirement E3-3.2: All information products, except data sets and custom tabulations, must undergo a content/subject-matter review and receive approval.  However, the documentation that accompanies data sets or custom tabulations must receive a content/subject matter review.

1. The following table specifies who must perform the subject matter review and approval:



Type of Information Product	Content/Subject Matter Reviewers
Abstracts	Author’s Division or Office Chief
All other information products	Reviewers who are outside the author’s organizational unit (branch), and who have expertise in the subject matter, operation, or statistical program discussed in the information product. If a qualified outside reviewer is not available, a reviewer within the author’s organizational unit is permitted.



2. The content/subject matter reviewer must verify that the following requirements have been met:
   1. The content of the information product is technically and factually correct.
   2. The information is presented logically and any conclusions follow from the data and the analysis.
   3. Any anomalous findings are addressed appropriately.
   4. Subject-matter literature is referenced in the information product, as appropriate.
3. The content/subject matter reviewer must either approve the information product or provide the author with specific written instructions on issues to be revised.
4. The content/subject matter reviewer must review the information product again after the author addresses any recommended revisions.  If the reviewer and the author disagree with how the comments are addressed, they must inform their supervisors so that a resolution can be reached.
   
   Note: If an information product is generated from a program sponsored by an outside organization or uses data provided by an outside organization, the author’s Division or Office Chief should determine whether to send the product to the outside organization for an additional review.

Sub-Requirement E3-3.3: All information products must undergo a statistical review and receive approval, even if the author believes the information product involves no statistical methodologies.

1. The following table specifies who must perform the statistical review and approval:



Type of Information Product	Statistical Reviewers
Conference papers	Reviewers who have expertise in the statistical methodology or program discussed in the information product Note: Appendix E3-B provides a list of statistical review contacts for conference papers.
Abstracts	Author’s Division or Office Chief Note: If the Division or Office Chief determines that an abstract requires a more rigorous statistical review, he or she must refer the abstract to the appropriate Research and Methodology Assistant Division Chief (ADC).
All other information products	Research and Methodology ADC of the program related to the topic of the information product Note: Appendix E3-B provides a list of statistical review contacts by topic/subject matter.

2. The statistical reviewer must verify that the following requirements have been met:
   1. The discussion of assumptions and limitations is accurate and appropriate.
   2. The description of the reliability of the data is accurate and complete.
   3. Statistical testing is performed correctly to support any comparison statements, whether expressed directly or implied.
   4. Calculations and equations are accurate and statistically sound.
   5. The content, conclusions, and any recommendations on technical, statistical, or operational issues are supported by the methodology used and the data presented.
   6. A source statement is included in the information product.  (See Requirement E2-2, item 2, in Statistical Quality Standard E2, Reporting Results.)
   7. Statistical uncertainty is appropriately conveyed.
   8. Comparison statements, such as historical comparisons, are appropriate.
3. The statistical reviewer must either approve the information product or provide the author with specific written instructions on issues to be revised.
4. The statistical reviewer must review the information product again after the author addresses any recommended revisions.  If the reviewer and the author disagree on how the comments are addressed, they must inform their supervisors so that a resolution can be reached.
   
   

   Notes:

   1. Media releases that do not contain estimates or discussions of statistical or survey methodology need not undergo a statistical review (e.g., media advisories such as the one titled, “Census Bureau Releases Timetable for 2008 Income, Poverty and Health Insurance Estimates and American Community Survey Data”).
   2. Two types of geographic products need not undergo a statistical review:
      1. Thematic maps presenting data from the census short form if the underlying data have been reviewed and approved.
      2. Geographic reference products (e.g., reference maps, and documents showing lists and numbers of geographic entities and relationships between entities).

Sub-Requirement E3-3.4: All information products involving methodologies other than statistical must undergo a methodological review and receive approval.

1. The review must be conducted by individuals with expertise in the methodologies used in the information product (e.g., cognitive psychology, economics, demographic analysis, geographic information systems, or any other specialized methodology).
2. The methodological reviewer must either approve the information product or provide the author with specific written instructions on issues to be revised.
3. The methodological reviewer must review the information product again after the author addresses any recommended revisions. If the reviewer and the author disagree on how the comments are addressed, they must inform their supervisors so that a resolution can be reached.

Sub-Requirement E3-3.5: All information products must undergo a policy and sensitivity review by the author’s Division or Office Chief. The Division Chief or Office Chief may not delegate this review.

Notes:

1. Appendix E3-C provides a checklist developed by the Office of Analysis and Executive Support (OAES) to assist in the policy and sensitivity review.  If the Division or Office Chief needs guidance on a specific issue, he or she may refer the issue to the Associate Director, the OAES, the Congressional Affairs Office (CAO), or the PIO, as appropriate.
2. When the author is a Division or Office Chief or higher-level manager, the policy and sensitivity review is at the discretion of the author’s supervisor.

Requirement E3-4: All presentations (with or without a paper) to be delivered by Census Bureau staff at meetings and conferences open to the public (including advisory and data user meetings) must undergo a dry run rehearsal.

1. A senior division manager (ADC or higher) must attend the dry run.
2. All reviewers must be invited to the dry run.
3. Authors must provide copies of their presentations and any other relevant materials to everyone invited, in advance of the dry run.
   
   

   Notes:

   1. Presentations that have had a dry run and are simply being repeated at another venue do not need another dry run unless substantive changes have been made to the presentation.
   2. The dry run is optional for Division or Office Chiefs or higher and for Senior Technical (ST) employees, at the discretion of their supervisors.

Requirement E3-4.1: Authors of informal presentations (e.g., presentations without written remarks or audio-visual aids, including unwritten discussant or panelist remarks) must review their approach with their Division or Office Chief.

Note: When the author is a Division Chief, Office Chief, or other higher-level manager, this review is at the discretion of the author’s supervisor.

Requirement E3-5: The results of the review and approval of information products must be documented, either electronically or on paper, and the documentation retained according to division or directorate policies and procedures.

Examples of documentation include:

• Completed approval forms.
• Approval e-mail messages from reviewers.