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Procedures for disclosure avoidance have long been in place for quantitative data, and are continuing to evolve in response to real-world changes that threaten data security. In particular, advances in computing and access to large datasets combined have the potential, if left unchecked, to facilitate data linkage and identification of research participants. These real-world changes not only pose challenges for quantitative research products; they raise new questions about qualitative research products that were previously considered less vulnerable to such attacks. In June 2018 the issue of disclosure for qualitative findings was discussed at a meeting of the Census Bureau’s Data Stewardship Executive Policy (DSEP) Committee. In a separate but related development, in September 2018, the question of disclosure avoidance in qualitative research came to light in response to a legal discovery request that involved release of focus group transcripts. At that time the Census Bureau’s Disclosure Review Board (DRB) issued interim guidelines for de-identifying focus group transcript summaries. The Census Bureau then convened a small group of senior survey methodologists who regularly conduct qualitative research. The team’s purpose was to draft an issue paper on disclosure avoidance procedures for qualitative research in particular, and to recommend guidelines for implementation. After nearly a year in development the team produced a set of Disclosure Avoidance Guidelines for Qualitative Research that was fully vetted by multiple divisions within the bureau, and ultimately approved by DSEP. This paper documents that process along with the guidelines themselves.
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