+-----------------------------------------------------------+----------+
| **Local Update of Census Addresses Program**              |          |
+-----------------------------------------------------------+----------+
| *Confidentiality and Security Guidelines*                 | Form     |
|                                                           | D-1654   |
| U.S. Department of Commerce                               |          |
|                                                           | Local    |
| Economics and Statistics Administration                   | Update   |
|                                                           | of       |
| U.S. Census Bureau                                        | Census   |
|                                                           | A        |
| ![](media/image1.wmf){width="2.2597222222222224in"        | ddresses |
| height="0.35in"}                                          |          |
+-----------------------------------------------------------+----------+

**Confidentiality and Security Guidelines**

> The law requires the U.S. Census Bureau to maintain the
> confidentiality for all of the information that it collects. The
> Census Bureau takes its responsibility to protect the confidentiality
> of the information it collects very seriously. Respondents place their
> trust in the Census Bureau each time they complete a survey or an
> interview. This trust in confidentiality is critical to the success of
> the Census Bureau's mission to collect and report the most accurate
> data possible. To uphold the law, the Census Bureau requires that all
> individuals who work with the Census Bureau's confidential materials
> read, understand, and agree to abide by the confidentiality and
> security guidelines outlined below.

**Why Address Information Is Protected**

> Title 13, United States Code (U.S.C.), provides for the confidential
> treatment of census-related information. Chapter 1, Section 9 of the
> code states:
>
> *"Neither the Secretary, nor any other officer or employee of the
> Department of Commerce or bureau or agency thereof, or local
> government census liaison, may, except as provided in section 8 or 16
> or chapter 10 of this title...*

1)  *use the information furnished under the provisions of this title
    for any purpose other than the statistical purposes for which it is
    supplied; or*

2)  *make any publication whereby the data furnished by any particular
    establishment or individual under this title can be identified; or*

3)  *permit anyone other than the sworn officers and employees of the
    Department or bureau or agency thereof to examine the individual
    reports."*

> Section 214 of the Code and the Uniform Sentencing Act of 1984 set the
> penalty for the wrongful disclosure or release of information
> protected by Title 13 at a fine of not more than \$250,000 or
> imprisonment for not more than 5 years, or both.
>
> To implement this law, all Census Bureau employees (both temporary and
> permanent) take an oath to maintain the confidentiality of the census
> information they encounter in their work. Census information includes:

-   Everything on a completed or partially completed questionnaire or
    obtained in a personal or telephone interview.

-   Individual addresses maintained by the Census Bureau that Local
    Update of Census Addresses (LUCA) Program liaisons review.

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-   Maps that identify the location of individual housing units and/or
    group quarters ("structure points").

> Title 13 of the U.S.C. does not protect generalized address
> information, such as the address range data available in the Census
> Bureau's TIGER/Line products.
>
> In 1994, the U.S. Congress amended Chapter 1 of Title 13 to allow
> local government designated census liaisons to review the Census
> Bureau's address list for their area. This amendment recognizes the
> important role that local knowledge and participation can play in
> building and updating an accurate, comprehensive census address list.
> In amending this chapter, the Congress reaffirmed the confidential
> nature of address information.

**The Confidentiality Agreement**

> Each participating government must designate a primary liaison. The
> primary liaison and all reviewers must understand and sign the
> Confidentiality Agreement. The Census Bureau considers all individuals
> who have access to the Census Bureau's address information and maps
> showing the location of housing units and group quarters, liaisons.
> Therefore, all Option 1 and
>
> Option 2 LUCA Program reviewers must sign the Confidentiality
> Agreement and Self-Assessment Forms.
>
> Signatures on this form constitute an agreement by each individual to
> abide by the security guidelines outlined below. While access to Title
> 13 protected information is temporary, the commitment to keep the
> information confidential is permanent.

-   **The Census Bureau will not deliver the address list materials to
    participants choosing Option 1 and Option 2 until we have received a
    completed and signed Confidentiality Agreement and Self-Assessment
    Form.**

-   **Although you may have prior confidentiality agreements on file at
    the Census Bureau, these will not fulfill the requirements of the
    LUCA Program.**

**Security Guidelines**

> The Census Bureau recognizes the fact that the implementation of these
> guidelines may vary slightly from one participant to another.
> Regardless, the result must be the same for each participant --
> nondisclosure of information protected by Title 13, U.S.C.
>
> The primary liaison accepts the responsibility for protecting and
> safeguarding the LUCA Program materials covered by Title 13, U.S.C.
> This includes any list that shows individual Census Bureau addresses
> and any Census Bureau map or digital file that shows individual
> housing units and/or group quarters location ("structure points"). The
> primary liaison must restrict access to the Census Bureau's address
> information to those individuals who have signed the Confidentiality
> Agreement. Only those individuals directly involved in the review
> should sign the Confidentiality Agreement.
>
> As you read the Census Bureau's security requirements, keep in mind
> the important role security plays in the overall responsibilities of
> each LUCA Program liaison and reviewer. The Census Bureau must have
> your full cooperation and commitment to following these guidelines.
> Together, we will maintain the confidential information entrusted to
> the Census Bureau by the Congress and the American public.

**Protecting Census Bureau Address Information**

> The Census Bureau will conduct workshops covering all aspects of the
> LUCA Program. In addition, the workshops will provide the
> participating governments with an opportunity to review the security
> guidelines and safeguards to protect against illegal use of Census
> Bureau address information. Census Bureau staff conducting the
> workshops will help you decide who in your organization needs to have
> access to the Address List and will review the civil and criminal
> penalties for improper or illegal use of the data.

**Onsite Visits**

> To ensure that participating entities or organizations are maintaining
> adequate security safeguards, the Census Bureau may make on-site
> visits to review your entity or organization's security procedures.
> The Census Bureau will strive not to disrupt your office's operations.
> A typical visit would include a review of:

-   Storage and handling of Census Bureau address information.

-   Employee access to Census Bureau address information.

-   The physical safeguard of the computers, rooms, and buildings where
    the Census Bureau address information is stored.

-   Instructions to employees about security.

-   Data processing operations (including use of passwords).

-   Employee awareness of their responsibilities to protect the
    confidentiality of Census Bureau addresses.

**Protecting Paper Copies of Census Bureau Address Information and
Maps**

-   Keep all Census Bureau address information in a locked room during
    non-work hours. If possible, store the Census address materials and
    maps showing structure points in locked desks or cabinets.

-   During work hours, do not leave a room unattended where Census
    Bureau address information is stored. Lock the room whenever you
    leave.

-   Do not leave Census Bureau address information unattended at your
    desk. Return any Title 13 data to secure storage when you are not
    using it.

-   Only make copies of the information necessary to complete your task.
    Do not leave the copying machine unattended while making copies. All
    copied material containing Title 13 information must bear the
    statement:

> ***"This document contains information, the release of which is
> prohibited by Title 13, U.S.C., and is for U.S. Census Bureau official
> use only."***

-   To FAX a document containing Census Bureau address information to a
    Census Bureau location, make sure the document is properly labeled,
    verify the FAX number before sending, and arrange for a Census
    Bureau employee to be at the FAX machine to receive it and
    acknowledge receipt.

-   Do not disclose precise or even anecdotal information about Census
    Bureau addresses or locations to anyone who is not a liaison,
    reviewer, or a Census Bureau employee.

**Protecting Electronic Census Bureau Address Information and Maps**

> Operating systems, programs, applications, and data related to the
> review of Census Bureau addresses must be accessible only to LUCA
> Program liaisons and reviewers. The automated data processing (ADP)
> system should restrict the read, write, delete, and execute functions
> applicable to the Census Bureau's addresses.
>
> The ADP system must use log-on routines that require a user-ID and
> password that conform to the following guidelines:

-   Assign a unique user-ID and password for liaisons and reviewers.

-   Passwords must consist of at least 8, nonblank characters consisting
    of at least one alphabet letter and either one number or one special
    character (\$,\*, &). No more than six consecutive characters
    (AAAAAA) may appear in the password, and then only once.

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-   Reject passwords that are the same as the user-ID or that have been
    used within the last 6 months.

-   Encrypt passwords.

-   Disable passwords after three bad attempts.

-   Do not display passwords on terminals or printers.

-   Change passwords every 90 days (more frequent change is optional) or
    immediately, if compromised.

-   On new accounts, the user must change the assigned password to a
    unique password the first time they log on.

> The ADP system must display a warning log-on feature. Computer screens
> must display a warning that states:
>
> **\*\*WARNING\*WARNING\*WARNING\*\***
>
> **YOU HAVE ACCESSED A COMPUTER SYSTEM CONTAINING UNITED STATES
> GOVERNMENT INFORMATION. USE OF THIS COMPUTER WITHOUT AUTHORIZATION OR
> FOR PURPOSES FOR WHICH AUTHORIZATION HAS NOT BEEN EXTENDED IS A
> VIOLATION OF FEDERAL LAW AND CAN BE PUNISHED BY FINE OR IMPRISONMENT
> (Public Law 99-474). ALL USE MAY BE INTERCEPTED, MONITORED, RECORDED,
> COPIED, AUDITED, INSPECTED, AND DISCLOSED TO AUTHORIZED LAW
> ENFORCEMENT OFFICIALS. REPORT SUSPECTED VIOLATIONS TO YOUR AGENCY
> SECURITY OFFICER. USE OF THIS SYSTEM INDICATES YOU CONSENT TO THIS
> WARNING. LOG OFF IMMEDIATELY IF YOU DO NOT AGREE TO THE CONDITIONS OF
> THIS WARNING.**
>
> **\*\*WARNING\*WARNING\*WARNING\*\***
>
> If Census Bureau address information is placed on a shared computer
> system, construct electronic security profiles to allow only LUCA
> Program liaisons and reviewers access to the Census Bureau's address
> information. Test your security to ensure that only LUCA liaisons and
> reviewers are permitted access to the Census Bureau's address
> information.
>
> Encrypt all Title 13 Census Bureau address information transmitted via
> FTP to the Census Bureau's data site with an appropriate product.
>
> Lock all rooms containing computers and all associated media during
> nonwork hours.
>
> Do not leave computers with Census Bureau address information
> unattended during work hours. Log-off the computer or lock the room
> whenever you leave.
>
> Label any computer diskettes, CD-ROMs, DVDs, tapes, cartridges or
> other computer storage media containing Census Bureau address
> information with the following:
>
> ***"This document contains information, the release of which is
> prohibited by Title 13, U.S.C., and is for U.S. Census Bureau official
> use only."***
>
> If backup is necessary, do not send the tapes, cartridges, or disks
> off-site. Store them in a secured area. **Do not mix, store, or
> back-up LUCA data with other data.**
>
> Clear magnetic media (tapes, disks, hard drives) containing Census
> Bureau address information before reuse. To clear magnetic media,
> overwrite all Title 13 data three times at a minimum using a
> commercial disk utility program or degauss using a commercial
> degausser.
>
> Program any software you develop for displaying the Census Bureau
> addresses to label each affected page of a printout containing Census
> Bureau address information with the following:
>
> ***"This document contains information, the release of which is
> prohibited by***
>
> ***Title 13, U.S.C., and is for U.S. Census Bureau official use
> only."***

**Returning Census Bureau Title 13 Materials**

> Once you have completed your initial review and update of the LUCA
> materials, return only those materials with updates to the Census
> Bureau's Regional Office responsible for your jurisdiction. Retain all
> nonannotated Title 13 materials until you receive your feedback
> materials. Use the following guidelines to ship the updated materials:

-   Enclose a letter to the Census Bureau's Regional Office notifying
    them of the shipment and listing its contents.

-   Ship all Census Bureau confidential material in two opaque sealed
    envelopes that are durable enough to prevent someone from viewing or
    tampering with the enclosed materials.

-   Seal and reinforce all packages.

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-   Label both sides of the inner envelope or wrapping with
    **"DISCLOSURE PROHIBITED BY Title 13, U.S.C."**

-   **DO NOT** label the outer addressed envelope with the **"DISCLOSURE
    PROHIBITED BY Title 13, U.S.C."** notice.

-   Address the outer envelope to the Director, Census Bureau Regional
    Office for your jurisdiction, to the attention of the LUCA Staff.

-   Use shipping contractors that provide tracing services, such as U.S.
    Postal Service certified or registered mail, FedEx, United Parcel
    Service, or similar service.

**Methods for Destroying Census Bureau Confidential Materials**

> After receiving and reviewing your feedback materials, all Title 13,
> U.S.C., Census Bureau address lists and maps containing structure
> points **must be destroyed and/or returned** according to the Census
> Bureau's specific guidelines for destroying or returning confidential
> material.
>
> The primary liaison is required to verify the destruction of any
> remaining Title 13 materials, both paper and computer-readable (i.e.,
> paper copies, backup files, etc.). The primary liaison must sign and
> return to the Census Bureau the Destruction of Title 13, U.S.C.,
> Materials form. In addition, all LUCA Program reviewers are required
> to sign this form at the completion of the LUCA Program. Should any
> liaison or reviewer leave before the completion of the LUCA Program,
> they are required to "sign-out" of the program by signing and dating
> this form.
>
> Only those individuals who signed the Confidentiality Agreement are
> permitted to destroy the materials.

-   Never deposit Census Bureau confidential materials in a trash or
    recycle container.

-   Store the materials in a secure area in a container labeled
    "document destruction container" until they are destroyed.

-   The destruction process must prevent recognition or reconstruction
    of the paper or computer-readable information. Use one of the
    following methods to destroy census confidential materials:

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-   Shredding.

-   Chemical decomposition.

-   Pulverizing (such as, hammer mills, choppers, etc.).

-   Burning (only in a facility approved by the Environmental Protection
    Agency).

-   Clear magnetic media (tapes, disks, hard drives) containing Census
    Bureau address information before reuse. To clear, overwrite all

> Title 13 data a minimum of three times using a commercial disk utility
> program or degauss using a commercial degausser.

-   Clear diskettes by running a magnetic strip of sufficient length to
    reach all areas of the disk over and under each surface a minimum of
    three times. If the information cannot be destroyed as suggested,
    damage the disk in an obvious manner to prevent use in any disk
    drive unit and discard.

> **Note:** Hand tearing or burying information in a landfill are
> unacceptable methods of disposal.

-   Destroy CD-ROMs and DVDs using a commercial grade shredder, suitable
    for rendering them un-usable, or cut them up with scissors in an
    obvious manner to prevent use in a drive unit.

> Once you have selected a method of destruction, contact the Census
> Bureau's Regional Office staff who will provide you with the precise
> specifications for the destruction method you have selected*.*