Expanding Secure Access to 

Confidential Data Assets

Spiro Stefanou

Administrator, Economic Research Service, USDA

Federal Committee on Statistical Methodology

2023 Research and Policy Conference 

College Park, MD October 24-26, 2023 

Session G-4: Advances in Implementing Title III of the Evidence Act: Enhancing Public Trust 

in Official Statistics and Expanding Data Access for Evidence Building
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ICSP Data Access and Confidentiality Project

• Motivated by Evidence Act

–Identify, adopt, communicate and coordinate emerging best 

practices to manage data access and confidentiality

–Federal Statistical Agencies:

• Strength Confidence and Trust

•Improve capacity to expand data access for evidence 

building

• Themes

–Regulation Plan

–Stakeholder Engagement Plan

–Methods Coordination Plan
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Elicit feedback on goals, principles, 

and frameworks

Shared understanding of the 

challenges 

Identify innovative ways to meet 

the goals and overcome challenges

Engaging Advisory 

Council on Data and 

Evidence Building 

(ACDEB) 

Subcommittees
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Regulation

Goals and Guidance for Developing Expanding Secure Access to Data Regulation 

(Evidence Act Section 3582)

Regulation Goals

• Shared responsibility for protecting data

• Treating privacy/re-identification as a continuum

• Address both current and future data holdings of the Federal Statistical System

Per Section 3582 Regulation Must Include

• Standards to assess for each data asset

– sensitivity level

– corresponding level of accessibility

– whether less sensitive versions can be created

• Standards to improve access by removing/obscuring identifiers

• Requirement to conduct re-identification risk assessments

• Requirement to make processes transparent and easy to understand
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Regulation

Example Guidance on Regulation "Must Dos"

Sensitivity Levels: "Not all data are equally sensitive. Our 

regulation should not create a presumption of equal 

sensitivity."

Risk Assessments: "Re-identification risk is only one 

component of a risk assessment. The regulation must 

also consider reputational risk to an agency and concerns 

regarding respondent trust."

Removing/Obscuring Identifiers: "Guidelines we set for 

data sets standing alone may be insufficient when those 

data sets are linked to other data sources. When 

articulating guidelines, consider linked data."
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Regulation

Goals and Guidance for Developing Expanding Secure Access to Data Regulation 

(Evidence Act Section 3582))

Known Constraints

–Use of Agency-specific confidentiality laws and how 

they fit into a CIPSEA framework

–Data agreements to procure or collect past data often 

have limitations on data use

–Budget 
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General Principles

1. More (Not Less) Data Available

2. Not All Data Are Equally Sensitive

3. Disclosure Risk Is a Continuum

4. Consistent With Other CIPSEA Efforts

5. Address Current and Future Data

6. Shared Responsibility

7. Protect Good Faith Actors from Unknown Disclosure Risks

8. Consider Linked Data

9. Consider Multiple Audiences in Determining Sensitivity

10.Risk Assessments More Than Re-identification Risk

11.View Expansively – Improve Access to Administrative Records

12.Cost Effectiveness

13.Consider Agency-Specific Privacy Laws
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Elements of the Regulation Draft

• Codifying and clarifying definitions

• Standard to Assess Sensitivity

–Evaluating likelihood of unauthorized re-identification

–Risk of harm: financial, legal, emotional, & reputational

–Assigning Low, Medium, High Risk

• Common Sensitivity Levels and Levels of Accessibility

–Five Accessibility Tiers: Public Access + CIPSEA Levels 1-4

• Determining Whether a more Accessible version of Data 

Asset can be produced

–Increase accessibility using statistical disclosure limitation 

methods
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Elements of the Regulation Draft (cont’d)

• Standards for Disclosure Risk Mitigation

–Determine if disclosure risk is mitigated 

(incl. if combined with other data source)

–Shared responsibility with user’s institution

• Comprehensive Risk Assessment

–Institutionalize Disclosure Review Capacity: 

Board & Officer

• Transparency 

–Publicly available policies and procedures, 

annual reporting, public feedback 

mechanisms
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Document Status

o Draft in development by ICSP Working Group. 

o Draft is aligned with other guidance and regulations: 

o SAP (Evidence Act section 3583), 

o Trust regulation (Evidence Act section 3563a) and 

o other ICSP engagement documentation.

Accomplished our goal to hew as tightly as possible to Section 3582 

and to incorporate as many of the ICSPs 13 guiding principles as are 

relevant.
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Questions?
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