Privacy Principles and Data Sharing: 

Implications of CIPSEA for Economic Survey Respondents 

Alfred D. Tuttle 

Diane K. Willimack 

U.S. Census Bureau1

I. Introduction 

Historically, sharing data among federal statistical agencies has been limited by 

tight legal restrictions emphasizing the privacy and confidentiality of information 

provided by individuals and business entities. The safekeeping of confidential 

information submitted in good faith by the public deserves our full attention. 

However, it contributes to the already-significant burden imposed by our 

decentralized federal data collection system on business respondents in 

particular, especially for large companies that are continually selected for many 

different government surveys. In addition, some core items must be collected 

independently by multiple agencies conducting establishment surveys, in order to 

aid descriptive classification of establishments for summarizing or analyzing the 

data. A recent law intended to alleviate some of this accumulating burden on 

business survey respondents and improve the efficiency of the federal statistical 

system now permits limited sharing of data among three designated statistical 

agencies, one of which is the US Census Bureau.

The new law, along with existing laws, the Standards and Guidelines for 

Statistical Surveys recently proposed by the Office of Management and Budget 

(OMB), and the Census Bureau’s own Privacy Principles, explicitly require survey 

programs to make respondents aware of the “planned uses” of the data they 

submit, and of the nature and extent of the confidentiality of the information they 

provide. Because of the new law, “planned uses” now includes the fact that 

collected business data may be shared with another agency. Since the new law 

permits data sharing only for business data, the Census Bureau’s principles and 

policies must be applied differently for economic programs than they are for 

demographic surveys. The Census Bureau’s implementation of privacy and 

informed consent policies in the context of its newly-legislated data sharing ability 

will be informed by research, the first steps of which are reported in this paper2

. 

To provide a foundation for the development of a research program, we reviewed 

1

This report is released to inform interested parties of research and to encourage discussion. 

The views expressed on methodological, technical, or operational issues are those of the authors 

and not necessarily those of the U.S. Census Bureau. The authors acknowledge assistance from 

various Census Bureau economic programs that provided materials to support this research, 

along with their feedback on our work. We also express gratitude for helpful review comments 

from Rita Petroni and, especially, Rochelle Wilkie Martinez and other members of the Census

Bureau’s Policy Office. 

2 While the focus of this paper is on informed consent messages in the context of data sharing,

our research serves the dual benefit of providing a baseline of the current state of economic 

survey programs relative to the requirements of OMB’s Proposed Standards and Guidelines for 

Statistical Surveys. 

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literature on what is known about informed consent message construction and 

household respondents’ reactions to informed consent materials. We also 

reviewed a convenience sample of current Census Bureau economic survey 

programs’ informed consent messages. 

II. Background 

Intended to alleviate some of the burden arising from redundant data requests, 

the Confidential Information Protection and Statistical Efficiency Act (CIPSEA, 

2002; incorporated into the E-Government Act of 2002) allows for business 

survey data to be shared among three designated federal statistical agencies – 

the Bureau of Labor Statistics, the Bureau of Economic Analysis, and the Census 

Bureau – under carefully prescribed conditions designed to uphold the 

confidentiality of the information. The three designated statistical agencies may 

share business data after entering into a written agreement specifying the data to 

be shared, the exclusively statistical purposes for which the data will be used, the 

agents of the receiving agency authorized to handle the data, and appropriate 

security protections to be put in place to safeguard the data. The law does not 

require agencies intending to share previously collected data to inform business 

respondents directly that some of their information may be provided to another 

agency; it is sufficient for the collecting agency to describe the terms of the 

agreement “in a public notice” after the data have been collected.3

However, CIPSEA, the Paperwork Reduction Act (1995), OMB’s Proposed 

Standards for Statistical Surveys, and the Census Bureau’s Privacy Principles all 

require that respondents be informed about “routine planned uses” of the data 

they are asked to submit. Insofar as the intention to share business data with 

another eligible statistical agency qualifies as a routine planned use of the data, 

then business respondents should be notified prior to collection of their data. 

Additionally, respondents should be made aware of the confidentiality protections 

in place in the eligible agencies involved in the data sharing agreement. Since 

sharing demographic data is not permitted, policies dealing with privacy and 

informed consent will need to take CIPSEA-enabled sharing of business data into 

account, and thus must be administered differently for economic survey 

programs than for demographic surveys. Specifically, the language of economic 

survey informed consent statements would need to meet the criteria outlined in 

such policies. Such statements will require careful crafting to avoid unnecessary 

concern for business respondents, for whom the data we request is often very 

sensitive and of great proprietary and strategic value. 

III. Assessing the Implications of Data-sharing for Business Respondents 

Previous research into respondents' beliefs and concerns about the data they 

provide and the ability of the Census Bureau and other statistical agencies to 

uphold the confidentiality of that data provides a useful starting point for effective 

3 U.S. Census Bureau Policy Office Legislative Fact Sheet, bill number H.R. 2458, P.L. 107-347, 

“E-Government Act of 2002” 

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communication with business respondents informing them that their companies' 

data may be shared. Respondents' beliefs about the sensitivity of their 

companies' data generally depend on the types of data being requested and on 

the characteristics of their companies and the environments in which they 

operate. Greenia et al. (2001) found that data believed most sensitive are those 

pertaining to employee’s identities (though not the size of the staff roster) and 

financial information including payroll, operating costs, profits, and tax liabilities.

Most respondents tend to consider such data sensitive for at most five years. 

Smaller firms generally seem to believe that financial information is much more 

sensitive than do larger firms, and smaller firms are consequently more

concerned than larger firms about providing information to the Census Bureau 

and other statistical agencies, while multi-unit companies consider company-level 

data more sensitive than establishment-level data. Willimack, Nichols, and 

Sudman (2002) note that "businesses that are more dependent on their [external] 

environments, such as publicly-traded firms, have higher motivation to disclose 

information, while those that are insulated or in unregulated environments are 

more protective of information...Those in more volatile industries [or markets]

were more protective of their data, because releasing information could result in 

a loss of competitive advantage" (p. 223). 

In spite of these strictures, economic surveys conducted by the Census Bureau

enjoy relatively high response rates compared with private sector surveys, owing 

substantially to the willingness of respondents and their companies to provide 

requested information. Willimack (2001) reports that respondents tend to trust 

Census Bureau pledges of confidentiality, but also notes that much of the data 

they report tends to be publicly available anyway. Business respondents tend to 

place more importance on reporting burden than on concerns for the 

confidentiality of the information they report. Nichols and Willimack (2001) 

observe that business respondents often have to prepare duplicate reports and, 

in the words of one respondent, different statistical agencies ask for "the same 

data five different ways." Redundant external data requests, especially for larger 

firms, appear to make the prospect of data sharing by designated statistical 

agencies preferable. Larger companies show a slightly higher rate of support for 

data sharing than small to mid-size businesses, suggesting that above a certain 

threshold, concerns for response burden outweigh concerns about data sharing 

(Willimack 2001). In fact, most of the business respondents surveyed by Greenia 

et al. (2001) believe that Federal statistical agencies already share data freely 

among themselves. 

Nichols and Willimack (2001) report that business respondents have definite 

ideas about conditions they would find acceptable for data sharing. First and 

foremost, data sharing must reduce reporting burden. Strict security pledges 

must be in place, describing both data protection procedures and the individuals 

and agencies with access to shared information. Agencies must keep 

respondents abreast of changes in data-sharing arrangements. Perhaps most 

importantly, respondents say they must be able to restrict access to certain 

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agencies, particularly the Internal Revenue Service, and the purposes for which 

shared data are used. Clearly, the concerns of respondents must be thoroughly 

understood and systematically addressed in order to reassure respondents and 

maintain their cooperation. 

Some findings from research with household survey respondents can inform our 

discussion of the impact of data sharing on business surveys. Bates (2003) 

studied alternative requests for permission from household respondents to use 

their social security numbers for linking to administrative records received from 

another Federal agency to obtain data for statistical uses, a procedure intended 

to reduce the burden on respondents. She found that some respondents likely 

misunderstood the logistics of the administrative data acquisition procedure as

communicated in the informed consent messages, and that some thought that 

the Census Bureau was asking for their permission to share their answers with 

other statistical agencies. Other research has found that some respondents 

have a difficult time believing that the flow of data is one-way, only from the 

supplying agency to the Census Bureau, and not two-way, thinking that the 

government already has access to their personal information and it is shared 

among agencies anyway (Landreth 2003b). Some business respondents share 

these beliefs (Greenia et al. 2001). The difficulty in clearly communicating these 

kinds of concepts is pertinent to the construction of informed consent messages 

about data sharing in the business survey context. 

When reading advance letters and other materials accompanying or associated 

with surveys, household respondents tend to look for “one or two highly salient, 

diagnostic pieces of information” to help them decide whether or not to 

participate in the survey (Landreth 2003a: 4). They often stop reading a cover 

letter, for example, and cease cognitively processing the request it contains when 

they feel they have gotten enough information upon which to base a decision. 

One study identified several questions asked by household respondents that 

affected their decision whether or not to participate in a survey (Landreth 2002):

• What is this and what is it used for? (i.e., What information is being 

requested and what is the purpose of the survey?) 

• Who is doing the survey? 

• How will my information be handled? (e.g., planned uses, confidentiality 

protections) 

• How was I chosen? 

Providing satisfactory answers to these questions may encourage respondents to 

cooperate with data collection. On the other hand, other questions often asked 

by respondents which, when answered unsatisfactorily, gave them sufficient 

reason to refuse to participate: 

• How long will this take? 

• Is this voluntary? 

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The Census Bureau’s survey programs are required by law and by agency policy 

to provide answers to these questions, as part of the Federal government’s 

commitment to fairness and openness with regard to the individuals and 

organizations who provide the information we request. Landreth concludes that 

care must be taken to construct messages that satisfy respondents’ concerns, 

but that do not overly sensitize them to or allow them to fixate on any issues of 

likely concern, such as confidentiality and data-sharing, at least not before they 

have had a chance to process more persuasive elements. 

IV. Assessing the Implications for Census Bureau Economic Surveys 

This section summarizes the findings of an evaluation of informed consent 

messages that currently appear in selected self-administered Census Bureau 

economic survey mail-out packages. Our evaluation was conducted to provide a 

baseline understanding of the ways in which informed consent information is 

currently presented, both in terms of the range and depth of presentation and as 

a means of inferring the strategies that survey designers employ in their informed 

consent communications. This analysis is guided by generally accepted survey 

design standards and research into cover letter construction. A generic 

economic questionnaire front page from Statistics Canada was also reviewed for 

sake of comparison. 

Methodology

Sample: We gathered a convenience sample of questionnaires, cover letters, 

and other mail-out materials for thirteen separate survey programs, some with 

multiple versions (e.g., versions of the 2002 Economic Census for five sectors). 

The survey programs included in our review are listed in Table 1. 

Table 1: Sample of economic survey programs

Program Frequency Mandatory?

Economic Census Quinquennially Yes 

Survey of Business Owners Quinquennially Yes 

Annual Survey of Manufactures Annually Yes 

Annual Retail Trade Survey Annually Yes 

Current Trade Report Monthly No 

Construction Project Report Monthly No 

Report of Privately-Owned Residential Building 

or Zoning Permits Issued Annually No 

Quarterly Services Survey Quarterly No 

Vehicle Inventory and Use Annually Yes 

Quarterly Financial Report Quarterly Yes 

Annual Capital Expenditures Survey Annually Yes 

Survey of Industrial Research and Development Annually Yes 

Manufacturing and Energy Consumption Survey Annually Yes 

Materials: The selected survey packages typically consist of a survey form and 

a cover letter. Cover letters are typically one page in length, containing five to six 

paragraphs. Eight packages include separate instruction sheets and/or FAQ 

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(Frequently Asked Questions) sheets containing informed consent information, 

which are also included in this analysis. 

Evaluation Criteria: Survey packages were evaluated on the basis of: 

• Their compliance with criteria derived from the Census Bureau’s Privacy 

Principles, a proposed informed consent policy, the Privacy Act (1974) 

and the Paperwork Reduction Act (1995) – summarized in Table 2 below; 

• Topics we hypothesize to be of concern to business respondents; 

• Information found to be critical to household respondents for making a 

decision to participate or not, based on research with household 

respondents.

Table 2: Evaluation criteria taken from the Privacy Act and the Paperwork Reduction Act

Criteria Privacy Act Paperwork Reduction Act

Legal authority for data collection X 

Purpose for data collection X X 

Planned uses of data X X 

Voluntary/mandatory indication X X 

Confidentiality precautions, citing legal authority X X 

Estimated average number of burden hours X X 

Contact information for the Census Bureau X X 

Request that the public contact the Census Bureau to 

comment on the burden estimate and suggest ways to X X 

reduce the burden

Valid Office of Management and Budget (OMB) control 

number and a statement describing this requirement for X 

authorized collections of data

It should be noted that the Privacy Act applies only to business data collected 

from individuals. The Census Bureau imposes additional informed consent 

requirements on its economic survey programs beyond those required by law, 

which have been incorporated into the proposed informed consent policy. 

It is important to distinguish between the purpose of a data collection and the use 

of the data once it is collected. The purpose of a data collection is the utilization 

of the data once it is published in statistical summaries, e.g., used by Congress 

to inform policy-making decisions. Uses of the data include such intra-agency 

procedures as processing, frame building, and publication, and inter-agency 

procedures as administrative data acquisition and data sharing. 

In addition to the above legal criteria, we hypothesized that some other topics 

may be salient for business respondents, based on Landreth’s (2002) household 

research and on the authors’ experience with business respondents, namely:

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• Due date 

• Types of information the survey asks for 

• How or why a respondents’ company is selected 

Other information we hypothesized to be salient on the basis of research with 

household respondents is described in Section III. 

Results 

A. Due Date, Legal Authority, Mandatory/Voluntary Statements, and 

Confidentiality Precautions 

When people in Western societies read information on a page, they tend to follow 

a particular navigational path, beginning at the top left, reading items horizontally 

from left to right, and returning to the left margin to scan down to the next item 

(Dillman 2000: 113). Therefore, information placed in the top left quadrant of a 

page tends to be attended to first by a reader. The attention of people raised in 

the West can also be attracted by visual elements, especially large and bolded 

print, and drawn to particular parts of the page (Dillman 2000: 106). 

We infer that designers of Census Bureau economic survey forms typically 

employ these visual design tactics to increase the likelihood that respondents will 

be aware of several key informed consent elements: the date by which the 

survey should be returned; a statement describing the mandatory nature of the 

survey, when applicable; and a description of the practices by which the 

confidentiality of reported data is maintained. Mail and telephone contact 

information for assistance with the form is also universally placed in this 

prominent location. These well-placed pieces of information are likely the most 

effective in persuading respondents to complete and return their survey forms. 

Their importance is also evident from their repeated presentation in additional 

places, i.e., in cover letters, separate instructions, and FAQs, and their frequent 

emphasis with large or bold print in those locations. 

Due date: The due date is not placed in exactly the same location on every 

form, but it is always in the upper left quadrant. Although on many forms this 

area tends to be “cluttered” with text and non-text information, the due date 

appears to be well placed for getting respondents’ attention. 

Legal authority: Legal authority for survey collection is generally not cited per 

se, but is usually cited in reference to a legal mandate and legally prescribed 

confidentiality protections. One exception is the Survey of Business Owners 

(SBO). On the back of the cover letter for the SBO are printed five excerpts from 

various sections of the U.S. Code pertaining to the authority to conduct the 

Economic Census and collect other statistical data, etc. Citation of legal 

authority in this case may be useful as a means of persuasion, in that it may lend 

greater credibility and authority to the form, which collects, among other data, 

race, ethnicity and gender of business owners; such personal information is 

atypical of many other government-sponsored business surveys. 

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Mandatory/voluntary indications and confidentiality precautions:

Indications of whether a particular form is mandatory or voluntary and statements 

describing ways that confidentiality is maintained appear within the survey forms 

themselves, in the cover letters accompanying the forms in the mail-out package, 

and often in supplemental materials, like FAQ pages, as well. In particular, 

mandatory indications and confidentiality precautions appear to be the most 

important information conveyed by survey designers, judging by their prominence 

and their presentation in multiple places in survey packages. The packages we 

reviewed vary in the number and types of statements they present describing 

reporting conditions and data protections. 

Survey Forms 

On the survey forms in our evaluation, mandatory and confidentiality statements 

are usually combined into the same paragraph. Typically, such a paragraph 

contains one statement indicating mandatory reporting, and another one to three 

statements describing confidentiality protections. All the mandatory forms we 

evaluated indicate the reporting requirement on the front page of the form. If a 

form is voluntary, then only the confidentiality protections are mentioned in the 

paragraph on the front page of the form (described in detail below). Of the four 

voluntary survey forms we evaluated, only one indicates on the form itself that it 

is voluntary; the other packages present this information in cover letters. 

Combined mandatory/confidentiality statements on mandatory surveys are 

usually displayed fairly prominently on the front page of the form. Most often they 

are located directly below the address label, spanning the entire width of the 

page with key statements in bold. Sometimes they are found above the address 

label or in the column to the right of the address label. The following is a typical 

paragraph, both in terms of the verbiage and the visual appearance: 

YOUR RESPONSE IS REQUIRED BY LAW. Title 13, United States Code, requires 

businesses and other organizations that receive this questionnaire to answer the 

questions and return the report to the U.S. Census Bureau. By the same law, YOUR 

CENSUS REPORT IS CONFIDENTIAL. It may be seen only by persons sworn to uphold 

the confidentiality of Census Bureau information and may be used only for statistical 

purposes. Further, copies retained in respondents’ files are immune from legal process. 

There are two exceptions among our convenience sample of survey programs. 

One form presents a somewhat lengthier paragraph, citing several specific laws 

in addition to Title 13, reflecting sponsorship of the survey by another 

government agency. On the other, the mandatory and confidentiality statements 

are split into 2 paragraphs located separately, one for confidentiality, the other for 

mandatory authority. The content of both is essentially the same as that 

displayed above. 

The manner in which the voluntary surveys we reviewed address confidentiality 

is similar to the mandatory surveys, except that they have a single paragraph 

emphasizing only the confidentiality protections. These paragraphs are 

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otherwise the same as the mandatory paragraphs, lacking only the first line. One 

form includes no statement addressing confidentiality, because it asks for 

building permit information from public officials, and that information is a matter of 

public record. 

Cover letters 

As on the forms themselves, mandatory statements are generally among the few 

items emphasized most strongly in cover letters, mainly through the use of boldprint, which may be quite eye-catching for respondents. Other bold-printed items 

in cover letters tend to include due dates, confidentiality statements, telephone 

numbers for assistance, and indications that “estimates are acceptable.” Bold 

print items appear to be the few items most urgently communicated to 

respondents by survey designers; their importance is also evident in their 

repetition across survey package components. Three of the four voluntary 

surveys in our sample made reference to their voluntary nature in the body of the 

cover letter; the fourth, as noted above, indicates it in the form itself. 

Supplements 

Several survey programs include supplemental materials in the way of FAQ 

sheets or separate instructions that repeat or elaborate (to some degree) on 

informed consent information. 

Confidentiality protections – tallies, types

Statements describing the ways that the confidentiality of respondents’ 

information will be protected are fairly uniform across the packages that we 

evaluated, with some variations. The three most common confidentiality 

protections (below) typically appear together in most of the packages: 

• “Your report will be seen only by persons sworn to uphold confidentiality of 

Census Bureau information.” 

• “Your report will be used only for statistical purposes.” Or “Your data will 

be summarized” or “aggregated.” 

• “Copies kept in respondents’ files are immune from legal process.” 

The phrase “statistical purposes” in the second bullet above is the preferred 

language adopted by the Census Bureau’s Economic Directorate, and its 

variants presumably are older statements that are yet to be updated (Martinez 

2005). A few additional statements found in the evaluated packages are:

• “No individual establishment, firm, business, etc, or its activities may be 

identified.”

• “Census Bureau publications summarize responses so that the 

confidentiality of respondents and their business activities is fully 

protected.” 

• “Your reported data are exempt from requests made under the Freedom 

of Information Act.” 

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The presentation of these confidentiality points varies quite a bit across our 

selected survey programs. Eight survey packages had at most three pieces of 

information about confidentiality in either the form or the letter. The survey 

collecting data of public record contains no confidentiality statements. The 

remaining four survey packages have four or more confidentiality points in 

various parts of the packages (form, letter, etc.). One has five points in the letter. 

Another has four in each of two parts, one part consisting of excerpts from 

sections of the U.S. Code on the second page of the cover letter and the other a 

two-page FAQ. The other two surveys have four each in a single section. These 

variations in the presentation of confidentiality elements may be due to the 

survey designers’ differing perceptions of the strength of confidentiality 

assurances necessary to ensure participation. We suggest these be tested for 

their efficacy in reassuring respondents and encouraging cooperation. 

B. Elements found in the OMB Burden Statement 

Response “burden statements” are required by the Paperwork Reduction Act and 

by the Office of Management and Budget. These are fairly uniform across 

survey programs, containing four informed consent elements (listed below). 

They typically appear at the bottom of the last page of the form or in separate 

instructions, but may also appear on the front of the form, in an FAQ section, on 

the back of a cover letter, or in the text of the letter itself. The burden statement 

contains the following standard items: 

• Estimated time of completion: This statement lists a range of times and 

the average. 

• Contact information for the Census Bureau: Census Bureau contact 

information is fairly prominent within the burden statement, and usually 

contains an email address and a postal address. 

• Statement requesting public to comment on accuracy of burden 

statement and ways to reduce burden to Census Bureau

• Valid OMB number and statement describing the requirement that 

survey forms display a valid OMB number

C. What do Census Bureau establishment survey designers seem to think 

are salient items for respondents? 

Survey designers appear to devote the most prominent locations on

questionnaires, letters, and other materials to information believed to be most 

persuasive in order to maximize their effectiveness in encouraging respondents 

to participate in the surveys. Mandatory reporting, confidentiality protections, and 

legal authority are communicated in multiple places (i.e., on forms, in letters, and 

in supplemental materials) and are often emphasized using bold print. Typically 

these are combined in a single paragraph, with one sentence citing the law that 

makes reporting mandatory, and two or three others elaborating confidentiality 

protections. Two “summary” lines in the paragraph, indicating mandatory 

reporting and confidentiality are bolded to draw attention to and emphasize these 

10
 

two important features. Contact information is also repeated on the form and 

other materials, apparently encouraging respondents to call with any concerns, 

questions, or problems, rather than disregard the survey. 

Front pages of survey forms universally present several pieces of information: 

• Name and form number of survey 

• Due date 

• Identification of agency sponsoring/conducting the survey (though this 

information, in the form of a logo, is often understated, perhaps to the 

point of being “invisible” to respondents) 

• Contact information 

• OMB approval number in upper right corner (required by OMB regulation) 

• Legal authority, mandatory, and confidentiality statements 

Most prominent on the front pages are the survey name, due date, return 

address, telephone number for assistance, and mandatory/confidentiality 

statements, which appear in larger and/or bold print and stand out against 

small/plain print. These may be the necessary elements which designers want to 

ensure that respondents see, because they are the most critical for the purposes 

of persuading respondents to fill out the forms, telling them where to send 

completed forms, and helping them solve any problems they may encounter. 

Cover letters typically relate: 

• A brief, general description of the purpose of the survey; 

• Due date; 

• Legal authority, mandatory/voluntary statement, confidentiality protections, 

usually citing Title 13 of the U.S. Code; 

• Brief, general description of data uses, particularly as they relate to 

confidentiality protections; 

• Contact information; 

• The Census Bureau as the agency conducting the survey (usually 

identified either in text of letter or by the letterhead). 

Other supplemental materials like FAQ pages provide additional space to devote 

to details about information already mentioned elsewhere. Sometimes these 

supplements are the location of information not placed elsewhere, like OMB 

burden statements, meeting requirements that these be addressed in survey 

materials. 

Laws and policies prescribe which specific pieces of information must be 

communicated to respondents, but not the sequence (from a cognitive 

perspective) in which they are presented. This means that Census Bureau 

survey designers are able to exercise some discretion in their presentation of 

informed consent criteria. Among the economic survey materials we reviewed, 

required elements of informed consent are presented in such a way that 

respondents are more likely to find and process positive and persuasive 

statements first and potentially discouraging statements afterward as they peruse 

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the survey package materials. This seems a judicious use of discretion, 

considering the Census Bureau’s commitment to fulfilling legal and ethical 

requirements while at the same time carrying out its mission of providing 

complete and accurate statistics about the nation’s economic activities. 

Additionally, the potentially dissuasive effect on respondents of certain kinds of

information may be mitigated by co-mingling it with other, more positive 

information. Two pieces of information are typically presented this way: 

estimated amount of time for completing the questionnaire, and an indication of 

voluntary response. The salience of these particular items for business 

respondents is not clear. In our experience, business respondents often assess 

the time and effort required to fill out a questionnaire by scanning through it, so 

they may tend not to look for a statement estimating the completion time. Insofar 

as many respondents assume that government surveys are mandatory, they may 

not be likely to look for an indication that the questionnaire in front of them is 

voluntary. These points notwithstanding, such approaches to design as strategic 

sequencing and co-mingling serve to de-emphasize potentially dissuasive pieces 

of information, while keeping with the Census Bureau’s Privacy Principles. 

Alternative strategies motivated by the Landreth research need to be investigated 

with business respondents before implementation. 

D. How do salient items of survey designers correspond or fail to 

correspond with items salient for respondents? 

Previous research on household survey respondents (Landreth 2003a, 2002) 

and our own experience with business respondents suggest several concerns

business respondents may have when considering whether or not to comply with 

a survey request (see Section III). We compared the survey program packages 

in our sample to these hypothetical criteria: 

What information is being asked? Only two survey packages explicitly provide 

indications of what kinds of information they request. One example is the letter 

accompanying a voluntary questionnaire that measures building construction 

activity. The letter describes the types of information asked on the initial form 

and on subsequent forms; the initial form requests details about a particular 

project, and asks on a monthly basis thereafter only for a single figure on the 

value of work completed in the previous month. This somewhat lengthy letter 

apparently attempts to mitigate what may be obvious and negatively salient 

information, namely that the survey is voluntary and that it appears burdensome. 

The Survey of Business Owners (SBO) describes in great detail on a separate 

FAQ sheet the kinds of information the form collects and why the information is 

requested. The SBO actually has much in common with demographic surveys, 

in that it asks for information about business owners’ race and ethnicity. 

Individual racial/ethnic information may be sensitive for respondents, and 

potentially more suspicious when requested at the same time as the individual’s 

business information. Therefore, the great amount of detail about legal 

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authorization, confidentiality protections, and the purpose of the survey, among 

several other items, may be offered in order to assure respondents that their 

information will not be used for purposes that may be harmful to them. 

As for the remaining survey packages, statements explicitly identifying the types 

of information requested in the questionnaire are not included in the materials 

that accompany and introduce their questionnaires. The lack of such statements 

may suggest that survey designers believe that other text (e.g., the title of the 

survey) communicates this information or that its pertinence is outweighed by 

other factors, such as authority. We believe that this assumption should be 

tested. 

What is the purpose of the survey? Several survey cover letters give a 

general description of the purpose of the survey, mainly in terms of which parties 

inside and outside of government will make use of the statistical data and how. 

An example from the Current Trade Report follows: 

The summary data compiled from this survey are used by the government to make 

economic policy decisions and as input to the Gross Domestic Product (GDP). In 

addition, government agencies, market research firms, universities, and businesses use 

the summary data for planning and decision making. 

Statements of purpose tend to be linked with appeals to business respondents’ 

or their companies’ self-interests, civic duty, etc. Whether these statements are 

sufficient to satisfy respondents’ curiosity or concerns is a subject for testing. 

Who is conducting the survey? The Census Bureau’s identity is often deemphasized on survey forms, letters, and other materials. The agency is 

mentioned by name in some letters, and some letters have the “U.S. Census 

Bureau” watermark at the bottom. The letterhead at the top of some letters 

contains the same design found on forms, in which the Department of Commerce 

is most prominent, and the Census Bureau is subordinated to the Department 

and to the Economic Statistical Administration. On forms and letters, “U.S. 

Census Bureau” in this design is of the smallest print, not at all prominent or 

memorable. This may contribute to business respondents’ general perception of 

“the government” as a single undifferentiated body, and their categorization 

simply of “Department of Commerce” forms, as was observed by Sudman et al. 

(2000). 

How will my information be handled? This question corresponds to the 

informed consent elements “planned uses” and “confidentiality precautions,” 

which are typically co-mingled in survey packages. Descriptions of planned uses 

are generally limited to the phrase “statistical purposes,” although a couple of 

letters mention publication of aggregated or summarized responses. Whether 

these very basic descriptions are satisfactory for business survey respondents is 

an open question and should be explored in testing.

13
How/why was our company selected? Cover letters for a few surveys 

describe, in very general terms, how companies are selected for the survey (e.g., 

“identified from public records,” “scientifically selected sample,” “selected at 

random”). These statements tend to be mingled with persuasive elements 

indicating that asking for information only from a sample of companies “reduces 

survey cost” and generally reduces the burden on businesses, and at the same 

time increases the importance of individual (representative) responses.

For other items we hypothesized to be salient (voluntary/mandatory indications,

confidentiality precautions, time estimates, contact information), their relative 

importance and the most effective or satisfactory configurations should be 

researched with business respondents.

E. Evaluation of Statistics Canada Informed Consent Content 

In the United States, which has a decentralized statistical system, confidential 

data cannot be shared across statistical agencies without legal authority. In 

Canada’s centralized statistical system, that authority is manifested quite 

differently, since collected data are “owned” by a single statistical agency, rather 

than many. That data may be “shared” for statistical purposes is intrinsic; 

however, data-sharing agreements exist with outside agencies as well (e.g., 

provincial statistical agencies). 

Because of this contrast between our statistical “cultures,” we reviewed a generic 

front page from Statistics Canada business surveys using the same criteria 

applied to Census Bureau survey packages, in order to see if their approach 

might offer some useful insight into informed consent message construction. The 

lower half of the front page of Statistics Canada business surveys is devoted to 

the presentation of informed consent elements, including:

• Survey purpose 

• Coverage (i.e., scope of survey) 

• Data-sharing agreements 

• Confidentiality 

• Return of questionnaire 

• Disclosure of risk in using fax or other electronic transmission to submit 

reports 

The front page, which contains only informed consent-type information with no 

survey data items, is thus a standardized preliminary step to completing the 

survey. Items corresponding to the Census Bureau’s informed consent elements 

appear prominently; several are clearly presented in a two-column matrix format. 

Several of the apparently more salient elements are accompanied by brief, 

concise descriptions or explanations. For example, the description of “Survey 

Purpose” makes a direct link between the types of data collected in the 

questionnaire and their policy uses. The section on “Data-sharing Agreements” 

emphasizes in bold print that “Your responses are not shared with Canada 

Customs and Revenue Agency,” but offers little detail about the specifics of data14
 

sharing arrangements aside from the fact that they do exist between Statistics 

Canada and provincial and territorial statistical agencies; any data shared are 

only used for statistical purposes. It is interesting to note that the explanation 

associated with “Confidentiality” differs from the Census Bureau in that Statistics 

Canada is the subject of the sentence, i.e., “Statistics Canada is prohibited by 

law...,” whereas in Census Bureau confidentiality statements, it is usually “your

report” that is confidential by law. The mandatory indication and legal authority 

appear in the upper right corner of the survey front page, to the right of the 

Statistics Canada emblem and the name of the survey, and they are printed in 

small, but bold, print compared with other text on the page. 

V. Conclusions 

We derive two important conclusions from our analysis of economic survey 

program materials. As with household surveys, designers of economic surveys 

appear to emphasize informed consent elements of presumed positive salience 

and to de-emphasize elements perceived to be discouraging to respondents. 

Making persuasive elements prominent and negative elements less so may help 

to increase the likelihood that respondents will complete and return 

questionnaires. Further, the designers appear to mediate any potentially harmful 

impact of negatively salient items by co-mingling or embedding less appealing 

information within more positive elements and thereby “softening the blow.” By 

promoting and “mixing” information in these ways, designers seem to believe that 

it will increase the likelihood that indecisive and reluctant respondents will be 

able to find the “one or two highly salient pieces of information” that help 

convince them to participate before they find other, less positive details – the 

strategy used by Census Bureau field representatives when asking potential 

respondents to cooperate with a survey (Landreth 2003a). This approach makes 

intuitive sense, but it is essential that survey designers have a thorough 

understanding of the beliefs and concerns of their respondents in order to make 

the most effective use of it. 

VI. Future Research 

The information reported in this paper documents typical informed consent 

practices currently used in a small number of the Census Bureau’s economic 

programs. It forms a baseline from which to develop informed consent 

messages addressing the requirements of CIPSEA and to evaluate their 

effectiveness. Nevertheless, additional research is needed to guide the Census 

Bureau’s implementation of policies that relate to CIPSEA. 

First, it would be useful to compare the informed consent practices of other 

statistical agencies and their economic surveys’ participation rates, to look for 

clues as to the impact of particular forms of informed consent message 

construction and any areas of potential sensitivity. Paired with findings from 

demographic survey research on privacy and informed consent, these results 

provide a basis for drafting informed consent messages for business surveys. 

15
 

However, potential data sharing under CIPSEA adds a new dimension to 

informed consent not previously addressed by household survey research, or, for 

that matter, business survey research. 

Thus, future research must attempt to gain insights from the perspectives of 

business survey respondents and investigate their views of data sharing in the 

context of privacy and informed consent. Specifically, what concerns will 

business respondents have with regards to sharing data, in terms of the types of 

data shared, the agencies involved, confidentiality protections, and other specific 

procedures? How might business respondents – and business surveys – be 

affected by informed consent messages about data sharing? What is the most 

effective way to construct messages that communicate data sharing in a manner 

that addresses these issues, relieves respondents’ concerns, and minimizes any 

potential negative impact on their cooperation? Indeed, research on privacy by 

Singer (2003) and Gerber (2001) demonstrates that, while we must be 

concerned about appropriate formulation of messages communicating the 

various elements of informed consent, they can be expressed in a reassuring 

manner. 

Moreover, future research might also attempt to relate informed consent issues in 

business surveys with those in household surveys, in order to identify 

consistencies between the two as well as points of departure. For instance, 

research should also investigate informed consent messages vis-à-vis typical 

attributes of business surveys, such as establishment-level versus company-level 

data, respondent identity and authority, and variation in size and industry 

affiliations of companies. 

It is our intent that the baseline information presented here provides a foundation 

supporting future research. Results may then be used to guide decisions about 

implementing informed consent practices among the Census Bureau’s economic 

surveys of businesses, institutions and organizations. 

References

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evaluation research survey (QDERS).” Paper submitted to the U.S. Census 

Bureau. 

Dillman, Don A. (2000) Mail and Internet Surveys: The Tailored Design Method. 

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Gerber, Eleanor (2001) “Privacy beliefs and data collection: An ethnographic 

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