Best Practices for Collecting 

SOGI Data on Federal Surveys

Bob Sivinski

FCSM 2023

Any opinions and conclusions expressed herein are those of the author and 

do not reflect the views of the Office of Management and Budget. 1
SOGI: Charge/Goals

Improve the quality and availability of 

Federal survey statistics on the LGBTQI+ 

population.

The Office of the Chief Statistician developed 

this report to spotlight best practices in the 

collection and protection of SOGI data on 

surveys. These recommendations will provide 

all federal agencies with a roadmap for the 

responsible collection, protection, and 

publication of survey data on the LGBTQI+ 

population. https://www.whitehouse.gov/wpcontent/uploads/2023/01/SOGI-Best-Practices.pdf 2
SOGI: Surveys vs. Forms

We know a lot about how to collect SOGI on 

surveys:

• Statutory authority (for both the collection and the agency)

• Valid use 

• Privacy/confidentiality protections

• High quality data (more honest responses)

Special cases: proxy, youth, employee surveys, 

ACS/Census, etc.

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SOGI: Breaking Down Barriers!

• Evidence shows adding SOGI does not increase nonresponse or drop-offs.

• Best practices for combining multiple years of data, and 

aggregating responses to ensure sufficient sample.

• Clarify that producing general use statistics is a valid 

planned use.

• Multiple proven examples of SOGI questions

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Data 

Collection 

Principles

Utility and Quality

Minimization

Inclusivity and Sensitivity

Privacy Protection

Consistency

Compliance

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Quality and Utility

• Context matters. Test your items.

• Have a plan for coding, handling item non-response, 

and aggregating/publishing data.

• Consider the power of your tests.
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Minimization

Only collect the data if there are plans to use it. Only collect 

the minimum amount of information necessary to meet the 

planned uses.

• If sex or gender is already on a form but there are no 

current or planned uses, consider removing it.

• It may be sufficient to know whether the individual is a 

member of a protected class, not whether they identify 

with a specific gender identity or sexual orientation.

• Equity analysis and production of public statistics counts 

as a planned use! But agencies should also have plans to 

use data to address possible inequity.
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Inclusivity and Sensitivity

Use language that makes respondents feel accepted and 

respected. This cuts both ways! Federal forms and surveys 

must consider inclusivity and sensitivity for all respondents. 

• Asking binary sex/gender can leave out a significant 

portion of the population.

• Respondents can find more detailed SOGI questions 

invasive or offensive.

• For example, asking SOGI on administrative forms could 

make SGM respondents feel like they have to out 

themselves in order to receive benefits or services.
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Privacy Protection

This is not an abstract concept; there are real risks to 

respondents’ jobs, families, access, safety, and personal 

relationships. When linked to PII, SOGI data could be used to 

target individuals or to deny them benefits or services.

Most administrative forms and some surveys do not currently 

collect data with such large privacy risks. As a result, they may 

not have the right infrastructure, processes, and policies in 

place to protect the data.
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Privacy Protection

• Talk to your Senior Agency 

Official for Privacy (SAOP)

• Strip out SOGI before 

adjudication

• Consider data held by States, 

schools, grantees, etc.

• Explicitly list allowable uses in 

regs, SORNS, or other binding 

policies

• Informed consent: is the 

response voluntary, mandatory, 

required for a service or benefit?

• Explain possible uses to 

respondents

• Establish data governance 

principles; access and control for 

staff 

• Have a plan for FOIA requests, 

talk to your GC.

• For HR systems, allow 

employees to access and modify 

their responses at any time 

without restriction.

• Dispose of historical records.
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Consistency

Be as consistent as possible across the agency 

in the creation, handling, and use of this 

information. 

• Involve your Data Governance Council (CDO, SO, 

and EO) and create agency- wide policies and 

guidance. 

• Talk to your OIRA desk officer.

• Join the FCSM SOGI Interest Group to keep up 

with what other agencies are doing and learning.
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Compliance

Make sure the agency has specific statutory authority to collect 

this data, and that its collection complies with relevant statutes and 

policies including:

• The Paperwork Reduction Act (PRA)

• Privacy Act

• OMB Circular A-130

• Agency data policies

• Agency or program specific authorities to collect and protect 

data
What sex were you assigned at birth, on your original birth certificate?

 Female

 Male

How do you currently describe yourself? (Mark all that apply.)

 Female

 Male

 Transgender

 None of these

[IF “ASSIGNED AT BIRTH” NE “CURRENTLY DESCRIBE”] Just to confirm, you were assigned 

[$MALE/$FEMALE] at birth and now you describe yourself as [$FEMALE/$MALE]. Is that correct?

 Yes

 No

Example SOGI Module: Gender Identity

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Which of the following best describes how you think of yourself?

 Gay or lesbian

 Straight, that is not gay or lesbian

 Bisexual

 I use a different term (specify) _______________

 I don’t know

Example SOGI Module: Sexual Orientation

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Example Inclusive Gender Question

Are you:

Mark all that apply.

 Male

 Female

 Transgender, non-binary, or another gender identity

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Which of the following do you consider yourself to be? 

You can select as many as apply. 

 Straight or heterosexual 

 Gay 

 Lesbian 

 Bisexual 

 Transgender

Example LGBTQ Status Question 

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Example LGBTQ Status Question 

Thank You!

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