An Approach to Tiered Access in the 

Department of Veterans Affairs 

Michael Schwaber 

September 21, 2020

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Note: The information in this presentation pertains to the 

Office of Data Governance and Analytics within the 

Department of Veterans Affairs Office of Enterprise 

Integration. It does not to apply to the Department of 

Veterans Affairs as a whole.

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• Office of Data Governance and Analytics (DGA) 

• USVETS Database 

• Tiered Access 

• The Five Safes 

• DGA’s Vision of Tiered Access for USVETS 

• DGA’s Future Plans Regarding Data Access

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Overview
• DGA is an office within the VA Office of 

Enterprise Integration 

• Is VA’s authoritative clearinghouse for collection, 

analysis, and dissemination of information about 

Veterans and VA programs

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Office of Data Goverance and Analytics (DGA)
DGA Products 

• Veteran Population Projection Model (VetPop) 

• United States Veterans Eligibility Trends and Statistics (USVETS) 

database 

• Reports about veterans 

– Income, poverty, health education, employment, utilization of VA benefits and 

services

• Maps 

– Veteran population distribution by geography

• VA geographic distribution of expenditure tables

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Office of Data Goverance and Analytics (DGA)
United States Veterans Eligibility Trends and 

Statistics (USVETS) database 

• Is one of the motivating factors for DGA’s interest in tiered access 

• Contains record level data for approximately 39.3 million living and 

deceased veterans 

• Integrates data from 35 VA, non-VA federal, and commercial data 

sources

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USVETS Database
United States Veterans Eligibility Trends and 

Statistics (USVETS) database 

• Contains record level data for approximately 39.3 million living and 

deceased veterans 

• Integrates data from 35 VA, non-VA federal, and commercial data 

sources 

• Stored in SAS datasets

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USVETS Database
United States Veterans Eligibility Trends and 

Statistics (USVETS) database

• Contains data regarding veteran identity and veteran demographics 

• Demographics data includes information on veteran age, race, gender, 

socioeconomics, geography, military history, and utilization of VA benefits and 

services 

• Can be used to perform statistical analyses on the veteran population, and the 

results of these analyses which can lead to more informed decision-making 

regarding policies that affect veterans

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USVETS Database
USVETS Database History 

• Created by DGA in the year 2009 

• Initially had few data fields, and now has 58 data fields 

available to organizations external to VA 

• Since 2009, the number of data sources has increased from 6 

to 35

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USVETS Database
Current Usage of USVETS Database 

• USVETS database is one of several data sources that are used as inputs to the 

Veteran Population Projection Model 

• Used a data source for several reports on veterans including the Women’s 

Veterans Report and the Minority Veterans Report 

• Is shared with the Veterans Health Administration (VHA) and the Veterans 

Benefits Administration 

• Used as data source for some data requests from offices within VA and 

organizations external to VA

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USVETS Database
Desire to Expand Usage of USVETS Database 

• Initially in the year 2009, there were data quality issues with the 

USVETS database 

• Over time, the quality of the data improved 

• At this time, DGA has a high level of confidence in the data 

• DGA now wants to increase the availability of the data to more 

offices within VA and organizations external to VA, while at the 

same time protecting the data

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USVETS Database
Desire to Expand Usage of USVETS Database 

• DGA thinks the data might be useful in some areas of medical research, operational 

analyses, and programmatic analyses, including homelessness and suicide prevention 

• Desire to expand usage of USVETS data is reinforced by the recent Foundations for 

Evidence-Based Policymaking Act and the recent Geospatial Data Act 

• VA does not have a principal statistical agency or unit, and USVETS database is not 

covered by the Confidential Information Protection and Statistical Efficiency Act 

(CIPSEA). As a result, the USVETS database does not have the sharing restrictions 

that fall under CIPSEA. However, in DGA’s USVETS data sharing agreement, it is 

specified that USVETS data is to be used for statistical purposes only.

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USVETS Database
What Is Tiered Access? 

• According to the Commission on Evidence-Based Policymaking’s report 

of 2017 entitled “The Promise of Evidence-Based Policymaking,” 

– “tiered access is an application of data minimization”

• “data minimization means giving access to the least amount of data needed to complete an approved 

project”

– “tiered access structures set data access and security requirements based on an 

assessment of dataset sensitivity”

– “A well-designed and properly implemented data minimization strategy like tiered 

access can reduce the risk of unauthorized use and unintended harm to individuals.”

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Tiered Access
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Tiered Access

Level Sensitivity Description

5 Crimson Maximally restricted.

Highly sensitive. Identifiable records from data collected with a promise of confidentiality.

4 Red Restricted.

Sensitive. Identifiable records from data collected with a promise of confidentiality.

3 Yellow Restricted.

Crimson or Red datasets modified by technologies that mask individual records (e.g. data

query tools, differential privacy).

2 Green Minimally restricted.

Notsensitive. Data files made available to the public butsubject to procedures designed to

raise accountability by users, such as registration before accessing.

1 Blue Public data.

Mostsafe. Open data.

 Model of Sensitivity Levels for Federal data from CEP report

 Based on the Harvard Model. 

 CEP final report “The Promise of Evidence Based Policy Making” www.cep.gov/report/cep-final-report.pdf, p. 40. 
What is the “Five Safes?” 

• The Five Safes is a framework that can be used to assess and manage 

disclosure risk 

• Safe People, Safe Projects, Safe Settings, Safe Data, and Safe Outputs 

• According to the Australian Bureau of Statistics, the Five Safes framework 

is used by 

– Australian Bureau of Statistics

– Office of National Statistics (UK)

– Statistics New Zealand

Source: Australian Bureau of Statistics https://www.abs.gov.au/

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The Five Safes
Elements of the Five Safes Framework 

• Safe people: Is the researcher appropriately authorized to access and use the data? 

• Safe projects: Is the data to be used for an appropriate purpose? 

• Safe settings: Does the access environment prevent unauthorized use? 

• Safe data: Has appropriate and sufficient protection been applied to the data? 

• Safe outputs: Are the statistical results non-disclosive? 

Source: Australian Bureau of Statistics https://www.abs.gov.au/

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The Five Safes
How to approach the dimensions for tiered access? 

• Safe projects 

– Data use considerations: laws, ethics, consent, for profit motive

• Safe people 

– Organizational Affiliation: VA employees, employees of other federal agencies, academics and non-profit, private 

industry with a for-profit motive, the public

– Expertise: statistics, analysis, or medical, social or behavioral science

– Training on data stewardship

• Safe settings 

– IT systems and physical environment: VA servers, secure enclaves, remote access with credentials; access and audit 

controls; secure file transfer and communication protocols

• Safe data 

– Spectrum of sensitivity: data elements such as PII, income

– “Need to know”: which data elements, how much data, how many datasets linked/integrated

• Safe outputs 

– Statistical disclosure control: on data or output, cell suppression, data swapping, differential privacy

Which combinations of criteria have acceptable risk?

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DGA’s Vision of Tiered Access for USVETS
Model of Sensitivity Levels (preliminary) 

Red : Any file or database that includes direct Personally Identifiable Information (PII) or Protected Health 

Information (PHI), especially 

– SSN (or part), Name (any part)

– Date of Birth, Date of Death, Address – in conjunction with SSN or Name

Orange : Any microdata file or database that does not include SSN or Name, and instead has a unique person 

identifier that does not carry information in the value, i.e. the values are random, NOT created from a sort or 

index using personal or household information or from a canned hash 

Yellow : Tabulated or aggregated data that have not had disclosure techniques applied, e.g. cell suppression, 

rounding 

Green : Public data that have been disclosure-reviewed and approved for dissemination outside of the DGA or 

VA firewall, maybe also sensitivity reviewed

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DGA’s Vision of Tiered Access for USVETS
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DGA’s Vision of Tiered Access for USVETS

1. Input Data Folder 

VA files and files received 

from other agencies/

organizations.

2. Working Folder 

This is where data 

Processing happens, 

Where USVETS is 

created

3. Final PII Data 

Final data files when USVETS latest 

static and FY files are finalized, a single 

copy goes here, as well as a crosswalk 

from the “random” person identifier to 

SSN, Name, DOB

4. Research Data Folder 

A single copy of each 

the final USVETS data 

files but without SSN, 

Name, DOB, and address 

Instead has a “random” 

Unique person identifier

5. Project and User 

Working Folders 

Where researchers 

create and store 

extracts, run data 

and models, etc. 

using ORANGE data 

only 

6. Aggregated data 

Folder 

Tabulated or aggregated 

data that have not had 

disclosure methods applied

7. Public data 

Aggregated or 

tabulated data that 

have had cell 

suppression, rounding, 

and other disclosure 

techniques and gone 

through disclosure 

review

Concept of Server/Folder/File Separation (each box represents a separate server or folder)
Access Control: Red, Orange 

Red 

• Only a limited number of people have access 

– People who work on the data build for the USVETS (employees, contractors)

– Researchers who need to access a copy of the finalized data and crosswalks in order to 

match with their own data

• The researchers should have time-limited access to Red folders

• DGA should have an MOU in place with the researchers’ agency or unit

Orange 

• Researchers who only need access to USVETS, do not need to link with other 

data, AND the cubes don’t have the information they need for analysis

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DGA’s Vision of Tiered Access for USVETS
Access Control: Yellow, Green 

Yellow 

• Researchers who can use the content in the Cubes for their analysis 

Green 

• Anyone with a BISL account 

• Could make copies of this available on an FTP site

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DGA’s Vision of Tiered Access for USVETS
Additional Access Criteria 

EACH user of Red, Orange, or Yellow data must sign 

• A document such as Rules of Behavior or Acceptable Use Policy 

• Attest to applying DGA’s Disclosure Rules/Cell Suppression/Rounding standard 

operating procedure 

• Certify destruction of data extracts at end of projects 

DGA maintains Access Control Lists (ACLs) 

• Conduct regular audits of ACLs – do users still need access, activities 

• When a user is added to an ACL, automate reminders of when to remove access 

• Conduct regular reminders to users to review and delete files that are no longer 

needed – this is a privacy issue as much as a storage issue

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DGA’s Vision of Tiered Access for USVETS
In an evolving data access environment in which updates to 

data policy and new laws encourage more data access across 

agencies and to the public: 

• DGA intends to expand access to USVETS data within VA and 

to organizations external to VA 

• DGA will seek to refine and enhance its use of tiered access 

and other data security measures and will continually seek out 

new ways to protect its data

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DGA’s Future Plans Regarding Data Access
 Michael Schwaber 

 mike.schwaber@va.gov 

 Office of Data Governance and Analytics webpage for data products and reports: 

 www.va.gov/vetdata 

 (National Center for Veterans Analysis and Statistics webpage)

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Contact Information