Regional Seminar - statistics.caricom.orgstatistics.caricom.org/Files/Meetings/PRASC/Mtg_Seminar_Admindat… · Provisions Statistics Canada The Statistics Model Bill vi. NSO to first

The Fundamental Role of

Administrative Data

in Official Statistics

Linda Howatson-Leo, Julie Trépanier and Gabrielle Zboril

Presentation to the PRASC

January 26-28, 2016

Regional Seminar

Part 2: Acquisition of Administrative

Data

Outline

Part 2 : Acquisition of administrative data

2.1 Establishing a governance framework GAMSO 1.2

2.1.1 Legislation (E1)

2.1.2 Policies and directives

2.1.3 Organizational and governance structures (E2)

2.2 Designing data acquisition agreements GSBPM 2.3 (E3)

2.3 Developing corporate tools GAMSO 3.8, GSIM exchange

2.4 Managing strategic collaboration GAMSO 1.3

4

2.1 Establishing a governance framework

2.1.1 Legislation

The “ideal” provisions to favor access

Provide the NSO access to administrative data,

including identifiers

Provide the NSO access to administrative data from

public authorities free of charge

The NSO’s right of access applies notwithstanding

other enactments, other than those pertaining to the

protection of public order or the security of the state

5


2.1.1 Legislation

The “ideal” provisions to favor use

Provide the NSO with the right to use the data to

produce and support any official statistics, including

the right to match data from different sources

Compel the public authorities to consult with the

NSO when introducing, revising or extending an

administrative data system

6


2.1.1 Legislation

The “ideal” provisions to enforce use

Instruct the NSO to use administrative data when

possible

Mandate the NSO to coordinate the national

statistical system and to promote the avoidance of

duplication in data collection by governments

7


2.1.1 Legislation

The “ideal” provisions to protect data

Protection of the confidentiality of administrative

data, i.e., the principle of “one-way traffic”

Privacy rights of individuals with respect to

collection, use, disclosure, disposal, retention,

accuracy and protection of their personal

information

8


2.1.1 Legislation

In Canada these provisions can be found in:

Statistics Act

Privacy Act

Access to Information Act

Personal Information Protection and Electronic Documents Act

Other acts that recognize the authority of the Statistics Act

Acts that authorize use of data available to the public

9

Exercise 1

Analysing country-specific

legislation


2.1.1 Legislation

11

Provisions Statistics Canada The Statistics Model Bill

i. Access to which

administrative data?

All, except data held by individuals.

Chief Statistician can delegate

his/her authority to acquire data.

Access to personal information in

accordance with the Canadian

Privacy Act and PIPEDA

All, except data held by individuals.

Subsection 9(3)

Chief Executive can delegate authority

to obtain. Subsection 9(3)

ii. Access free of

charge?

No mention No mention


2.1.1 Legislation

12

Provisions Statistics Canada The Statistics Model Bill

iii. Supersedes other

acts?

No mention Yes. Contains this “Notwithstanding the

provisions of any law adjoining

secrecy…in subsection 9(3)”

Also notes that the Act shall supersede

any other legislation and/or regulation

with respect to the collection of data for

statistical purposes in subsection 9(5)


2.1.1 Legislation

13

Provisions Statistics Canada The Statistics Model

Bill

iv. Limitations on use? Yes, only as per s.3 (mandate), s.19

(censuses) and s.22 (matters)

Yes, for statistical

purposes only as per

9(4)

v. Ability to influence administrative

data systems?

No mention No mention


2.1.1 Legislation

14


Bill

vi. NSO to first use administrative

data?

No, but s.3(d) mentions “to avoid

duplication in the information

collected”

No mention

vii. NSO to coordinate national

statistics system and avoid

duplication

Yes, as per s.3 Only pertaining to the

country

(s.4(e)e)


2.1.1 Legislation

15


Bill

viii. NSO to protect

administrative data?

Yes, as per s.17 and Access to

Information Act. Strict conditions under

which further disclosure is allowed.

Yes, as per s. 13.

However no mention of

disclosure of

administrative data

ix. Privacy rights of individuals

that prohibits access to data?

No, but the Canadian Privacy Act

recognizes the authority of the Statistics

Act to obtain administrative data.

No, but possible in the

country-specific

privacy legislation



Purpose:

Translate legislative requirements and central government policies and

directives into requirements and responsibilities

Communicate requirements and responsibilities to NSO managers and

employees

Include provisions for non-compliance

16



17

Title Objective

2.1.2.1 Policy on the use of

administrative data obtained

under the Statistics Act

OVERARCHING: To maximize the efficiency and

effectiveness of the use of administrative data in

statistical programs

Expects the NSO to:

1) Identify, influence and increasingly gain access to administrative data sources for statistical

purposes

2) Undertake new or revised data collection activity only when it is satisfied that the statistical needs

cannot be met effectively using administrative data

3) Use corporately-recognized quality assurance processes to assess the fitness for use of

administrative data in its statistical programs

4) Use administrative data in a way that achieves an overall better balance among response burden,

costs, data quality, and the relevance of statistical outputs for users



18

Title Objective



under the Statistics Act (cont’d)




Expects the NSO to:

5) Take a collaborative approach to data providers and treat them consistently across programs in

regard to the application of the statistical legislation

6) Avoid arrangements to access administrative data that place undue restrictions on its statistical

use of the data (corporate resource)

7) Appropriately document the arrangements with data providers

8) Identify an administrative data custodian for each administrative data source to obtain and

manage access to the data on behalf of the NSO



19

Title Objective







Expects the NSO to (cont’d):

9) Document all administrative data obtained for use in a corporate inventory

10) Provide researchers with equitable, timely and secure access to identifiable administrative data

11) Communicate its statistical use of administrative data to stakeholders and the public in a

proactive, coherent and transparent manner



20

Title Objective







Expects the NSO to (cont’d):

12) Assess and report on the data quality and methodology of statistical outputs that use

administrative data in accordance with other NSO policies and directives

13) Use administrative data in compliance with all relevant legislation and government policy,

including the Statistics Act, the Privacy Act and the Access to Information Act.



21

Title Objective

2.1.2.2 Directive on obtaining

administrative data under the

Statistics Act

ACQUISITION: To reduce its operating costs and to reduce

respondent burden, the NSO will undertake agreements

with organizations that hold administrative data that can

facilitate the fulfillment of the NSO mandate.

1. Identifies a central entity, i.e., an administrative data coordination function, as responsible for the

directive and being in charge (i.e., administrative data custodian) of complex or broad use data

acquisitions and of any other corporate strategies with administrative data

2. Requires the administrative data coordination function to maintain a corporate inventory of

administrative data with input from statistical programs



22

Title Objective



Statistics Act (cont’d)





3. Requires statistical programs to inform the administrative data coordination function of their

intention to negotiate new data acquisitions, and that the administrative data coordination function

assist them with corporate instruments, services and processes and avoid agreements that impose

significant restrictions or costs on the NSO (otherwise decision refers to higher governance

bodies)



23

Title Objective








4. Requires the administrative data coordination function to consult across the NSO to establish

corporate-wide needs for administrative data (broadcast) before agreements are prepared and to

make a recommendation on who should be the custodian

5. Requires statistical programs to inform the central legal support service, of their intention to

negotiate, modify or terminate agreements and that legal support service assist them with advice,

templates to document agreements and prepare proper delegation of authority



24

Title Objective








6. Requires legal support service to review all final formal data acquisition agreements or any other

informal documentation and store copies in a corporate registry

7. Requires statistical programs to inform the central procurement service of their intention to acquire

administrative data at a cost from a private sector organization, and that the procurement service

conduct procurement and prepare contracts as per government legislation and contracting policies



25

Title Objective








8. Requires statistical programs to assess the quality of potential administrative data and the

administrative data coordination function to offer quality assessment tools to do so

9. Requires the administrative data coordination function to post summaries of the NSO’s usage of

administrative data on the NSO website



26

Title Objective








10.Requires statistical programs to authorize NSO employees to access identifiable administrative

data, for which they are the administrative data custodian, based on the need-to-know principle,

and to consult as required, with the providing organization on behalf of other statistical program

managers regarding questions and concerns about the administrative data

11.Requires statistical programs to comply with the terms and conditions stated in agreements



Others that relate to administrative data – will be covered in Part 3,– Use of

administrative data:

3.2.3.1 Directive on conducting privacy impact assessments

3.2.3.2 Directive on record linkage

3.2.3.3 Directive on the use of deemed employees

27



Others that relate to administrative data – will be covered in Part 4, Management

of administrative data:

28

• 4.2.2 Directive on the Management of

Statistical Microdata Files

• 4.2.3 Directive on the Management of

Aggregate Statistics

• 4.3.1 Directive on Discretionary

Disclosure

• 4.3.2 Directive on Data Sharing

• 4.4.1 Policy on Informing Users on

Data Quality and Methodology

• 4.4.2 Directive on Informing Survey

Respondents

• 4.4.3 Directive on Record Linkage

• 4.1.1 Policy on Privacy and

Confidentiality

• 4.1.2 IT Security Policy

• 4.1.3 Directive on the Security of

Sensitive Statistical Information

• 4.1.4 Directive on the Transmission of

Protected Information

• 4.1.5 Information and Privacy Breach

Protocol

• 4.2.1 Policy on Information

Management

Statement of Principles (e.g., United Nations Fundamental Principles of Official Statistics)

1.Specify

Needs2.Design 3.Build 4.Collect 5.Process 6.Analyse 7.Disseminate

Governance Instruments for Admin Data and the Generic Statistical Business Process Model

Policy on the Use of Administrative Data under the Statistics Act

Conducting Privacy

Impact Assessments

Data Sharing under Section 11 and 12

Prescription for Data

Collection

Obtaining Administrative Data under the

Statistics Act

Use of Deemed Employees

Record Linkage

Informing Survey Respondents

Discretionary

Disclosure

Discretionary

Disclosure

Discretionary

Disclosure

Security of Sensitive Statistical Information

8.Evaluate

Related policies: Privacy and Confidentiality, Microdata Access, Information Management, Informing Users

of Data Quality and Methodology

Management of Statistical Microdata Files

29

Exercise 2

Identifying specific functions

within the NSO


2.1.3 Organizational and governance structures

Specific functions within the NSO

31

Functions Who in your NSO?

Administrative data custodian

Legal support service

Information management

Procurement service

Administrative data coordination

Administrative data operations

Statistical registers

32

Administra-

tive Data

Custodian

Legal

support

serviceInformation

manage-

ment

Procure-

ment

service

Administra-

tive data

coordination

Administra-

tive data

operations

Statistical

registers



The NSO should put in place the concept of administrative data custodian, i.e.,

the person who:

Liaises with the rest of the NSO to understand the NSO needs for administrative data held

by a given data provider

Negotiates access to administrative data from the same data provider, and has

delegated authority to sign and/or administer the agreement, – including

making sure the terms and conditions are respected, – and obtain metadata

associated to the administrative data

Provides access to the administrative data to others in the NSO based on

the need-to-know principle

Receives and handles questions on the administrative data and liaises with the data

provider and other stakeholders as needed33

Administra-

tive Data

Custodian



The NSOs should consider creating centralized functions (the same entity can

have more than one):

Legal support service and information management

Procurement service: for contracts with private sector

organizations

Administrative data coordination: for 1) the management of

corporate strategies, processes, tools; 2) the custody of

broad administrative data files or files that are

complex to acquire

34

Legal

support

service

Information

manage-

ment

Procurement

serviceAdministrative

data

coordination



The NSOs should consider creating centralized functions (the same entity can do

more than one) (cont’d):

Administrative data operations: for the receipt, capture,

formatting/standardization, coding and validation of all incoming administrative

data files

Statistical registers: for 1) the creation of base statistical registers and statistical

identification numbers; 2) the de-identification of administrative data file and re-

identification with statistical

identification numbers

35

Administrative

data

operations

Statistical

registers



The NSO should consider creating an Administrative Data Management

Committee with representatives from all areas of the NSO:

To oversee the development, implementation and adherence to corporate

strategies with respect to administrative data

To determine the custodian of broad use administrative data files or files that are

complex to acquire

To make decisions on whether to pursue acquisitions of administrative data files

that impose significant restrictions or costs on the NSO

To refer decisions to the most senior management committee of the NSO

36

2.2 Designing data acquisition agreements

The terms and conditions related to the acquisition, management, use

and disposal of administrative data by the NSO should be documented

The documentation may take the form of:

Formal data acquisition agreements such as Memorandum of

Understanding (same level of government) and Agreements

(different level of government or private sector at no cost)

Contracts (with private sector when costs are involved)

Informal written communication (if permitted by legislation)

Under the responsibility of the legal support service function

37

2.2 Designing data acquisition agreements

At a minimum, any documentation should mention:

▫ The NSO’s legal authority to obtain the administrative data

▫ The NSO’s intended uses of the administrative data, e.g.:

• “For statistical purposes only as legally permitted under the Statistics Act”

• “For uses by the Census and Social Statistics Programs”

• When the administrative data contain mainly tombstone information on individuals or businesses:

“For uses that improve the quality and efficiency of the statistical processes leading to the

production of statistical outputs in the Census and Social Statistics Programs”

• Avoid statements that limit the use to a specific survey, division or type of uses!

▫ The NSO’s legal requirements to protect the administrative data

38

Exercise 3

Designing data acquisition

agreements

2.3 Developing corporate tools

Administrative data inventory to register all incoming administrative data

files

Consultation (“broadcast”) to collect information on potential uses of

administrative data files about to be negotiated

Quality assessment tool of administrative data

when no data are at hand GSBPM 1.5

Central registry of agreements (formal or informal)

Central tool to access administrative data

40


Administrative data inventory

Anyone in the NSO can populate and consult the inventory at any time

Maintenance and monitoring assigned to the administrative data

coordination function

41

Objectives: To provide a central repository of information on administrative data holdings

To support efficient uses (or potential new uses) of administrative data files


Consultation (“broadcast”) to collect information on potential

uses

Consultation is conducted by the administrative data coordination

function with support from subject matter experts

43

Objectives: To ensure NSO needs for the data are well understood and that the use of the

data will be maximized

To avoid costly duplication of efforts on both the NSO and the data provider

resulting from unclear need

To reduce acquisition costs for the NSO


Consultation (“broadcast”) to collect information on potential

uses

The consultation template includes:▫ What we know about the data provider and data product, and how it could potentially be

used

▫ A questionnaire to collect needs of your NSO colleagues

A debrief is produced after collection to:

▫ Inform managers of the results of the consultation

▫ Determine the administrative data custodian that will negotiate the acquisition

▫ List action items, e.g., creating a working group of users to further discuss the acquisition

and uses

44

Consultation template


Quality assessment tool when no data are at hand

Assessment is conducted by the designated administrative data

custodian

The results should be centrally stored by the administrative data

coordination function

46

Objectives: To determine if the administrative data can fulfill the needs of the NSO using

metadata and information available from the organization

To provide a decision point to investigate further and acquire the administrative

data, or at least a sample or test version of the data



The assessment at this stage focuses on:

• Institutional environment (of the data provider)

And also the following quality dimensions:

• Relevance

• Timeliness

• Accessibility

• Interpretability

• Coherence

47



Institutional environment (of the data provider) is the organizational or

institutional factors that may have an impact on the provider’s capacity to

supply quality administrative data over time such as:

• Legislative or regulatory terms of access

• Reliability of the data provider or data source

48



Relevance is the extent to which the administrative data meet the

agency’s statistical needs, i.e.:

▫ Alignment with the desired statistical population, both in terms of coverage and

reference period

▫ Alignment with variables needed and their reference period

▫ Any particularity of the administrative data collection and processing that may

impact relevance (and/or accuracy)

Timeliness is the period between the reference point to which the

administrative data pertains and the date on which the information

becomes available to the NSO

49



Accessibility is the ease with which the NSO can use the administrative

data

• Format of the file or its variables

Interpretability is the availability of information and metadata needed to

interpret and use the administrative data appropriately

Coherence is the degree to which the administrative data can be used

with the statistical agency’s other data within a broad analytical

framework over time, i.e.:

• Stability of the population over time

• Stability of the content50


Quality assessment tool when no data at hand

In addition to analysing institutional environment and quality, the NSO

should also look at the impact the use of the administrative data source

could have on:

• Costs and savings

• Human resources

• Response burden

Any dimension or element may be given a level of importance based on

the intended use of the administrative data

A final decision is made to investigate further and acquire the

administrative data (in whole or in part)51


Central registry of agreements

53

Objectives: Ensure that the NSO meets its legal requirements and monitors the

confidentiality of the information collected under its enabling legislation

Ensure that the Chief Statistician’s authority for the activities undertaken by

the NSO are recorded and monitored on an accurate and timely basis

Communicate information to internal stakeholders who have specific

accountabilities under policy instruments associated with the NSO’s enabling

legislation and any privacy legislation that applies



Maintenance and monitoring assigned to the responsibility of the legal

support service function

The registry:

• Contains standardized metadata common to various legal instruments to

facilitate reporting and retrieval

• Maintains relationships between various legal instruments for cross-reference

and tracking purposes

• Includes copies of legal instruments for ease of reference

54



Anyone in the NSO can:

• Consult and search the contents of the registry

• View associated legal instruments

• Create and extract reports against the content of the registry

• In some cases, add content to the registry

55



Under the responsibility of information management

56

Objectives: Provide a uniform way for all users at the NSO to request and authorize

access to data

Enable workflows to move the request along to the appropriate authorization

and implementation chain

Audit and report on authorization and permissions to access data

Automatically remove access to data once permission periods expire or

responsibilities of users change



Anyone in the NSO can add a data access request form to the tool to

monitor access requests and permissions to their data

Anyone in the NSO can submit a request via the tool to obtain access to

specific data, without needing to know the appropriate authorization and

implementation chain

57

2.4 Managing Strategic Collaboration

Collaboration with data providers is key to increase the statistical use of

administrative data in a NSO

It can lead to better data, as well as better methods and processes to

use the data

The strategy is four-fold:

• Clearly communicating the NSO intention

• Finding win-win strategies to secure access to

quality data

• Partnering with other interested stakeholders

• Maintaining long-term partnerships

58


Clearly communicating the NSO intention

Start by explaining in simple terms how the NSO plans

to use the administrative data, and the benefits for:

• the country (new statistical information)

• its citizens (saves their money and their time)

• Its businesses (saves their money and their time, provides insight for their industry)

Explain the legal authority to obtain the data

• The organization holds data about others; the organization must be able to inform them

that it legally had to provide the info to the NSO

Explain the legal obligation to protect the data and the security measures

in place in the NSO to do so59


Finding win-win strategies to secure access to quality data

Examples:

Offering to share non-confidential results on the quality of the data with the

data provider

Proposing to the data provider ways to improve the collection and processing

of the data and its documentation

Returning the administrative data to the data provider once

cleaned (with no other confidential data added)

More globally, working with other departments on

government-wide strategies and policies that would benefit

both the statistical use and the administrative use of administrative data60


Partnering with other interested stakeholders

Identify anyone else who could benefit from the NSO

obtaining the data, and seek their support

• Local or regional statistical offices that care about statistics

• Other organizations that will value the statistical outputs produced from the data

because it fills important gaps

• Association of businesses or citizens that would be happy to see the burden of their

members decrease

Keep privacy commissioners informed

Mention organizations that were consulted or support you in your

communication with the data provider

61


Maintaining long-term partnerships

Establish bilateral committees with important data providers (at different levels)

to ensure no interruption in delivery, no unplanned changes to the data,

engage in constant discussion on how to improve the data and find win-win

strategies

62

Consider a committee of heads of

departments that will value data,

provide directions for its proper

management, and promote its use for

policy development and evaluation,

measurement of government program

efficiency and official statistics