Confidentiality & Informed Consent

National Longitudinal Survey of Youth - 1979 Cohort

Confidentiality & Informed Consent

The NLS program has established set procedures for ensuring respondent confidentiality and obtaining informed consent. These procedures comply with Federal law and the policies and guidelines of the U.S. Office of Management and Budget (OMB) and the U.S. Bureau of Labor Statistics:

OMB Procedures and Federal Laws

OMB Procedures

The Office of Management and Budget (OMB) is responsible for setting overall statistical policy among Federal agencies.  For example, OMB has established standards on collecting information about race and ethnicity, industry, occupation, and geographic location.  OMB also has established standards on the manner and timing of data releases for such principal economic indicators as the gross domestic product, the national unemployment rate, and the Consumer Price Index.  In addition, OMB sets standards on whether and how much respondents to Federal surveys can be paid for their participation, an issue of particular concern in the NLS program.

Another of OMB's responsibilities is to review the procedures and questionnaires that Federal agencies use in collecting information from 10 or more respondents.  Federal data collections reviewed by OMB include administrative data, such as the tax forms that the Internal Revenue Service requires individuals and corporations to complete.  OMB also reviews all censuses and surveys that Federal agencies conduct, either directly or through contracts.  

Surveys that are funded through Federal grants to universities and other organizations generally do not have to undergo this OMB review process unless the grantee in turn contracts with a Federal statistical agency such as the Census Bureau to collect the data.  In place of OMB review, surveys funded through grants typically must undergo a competitive peer-review process established by the agency administering the grant, and that review process examines the procedures for maintaining respondent confidentiality and obtaining the informed consent of the participants.  In addition, such surveys also typically are scrutinized by an institutional review board established at the grantee's institution.

OMB examines a variety of issues during these reviews, such as the:

  • amount of time (and money, if any) that the agency collecting the information estimates respondents will spend to provide the requested information
  • agency's efforts to reduce the burden on respondents of providing the information
  • purpose and necessity of the data collection, including whether it duplicates the objectives of other Federal data collections
  • ways in which the agency obtains informed consent from potential respondents to participate in the data collection
  • policies and procedures that the agency has established to ensure respondent confidentiality
  • statistical methods used to select representative samples, maximize response rates, and account for nonresponse
  • payment of money or the giving of gifts to respondents
  • questionnaire itself, including the quality of its design and whether it includes questions that respondents may regard as sensitive

These OMB reviews are very thorough.  From the time an agency prepares an OMB information collection request until the time OMB approves the data collection, the process typically takes 7 months or more and includes multiple layers of review within the agency and at OMB.  These reviews are helpful in improving survey quality and ensuring that agencies treat respondents properly, both in terms of providing them with information about the data collection and its uses and protecting respondent confidentiality.

The review process also provides the general public with two opportunities to submit written comments about the proposed data collection.  The agency conducting the data collection publishes a notice in the Federal Register describing the data collection and inviting the public to request copies of the information collection request, questionnaires, and other materials that the agency eventually will submit to OMB.  The public is invited to submit written comments to the agency sponsoring the data collection within 60 days from the time the Federal Register notice is published.  In the history of the NLS program, the public very rarely has submitted comments to BLS, but when comments are received, they are summarized in the information collection request that ultimately is submitted to OMB.

After the request has been submitted to OMB, the agency sponsoring the data collection then publishes a second notice in the Federal Register and invites the public to submit comments directly to OMB within 30 days.  Again, in the history of the NLS program, the public very rarely, if ever, has submitted comments to OMB.  Once OMB has received the information collection request, they have 60 days to review the package, ask follow-up questions, suggest changes (or, occasionally, insist upon changes) to the survey questionnaire or procedures, and ultimately grant approval.

Respondents' Advance Letter. After OMB grants approval, the sponsoring agency can begin contacting potential respondents and collecting information from them.  The process of contacting potential NLS respondents begins with sending them an advance letter several weeks before interviews are scheduled to begin.  The advance letter serves several purposes.  The obvious purpose is to inform respondents that an interviewer will be contacting them soon, but BLS and the organizations that conduct the surveys for BLS also use the letter to thank respondents for their previous participation and to encourage them to participate in the upcoming round.  Another important objective of the advance letter is to remind respondents that their participation is voluntary and to tell them how much time the interview is expected to take.  The letter also explains to respondents how the data will be used and how respondents' confidentiality will be protected by BLS and the organizations that conduct the surveys for BLS.  An example of an advance letter, along with the confidentiality statement that appears on the back of the letter, is shown in Figure 1.

Figure 1. NLSY79 Round 20 Advance Letter

 Date
 Respondent First and Last Name
 Street Address
 City, State  Zip Code

Dear [Respondent First Name],

In a country increasingly committed to volunteerism, we on the National Longitudinal Survey of Youth 1979 (NLSY79) appreciate your continued participation in this study, which is sponsored by the Bureau of Labor Statistics of the U.S. Department of Labor.  The economic, political, and military challenges faced by our country in recent months make the study even more important.  Many leaders in business, education, and government believe that these circumstances could lead to long-term changes.  The time that you volunteer every two years provides policy makers and researchers in a variety of fields with a wealth of information about the experiences of your generation and changes in your life.  You alone can make this contribution, as you cannot be replaced.  Your participation is vital to the success of this important research project.  We remain extremely grateful to you for your continuing participation and look forward to speaking with you again in 2002. 
The interview will take about 60 minutes to complete.  At the end of the interview, you will receive $40 in appreciation for your time.  If you'd like, we'll gladly provide you with a certificate confirming that you completed 5 hours worth of community service. As always, the information you provide is protected under the Privacy Act and will be held in confidence to the full extent permitted by law.  (Please see the Privacy Act statement on the back of this letter.)  In case you have questions, the OMB control number for this survey is 1220-0109.  Without this number, we would not be able to conduct this survey.  (Please see the Disclosure Notice on the back of this letter.) One of our interviewers from NORC at the University of Chicago will be contacting you in the coming weeks to set up a convenient appointment for your interview. 
In the meantime, if you have any questions about the study, please feel free to call us toll free at 1-877-853-5908 or send us an e-mail at NLS79@norcmail.uchicago.edu.  More information about the NLS and the Bureau of Labor Statistics is available online at http://www.bls.gov/nls.
We look forward to talking with you soon! 
And again, thank you!
Sincerely,                  
Dr. Charles R. Pierret
Program Director
National Longitudinal Surveys
 

WHY IS THIS STUDY IMPORTANT?  Thanks to your help, policymakers and researchers will have a better understanding of the work experiences, family characteristics, health, financial status, and other important information about the lives of people in your generation.  This is a voluntary study, and there are no penalties for not answering questions.  However, missing responses make it more difficult to understand the issues that concern people in your community and across the country.  Your answers represent the experiences of hundreds of other people your age.  We hope we can count on your participation again this year. 

WHO AUTHORIZES THIS STUDY?  The sponsor of the study is the U.S. Department of Labor, Bureau of Labor Statistics.  The study is authorized under Title 29, Section 2, of the United States Code.  The Center for Human Resource Research at The Ohio State University and the National Opinion Research Center at the University of Chicago conduct this study under a contract with the Department of Labor.  The U.S. Office of Management and Budget (OMB) has approved the questionnaire and has assigned 1220-0109 as the study's control number.  This control number expires on January 31, 2007.  Without OMB approval and this number, we would not be able to conduct this study. 

WHO SEES MY ANSWERS?  We want to reassure you that your confidentiality is protected by law.  In accordance with the Confidential Information Protection and Statistical Efficiency Act of 2002, the Privacy Act, and other applicable Federal laws, the Bureau of Labor Statistics, its employees and agents, will, to the full extent permitted by law, use the information you provide for statistical purposes only, will hold your responses in confidence, and will not disclose them in identifiable form without your informed consent.  All the employees who work on the survey at the Bureau of Labor Statistics and its contractors must sign a document agreeing to protect the confidentiality of your data.  In fact, only a few people have access to information about your identity because they need that information to carry out their job duties. 

Some of your answers will be made available to researchers at the Bureau of Labor Statistics and other government agencies, universities, and private research organizations through publicly available data files.  These publicly available files contain no personal identifiers, such as names, addresses, Social Security numbers, and places of work, and exclude any information about the States, counties, metropolitan areas, and other, more detailed geographic locations in which survey participants live, making it much more difficult to figure out the identities of participants.

Some researchers are granted special access to data files that include geographic information, but only after those researchers go through a thorough application process at the Bureau of Labor Statistics.  Those authorized researchers must sign a written agreement making them official agents of the Bureau of Labor Statistics and requiring them to protect the confidentiality of survey participants.  Those researchers are never provided with the personal identities of participants.  The National Archives and Records Administration and the General Services Administration may receive copies of survey data and materials because those agencies are responsible for storing the Nation's historical documents. 

HOW MUCH TIME WILL THE INTERVIEW TAKE? Based on preliminary tests, we expect the average interview to take about 60 minutes.  Your interview may be somewhat shorter or longer depending on your circumstances.  If you have any comments regarding this study or recommendations for reducing its length, send them to the Bureau of Labor Statistics, National Longitudinal Surveys, 2 Massachusetts Avenue NE., Washington, DC 20212.

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