1. Broad description
The Case Study presents the management issues at the Statistical Office of the Republic of Slovenia (SORS) associated with the release of microdata to researchers. Tasks of the Data Confidentiality Committee and the system of rules and procedures regarding the release of microdata to researchers are presented.
With the procedure described, the Director-General of SORS has the necessary advice before deciding on the release of microdata to researchers and all the researchers are treated in the equal standardised way.
2. Why is it good practice?
It provides the necessary advice to the Director-General of SORS before deciding on the release of microdata.
Researchers are treated in equal way.
Trust in SORS regarding confidentiality of data is maintained.
SORS's staff is well informed about the procedure and can monitor the decision process and outcome which is applied in a routine fashion.
3. Target audience
Target audience are researchers in research and government bodies as well as individual researchers and social science data archives.
4. Detailed description
4.1 Data Confidentiality Committee
The Data Confidentiality Committee deals with the problems of data confidentiality at SORS and was established as an advisory body of the Director-General.
The Committee has the following tasks:
- To take care of the implementation of the Rules on the Procedures and Measures for the Confidentiality of Data Collected Under the Program of Statistical Surveys by SORS
- To deal with various matters and to give advice to the Director-General of SORS regarding issues that cannot be solved by general rules from the field of data confidentiality
- To report to the Director-General of SORS and the Statistical Council of the Republic of Slovenia regarding the situation in the field of data protection at SORS.
With reference to its tasks, the Data Confidentiality Committee adopts findings, positions and opinions and forwards them to the Director-General of SORS. Members of the Data Confidentiality Committee are experts from SORS and authorised producers of national statistics as well as external data protection experts. Committee members are appointed by the Director-General of SORS.
4.2 The system of rules and procedures regarding the release of microdata to eligible users
4.2.1 Organizational rules and procedures
All requests received by SORS for the release of microdata are transmitted to the Data Confidentiality Committee, which prepares the opinion about the possibility of releasing the requested microdata and forwards it to the Director-General of SORS for approval. In preparing the data, subject matter specialists must take into account the »need to know« principle.
4.2.2 Rules for the release of non-anonymised microdata
a. Release of microdata within the system of national statistics
Good practice: for implementing the Annual Program of Statistical Surveys, it is possible to exchange microdata between SORS and authorised producers of the program of statistical surveys.
b. Release of microdata collected with combined questionnaires to partner institutions
In some cases SORS sends together with one of the government institutions to the reporting units a combined questionnaire, thus decreasing the burden of reporting the same or similar microdata twice to government institutions.
Good practice: SORS collects microdata with a combined questionnaire together with a partner institution only if SORS and the partner institution have a legal basis to do this and if SORS's interest is not threatened by this method of microdata collection.
The legal basis for microdata collection by SORS and a partner institution must be printed on the questionnaire and the information letter must explain the purpose of microdata collection for the partner institutions.
c. Release of microdata to observation units requesting own microdata
In some cases observation units ask SORS for own microdata that they sent to SORS in the past.
Good practice: if SORS has these microdata, it transmits them to the observation unit within its technical and financial capacity. For the 2002 Population Census, SORS transmits prints of scanned census questionnaires.
d. Release of microdata about their members to commercial and interest associations
To rationalise microdata collection and decrease the burden of reporting units, some commercial and interest associations do not collect microdata for various analyses themselves but ask SORS to transmit these microdata to them.
Good practice: SORS transmits individual microdata on a member of an association after obtaining written consent from the member.
e. Release of microdata for the purpose of interviewing
For the purpose of interviewing, SORS may transmit to registered scientific research organizations and registered individual researchers only the following personal microdata: name and family name, address, year of birth, sex and occupation (see National Statistics Act).
4.2.3 Rules for the release of anonymised microdata
a. Release of microdata to scientific research institutions and individual researchers
Good practice: microdata for scientific research and analytical purposes (secondary data analysis) are transmitted only to scientific research institutions and registered researchers that can prove their registration.
b. Release of microdata to researchers in government bodies
Government bodies are statistical microdata users that have great and specific needs for microdata, so SORS facilitates their work regarding policymaking by enabling them to use microdata.
Good practice: microdata are transmitted to the government body if the purpose of microdata use is research or analysis.
The request is denied if the purpose of microdata use is to determine administrative advantages or disadvantages for business entities or natural persons.
c. Release of microdata to social science data archives
By transmitting microdata to data archives, SORS enables analytical and research work.
Good practice: microdata transmitted to various social science data archives have the highest level of confidentiality based on the contract between SORS and the data archive.
5. Supporting legislation
5.1 National Statistics Act
National statistics shall be implemented on the different principles among others on statistical confidentiality (Article 2).
The professional tasks performed by the Office within the framework of its basic functions shall among others develop methods and techniques for data protection (Article 7).
Dissemination of data shall be carried out in such a way that the persons or businesses cannot be identified (Article 34, 47).
For the purpose of conducting surveys, the Office may transmit to registered scientific research organizations and registered individual researchers only the following personal data: first name and family name of an individual, his/her place of residence, year of birth, sex and occupation (Article 41).
Statistics may be published in aggregate form only, by way of exception, data may also be published individually:
- upon written consent of the reporting unit as regards publication of the data in such a way;
- if data have been collected from public (generally accessible) data collections (records,
registers, databases, etc.);
- if data are published in such a way that the person or business involved cannot be directly identified (Article 50).
5.2 Rules on procedures and measures for the protection of data collected through programmes of statistical research at the Statistical Office of the Republic of Slovenia
In communicating data to users, the principle of statistical confidentiality shall be respected. The principle of statistical confidentiality means that no data may be communicated to users
outside the system of national statistics, which can be ascribed to a particular observation unit or which could indirectly enable this (Article 5)
Before communicating data referred to in the previous paragraph, the research organization or registered individual researcher shall sign the declaration on data protection (Article 16).
Data for research purposes may only be used by a registered research organization or registered individual researcher that has concluded an appropriate contract with the Office, which must contain the status of the user, the intended use of the data, protection of data and the manner and ti me of publication of the data (Article 17)
A proposal for concluding a contract shall be discussed by the Committee for Data Protection before the contract is concluded (Article 17).
- It provides the necessary advice to the Director-General of SORS before deciding on the release of microdata.
- Researchers are treated in equal way.
- Rules and procedures for microdata release are transparent (they are published on intranet and internet)
- Procedures are easy to understand for the staff of SORS and researchers.
- Trust in SORS regarding confidentiality of data is maintained.
- Staff of SORS is adequately informed about the procedure for managing decision making on confidentiality and can monitor the decision process and outcome which is applied in a routine fashion.
- There are clear responsibilities for the upgrading of the system for managing decision making on confidentiality.
- Time lag between the data request and approval
National Statistics Act ( http://www.stat.si/doc/drzstat/ZAKON_O_DSTA_ENG.PDF)
Description of access to microdata on SORS's home page http://www.stat.si/eng/drz_stat_mikro.asp
Rules on procedures and measures for the protection of data collected through programmes of statistical research at the Statistical Office of the Republic of Slovenia http://www.stat.si/doc/stat_urad/pravilniki/06-0471pravilnik_varstvo_podatkov_en.pdf
30 Aug 2013