Privacy Impact Assessment Questionnaire

Retention

The following questions are intended to outline how long information will be retained after the initial collection.

• How long is information retained in the system?
  PII is used to locate and contact respondents. Therefore, this information will be retained in the system for as long as the survey is active. Once the survey is no longer active, all PII can be destroyed.

• Has the retention schedule been approved by the DOL agency records officer and the National Archives and Records Administration (NARA)?
  The NLSY79 is part of the NARA’s Schedule of Records. The NLSY97 does not have a Schedule of Records.

• What efforts are being made to eliminate or reduce PII that is collected, stored or maintained by the system if it is no longer required?
  See answer under first bullet above.

• How is it determined that PII is no longer required?
  See answer under first bullet above.

• Privacy Impact Analysis
  The main risk identified was the use of SSNs for locating respondents. To mitigate this risk, the NLS removed SSNs from its databases and stores them in a secure database at the BLS National Office. Once the survey is no longer active, the SSN database can be destroyed.

Internal Sharing and Disclosure

The following questions are intended to define the scope of sharing within the Department of Labor.

• With which internal organization(s) is the PII shared, what information is shared, and for what purpose?
  NORC employees utilize personal and telephone interviews, as well as Voice Over Internet Protocol technology (VOIP) to collect the NLS data. PII is included in the file when it is transmitted to CHRR for further processing.
  
  Data is shared between the two organizations because they are responsible for different aspects of the production process. NORC is responsible for data collection, while CHRR is responsible for data processing and the creation of output files.

• How is the PII transmitted or disclosed?
  CHRR and NORC communicate through automated processes, over a secure file transfer protocol (SFTP) connection that allows NORC data collectors in the field to securely transmit completed interviews into a database for further processing and to retrieve new survey assignments. The data transmissions are batched twice daily over this encrypted connection.

• Privacy Impact Analysis

The main risk identified is the inclusion of SSNs in the contractor databases and their transmission between those databases.

To mitigate this risk, the NLS removed SSNs from its databases and they are stored only in a secure database at the BLS National Office.

External Sharing and Disclosure

The following questions are intended to define the content, scope, and authority for information sharing external to DOL which includes federal, state and local government, and the private sector.

• With which external organization(s) is the PII shared, what information is shared, and for what purpose?
  The vast majority of PII is not shared with data users. However, there are three categories of information that are shared:
  • Medical Information
  • Device Identifiers
  • Educational Records
  A brief description of each category of information and how it is shared is provided below. These data are shared with data users for research purposes.
  
  Medical Information
  Respondents in each cohort have answered questions about their health; however, the specific questions have varied widely as the health sections were modified to reflect the respondents' varying life cycle stages. These data are available on the NLS public-use files which can be downloaded for free from the BLS website.
  
  In the NLSY79 questionnaires, respondents were asked a variety of health questions. The health section is divided into two phases: from 1979 to 1996 and from 1998 to the current round. In the earlier health sections, questions focused on health concerns that restricted or inhibited the respondent’s ability to work. During the current period, the Health section was expanded to provide a baseline profile of the respondent’s overall health as they turn 40 years old (otherwise known as the 40-and-over module). Questions for the 40-and-over were grouped into 3 main parts. In the first part, respondents were asked to answer the Center for Epidemiological Studies Depression Scale (CES-D). In the second part, respondents were asked when they last saw a health professional and information about that visit. They were also asked a series of questions about their parent’s health. In the final part, respondents were asked a 12-question health survey designed to measure the respondent’s mental and physical health.
  
  In the NLSY79 CYA questionnaires, the health section gathers general information on height and body weight, types of limitations, the number of accidents and injuries, associated hospitalizations, and insurance coverage.
  
  In the NLSY97 questionnaires gather general health information about height, weight, health insurance coverage, and the age at which the onset of puberty occurred. In certain rounds, additional health information was collected on the respondent’s physical, mental, and emotional conditions.
  
  Device Identifiers
  Respondents of the NLSY79 were asked in the year 2004 if they wear a hearing aid.
  
  This variable is available on the NLSY79 public-use file, which can be downloaded for free from the BLS website.
  
  Educational Records
  NLSY79
  Information on NLSY79 respondents’ educational experiences has been collected during each survey year. In addition, three special data collections conducted during 1980–83 gathered the following for select universes: (1) supplementary information on degrees and certifications received as of the 1980 survey; (2) detailed information on the amount of time spent at school on each of the past seven days and the amount of time spent in various school-related activities, e.g., attending classes, studying, participating in other activities; and (3) high school course information gathered (directly from school records) during the 1980–83 transcript surveys.
  
  Data have been collected during each NLSY79 survey on respondents’ current school enrollment status, highest grade attended, and highest grade completed. Additionally, each survey recorded the month and year in which respondents obtained their high school diploma or General Equivalency Diploma (GED). During select survey years, information was also gathered on type of high school curriculum, whether the respondent was enrolled full- or part-time in college, the types of diplomas or college degrees received, and major field of study in college. Data on the timing of a college degree are available for the early survey years, while the data on the highest degree received and type of highest degree completed since last interview are available for post-1987 interviews. Beginning with the 1981 survey, information was gathered on the specific months and years in which those respondents who had attended school since the last interview were enrolled. During the 1979–85 surveys, respondents who had served in the Armed Forces since the last interview or were serving at the current interview date were asked a series of questions on high school or college courses taken and years of school completed while in the Armed Forces.
  
  A separate mail survey of the schools attended by civilian NLSY79 respondents was conducted during 1980. Designed to supplement both subjective respondent information on educational experiences collected during the main surveys and the transcript data collections described below, the school survey gathered information on each school’s total enrollment, type of grading system, number of books in the school library, vocational/technical course offerings, dropout rate, ethnic/racial composition of students and faculty, percent of economically disadvantaged students, characteristics/qualifications of the staff, and percentage average daily attendance.
  
  Also collected was respondent-specific information for the school surveyed including month/year last enrolled; reason not enrolled; highest grade attended; and whether or not the respondent had participated in remedial English, remedial mathematics, English as a second language, or bilingual education classes. Scores from intelligence and aptitude tests administered to the youth during his/her schooling were also collected.
  
  During 1980–83, transcript information was collected for 8,778 civilian NLSY79 respondents who were 17 years of age or older and who were expected to complete high school within the United States. The types of information gathered for each of up to 64 courses included grade level at which the course was taken, a code for the high school course, the final or computed grade for that course, the source of the final grade, and the credits received.
  
  Additional information collected from each school for each surveyed respondent included number of days the respondent was absent from school in each of the high school grades attended, the respondent’s rank in class for the last year attended, number of students in the respondent’s class for the last year attended, dates (month/year) last enrolled at this school, and reason left this school.
  
  NLSY79CYA
  Young Adults respondents in the NLSY79 CYA are asked a wide range of question concerning their education. First time Young Adult respondents answer core questions about repeating or skipping grades and dropping out. Additionally, questions are asked about (1) school quality and time spent on homework, as well as practices used by teachers and parental involvement in homework and the school community for respondents currently in grades 1-12; (2) the use of career planning or college preparations services, for respondents who are high school juniors or seniors; (3) the names of the colleges and/or universities applied to and whether or not the respondent was accepted to them, for respondents in twelfth grade or first year in college; and (4) the name, type of school, major, degree receipt and financial assistance , for college students.
  
  NLSY97
  NLSY97 respondents are asked about their educational activities, attitudes, and status. These grade-appropriate questions ask about the respondent's educational experience prior to high school, in high school, and in college. Additional questions focus on school-based training programs in which the respondent participates. Finally, the school and transcript surveys gathered data about the schools in the NLSY97 sample areas and the academic records of NLSY97 respondents.
  
  Questions regarding high school include general information about the respondent’s schooling experience such as the names of schools attended, dates, level of school, and type (public, private). It is important to note that school names are not released to the public. Rather, each school is assigned an identification number so that user can tell if a respondent attended the same school in more than one round.
  
  There are also a series of questions for those respondents that attended college. Topics on which information is gathered include the characteristics of enrollments, such as the degree sought, credits required, financial aid, and characteristics of the respondent’s attendance during each term (such as tuition, major, and remedial classes taken).
  
  To provide a more complete picture of respondents' educational experiences, data collected during the regular survey have been supplemented with two special surveys. School surveys conducted in 1996-97 and 2000-01 provide data about high schools in the areas where NLSY97 respondents live. Transcripts collected in 1999-2000 and in 2004 give information about the classes taken by NLSY97 youths, as well as other related aspects of their high school experiences.

• Is the sharing of PII outside the Department compatible with the original collection? If so, is it covered by an appropriate routine use in a SORN? If so, please describe. If not, please describe under what legal mechanism the program or system is allowed to share the PII outside of DOL.
  Yes. NLS does not consider these data to pose a confidentiality risk, as these data are not linked to individuals in public files. Routine use is covered in SORNs:
  
  BLS-13 National Longitudinal Survey of Youth 1979 (NLSY79)
  
  BLS-17 National Longitudinal Survey of Youth 1996 (NLSY96)
  
  Published in Federal Register, April 8, 2002, pgs 16856-16859

• How is the information shared outside the Department and what security measures safeguard its transmission?
  The NLS program produces three main outputs for the current surveys: a public-use file, a geocode file, and a restricted data access file. This tiered system allows the NLS to control the level of information available users.
  
  Public-Use Files
  The public-use files are made available for free to the public and can be downloaded from the NLS website. To protect the confidentiality of respondents, public-use files do not contain respondent PII such as name, SSN, address and phone number. In addition, they also lack higher level geographic variables such as state, county, and metropolitan areas. However, public-use files do contain medical information and medical identifiers.
  
  Geocode Files
  Geocode data are essentially the public-use files with the additional geographic variables of state, county, and MSA for each respondent. To protect the confidentiality of respondents, the Bureau of Labor Statistics (BLS) only grants access to geocode files for researchers in the United States who agree in writing to adhere to the BLS confidentiality policy and whose projects further the mission of BLS and the NLS program to conduct sound, legitimate research in the social sciences. These researchers can use NLS data with geographic information at their own facilities, provided that the research project and physical and electronic security measures described in the NLS geocode application are approved by BLS.
  
  Restricted Data Access Files
  Restricted data access files can be divided into two types: NLSY Zip Code and Census tract files and the NLSY School Survey Data. These files contain data that is not available on either the public-use of geocode files. These restricted data files are available to researchers from colleges and universities, government, and eligible non-profit organizations. These confidential files are available for use only at the Bureau National Office in Washington, DC, on statistical research projects approved by BLS.

• Privacy Impact Analysis
  PII such as SSNs, names, addresses, and phone numbers are not available on any of the NLS files. In cases where higher level geographic identifiers are available, access is restricted to users that have been approved after submitting to a formal application.

Notice

The following questions are directed at notice to the individual of the scope of PII collected, the right to consent to uses of said information, and the right to decline to provide information.

• Was notice provided to the individual prior to collection of PII?
  The NLS program has established a variety of 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), the Department of Labor, and the U.S. Bureau of Labor.
  
  Respondent Confidentiality
  BLS policy requires that advance letters sent to potential respondents in these surveys include on the back of the letter the series of questions and answers about confidentiality and other survey topics. In addition to these written questions and answers, survey interviewers are trained how to answer questions from respondents about how their privacy will be protected.
  
  Interviewers explain to potential respondents that all the employees who work on the surveys at BLS, NORC, and CHRR are required to sign a document stating that they will not disclose the identities of survey respondents to anyone who does not work on the NLS program and is therefore not legally authorized to have such information.
  
  Interviewers also explain that the answers respondents provide will be made available to researchers at BLS and other government agencies, universities, and private research organizations, but only after all personal identifiers—such as names, addresses, Social Security numbers, and places of work—have been removed. In addition, the publicly available data files exclude any information about the States, counties, metropolitan statistical areas, and other, more detailed geographic locations in which respondents live, making it much more difficult to infer the identities of respondents. Respondents are told that some researchers are granted special access to data files that include geographic information, but only after those researchers undergo a thorough application process at BLS and sign a written agreement making them official agents of BLS and requiring them to protect the confidentiality of respondents. In no case are researchers provided with information on the personal identities of respondents.
  
  Consent Statements
  Consent from NLSY97 respondents and parents. Because of the young ages of this cohort in the initial survey years, additional measures were taken to obtain informed consent from minors and their parents. Consent procedures for rounds 1 through 5 of the NLSY97 included the following protocol:
  
  
  1. For respondents age 17 and younger, parents were asked to complete a written Parental Permission to Interview Youth form prior to the youth’s completion of the interview. Respondents themselves were asked to complete a written Youth Assent to Participate form prior to completing the interview. This protocol also applied to respondents whose interviews were completed by a proxy. (Proxy interviews are conducted in cases in which a disabled respondent could complete the interview only with the assistance of a parent, guardian, or other caretaker.)
     Respondents who were age 17 or younger and had attained independence or were considered “self-supportive” were not required to have a parent complete a permission form.
  2. Whether or not a parent permission form was required, all youths, regardless of age, signed a consent form prior to completing the interview.
  
  Through the completion of round 5 data collection in May 2002, a significant proportion of NLSY97 sample members required signed parental permission because they had not yet reached age 18 or established legal independence.
  
  As of January 1, 2003, all NLSY97 sample members were at least age 18. Beginning in round 6, consent procedures changed to align with procedures of other large surveys of adults. Respondents age 18 and older now verbally consent prior to completing the interview. For incarcerated respondents and respondents whose interviews are completed by proxy, the NLS program continues to require signed consent as an additional safeguard against possible coercion.
  
  NLSY79 respondents and Young Adults age 18 and older
  Respondents are able to review the confidentiality and consent information presented in the advance letter. The respondent gives verbal consent to participate at the beginning of the interview.
  
  Children of the NLSY79
  In the Children of the NLSY79, the biological children of female NLSY79 sample members are assessed, and the mothers are interviewed about their children. Children ages 4 to 14 are given a variety of assessments depending on their age; children younger than age 4 are not assessed. The mother’s consent is required for these assessments to be administered. The field interviewer asks the mother to sign a consent form. The back of the parental permission form has the questions and answers shown in figure 2 of this chapter. In the rare cases in which the child is not assessed but the mother is interviewed by telephone about the child, the mother gives verbal consent over the telephone. The field interviewer signs the consent form and returns it to the central office of the NLS contractor for secure storage. Children ages 10 to 14 are asked a series of questions through a self-administered questionnaire on a variety of potentially sensitive topics. After the mother verbally agrees that the child may answer these questions, the interviewer reads a consent statement to the child and obtains verbal consent. This consent statement is similar to the statement used with older respondents but has been cognitively tested and revised to ensure that it is appropriate for preteens.
  
  Young Adults under age 18, parental consent
  Parental permission is required for young adults ages 15 to 17 who undergo an interview modeled on the questionnaire used in the main NLSY79. For telephone interviews, the field interviewer asks to speak to the parent and requests permission from that parent to interview the young adult. When the parent grants permission, the interviewer signs the consent form and returns it to the central office of the NLS contractor for secure storage.

• Do individuals have the opportunity and/or right to decline to provide information?
  Participation in the survey is voluntary. Respondents have the right to decline the entire interview or specific questions, including PII related questions.

• Do individuals have the right to consent to particular uses of the information? If so, how does the individual exercise the right?
  As stated earlier, respondents are made aware of how the answers they provide may be used. Based on that information, they have the right to refuse to participate in the survey or decline to answer specific questions.
  
  NLSY97
  In terms of PII, the NLSY97 has a specific series of questions that asks the respondent for permission to use their contact information under different locating situations. The questions are as follows:
  
  We appreciate your help in answering these questions. As part of this survey I will ask you some questions that may help us contact you in the future. By sharing this contact information, you give your permission for us to use it to try to contact you for future interviews. In attempting to reach you, we will never reveal any of the answers you've provided to the survey questions.
  • R AGREES WITH PROVIDING CONTACT INFORMATION
  • R DISAGREES WITH PROVIDING CONTACT INFORMATION
  
  (if 1, go to next series of question)
  
  
• If the contacts you have provided offer the names of other people who may help us reach you, may we contact those people as well?
  1, Yes 0, No
  
  
• We value your participation each year. Address and phone information in directories and public records can help us reach you. May we use them, only if needed?
  1, Yes 0, No
  
  
• If you are or were to become a member of the Armed Forces, or if you were to enter a correctional facility or a residential care facility, may we contact government or other administrative officials to get their help in locating and interviewing you? When attempting to locate and interview you, we may reveal the fact that you are a participant in this survey. However, as stated earlier, we will never reveal any of the answers you've provided to the survey questions.
  1, Yes 0, No
  
  NLSY79
  The NLSY79 also asks the respondent for permission to use their contact information for locating purposes, but the questions are more general in nature.
  
  In order to confirm your contacting information, may we search the Web, check phone and address directories, consult public records, and use companies that provide directory assistance or other commercial locator services? As always, we won't reveal your participation in the survey when using these services.
  
  We would like to collect contact information for people who would be most likely to know how to contact you. Could you please give us contact information for at least one person you keep in touch with?
  
  
• Privacy Impact Analysis
  Respondents are informed of how their data will be used at the start of each round. In addition, they have the right to refuse to participate in the survey or decline to answer specific questions.

Access, Redress, and Correction

The following questions are directed at an individual’s ability to ensure the accuracy of the information collected about them.

• What are the procedures that allow individuals to gain access to their information?
  Respondents can request their information from the NLS program.

• What are the procedures for correcting inaccurate or erroneous information?
  In most cases, erroneous or inaccurate information is corrected by the respondent. Updates generally occur during the annual (NLSY97) or biennial (NLSY79) interview process. Outside of the actual interview, the respondent may provide updated contact information such as address or phone number via a respondent locator card, respondent website, or pre-interview phone call.
  
  In cases where a respondent has been identified as unlocatable, the NORC field staff may utilize either public or commercial search engines (Accurint) in an attempt to update respondent contact information such as an address or phone number.

• How are individuals notified of the procedures for correcting their information?
  There is no formal process for notifying respondents of corrected information. In most cases, if information is inaccurate, the respondent provides the correct information during their next interview. After the respondent has provided the information, the field interviewer will confirm with the respondent that the information provided is correct.

• If no formal redress is provided, what alternatives are available to the individual?
  Not applicable.

• Privacy Impact Analysis
  Respondents have the opportunity to correct inaccurate information from prior rounds during their next interview.

Technical Access and Security

The following questions are intended to describe technical safeguards and security measures.

• What procedures are in place to determine which users may access the system and are they documented?
  All employees of NORC and CHRR who work on the NLS contract must be designated by BLS as agents under the requirements of the Confidential Information Protection and Statistical Efficiency Act (CIPSEA) of 2002. A BLS agent agreement must be signed by each NORC or CHRR staff member and by the Contracting Officer's Technical Representative at BLS. BLS, NORC, and CHRR maintain the lists of authorized agents and add and remove agents from these lists on a contemporaneous basis. No employee of NORC or CHRR may access the NLS system without signing a BLS agent agreement. Access to specific areas of the NLS system also depends on the job duties of the NORC or CHRR employee, and access is controlled by a series of firewalls, which require passwords and other forms of authentication.

• Will Department contractors have access to the system?
  Yes.

• Describe what privacy training is provided to users, either generally or specifically relevant to the program or system?
  All BLS agents at NORC and CHRR must complete BLS Confidentiality Training at the time they become BLS agents and annually thereafter. All BLS agents also must complete the Department of Labor Information Systems Security Awareness Training at the time they become BLS agents and annually thereafter. NORC and CHRR also provide their employees with orientation training, which includes discussions of security regulations and policies. BLS agents at NORC and CHRR who have IT security responsibilities also complete a required number of role-based training hours annually, and the number of hours required depends on their level of responsibility. Completion of all training is documented by BLS, NORC, and CHRR.

• What auditing measures and technical safeguards are in place to prevent misuse of data?
  The NLS System complies with standards as specified by BLS, DOL, OMB, and NIST. Compliance with these standards is monitored through periodic tests by BLS, NORC, CHRR, and the Department of Labor Office of the Chief Information Officer. The NLS system also underwent an information security audit in 2009 by the Department of Labor Office of the Inspector General.

• Privacy Impact Analysis
  All BLS agents at NORC and CHRR who access the NLS system complete the annual BLS Confidentiality Training and Department of Labor Information Systems Security Awareness Training. BLS agents at NORC and CHRR who have IT security responsibilities also complete a required number of role-based training hours annually, and the number of hours required depends on their level of responsibility. Completion of all training is documented by BLS, NORC, and CHRR.

Technology

The following questions are directed at critically analyzing the selection process for any technologies utilized by the system, including system hardware, RFID, biometrics, and other technology.

• What stage of development is the system in, and what project development life cycle was used?
  The system is in Operations and maintenance stage of the DOL System Development Life Cycle.

• Does the project employ technology which may raise privacy concerns? If so please discuss their implementation?
  No, the system does not employ technology that would raise privacy concerns.

Determination

As a result of performing the PIA, what choices has the agency made regarding the information technology system and collection of information?

BLS has completed the PIA for NLS, which is currently in operation. BLS has determined that the safeguards and controls for this moderate system adequately protect the information.

BLS has determined that NLS is collecting the minimum necessary information for the proper performance of a documented agency function.

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