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Consolidation of IT systems, if not carefully planned and managed, could impair credibility if, for example, a statistical agency’s data systems are—or are even thought to be—combined with those of a regulatory or program agency. Credibility could also be affected if statistical agencies are not able to control data processing resources sufficiently to meet announced schedules for release of key economic and social indicators, such as the monthly unemployment rate or Consumer Price Index. As P&P notes (p. 9), “Adherence to predetermined release schedules for important economic or other indicator data serves to prevent even the appearance of manipulation of release dates for political purposes.”

Trust of Providers

Data providers must be able to rely on the word of a statistical agency. An agency achieves credibility with its providers by ensuring appropriate confidentiality of responses. Maintaining confidentiality, in particular, precludes the use of individually identifiable information for any administrative, regulatory, or enforcement purpose. (P&P, p. 5)

The E-Government Strategy (p. 11) proposes “building strong privacy protections into the E-Government initiatives.” However, if not carefully implemented, consolidation of IT systems across agencies within a department could inadvertently make it possible for administrative or enforcement agencies to gain access to confidential information provided by individual respondents solely for statistical purposes. Trust could also be impaired if survey respondents or other providers believe that their data are readily available to program or regulatory agencies.

Independence

A large and widely acknowledged position of independence is necessary for a statistical agency to have credibility and to carry out its function to provide an unhindered flow of useful, high-quality information for the public and policy makers. Without the credibility that comes from a strong degree of independence, users may lose trust in the accuracy and objectivity of the agency’s data, and data providers may become less willing to cooperate with agency requests.

In essence, a statistical agency must be distinct from those parts of the department that carry out enforcement and policy-making activities. To be credible, a statistical agency must be impartial and avoid even the appearance that its collection, analysis, and reporting processes might be manipulated for political purposes or that individually identifiable data might be turned over for administrative, regulatory, or enforcement purposes.

…Characteristics related to independence are that the statistical agency have: authority for professional decisions over the scope, content, and frequency of data compiled, analyzed, or published…; authority for selection and promotion of professional, technical, and operational staff;…[and] dissemination policies that foster regular, frequent release of major findings from an agency’s statistical programs to the public via the media, the Internet, and other means. (P&P, p. 6)

In the spirit of P&P’s comments on independence, we believe that careful consideration must be given to the costs, as well as the benefits, of any plan to integrate federal statistical agency IT systems with those of other agencies in a department. Offsetting the possible benefits to a department from budgetary savings and simplification of such processes as IT systems acquisition and maintenance are the possibly serious consequences for the ability of statistical agencies to perform their mission. Integration plans need to be carefully formulated so as not to



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