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Policy on access to Research Microdata Files (RMFs) relating to data collected under the Statistics Act, 1993
- This policy relates solely to Research Microdata Files (RMFs);
- The legal framework under which access to RMFs is granted is the Statistics Act, 1993;
- Only those persons appointed as Officers of Statistics can access RMFs. Note an appointment as an Officer of Statistics is personal and non-transferable;
- An appointment as an Officer of Statistics is time bound and relates to a specified body of work;
- The confidentiality of data collected under the Statistics Act, 1993 is guaranteed in law. It should be noted in this regard that the Statistics Act, 1993 does not make a distinction between data on the basis of sensitivity (e.g. historical data periods) and data based on the type of information collected;
- Access to RMFs can only be granted by the Director General of the CSO (or by a senior staff member of the Office authorised by the Director General to do so under section 15(1) of the Statistics Act, 1993);
- Access to RMFs is granted solely for statistical purposes;
- Requests for access to RMFs must be made using the RMF application form;
- The application for access will be assessed vis-à-vis the RMF assessment criteria. However notwithstanding the specified criteria the ultimate discretion regarding the provision of access to RMFs rests with the Director General of the Central Statistics Office;
- Where it is practicable and feasible, data requests will be met via the provision of aggregate data as distinct from the provision of a RMF;
- In general only one version of an RMF will be created for an individual survey instance (e.g. Annual Services Inquiry 2007) containing the maximum level of detail that can/will be provided for that particular survey instance.
- Discussions/analysis relating to individual returns, or information (aggregate tables, descriptive text etc.) which could allow individual returns to be identified must be restricted to persons appointed as Officers of Statistics.
- Access to RMFs may be facilitated "off-site" or restricted to "on-site" access only. In general, access to RMFs relating to business surveys will be allowed only "on-site". For the purposes of this policy "off-site" relates to premises other than the CSO offices in Skehard Road, Ardee Road and Swords.
- Access to RMFs for students will be restricted to those undertaking at a minimum post-graduate work and in all such cases their supervisor (s) must also apply and be appointed as an Office of Statistics;
- In general, requests for the provision of RMFs to locations outside of the Republic of Ireland will not be facilitated ;
- "Off-site" access will only be granted once the CSO is satisfied that the confidentiality and integrity of the data can be maintained at the "off-site" location. This will include an analysis of the detailed specifications of the "off-site" IT security procedures and infrastructure;
- Where access is granted "off-site" the CSO reserve the right to inspect the procedures in place, at the "off-site" location without prior notification, to ensure that the appropriate procedures are in place to protect the confidentiality and integrity of the data;
- "On-site" access can be arranged at any of the CSO offices (Skehard Road, Ardee Road and Swords). Access will be provided on a desktop computer with all external media drivers disabled. Once the decision has been taken to facilitate access by the Director General, and the relevant documentation has been completed, the following procedures will apply:
- The relevant Statistician/Senior Statistician will liaise with theresearcher and identify the applications (IT) required by the researcher for the sanctioned research;
- Where the applications are already in use within the CSO, these will be loaded to the relevant desktop;
- Applications currently not is use within the CSO must be provided by the researcher and the appropriate licensing arrangements must be in place before these applications are loaded to the relevant desktop;
- It will only be permissible for the researcher to take non-confidential aggregate data off-site for further analysis;
- The relevant Statistician/Senior Statistician must verify that the aggregates that the researcher wishes to take "offsite" are non-confidential in nature. These must be assessed in the context of all available aggregate information to guard against disclosure through comparing different aggregates;
- In relation to intermediate aggregates (i.e. aggregates that are generated during the analysis phase of the project that will not be put into the public domain) it may be permissible, subject to prior agreement with the relevant Statistician/Senior Statistician, for these to be taken "off-site" without verification by the relevant CSO personnel. However responsibility for ensuring the confidentiality of all such aggregates rests with the individual appointed as an Officer of Statistics;
- IT Service Delivery will copy the relevant aggregates onto a medium prescribed by the researcher only after written sanction to do so has been given by the relevant Statistician/Senior Statistician indicating that the aggregates are of a non-confidential nature;
- RMFs will not contain any identifiable information (e.g name (person or entity) detailed address, PPSN) to avoid the direct identification of an individual respondent. A CSO generated reference number may be included on the RMF to facilitate linkage, by CSO staff only, with the source file for checking/validation purposes;
- The CBR, which is a CSO generated reference number for enterprises/local units, may be incorporated into RMFs relating to enterprises/local units where a business case acceptable to the CSO has been provided;
- Persons appointed as Officers of Statistics must not attempt to match/link(at a micro level) the RMF to any other data source;
- In general access, subject to adherence with the Statistics Act, 1993 and the associated policy and protocols for accessing RMFs, will only be granted to:
-
Individuals who, either in their own right or as employees of a recognised organisation/institution that has a proven track record in data analysis or research;
and
- individuals or individuals working in organisations/institutions that can give a clear rationale, acceptable to the Director General, for access being granted;
- Responsibility for ensuring the confidentiality of all outputs (reports, publications, presentations, articles etc.) based on the research carried out on the RMF (or using any element of the RMF) rests with the individual appointed as an Officer of Statistics;
- All outputs from the research project should be provided to the CSO for information purposes. If required by the CSO (specified in the Standard Agreement) all outputs (reports, publications, presentations, articles etc.) must be submitted to the CSO for approval, prior to being put into the public domain (i.e. communicated to anyone who is not an "Officer of Statistics") so that adherence to the Statistics Act, 1993 and the protocols attached to the assignment can be assured. In general this requirement will apply in respect of all RMFs containing enterprise/local unit based data;
- The CSO reserves the right to put outputs from the research into the public domain if the researcher (individual appointed as an Officer of Statistics) has not already done so;
- The RMF, regardless of any amendments made during analysis by the researcher(s) will at all times continue to be the property of the CSO;
- Access to business based RMFs will not be granted to individuals or individuals working in organisations that have a vested interest (i.e. have a material interest in the activities or business performance of a particular enterprise or set of enterprises) in any of the enterprises that exist on the RMF;
- The analysis/research undertaken must comply or be consistent with the specific purpose for which the access was granted;
- The CSO should be acknowledged as the data source in all outputs but the CSO will not take any responsibility for the views expressed or the outputs (as defined above) generated from the research undertaken on the RMF. In presenting results/analysis etc from the research project this point should always be highlighted (e.g. in footnotes to aggregate tables, analysis based on derived variables);
- The access must be lawful;
- The researcher may not copy the RMF (or subsets thereof), or any disclosive analysis/aggregates based on the RMF, to any medium or portable device (e.g. print, disk, CD, memory stick);
- Where access is provided to a RMF "off-site" the RMF (or subsets thereof) must not be copied or moved from the agreed location within the organisations IT infrastructure without the prior approval of the CSO;
- Where access is provided "on-site" the researcher may not take a copy of the RMF (or subsets thereof) or transfer to another computer (desktop, laptop etc) or portable medium (CD, USB stick etc.);
- On completion of the research or termination of the conditions relating to the appointment of the individual(s) as an Officer of Statistics all versions of the RMF (or subsets thereof) must be:
- Deleted/destroyed by the researcher; or
- Returned to the CSO. The RMF will be stored in situations where amendments have been made to the RMF by the researcher appointed as an "Officer of Statistics", and who may want to access the amended data file at some point in the future (which will only be possible under the Statistics Act, 1993).
- Where the RMF is to be deleted/destroyed the person(s) appointed as an Officer of Statistics must certify, in writing, that this task has been completed;
- The RMF will only be provided once the researcher(s) has
- Been appointed an "Officer of Statistics"
and
- Signed the Declaration of Secrecy
and
- Formally agreed to abide by the RMF Standard Agreement
- Where the RMF is being made available "off-site" the file will be transmitted via a secure transmission mechanism and will always be encrypted regardless of the transfer mechanism;
- It should be noted that RMFs will not contain any identifiable information to avoid the direct identification of an individual respondent (person or entity). In that context the CSO consider the following transmission mechanisms to be secure:
- Transmission of encrypted data via a dedicated site-to-site secure pipe;
- Encrypted CD delivered face-to-face (by hand);
- Transmission of encrypted CD via registered post;
- Transmission of encrypted CD via a recognised courier service;
- Any breach of the Statistics Act, 1993 is an offence, which may be subject to prosecution;
- The CSO may undertake an audit (unannounced) of the access granted to ensure compliance with the Statistics Act, 1993 and the policy and protocols attached to the assignment-;
- Failure to comply with the protocols etc. specified in the standard agreement attached to the provision of RMFs may have implications, for the individual and the organisation/institute for whom they work, and for future access to RMFs. In addition failure to comply with the protocols etc. will lead to a termination of the appointment as an Officer of Statistics and all data provided by the CSO must be destroyed/deleted or returned to the CSO;
- The CSO will maintain a detailed register of individuals appointed as Officers of Statistics for the purpose of accessing RMFs.
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