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Attachment 2, DepSecDef memo: "Ensuring the Quality of Information Disseminated to the Public"

Ensuring the Quality of Information Disseminated

by the Department of Defense

Definitions

1.  Affected persons.  Persons who may benefit, be harmed, or otherwise affected by the disseminated information.  This includes persons who are seeking to address information about themselves as well as persons who use information.  "Persons" includes groups, organizations and corporations as defined by the Paperwork Reduction Act (PRA) of 1995.

2.  Dissemination.  Component initiated or sponsored distribution of information to the public.  Dissemination does not include distribution limited to: government employees or component contractors or grantees; intra- or inter-Component use or sharing of government information; and responses to requests for Component records under the Freedom of Information Act, the Privacy Act, the Federal Advisory Committee Act or other similar law.  This definition also does not include distribution limited to: correspondence with individuals or persons, press releases, archival records, public filings, subpoenas or adjudicative processes.

3.  Influential.  When used in the context of scientific, financial, or statistical information, means that the Component can reasonably determine that dissemination of the information will have or does have clear and substantial impact on important public policies or important private sector decisions.  Each Component is authorized to define "influential" in ways appropriate given the nature and multiplicity of issues for which the Component is responsible.

4.      Information.  Any communication or representation of knowledge such as facts or data, in any medium or form, including textual, numerical, graphic, cartographic, narrative, or audiovisual forms.  This definition includes information that a Component disseminates from a web page, but does not include the provision of hyperlinks to information that others disseminate.  This definition does not include opinions, where the Component's presentation makes it clear that what is being offered is someone's opinion rather than fact or the Component's views.

    4.1.  Specific types of information that are not subject to these guidelines

        4.1.2.    Distribution of information that is limited to government employees, Component contractors or grantees.

        4.1.3.    Intra or inter-Component or other Department or Agency use of sharing of government information including responses to requests under the Freedom of Information Act (FOIA), Privacy Act, the Federal Advisory Committee Act, or other similar laws.

        4.1.4.    Distribution of correspondence with individuals or persons.

        4.1.5.    Information limited to subpoenas and adjudicative processes.

        4.1.6.    Information that has previously been disseminated to the public and is subsequently presented to Congress as part of the legislative or oversight processes, including testimony of officials, and information or drafting assistance provided to Congress in connection with pending or proposed legislation.

        4.1.7.    Press releases and other information advising the public of an event or activity.

        4.1.8.    Procedural, operational, policy, and internal manuals prepared for the management and operations of the Component that are not primarily intended for public dissemination, including personnel notices such as vacancy announcements.

        4.1.9.    Information that is not otherwise disseminated to the public.

        4.1.10.                        Applicability of these DoD information quality guidelines may be waived by any DoD agent, for information disseminated under urgent situations, including imminent or credible threats to national defense and security.

5.  Information disseminating activity.  Any organization, office, entity or activity, not limited to the public affairs activity, that provides official information directly to the public.

6.  Information dissemination productAny book, paper, map, machine-readable material, audiovisual production, or other documentary material, regardless of physical form or characteristic, a Component disseminates to the public.  This definition includes any electronic document, CD-ROM, or web page.

7.  Integrity.  Refers to the security of information -- protection of the information from unauthorized access or revision, to ensure that the information is not compromised through corruption or falsification.

8.  Objectivity.  Involves two distinct elements, presentation and substance.

    8.1.  "Objectivity" includes whether disseminated information is being presented in an accurate, clear, complete, and unbiased manner.  The information must also be presented in the proper context.  Sometimes, in disseminating certain types of information to the public, other information must also be disseminated in order to ensure an accurate, clear, complete, and unbiased presentation.  Also, the Component must identify the sources of the disseminated information (to the extent possible, consistent with confidentiality protections) and, in a scientific, financial, or statistical context, the supporting data and models, so that the public can assess for itself whether there may be some reason to question the objectivity of the sources.  Where appropriate, supporting data (including classified data) should have full, accurate, transparent documentation, and error sources affecting data quality should be identified and disclosed to users when possible.

    8.2.  In addition, "objectivity" involves ensuring accurate and reliable information, including classified information.  In a scientific, financial, or statistical context, the original and supporting data shall be generated, and the analytical results shall be developed, using sound statistical and research methods.

    8.2.1. If the data and analytical results have been subjected to formal, independent, external peer review, the information can generally be considered of acceptable objectivity.  However, this presumption is rebuttable based on persuasive showing by the petitioner in a particular instance.

        8.2.2. In those situations involving dissemination of influential scientific, financial, or statistical information, a high degree of transparency of data and methods must be ensured to facilitate the reproducibility of such information by qualified third parties.

        8.2.3. Components shall not require that all disseminated original and supporting data be subjected to the reproducibility requirement.  Components may identify those particular types of data that can practicably be subjected to the reproducibility requirement, given ethical, feasibility, or confidentiality constraints.

        8.2.4. Making the data and models publicly available will assist in determining whether analytical results are capable of being substantially reproduced.  However, these guidelines do not alter the otherwise applicable standards and procedures for determining when and how information is disclosed.  Thus, the objectivity standard does not override other compelling interests such as privacy, trade secret, intellectual property and other confidentiality protections such as security classifications.

9.  Quality.  An encompassing term comprising utility, objectivity, and integrity.  Therefore, the guidelines sometimes refer to these four statutory terms, collectively, as "quality."

10.  Reproducibility.  The information is capable of being substantially reproduced, subject to an acceptable degree of imprecision.  For information judged to have more (less) important impacts, the degree of imprecision that is tolerated is reduced (increased).  If Components apply the reproducibility test to specific types of original and supporting data, standards for replication of laboratory data shall be established.  With respect to analytic results, "capable of being substantially reproduced'' means that independent analysis of the original or supporting data using identical methods would generate similar analytic results, subject to an acceptable degree of imprecision or error.

11.  Transparent/Transparency.  The practice of describing the data and methods of developing an information product in a way that it would be possible for an independent individual or organization to reproduce the results.

12.  Utility.  Refers to the relevance and timeliness of information to its intended users, including the public.  In assessing the usefulness of information that the Component disseminates to the public, the Component needs to consider the uses of the information not only from the perspective of the Component but also from the perspective of the public.

 

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