Policy on Access to Research Microdata Files
Retention Policy
Transparency Notice
Policy on Access to Research Microdata Files
Introduction
Research Microdata Files (RMFs) are unit record files provided for statistical research purposes by the Central Statistics Office (CSO) under Section 20(c) of the Statistics Act, 1993. While RMFs do not contain direct identifiers, the risk of disclosure through indirect identification may be significant. The processes for authorising access to RMFs and for managing RMF research projects are therefore strictly controlled by the CSO.
RMFs are not statistical products. Unlike statistical products which relate to aggregated statistical analysis, RMFs are not published or made available to the general public.
Legal Framework
The legal framework under which access to RMFs is granted is Section 20(c) of the Statistics Act, 1993. This section enables the Director General to appoint persons as Officers of Statistics
“to perform for a specified period particular statistical analysis which may necessitate access to data collected under this Act”.
Access is granted for research purposes, subject to a strict application of Section 20(c). This access must relate to a particular statistical analysis and it must be for a specified period. Thus, every appointment of an Officer of Statistics under Section 20(c) is:
The researcher must complete a Declaration of Secrecy as set out in Section 21 of the Statistics Act before access to an RMF is granted. The researcher is obliged by law to respect the statistical confidentiality of information contained in the RMF (Section 33) and may only use that information for statistical purposes (Section 32). Any breach of these requirements is an offence under Section 38 of the Act and may be subject to prosecution.
Application Procedure
Requests for access to RMFs must be made using ROSA, except where the request is for access to the CSO COVID-19 Data Research Hub; in this case, the Research Data Governance Board (RDGB) application form must be used. In all cases, the ultimate discretion regarding the provision of access to RMFs rests with the Director General of the CSO.
Confidentiality
The CSO emphasises that Officers of Statistics are legally obliged to ensure the confidentiality of RMF data. As part of this, persons applying for access to RMFs are required to demonstrate their knowledge of statistical disclosure control and to apply these methods to all tables intended for dissemination.
Any discussions of the data by the researcher (e.g. discussions of tables or analysis which could potentially disclose details of individual records) must be restricted to other Officers of Statistics appointed to the same statistical research project. The CSO also has the right to perform any appropriate statistical disclosure control, either before the RMF is issued to the researcher, or to any subsequent output generated from the RMF. This does not lessen the aforementioned obligations on the researcher appointed as an Officer of Statistics to perform all necessary statistical disclosure control. Failure to do so will result in CSO sanctions.
Access Criteria
Access to RMFs is a privilege granted to researchers who meet conditions and criteria as designated by the CSO. This policy sets out the conditions under which such access may be granted.
The application for access will be assessed vis-à-vis the RMF assessment criteria. The research proposal must state in sufficient detail:
a) the purpose of the research
b) the explanation as to why this purpose cannot be fulfilled using non-confidential data
c) the entity requesting access
d) the individual researchers who will have access to the data
e) the individual researchers’ proficiency in the use of statistical disclosure control
f) the access facilities to be used
g) the datasets to be accessed
h) the methods of analysing the datasets
i) the intended results of the research to be published or otherwise disseminated.
Access to RMFs, subject to adherence with the Statistics Act, 1993 and the associated policy and protocols for accessing RMFs, will, in general, only be granted to researchers who are employed by, or formally related to, a registered research organisation/institution. Researchers must also have a proven track record in data analysis or research, and provide a clear and specific research rationale, acceptable to the Director General, for access being granted.
Access to RMFs will not be granted to:
• individuals who are not part of a registered organisation/institution
• 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 a business statistics RMF
• media or related organisations (The CSO does not grant access to RMFs under the Re-Use of Public Sector Information regulations, for reasons of statistical confidentiality, but other non-confidential statistical products, such as Open Data, are available to facilitate media re-use.)
System Access
All access for researchers to RMFs will be controlled by the CSO by means of the CSO Researcher Data Portal (RDP). In the RDP, the analysis of RMFs takes place within CSO ICT systems. Access to the RDP may be provided on-site in the CSO or off-site, at the sole discretion of the CSO. Certain categories of RMF may only be accessed on-site.
The CSO RDP is a secure remote system through which approved researchers access microdata. There is no facility to copy data from the RDP to the local client PC.
Software applications provided for data analysis will be limited to a standard suite pre-installed on the virtual desktop.
For the purposes of this policy, off-site relates to premises other than the CSO offices in Skehard Road, Ardee Road and Swords. There are two different access types which are defined as follows:
a) On-site RDP: Researcher attends CSO office to access the RMF via RDP on a CSO PC
b) Off-site RDP: Secure remote access (via RDP) to RMFs residing in the CSO
Criteria for determining the type of access include:
a) The security and suitability of the working environment of the researcher
b) The researcher’s affiliation with a recognised organisation/institution that has a proven track record in data analysis or research
c) The indirect disclosure risk of the data included in the RMF
RMFs and RMF Access
All researchers, in order to be approved for access to an RMF, must successfully complete the researcher training modules in ROSA. The purpose of this training is to ensure awareness of the terms and conditions of the RMF Standard Agreement. 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 Officer of Statistics before access can be granted.
Access to the RMF, where granted, will only be provided once the researcher(s) has:
a) been appointed as an Officer of Statistics, and
b) electronically signed the Declaration of Secrecy, and
c) formally agreed to abide by the RMF Standard Agreement, and
d) successfully completed the researcher training modules in ROSA
This training course also sets out the legal obligations under the Statistics Act, 1993, to which a researcher is subjected when appointed as an Officer of Statistics.
The CSO will maintain a detailed register of individuals appointed as Officers of Statistics for the purpose of accessing RMFs.
Requests for access to RMFs from locations outside of the Republic of Ireland will not be facilitated. All researchers must be physically located in the Republic of Ireland when accessing RMFs.
RMFs sourced from administrative data will consist of sample data only and may be subject to additional terms and conditions as designated by the CSO.
In general, access to RMFs containing administrative data (excluding COVID-19 data) will be allowed only on-site.
Arranging On-Site Appointments
Researchers will contact the Researcher Coordination Unit (RCU) by email (rcu@cso.ie) at least one business-day in advance to book on-site appointments between the hours of 9:15 and 16:30. Only researchers with a scheduled appointment may be allowed onsite. RCU will maintain a Booking Register. Only researchers with an appointment in the Booking Register will be allowed on-site.RCU will notify the relevant Statistician by email in advance of the scheduled appointment.
On arrival, the researcher will present to CSO Reception. The Service Officer will verify the identity of the researcher by checking their photographic identification. Valid forms of photographic ID are: Passport (or passport card), driving licence, Public Services Card (PSC), employer ID, or university student ID. Photo identification should be confirmed each day the researcher comes on-site. Only those with valid forms of identification may be allowed on-site.
The researcher must sign in using the CSO Visitor Book and be issued a visitor badge and lanyard. The Service Officer will request the researcher to place any electronic recording equipment (mobile phone(s), tablet, etc.) into a bag to be provided by the Service Officer. This bag will remain at CSO Reception. Researchers will not be permitted to bring electronic recording equipment beyond the reception area. In Cork, the Service Officer will notify the statistician of the arrival of the researcher. The statistician or nominated POC will escort the researcher to the Researchers Room (GE14). In Dublin, the Service Officer will notify RCU of the arrival of the researcher. A member of RCU will escort the researcher to the Researchers Room. The researcher must leave their desk clear when leaving the office. Any notes not approved to be removed from the office by the data custodian must be destroyed.
In relation to RDP access:
a) Only those persons appointed as Officers of Statistics may use the remote access service.
b) The service must only be accessed from a secure location such as research facility or office (off-site researchers are permitted to connect remotely to the RDP from a home office, where approved).
c) The CSO reserves the right to audit the procedures in place at the approved off-site location(s), without prior notification, to ensure that the appropriate procedures are in place to protect the confidentiality and integrity of the data.
d) Access to the service is at all times strictly restricted to the appointed Officer(s) of Statistics. This implies that Researchers must ensure that the system is logged off when not in use, that the screen is to be locked when the researcher is away from their machine for any period of time and that data cannot be viewed by anyone other than the appointed Officer.
e) Log on credentials must not be physically stored, shared or otherwise communicated.
f) Recording, photographing, screen-sharing, copying or attempting to transfer data in any format from the RDP is strictly prohibited.
g) Any breach of the above must be reported immediately to the Researcher Coordination Unit (RCU) of the CSO.
On-site RDP access can only be permitted via a CSO desktop computer using the RDP infrastructure with all external media drivers disabled.
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. The restrictions and prohibitions on disclosure of information are set out in Sections 32 and 33 of the Statistics Act, 1993.
The researcher will be permitted to take only non-confidential aggregate data off-site for further analysis. The relevant Statistician/Senior Statistician will review aggregates from the RDP to check that they 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.
CSO staff will release the relevant aggregates to the researcher only after sanction to do so has been given by the relevant Statistician/Senior Statistician indicating that the aggregates checked are of a non-confidential nature.
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.
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.
The analysis/research undertaken must comply or be consistent with the specific purpose for which the access was granted.
Persons appointed as Officers of Statistics must not attempt to match/link (at a micro level) the RMF to any other non-CSO data source. Linkage to other CSO data sources is only permissible subject to the written agreement of the CSO. Any dataset derived from a CSO RMF by means of such linkage is subject to the same confidentiality requirements and conditions of use which apply to the original RMF.
On completion of the research or termination of the conditions relating to the appointment of the individual(s) as an Officer of Statistics, RDP access will be terminated.
In addition to the output safeguards described earlier, analysis sessions may be recorded by CSO staff to ensure that the RMF policy is fully adhered to.
The CSO reserves the right to monitor the implementation by researchers of their RMF agreement with the CSO, up to and including audits by the CSO, access logging and recording of RDP sessions
The CSO must be acknowledged as the data source in all outputs including citing in footnotes to aggregate tables and analysis based on derived variables. The following citation must be included in all publications:
“Results are based on analysis of strictly controlled Research Microdata Files provided by the Central Statistics Office (CSO). The CSO does not take any responsibility for the views expressed or the outputs generated from this research.”
In addition, acknowledgements or citations must be included in accordance with directions for the specific RMF as found within the “Guidelines and Instructions to Researchers on the use of CSO Datasets” available on the CSO website.
Failure to comply with the protocols, terms and conditions 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. These sanctions may include but are not limited to:
a) Termination of the individual’s appointment as an Officer of Statistics
b) Requirement to return and/or cease using all information provided by the CSO
c) Corresponding sanctions in relation to the organisation/institute and other RMF researchers in that organisation/institute
d) Denial of future requests for RMF research access
The CSO reserves the right to apply other sanctions, up to and including prosecution under the Statistics Act, 1993, where appropriate.
Where it is practicable and feasible, data requests will be met via the provision of aggregate data (such as anonymised microdata files (AMFs)) as distinct from the provision of an RMF.
The CSO will apply a principle of data minimisation when providing access to RMFs. I.e. the information provided to the researcher will be limited to those topics/variables in the survey which are necessary to the specific statistical research project.
The policy for business statistics RMFs is that the unique identifier is pseudonymised.
Office Notice 10/2016 sets out a “standard approach to the retention and secure disposal of statistical data (paper and electronic) and electronic storage media across the Office”. If data (paper and electronic) is to be retained, it needs to be justified.
The table below summarises retention rules for the RMF Project Application data that are set out in this document.
|
|
Collect |
Process/Analysis |
||
|
|
Paper Forms |
Scanned Image |
Database |
Project Data |
|
Project Data* |
N/A |
N/A |
N/A |
4 years |
|
RMF Application |
N/A |
2 years if successful, indefinitely if unsuccessful, subject to official review every five years |
2 years if successful, indefinitely if unsuccessful, subject to official review every five years |
N/A |
|
Certifications** |
Indefinitely subject to official review every five years |
Indefinitely subject to official review every five years |
Indefinitely subject to official review every five years |
N/A |
|
RMF Standard Agreement & Supplementary Forms*** |
N/A |
Indefinitely subject to official review every five years |
Indefinitely subject to official review every five years |
N/A |
|
Published Outputs |
N/A |
N/A |
Indefinitely subject to official review every five years |
Indefinitely subject to official review every five years |
* Researcher-generated content (code, working files, outputs, etc)
** Officer of Statistics Certificates, Research Organisation Registration and Researcher Registration forms
*** Add Researcher to RMF Project Application, Input and Output Request Forms
RCU requests that all applications are submitted electronically. Where applications are submitted on paper, the document will be immediately scanned and the paper form securely destroyed.
All hand-signed documentation (e.g. RMF Standard Agreements, Officer of Statistics certificates, RMF Renewal Application Form, Research Organisation and Researcher Registration forms) will be retained indefinitely on paper.
All scanned documents within RCU are required and retained for a minimum of two years for the proper and efficient administration of applications for access to RMF data under Section 20 (c) of the Statistics Act, 1993.
The RMF Application Form will be retained for a maximum period of two years after the application has been approved. If rejected, the application will be retained for as long as is necessary for the proper administration of the RCU processes. At the end of this period the data will be securely destroyed.
The RMF Standard Agreement and Officer of Statistics Certificates are evidence of access being granted at a point in time to specific RMF data for a specific purpose. As every person appointed as an officer of statistics signs a declaration of secrecy (S.21 Statistics Act, 1993), it is necessary to retain indefinitely a record of the data to which access has been granted.
Supplementary documentation such as the RMF Renewal Application Form, Research Organisation and Researcher Registration forms are scanned and stored digitally as a record of the signatories to the applications.
The RCU Microdata Portal and its backend database are an internal administrative system used to record submitted data pertaining to the Researcher, Research Organisation and Research Project as provided in the original RMF Application. It allows for the orderly retrieval of scanned records pertaining to the access to RMF data. For that reason, it is necessary to retain indefinitely details provided in the RMF Renewal, Research Organisation Registration and Researcher Registration application forms and unsuccessful RMF Application Forms.
All data stored within the Researcher Data Portal (RDP) is the property of CSO. All files, code, notes and documents created within the RDP by the researcher remains the property of the CSO. This data is archived immediately after the project has expired for a period of no longer than 4 years.
Published documents arising out of research carried out using CSO data is to be stored in a publicly available register indefinitely.
This notice sets out duties and responsibilities of the Central Statistics Office (CSO) under the General Data Protection Regulation (2016/679) regarding how we will manage the personal data that you provide in forms relating to microdata access.
Identity and the contact details for the CSO Contact details of the Data Protection Officer
Researcher Coordination Unit Data Protection Officer
Central Statistics Office Central Statistics Office
Ardee Road Skehard Road
Dublin Cork
D06 FX52 T12 X00E
Telephone: (+353)1 498 4376 Email: dpo@cso.ie
Email: rcu@cso.ie
The CSO will process the personal data that you provide:
• for the purpose of administration of access to RMFs as set out in this policy,
• for providing notices and updates to researchers, and
• for the purpose of maintaining a publicly available register of projects and project outputs.
It will not be used for any other purpose.
The personal data provided relating to an application for the Growing Up in Ireland RMF will be shared with the sponsor of the RMF, the Department of Children and Youth Affairs.
The Legal basis for the collection of this information is Section 20(c) of the Statistics Act, 1993 as part of the conditions and restrictions cited in that section.
The legal framework under which access to RMFs is granted is Section 20(c) of the Statistics Act, 1993. This section enables the Director General of the CSO to appoint persons as Officers of Statistics “to perform for a specified period particular statistical analysis which may necessitate access to data collected under this Act”.
The data that you provide to CSO in all forms relating to access to CSO RMFs will be retained by CSO until it is no longer required for administrative purposes. The RMF Application Form will be retained for a maximum period of two years after the application has been approved or rejected. At the end of this period the data will be securely destroyed.
The following forms will be retained indefinitely, subject to official review every five years:
• RMF Standard Agreement,
• Officer of Statistics certificate,
• Input and output request forms,
• Researcher and Research Organisation registration forms.
You can contact the Office of the Data Protection Supervisory Authority at:
Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231 Fax: +353 57 868 4757
E-mail: info@dataprotection.ie
Postal Address: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.
Under the General Data Protection Legislation, you have several rights with regard to your personal data. You have the right to request from us access to, and rectification of, your personal data and the right to restrict processing.
You do not have the right to erasure of your personal data or to object to its processing where it would impact the conditions mentioned in Section 34 of the Statistics Act 1993.