Minimizing Disclosure Risk in HHS Open Data Initiatives. 3. Open Data Policy—Managing Information as an Asset


Memorandum M-13-13 was issued by OMB in conjunction with the Executive Order, establishes a framework to support effective information management strategies that will promote open data. Agencies are directed to adopt the following policies: use machine-readable and open formats; use data standards; remove all restrictions on distribution of public data (open license); and describe data using common core metadata (for example, origin, linked data, geographic location, time period/interval, and data quality). Agencies were requested to take the following actions:

  • Create and maintain an enterprise data inventory
  • Create and maintain a public data listing
  • Create a process to engage with customers to help facilitate and prioritize data release
  • Clarify roles and responsibilities for promoting efficient and effective data release practices

The memorandum gives particular attention to the protection of privacy and confidentiality, and the Mosaic Effect is noted as an issue of particular concern to this goal. Risk minimization guidelines include: collect or create only necessary and useful information; limit collection of identifying information; limit sharing identifying or proprietary information; take into account the levels of risk and potential harm that are associated with the dissemination of particular datasets; and consider information that is already public when releasing de-identified data (that is, be aware of the mosaic effect).

View full report


"rpt_Disclosure.pdf" (pdf, 1.01Mb)

Note: Documents in PDF format require the Adobe Acrobat Reader®. If you experience problems with PDF documents, please download the latest version of the Reader®