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SUBMISSION FROM THE AUSTRALIAN BUREAU OF STATISTICS
Committee members seemed to have given great weight to other evidence given by Professor Sless, particularly his response to a question from Mr Mutch.
Mr Mutch: "It has been said that those surveys (ie by AGB-McNair) indicate significant opposition to the retention of census forms. Is that drawing a long bow?
Professor Sless: Yes, it is ......". (LCA 468)
Professor Sless has strong views that lead him to the conclusion that approaches to communication research other than his own cannot provide accurate information. All his evidence to the Committee reflects this 'anti market research position'. At times his evidence suggests that he does not understand the research that was undertaken by AGB-McNair, or that he had not studied it closely. For example:
Whilst agreeing with Professor Sless' view that it is not easy to measure "attitudes", his assertions that "attitudes don't predict behaviour" and hence "changed attitudes do not necessarily result in changed behaviour" border on the extreme. All information campaigns, including those run by private businesses and political parties, are aimed ultimately at changing behaviour. The many millions of dollars spent each year on market research, polling, and advertising campaigns suggest that many people do not agree with Professor Sless. Indeed, if the Committee were to accept his advice that the results of these surveys should be disregarded then the Committee would have to believe that all market research results should also be disregarded. Of course, acceptance of Professor Sless' message that "running campaigns .... doesn't necessarily result in predictable changes in attitude", would rule out the suggestion that a slick ABS public relations campaign prior to the next census will be sufficient to sway community attitudes and behaviours!
(c) The ABS position
The findings of the two AGB-McNair surveys are consistent with the other quantitative and qualitative evidence available to the ABS. This evidence strongly supports the ABS contention that the retention of names and addresses will adversely affect census data quality. With 89% of the population agreeing that 'census forms should be destroyed to protect people's privacy and confidentiality', and between 34% and 45% saying they 'would be less likely to complete a census form, if forms were kept', a non-response level of 10% or more in the census is possible. Such a level of non-response, quite likely of uneven impact across different segments of the community, would immeasurably damage the quality of census data. In turn many important uses of census data would be affected.
(iii) There is no evidence of substantial public good from retaining census forms.
Those in favour of retaining census records for family, general history or social research did not present convincing evidence of substantial public benefit from their work through the use of census records. Indeed, most did not address this issue, focusing instead on perceived personal benefit. Few articulated the actual uses that might be made of census records in 2076 or 3001, other than to say it could help compile family histories or conduct social research. In fact some researchers told the Committee that it is not possible to say whether the records would in fact be utilised.
The Committee heard evidence that there are abundant alternative sources that are already available for much of this work. Census records would merely provide another source that might, possibly, be more convenient to access and more complete. For example, the evidence from Mr Trujillo, an expert practitioner from the Genealogical Society of Utah:
Acting Chair: "If Australian census records were retained on, for instance, microfiche and were kept confidential for 100 years and were then released to the public, would they contain information which would not otherwise be available to researchers through any other source?"
Mr Trujillo: "No. There would be duplication under births, deaths and marriages and other records, but they would have a unique value to the genealogist. Every little bit of information, such as the street and suburb that somebody lived in and who else lived in the house, is of utmost importance to genealogists and family historians." (LCA459)
It was apparent that some of the social research anticipated would not need identifiable census data but could be undertaken from the already available aggregate census data relating to small areas or communities of interest. Many social research projects of high contemporary value have been conducted and widely reported in the media using aggregate census data (eg Professor Bob Gregory's work on income distribution). It is not clear from the evidence what additional value such research would have if identified census records were to be available.
It was argued that destroying records is wrong because "we never know what question society may wish to ask or seek answers to in the future" (LCA284). That is tantamount to an argument for retaining all records forever without the onus of establishing their value. Of course, unless the law were changed, the Privacy Act would not allow the use of records for any purpose not explained at the time their collection.
Some geneticists proposed (LCA 254) that the census forms be retained to assist with genetic research. In its initial submission the ABS raised some practical problems which make this difficult to implement. But ABS believes that the general public would strongly oppose the development and maintenance of a social register of all persons in Australia, based on the census (see the reaction to the Australia Card proposal).
The Australian Institute of Health and Welfare (LCA 337), proposed that the census forms be retained by the ABS, that ABS immediately commence matching the records against various administrative files (eg birth and death records) and then ABS make available those records, in a way that they could not be identified, to support epidemiological research. Evidence by New South Wales Health (LCA 206) outlined some of the failings of census records for such purposes, but ABS can accept that there could be some value to such epidemiological research. However, there would be significant privacy and ethical issues to be addressed, including likely community concerns about data matching across data bases, and data being available (albeit in unidentified form) immediately for researchers. While undoubtedly there would be some support for such work it is doubtful whether there would be a high degree of public support.
(iv) The compromises proposed are not viable.
Throughout the public hearings a number of 'compromises' have been canvassed. None are seen as viable due to the privacy concerns they raise, or because they would be difficult to explain and 'sell' to the public, or because they raise significant operational problems, or because of their cost.
Opt in/opt out:
One 'compromise' suggested is to give householders the option on their census form to indicate whether their form can be kept or not.
This proposal would raise significant legal and operational issues:
Finally, this option will not deliver the data that genealogists et al are seeking. At best it will lead to an incomplete set of census records which would not serve their intended purpose. At worst it could lead to a very incomplete data set, particularly if the proportion giving consent is as low as indicated by the AGB-McNair survey.
A PR campaign will fix everything:
The assertion that a PR campaign will fix everything has very much over-rated the likely effectiveness of such campaigns, especially when a majority of the community has indicated significant concerns about the proposal to retain Census forms. As discussed above, Professor Sless' evidence may also be relevant here.
In its evidence ABS has pointed out that even if a very effective PR campaign could convince the vast majority of the population that there is nothing to fear from the retention of names and addresses, if only 10% of the population are not convinced the quality, and hence value, of the census data would be significantly reduced.
No matter how good an advertising campaign is, a one-off event with universal coverage like the census is very vulnerable to an effective anti-census campaign. It is not good risk management practice to rely on the hypothetical success of a future advertising campaign to totally rid public's concerns about privacy, or the absence of anti-census campaigns, so the Census can continue to deliver quality data for effective decision making. Being a $150m event, there will be no opportunity to run the census again should a judgement that the retention of names and addresses will not adversely affect the census be found to be wrong.
The proposal to assist such a PR campaign by using the term "Centenary gift to nation" is also likely to be ineffective. If the proposition is seen as an unacceptable invasion of privacy, it would still be considered as such by the community, whether it is dressed up as a "gift to nation" or not. No advertising campaign will alter that fact.
Finally, it should be noted that the retention of census forms from just the 2001 Census would not meet the needs of many proponents (eg epidemiologists, social researchers).
Putting genealogists questions on a single page:
It is technically not feasible to put the nine or more topics required by genealogists on a single page - it is likely they would not fit on two pages. However, even if this could be achieved, the sequencing of the questions that is necessary to ensure high quality responses, would be disturbed.
This proposition also ignores the fact that name and address, which are the core items required to be retained, are the two items that arouse the strongest privacy concerns.
Retaining names and addresses electronically and separately from the statistical data:
Again, this ignores the fact that retaining names and addresses is perceived as the main threat to privacy.
Retaining this information electronically substantially, and significantly, increases the capability of matching names and addresses with other information held electronically. This is an area of significant public concern.
Proposals for ABS to retain forms and match census records and other information for AIHW:
The AIHW proposal requires the immediate access and use of the retained census records and the immediate matching of those records with other (sometimes quite sensitive) data bases. It is not clear whether the privacy concerns this would raise could be sufficiently allayed. While it is true that such a longitudinal study has not raised privacy concerns in the UK, their participation in the study is not explained to householders. This would not be acceptable in Australia.
The evidence shows that there is significant public opposition to the retention of census forms. The very important uses of the census should not be put at risk on the basis of an unproved assertion that this opposition does not exist or that an effective PR campaign will allay the public concerns. The very important uses of the census should not be put at risk to satisfy what is essentially a private benefit.
The ABS' professional, frank and fearless advice to the Committee is that there is a very significant risk that a change to the current policy of form destruction will impact adversely on the quality of census data. Nothing put to this Committee demonstrates that the costs to Australia in 2001 and beyond of poor quality census data would be outweighed by the benefits, particularly public benefit, of retaining the forms. The primary purposes of the Census should not be put at risk by the secondary purposes, however laudable they may be, or purport to be.
Australian Bureau of Statistics
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