REQUESTS FOR RESTRICTIONS

9.16 If an individual or organisation (the claimant) is concerned that the release of international merchandise trade statistics may identify their activities, they may lodge a request for the data to be suppressed. Anyone considering a request should first obtain a copy of the Information Paper: Requests to Confidentialise International Trade Data (cat. no. 5497.0.55.001).

9.17 The request should include the following information:

• The claimant's name and ABN, or CCID, of the owner of the goods being exported or imported. This information helps the ABS to identify the transactions.
• The commodity, i.e. the specific AHECC or Customs Tariff code.
• The reason the restriction is being requested.
• The classifications likely to reveal the trading activities of the claimant, e.g. the claimant may be the predominant importer into a particular state, or the sole exporter to a particular country.
• The type of restriction requested, e.g. the details of trade with a particular country or all details relating to the commodity.

9.18 A claim may be based on trade that is about to start, where the claimant expects that their activities will be revealed in particular aggregates. In this case the claimant needs to provide details of their expected volume and value of trade and when trade will start, in addition to the details above.

9.19 Requests to confidentialise data should be directed to the Confidentiality Manager, International Trade in Goods and Services Section, Australian Bureau of Statistics, PO Box 66, Hobart, TAS, 7001. Contact can also be made by telephone on 02 6252 5409 or email international.trade@abs.gov.au.


HOW THE ABS HANDLES REQUESTS

9.20 After a request for suppression of data has been received, the ABS will investigate the claim in terms of the number of traders and the respective significance of their trade. If the investigation confirms that the business activities of the claimant are likely to be identified an appropriate restriction will be implemented.

9.21 The ABS applies the following procedures in undertaking a confidentiality investigation. The procedures are described using the example of a claimant who claims its imports of commodity X are identifiable in ABS international merchandise trade statistics.

• Step 1 - All import transactions for the previous 12 months for commodity X are extracted and tables produced, which show:
  • the value of imports for the previous 12 months, by each importer and their contribution to the total
  • by month, the value of imports by country of origin, by importer and each importer's contribution to the country total
  • the value of imports by month, by state of final destination, by importer and each importer's contribution to the state total.
• Step 2 - These tables are used to establish whether the claimant's concerns are valid. Unless other information is available, the assumption is that future trade will be similar in significance and distribution to that of the previous 12 months.
• Step 3 - If the aggregates are assessed as likely to enable the identification of the claimant's trade, the next step is to determine what type of restriction will satisfy their concern. In doing so, in addition to suppressing a particular aggregate directly, care is taken to make sure that the aggregate is not derivable from other cross classifications. Various restrictions are simulated using the data for the past 12 months. The aim is to use the restriction which maximises data utility and preserves confidentiality.

9.22 When the appropriate restriction has been chosen, it is generally implemented from the beginning of the next available reference month. Only in exceptional circumstances are restrictions applied to data already processed. Restrictions are generally put in place for a period of 24 months.

9.23 If the pattern of trade is infrequent, it may be possible to only restrict the data for those months in which the claimant trades. The claimant's concerns can be met for the periods during which it trades, while still releasing useful data for other periods. If this option is used, the claimant will be requested to provide notice of the timing of future trade so that appropriate restrictions can be put in place.


EXAMPLES OF APPROPRIATE RESTRICTIONS

9.24 The restriction that is appropriate to a given situation depends on the extent to which the claimant's activities are identifiable. The following examples illustrate the appropriate restrictions for particular situations:

• If the claimant is identifiable as an importer of commodity X at the total level, it would be necessary to suppress all details of imports of commodity X unless the commodity is in a HS chapter where a 'Broad commodity details' restriction could be applied.
• If the claimant is identifiable as an importer of commodity X from country Y, it would be necessary to suppress details of the country of origin for imports of commodity X. If a 'Selected country details' restriction is sufficient to prevent disclosure it would be applied, otherwise a 'No country details' restriction would be applied.
• If the claimant is identifiable as an importer of commodity X into state Z, a 'Selected state details' restriction (or possibly a 'No state details' restriction) would be applied.
• If the claimant is identifiable as an importer of commodity X from country Y into state Z, there are several options which would be considered. It may be sufficient to apply a 'Selected state details', 'No state details', 'Selected country details' or 'No country details' restriction or some combination of these.

REVIEWS OF RESTRICTIONS

9.25 The application of a restriction for a particular commodity does not mean that it will be applied to all future statistics for that commodity. Once a restriction is put in place, the data remains restricted in all statistics until the restriction is lifted or changed. Restrictions are reviewed periodically to assess if they are still warranted in their current form. When changes in trading patterns are identified, a restriction may be lifted completely or amended to suppress more, or less, data.

9.26 International merchandise trade confidentiality restrictions are reviewed at least every 24 months. Where the risk of disclosure is marginal, or a restriction has been imposed on the basis of expected trade, a review may be undertaken after a shorter interval to check whether trading patterns have changed or the expected volumes of trade have occurred. After a periodic review, the individual or organisation who initiated the restriction is contacted to advise them of the outcome. If the data no longer need to be confidentialised, the restriction is lifted from the month following the review.

9.27 Where a user of the statistics considers that data for a particular commodity should no longer be restricted they may request an early review. In these cases a restriction may be reviewed in advance of the scheduled review date. The user initiating an early review is required to pay for the cost of the investigation, regardless of whether it results in the restriction being lifted or not. Any variation to, or lifting of, a restriction will usually only affect statistics from that time forward and will not be applied retrospectively.

9.28 The type of restriction imposed is based on an analysis of trading patterns for the 12 months preceding the request. As further analysis will not normally be undertaken for 24 months, it is important that interested parties monitor the statistics to ensure the restrictions continue to meet their requirements.