Supporting Statement A Certification of Identity Form BC-300_08272025

SUPPORTING STATEMENT A

U.S. Department of Commerce

U.S. Census Bureau

Certification of Identity (Form BC-300)

OMB Control No. 0607-1018

Abstract

The Census Bureau’s Freedom of Information Act (FOIA) Office processes approximately 260 Privacy Act requests each year. To safeguard individuals’ personal information and ensure compliance with privacy regulations, the FOIA Office developed the Certification of Identity (Form BC-300). This form serves as a verification tool to accurately identify requesters and deliver appropriate personnel records, thereby reducing the risk of inadvertently disclosing sensitive information to unauthorized individuals. Requesters are asked to provide basic identifying details—including their name, address, date of birth, and a description of the records sought. Form BC-300 enhances the protection and management of records governed by the Privacy Act and is available as a Common Form through the Census Bureau.

Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Privacy Act of 1974, as amended 5 U.S.C. Section 552a, establishes a framework of fair information practices governing the collection, maintenance, use, and disclosure of personally identifiable information maintained in federal agencies' systems of records. The Census Bureau adheres to specific regulations outlined in 15 C.F.R. Part 4, Subpart B, which detail the procedures by which individuals may request access to their personal records under the Privacy Act.

Requests for access may be submitted in person, electronically via the FOIA public website, or in writing to the Census FOIA Office. To facilitate proper identification and efficient retrieval, requesters must provide sufficient detail to allow Census Bureau personnel to locate the relevant system of records with reasonable effort (15 C.F.R. § 4.4(c)).

As specified in 15 C.F.R. § 4.24(b), requests should include, whenever possible, a description of the records sought, the time periods during which the records were compiled, and the name or identifying number of the system of records containing the information. Additionally, requesters must provide documentation to verify their identity (15 C.F.R. § 4.24(d)), including their full name, current address, date and place of birth, and where applicable, a sworn or notarized statement confirming their identity. Requests submitted remotely (i.e., not in person) must include identity verification either through notarization or by a signed declaration under penalty of perjury.

Federal law strictly prohibits the Census Bureau from disclosing information contained within these records except upon written request from the individual to whom the information pertains, or from their authorized legal representative.

2. Indicate how, by whom, and for what purpose the information is to be used.

Item #	Requirement	Statute	Regulation	Form	Needs and Uses
1	Form Requirement	Privacy Act of 1974	15 CFR § 4.24	BC-300	Public Use Internal agency use

Form BC-300 is utilized by the Census Bureau to collect essential identifying information from individuals requesting access to personal records. In accordance with 15 C.F.R. § 4.24(d), the form requires the requester’s name, address, date of birth, description of the request, and signature to ensure accurate records are provided to the correct individual.

The form includes key components such as the Privacy Act Statement, a disclosure statement, applicable legal authorities under which the Census Bureau is authorized to collect the information, and an outline of the estimated burden on the requester. As a “public use” form, Form BC-300 is employed for both external public requests and internal agency submissions involving personal records.

Form BC-300 is available in printable and electronic formats. The fillable online version streamlines the request process, reducing administrative burden and improving submission efficiency. Completed forms may be submitted via the Census FOIA website, fax, or postal mail. Regardless of the submission method, proper identification must be verified to ensure personal records are released only to authorized individuals.

While providing the requested information is voluntary, failure to do so may prevent the Census Bureau from fulfilling the request for personal records.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.
   
   

Form BC-300 is available in both printable and electronic formats, with an online fillable version developed to facilitate efficient submission. Individuals requesting personal records from the Census Bureau—including members of the public and internal agency staff—may access the form via the FOIA website. While a printed version remains available for submission by mail, the electronic version enables direct online transmission, ensuring requests are promptly delivered to the FOIA Office inbox for processing.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Question 2.

The method and structure of data collection employed by the Census Bureau are distinct to the agency. Instances of duplication are expected to be minimal, if not entirely absent, as each request pertains to a specific individual seeking access to their own personal records.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The data collection associated with Form BC-300 does not—and will not—impose any burden on small businesses or other small entities, as the form is exclusively intended for individual use in requesting personal records.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Failure to conduct this information collection would significantly compromise the Census Bureau’s ability to safeguard personal information and uphold the public’s trust in its data privacy practices. The Privacy Act 5 U.S.C. Section 552a mandates that federal agencies: (1) establish rules of conduct for personnel handling Privacy Act-protected records, and (2) implement appropriate administrative and technical controls over such information.

Form BC-300 plays a critical role in supporting these requirements by enabling the Census Bureau to standardize procedures for collecting, using, and disseminating personal records. It serves as both a verification mechanism and a control tool, ensuring consistent and compliant data handling in alignment with Privacy Act obligations.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in- aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no special circumstances for this data collection.

8. If applicable, provide a copy and identify the date and page number of publications in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

A 60-day Federal Register Notice was published on June 9, 2025, in Volume 90, pages 24267–24268. At the time of publication, the notice projected an estimated 250 respondents. Since then, the anticipated number of respondents has been revised to 260 to reflect updated projections based on an annualized average of three years of requests. We did not receive any public comments in response to the 60-day FRN.

The Census Bureau consulted with other federal agencies that utilize similar Certification of Identity forms. These agencies did not provide any recommendations for changes to the current collection. The Census Bureau will continue its communication and outreach efforts to support ongoing improvements to the form.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No gifts or incentives will be provided or are required for this data collection

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a system of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

The following Privacy Act Statement is included on the Form BC-300:

Privacy Act Statement: In accordance with 15 CFR Section 4.24(d), the U.S. Census Bureau requires you provide us with sufficient information to identify you when you submit requests by mail or otherwise not in person under the Privacy Act of 1974, 5 U.S.C. Section 552a. We take this step to ensure that we do not wrongfully disclose the records of individuals who are the subject of U.S. Census Bureau systems of records. In addition to those disclosures generally permitted under 5 U.S.C. 552a(b) of the Privacy Act, all or a portion of the records or information contained in this system may be disclosed to authorized entities, as is determined to be relevant and necessary, outside the Department as a routine use pursuant to 5 U.S.C. 552a(b)(3) and the published routine uses as identified in the Privacy Act System of Records Notice DEPT-5, Freedom of Information Act and Privacy Act Request Records. Providing this information is voluntary, however, if you do not provide it, we will be unable to take action on your request. If you provide false information on this statement, you may be subject to criminal penalties under 18 U.S.C. Section 1001 and/or 5 U.S.C. Section 552a(i)(3).

Information submitted by respondents to censuses and surveys are not covered by the BC-300 request process. Title 13, United States Code, Section 9 guarantees the confidentiality of the information provided pursuant to censuses and surveys. This confidential information may only be released to the person to whom the information pertains or to a legal representative pursuant to the process outlined in 15 C.F.R. Part 80.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

No sensitive questions are asked beyond the information required to certify the identity of the requester.

12. Provide estimates of the hour burden of the collection of information.

Estimate of burden to the requestors for Privacy Act requests:

Form #	Form Title	# of Burden Requests	Time to Complete	Total Hours
BC-300	Certification of Identity	260 (annualized average of three years)	6 minutes (per form)	26 hours

13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information.

The is no annual cost to respondents or recordkeepers for this data collection.

14. Provide estimates of annualized cost to the Federal government.

Cost of Privacy Act Requests to the Census Bureau:
	FOIA	HR/FLD	FOA	FOIA	Census Totals
	GS-12	GS-12	GS-13	GS-14	Totals Per Privacy Act Request
	Time Utilized	Time Utilized	Time Utilized	Time Utilized	Time Utilized	Cost
Evaluating Form	0.5	1	0	0	1.5	$81.48
Fulfilling Request	0	0.5	0	0	0.5	$27.16
Preparing Request	1	0	0	0	1	$54.32
Evaluating Request	0	0	1	0	1	$64.59
Finalizing Request	0	0	0	0.25	0.25	$19.08
Totals	1.5	1.5	1	0.25	4.25	$246.63
Privacy Act Requests Based on an annualized average over three years	260
Privacy Act Requests x Estimated Cost of Privacy Act Request = Estimated Cost to Agency
260 x $246.63 =	$64,123.80

15. Explain the reasons for any program changes or adjustments reported in ROCIS.
    
    

No changes or adjustments.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
    
    

There will be no publications or tabulations for this data collection.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The agency plans to display the expiration date for OMB approval of the information collection on all instruments.

18. Explain each exception to the certification statement identified in “Certification for Paperwork Reduction Act Submissions."

The agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3)

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