Since the United States’ founding, our leaders have been charged with using data to understand and serve our country—including through the Census, which was written into the Constitution. But news that the Department of Government Efficiency (DOGE) may be creating a government-wide, cross-agency database that links American’s personally identifiable data has rightfully concerned data and privacy experts. And DOGE’s seemingly unfettered access to federal databases that contain private information like citizenship status, income, social security numbers, and more should concern us all.
For 20 years, the Data Quality Campaign has helped state leaders across the country think about data governance, policies, and practices that would enable them to safely link data to ensure that people have the information they need to make education and workforce decisions. But what appears to be happening at the federal level is about more than just making education and workforce decisions: this effort could impact everyone.
Responsible and ethical data use is essential. State leaders develop data systems to bring together data from across agencies to make evidence-based decisions and empower people to make informed choices. But government leaders are data stewards, not owners, and they must adhere to laws and principles to collect, maintain, and use data appropriately.
DOGE’s apparent efforts to use data may very well be legal and ethical. But their lack of transparency and the absence of coordination with Congress bring their actions into question. To appropriately and effectively use data, the administration must be clear about how its use of data will help, not harm, people. It must also abide by these longstanding principles of ethical data use:
Follow federal privacy laws as well as established procedures and protocols. DOGE appears to be violating the Privacy Act as well as a host of education and workforce laws. Data is collected from individuals, institutions, states, and local governments for specific purposes. Each collection is detailed in a federal law or regulation that is debated publicly and either passed by Congress or enacted through public notice and comment. Numerous existing laws (e.g., Every Student Succeeds Act, Workforce Innovation and Opportunity Act, Perkins V) expressly prohibit the government from creating a database of individuals’ information and from using data for a purpose other than that for which it was collected.
Further, the usual process for cross-agency data sharing at the federal level involves, among other things, data-sharing agreements or memoranda of understanding, computer matching agreements, Federal Register notices about what data is being shared and for what purposes, and the involvement by the inspector general’s office within the agency to ensure data is shared securely and in accordance with existing laws. It’s unclear if this is happening.
Be transparent and build trust. Accessing individual-level data is not consistent with the administration’s stated goal of finding waste, fraud, and abuse. And DOGE is working behind closed doors, so that no one—not Congress or the public—has any clarity about exactly what is happening. Failure to be transparent raises questions.
Collecting and using a person’s data is an exercise in trust. Working on these federal data efforts in the dark is leading to public mistrust of data, data collections, and data sharing. States are increasingly concerned about moving forward with efforts like streamlined postsecondary admissions and processes for public benefits eligibility because they are concerned about holding too much private data for vulnerable individuals—and that the federal government might request the data for purposes not authorized by Congress.
Do no harm. Individuals provide detailed, personal data to government agencies because they are receiving a benefit (e.g., student financial aid, health care, public support through programs like SNAP and TANF) or because they are required (e.g., taxes). In exchange for this support, they expect accurate information and for government officials to use that information to better the programs and services they are providing. Implicit in this social contract is that the government will keep their information private and use it to benefit, not harm, them. Any linking of individual-level, personally identifiable data across agencies without specific authority, public transparency, and shared governance for its privacy and use would violate this fundamental tenet of data collection.
Data is fundamental to the evidence-based decisionmaking that all leaders should practice to ensure that policies and programs benefit people. But DOGE’s reported independent actions, taken behind closed doors, could compromise every American’s privacy and leaves us all uncomfortably in the dark.
