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  7. Customer Research That Does Not Need PRA Clearance

Customer Research That Does Not Need PRA Clearance

Author: Tyrone Huff, DHS Paperwork Reduction Act Officer

Ethnographic Interviews

You can interview 9 or fewer members of the public using the same questions, or any number of people in an unstructured conversation/usability test.

What this means

  • If you are asking identical questions, you may only ask 9 or fewer people.
    • Note: This means if you are standardizing for a research repository, and asking those questions outright for customer segmentation data, like demographic information, you need to go through the PRA clearance process, because you will be asking each set of 9 people - as soon as you ask the 10th person the question, you pass the 9-person threshold. You do NOT need to go through this process if you are using targeted recruitment strategies to capture the customer segments you need, rather than asking outright.
  • Questions about different parts/functions of the form are treated separately, and so do not aggregate towards the 9 or fewer limit. If, for example, you are asking questions about one form’s navigation (say, the I-9) to 9 or fewer people, and then another group needs to ask questions about the document upload experience in the same form (to 9 or fewer people), the second group of questions do not require PRA clearance as long as the questions are not identical to the scope of the questions asked of the first group of 9.
  • If you are asking questions regarding one form’s navigation to 9 or fewer people, you may ask 9 or fewer people about a different form’s navigation as long as the questions are not the same.
  • Similarly, if you are asking questions regarding completing one form to 9 or fewer people, you may ask questions about the experience of submitting the same form as long as the questions are different.
  • If you are having an unstructured conversation in front of a prototype or a form, you do not need clearance to perform your research.
    • If you have a checklist of things for observers to watch for while you’re having an unstructured conversation, that’s fine, you can ask things like “Why did you do that?” or “What happened?”
    • If you start asking questions like “What do you think about this checkbox in the upper left-hand corner”, then those questions would be considered standardized questions and need have PRA clearance, or to be asked of 9 or fewer people.

Surveys or Recruitment

You can ask questions with open text boxes, such as “Tell us how we’re doing”.

What this means

  • If you ask a question like “Would you like to provide feedback on your experience?” and provide a box in which you can paste the lyrics to your favorite song, or your grandmother’s cookie recipe in the text box instead of an email address, it does not need clearance.
    • Note: Consider the value that you might get from this type of customer feedback. While you might learn a lot about baking, sifting through the responses may require a disproportionate/significant amount of resources.
  • These questions should not be required in the course of something like applying for a benefit or opening an account.
Last Updated: 06/14/2024
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