Privacy Requirements and HSPD-12

1
Privacy Requirements and HSPD-12

• Jeanette Thornton
• Eva Kleederman
• Information Policy and Technology Branch

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What about privacy?

• Privacy should not be viewed as an after
  thought!!!
• Member of your team
• Must tackle the key issues early in the process
• What is the purpose of the system?
• What are the routine uses?
• What information is shared between agencies?

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What about Privacy?

• Build on existing law and OMB policy
• Ensure privacy documentation is developed early
  in the process
• Minimal data stored on the card and collected
  during card issuance
• Require a PIA to analyze key privacy questions
• Limited to strict set of control objectives

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DRAFT Privacy Deliverables for 10/27

• Updated System of Records Notice (or new)
• Privacy Impact assessment
• Provide Notice
• OMB PRA approval (if using new form)
• Keep to control objectives