1325.01 REV-1

Appendix G

GUIDELINES FOR ESTABLISHING SAFEGUARDS FOR RECORDS

SUBJECT TO THE PRIVACY ACT

G-1 Purpose. The Privacy Act of 1974 (the Act) required that records

subject to its provisions (Privacy Act records) be maintained with

\"appropriate administrative, technical, and physical safeguards to

ensure the security and confidentiality of records and to protect

against any anticipated threats or hazards to their security or

integrity which could result in substantial harm, embarrassment,

inconvenience, or unfairness to any individual on whom information

is maintained.\" This appendix contains guidelines to be used in

establishing appropriate safeguards.

G-2 Responsibility. Each Privacy Act system manager has the

responsibility for establishing and implementing appropriate

safeguards to ensure the security and confidentiality of the

Privacy Act records he manages.

G-3 Applicability. These guidelines apply to all Privacy Act records,

automated and manual, in all HUD components.

G-4 Sensitivity of Information. The sensitivity of information in

Privacy Act records varies from one group of records to another.

These guidelines specify the minimum safeguards which should be

implemented for Privacy Act records containing information of a

non-sensitive nature. Privacy Act system managers should develop

and implement more stringent safeguards for records containing

information of a more sensitive nature. Privacy Act system

managers should exercise sound judgment in deciding what

constitutes nonsensitive information and what constitutes sensitive

information. However, such information as name, address, complaint

status and disposition, HUD employee to whom assigned,

organizational designation, and similar information would normally

be considered non-sensitive. Such information as credit history,

arrest record, date of birth, social security number, medical

records, financial status, and similar information would normally

be considered sensitive.

G-5 Automated Records. Privacy Act system managers should establish

and implement safeguards for automated records in accordance with

National Bureau of Standards publication FIPS PUB 41 (May 30,

1975), titled Computer Security Guidelines for implementing the

G-1 10/95

1325.01 REV-1

Privacy Act of 1974, [OMB Circular
A-130](http://www.whitehouse.gov/omb/circulars/a130/a130trans4.html),
and the HUD ADP Security

Handbook, 2400.24 REV-1 and the Systems Development Methodology.

G-6 Manual Records. The Privacy Act system manager should consider the

sensitivity of the data contained in the records and the

anticipated threats or hazards to their security as a basis for

establishing safeguards to provide adequate protection. Privacy

Act records containing nonsensitive information with few

anticipated threats or hazards should be maintained subject to the

following minimum safeguards:

A. Areas in which the records are maintained or regularly used

should be posted with a warning that access to the records is

limited to authorized persons. The warning should state that

the Privacy Act provides for civil and criminal penalties for

unauthorized disclosure of records to which it applies.

B. During working hours, the area in which the records are

maintained or regularly used should be occupied by authorized

personnel or access to records should be restricted by their

storage in locked file cabinets or a locked room.

C. During non-working hours, access to the records should be

restricted by their storage in locked file cabinets or a

locked room.

D. Care should be taken to ensure that master keys are not

available to unauthorized personnel.

The Privacy Act system manager should develop and implement more

stringent safeguards if the sensitivity of the records or the

anticipated threats or hazards to their security warrant more

stringent safeguards. In all cases, the safeguards applied to any

group- of records should conform to the description of safeguards

contained in the published Federal Register notice covering the

group of records.

G-7 Methods of Destruction. The destruction of records subject to the

Privacy Act should be sufficient to prevent the association of any

individual name or identifier with any information pertaining to

that individual. Acceptable methods of destruction include

burning, shredding, or pulping.

10/95 G-2