S T R A T E G I C P L A N

2022 – 2026
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Privacy and Civil Liberties Oversight Board

Strategic Plan 2022-2026

MAY 2022

PRIVACY AND CIVIL LIBERTIES OVERSIGHT BOARD

800 N. CAPITOL STREET, NW

SUITE 565

WASHINGTON, DC 20002

This report is available at www.pclob.gov.

Send comments or questions to info@pclob.gov or to the mailing address above.
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TABLE OF CONTENTS

MESSAGE FROM THE BOARD ....................................................................................... 5

EXECUTIVE SUMMARY ................................................................................................ 7

BOARD HISTORY AND AUTHORITIES............................................................................ 7

AGENCY ORGANIZATION........................................................................................... 11

KEY CHALLENGES..................................................................................................... 11

KEY OPPORTUNITIES ................................................................................................. 11

VISION, MISSION, AND CORE VALUES........................................................................ 13

PCLOB STRATEGIC GOALS FOR FISCAL YEARS 2022-2026....................................... 14

CONCLUSION............................................................................................................. 28
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MESSAGE FROM THE BOARD

We are pleased to present the Privacy and Civil Liberties Oversight Board’s Strategic Plan 

for Fiscal Years 2022-2026. This plan will guide our work to help ensure that efforts by the federal 

government to protect the nation against terrorism appropriately protect privacy and civil liberties.

Our agency’s mission is rooted in the belief that our nation does not face a binary choice 

between protecting the homeland and safeguarding liberties, but rather that the government can 

and must provide security while respecting privacy and civil liberties.

Since its inception nearly 10 years ago, the agency has developed into a valued expert body 

and has fulfilled its statutory mandates to: (1) analyze and review actions the executive branch 

takes to protect the nation from terrorism, ensuring that the need for such actions is balanced with 

the need to protect privacy and civil liberties; and (2) ensure that liberty concerns are appropriately 

considered in the development and implementation of laws, regulations, and policies related to 

efforts to protect the nation against terrorism.

Additionally, the agency has focused on establishing itself and building an internal 

framework for effective agency operations. With a new quorum of Board Members in February 

2022, the agency is prepared to refocus its mission over the next four years.

This Strategic Plan establishes the following goals for this new phase:

➢ Conduct effective oversight of executive branch authorities, policies, and activities

related to efforts to protect the nation against terrorism to ensure appropriate protection

of privacy and civil liberties.

➢ Provide effective and timely advice to ensure that liberty concerns are appropriately

considered in the development and implementation of laws, regulations, and policies

related to efforts to protect the nation against terrorism.

➢ Strengthen the Board’s capabilities and knowledge regarding advanced and emerging

technologies, their potential impacts on, and potential to safeguard, privacy and civil

liberties, and their potential uses to perform oversight.

➢ Further promote the public’s interest in transparency regarding Board activities and

executive branch counterterrorism efforts that impact privacy and civil liberties to the

greatest extent possible, consistent with the protection of classified information and

applicable law.

➢ Continue to enhance the Board’s institutional strength and capacity.
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The Board looks forward to working with other executive branch agencies, the Congress,

outside experts, and the public as it pursues these goals in the years to come.

Sharon Bradford Franklin 

Board Chair 

Edward W. Felten 

Board Member 

Travis LeBlanc 

Board Member 

Beth A. Williams

Board Member 
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EXECUTIVE SUMMARY

The Privacy and Civil Liberties Oversight Board (“PCLOB” or “the Board”) is an 

independent agency within the executive branch. Its mission is to provide advice and conduct 

oversight to ensure that federal government efforts to protect the nation from terrorism 

appropriately protect privacy and civil liberties. Four core values guide the Board’s activities: 

integrity, transparency, rigor, and equity.The Board anchors its work in the vision of a nation that 

simultaneously counters terrorism and protects privacy and civil liberties.

With this plan, the Board establishes five strategic goals to guide its work:

➢ Strategic Goal 1: Conduct effective oversight of executive branch authorities, policies,

and activities related to efforts to protect the nation against terrorism to ensure

appropriate protection of privacy and civil liberties.

➢ Strategic Goal 2: Provide effective and timely advice to ensure that liberty concerns

are appropriately considered in the development and implementation of laws,

regulations, and policies related to efforts to protect the nation against terrorism.

➢ Strategic Goal 3: Strengthen the Board’s capabilities and knowledge regarding

advanced and emerging technologies, their potential impacts on, and potential to

safeguard, privacy and civil liberties, and their potential uses to perform oversight.

➢ Strategic Goal 4: Further promote the public’s interest in transparency regarding

Board activities and executive branch counterterrorism efforts that impact privacy and

civil liberties to the greatest extent possible, consistent with the protection of classified

information.

➢ Strategic Goal 5: Continue to enhance the Board’s institutional strength and capacity.

This Strategic Plan describes the objectives associated with each goal, as well as the

strategies the Board will use to achieve each objective.

BOARD HISTORY AND AUTHORITIES

The Board was created based upon a recommendation of the National Commission on 

Terrorist Attacks Upon the United States (“9/11 Commission”). Through the Intelligence Reform 

and Terrorism Prevention Act of 2004, Congress created a Privacy and Civil Liberties Oversight 

Board within the Executive Office of the President. In 2007, Congress established the Privacy 

and Civil Liberties Oversight Board in its current form as an independent executive branch agency 

through the Implementing Recommendations of the 9/11 Commission Act.
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A bipartisan, five-Member board heads the PCLOB: one full-time Chair and four part-time 

Members, each appointed by the President, with the advice and consent of the Senate, to staggered 

six-year terms. The Board’s statute requires that no more than three Members come from the same 

political party, and that the President should select nominees “on the basis of their professional 

qualifications, achievements, public stature, expertise in civil liberties and privacy, and relevant

experience.”1In August 2012, the Senate confirmed the Board’s first four Members, providing a 

quorum to begin operations. In 2013, Congress confirmed the Board’s first full-time Chair.

From 2013 to 2016, this full, five Senate-confirmed Member Board engaged in a variety 

of oversight and advice projects, held periodic hearings, and issued several major unclassified 

oversight reports. These reports included:

• Report on the Telephone Call Records Program Conducted Under Section 215 of the

USA PATRIOT Act and on the Operations of the Foreign Intelligence Surveillance

Court,

2 and

• Report on the Surveillance Program Operated Pursuant to Section 702 of the Foreign

Intelligence Surveillance Act.3

That original quorate Board’s work established the agency’s reputation for expert and 

thoughtful analysis, timely work, and insightful and actionable policy recommendations.

In January 2017, the Board entered its first sub-quorum period following the departure of 

the Board’s Chair and three Board Members. In October 2018, the Board regained a quorum of 

Members. Throughout the last strategic planning cycle, the Board and its staff continued oversight 

and advice projects, established new projects, and completed the agency’s first Federal 

Information Security Management Act (“FISMA”) and financial audits. In addition, the agency

enrolled its public-facing website in the DHS Vulnerability Disclosure Platform, established a 

Controlled Unclassified Information Program, and achieved full operational capability of its 

Counter-Insider Threat Program. The Board also issued new oversight reports, including two 

unclassified reports:

• Report on the USA Freedom Act Telephone Call Records program,4and

• Report on Executive Order 12333.5

1 42 U.S.C. § 2000ee(h)(2).

2 Available at https://documents.pclob.gov/prod/Documents/OversightReport/ec542143-1079-424a-84b3-

acc354698560/215-Report_on_the_Telephone_Records_Program.pdf.

3 Available at https://documents.pclob.gov/prod/Documents/OversightReport/823399ae-92ea-447a-ab60-

0da28b555437/702-Report-2.pdf.

4 Available at https://documents.pclob.gov/prod/Documents/OversightReport/87c7e900-6162-4274-8f3ad15e3ab9c2e4/PCLOB%20USA%20Freedom%20Act%20Report%20(Unclassified).pdf.

5 Available at https://documents.pclob.gov/prod/Documents/OversightReport/b11b78e0-019f-44b9-ae4f60e7eebe8173/12333%20Public%20Capstone.pdf.
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In summer 2021, the Board entered its second sub-quorum period, but in February 2022, 

Chair Sharon Bradford Franklin and Board Member Beth A. Williams were confirmed and sworn 

in, re-establishing the Board’s quorum. The Board thanks Members Felten and LeBlanc along with 

the Board's staff for their efforts during the sub-quorum period.

The Board’s enabling statute, 42 U.S.C. § 2000ee, authorizes it to “analyze and 

review actions the executive branch takes to protect the Nation from terrorism, ensuring that the 

need for such actions is balanced with the need to protect privacy and civil liberties,” and to 

“ensure that liberty concerns are appropriately considered in the development and 

implementation of laws, regulations, and policies related to efforts to protect the Nation from 

terrorism.”

The Board primarily implements this authority through conducting oversight of, and 

providing advice to, executive branch agencies that conduct counterterrorism activities. 

For oversight, the Board’s statute charges it with reviewing (1) regulations, policies, 

procedures, and practices within the Board’s jurisdiction to ensure that privacy and civil liberties 

are adequately protected, and (2) other actions within the Board’s jurisdiction to ensure that those 

actions appropriately protect privacy and civil liberties and are consistent with governing laws, 

regulations, and policies regarding privacy and civil liberties.6

For advice, executive branch agencies may consult with the Board (ideally at an early stage 

in development) on legislation, policies, programs, guidelines, or regulations, to help include

privacy and civil liberties protections by design.7

The Board’s statute also prioritizes transparency as an inherent part of the Board’s mission.

The Board must inform the public about its work through public hearings and must make its reports

available to the public to the greatest extent possible consistent with the protection of classified 

information and applicable law. The Board also must provide semi-annual reports to the Congress 

and appear and testify before Congress upon request.8

6

Id. § 2000ee(d)(2). The Board is also charged with continually reviewing information-sharing practices within its 

jurisdiction.

7

Id. § 2000ee(d)(1).

8

Id. § 2000ee(d)(4), (f).
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The Board has also accrued additional designated roles under the following authorities:

➢ Executive Order 13636, Improving Critical Infrastructure Cybersecurity, issued

in February 2013, calls upon certain agencies to develop and implement a cybersecurity

framework to minimize the risks of cyberattacks on critical infrastructure.9 Section 5

of this Executive Order requires the Department of Homeland Security to consult with

the Board in preparing a report recommending mitigation options for any privacy and

civil liberties risks in cybersecurity measures implemented under the Order. That report

must be reviewed annually and revised as necessary.

➢ Presidential Policy Directive 28 (“PPD-28”), issued by President Barack Obama in

2014, states principles guiding why, whether, when, and how the United States conducts

signals intelligence activities for authorized foreign intelligence and

counterintelligence purposes.10 This Directive encourages the Board to provide the

President with an assessment of the implementation of any matters contained in the

directive that fall within the Board’s purview.11

➢ Section 803 of the Implementing Recommendations of the 9/11 Commission Act

of 2007 (“Section 803”) requires certain executive branch departments, agencies, and

elements to designate at least one senior official as a privacy and civil liberties officer

(“P/CL officer”).12 Each agency’s P/CL officer must issue semi-annual reports on that

officer’s statutory activities.

13 Each P/CL officer submits these Section 803 Reports to

the head of the officer’s agency, designated congressional committees, and the Board.14

These reports must be unclassified and publicly available to the greatest extent

possible.15

In June 2016, the Board published recommendations for filing Section 803 reports. Board 

staff have continued to work with P/CL offices as they implement the Board’s recommendations.

9 E.O. 13636, Improving Critical Infrastructure Cybersecurity (Feb. 12, 2013). 

10 PPD-28, Signals Intelligence Activities (Jan. 17, 2014). 

11 The PCLOB’s PPD-28 report is available at https://documents.pclob.gov/prod/Documents/Projects/99da9b42-5e9f40fd-8ace-94d1e6a7d06c/PPD-28%20Report%20(for%20FOIA%20Release).pdf. 

12 Pub. L. No. 110-53 § 803 (2007), codified at 42 U.S.C. § 2000ee-1(a). The entities covered are the Office of the 

Director of National Intelligence, the Central Intelligence Agency, the National Security Agency, the Federal Bureau of 

Investigation, and the Departments of Defense, Health and Human Services, Homeland Security, Justice, and Treasury. 

13 Id. § 2000ee-1(f). Before its amendment in 2014, the statute required quarterly reports. 

14 Id. § 2000ee-1(f)(1)(A). 

15 Id. § 2000ee-1(f)(1)(B), (g)(1). 
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In addition to receiving and reviewing the P/CL officers’ semi-annual reports, the Board’s 

statute directs it to make recommendations, when appropriate, to P/CL officers regarding their 

activities and to coordinate their activities on relevant interagency matters.16

Lastly, through the USA FREEDOM Act, Congress has also tasked the Board to assist in 

recommending candidates for amici curiae to the Foreign Intelligence Surveillance Court. 17

AGENCY ORGANIZATION

PCLOB’s headquarters is in Washington, D.C. At present, the Board has four Members. For 

more information about the Board Members, please visit PCLOB’s website at 

www.pclob.gov/Board/Index.

KEY CHALLENGES

The Board is a small agency with limited resources, and there are numerous federal 

agencies that operate a wide variety of programs and activities to protect the country from 

terrorism. Accordingly, the Board must be strategic in setting its agenda and set reasonable 

expectations for what it may accomplish over the next four years. The Board must consider the 

resources required to complete existing projects as well as the potential value of new projects that 

respond to intervening developments and future realities.

Staff development and retention are critical to the Board’s ability to achieve its mission, 

and as such, the Board remains focused on hiring qualified candidates to complete oversight and 

advice projects, while working to address key challenges, such as the statutory pay cap and 

turnover during sub-quorum periods. Further, throughout this strategic planning cycle, the Board 

will assess its established staffing level to determine whether it should be expanded to better 

support the agency in achieving its mission.

KEY OPPORTUNITIES

The Board sees many opportunities for diligent oversight, constructive engagement with 

other executive branch agencies through its advice function, and informative public outreach and 

transparency. The Board anticipates that such engagement may occur through both its oversight 

and advice functions.

16 Id. § 2000ee(d)(3). The Board may also designate new departments, agencies, or elements of the executive branch for 

coverage by the requirements of Section 803. See id. § 2000ee-1(a).

17 USA FREEDOM Act, Pub. L. No. 114-23, 129 Stat. 268, § 401(i)(1) (2015).
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Additionally, the advent and development of new technologies present new areas for 

oversight activities of the Board. Adoption of new technologies by the government for 

counterterrorism purposes require careful attention for the protection of privacy and civil liberties. 

New and emerging technologies also have potential to enhance privacy and civil liberties 

safeguards. The Board anticipates that its independence, bipartisan composition, and ability to take 

a broad, long-term view, equip it well to inform public debate and support policymakers’ 

consideration of the implications of and safeguards that should apply to these technologies. Such 

efforts may require the development of new oversight and analysis techniques, assessment tools, 

and programs. The Board may also be able to implement new tools and rely on new technologies 

to improve its own oversight reviews and assessment of counterterrorism activities. 

Finally, transparency and public engagement are continuing priorities for the Board. The 

Board anticipates soliciting input from the public, Congress, outside experts, and other relevant 

stakeholders as it develops its new agenda and completes oversight and advice projects. Going 

forward, the Board hopes to find new and creative ways of soliciting public input and informing 

the public through its work.
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VISION, MISSION, AND CORE VALUES

VISION 

A nation that counters terrorism while safeguarding privacy and civil liberties.

MISSION

The Board provides advice and conducts oversight to ensure that efforts by the executive branch

to protect the nation from terrorism are appropriately balanced with the need to protect privacy

and civil liberties.

CORE VALUES

Four key values guide the Board’s work:

Integrity – As an agency whose power lies in its persuasiveness, the Board strives to preserve its 

reputation for independence, integrity, and credibility. The Board approaches its activities with 

objectivity and good faith. The Board strives to treat executive branch agencies and other outside 

parties with evenhandedness and respect, and to evaluate a wide range of relevant data, viewpoints,

and considerations.

Transparency – The Board aims to foster understanding of the impact of efforts to protect the

nation from terrorism on privacy and civil liberties. In addition, the Board conducts its own 

activities responsibly and transparently to foster confidence in its management of authorities, 

resources, and information. The Board promotes transparency by holding public hearings and

issuing public reports, to the greatest extent that is consistent with the protection of classified

information and applicable law, and by soliciting input from the public and outside experts.

Rigor – The Board strives for the highest standard of quality in its analysis and recommendations.

When examining government programs, the Board takes care to understand those efforts in all

their complexity. In assessing whether such efforts are consistent with the law and appropriately 

protect privacy and civil liberties, the Board strives to be thorough and accurate, and to account 

for the impact of new and emerging technologies and institutional reforms. When recommending 

changes to those efforts, the Board seeks to fully consider the foreseeable impact of its 

recommendations.

Equity – The Board is also committed to helping to ensure that all persons are treated equally 

under the law, both as a component of protecting privacy and civil liberties, and in its own internal 

operations. Safeguarding privacy and individual liberties also involves treating people equitably, 

and with dignity and respect. In addition, the Board endeavors to develop and implement internal 

policies and practices for its workforce that promote diversity, equity, and inclusion.
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PCLOB STRATEGIC GOALS FOR FISCAL YEARS 2022-2026

STRATEGIC GOAL 1: Conduct effective oversight of executive branch 

authorities, policies, and activities related to efforts to 

protect the nation against terrorism to ensure 

appropriate protection of privacy and civil liberties.

STRATEGIC GOAL 2: Provide effective and timely advice to ensure that 

liberty concerns are appropriately considered in the 

development and implementation of laws, regulations, 

and policies related to efforts to protect the nation 

against terrorism.

STRATEGIC GOAL 3: Strengthen the Board’s capabilities and knowledge 

regarding advanced and emerging technologies, their 

potential impacts on, and potential to safeguard, 

privacy and civil liberties, and their potential uses to 

perform oversight. 

STRATEGIC GOAL 4: Further promote transparency regarding Board 

activities and executive branch counterterrorism 

efforts that impact privacy and civil liberties, to the 

greatest extent possible consistent with the protection 

of classified information and applicable law.

STRATEGIC GOAL 5: Continue to enhance the Board’s institutional strength 

and capacity.
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STRATEGIC GOAL 1: Conduct effective oversight of executive branch authorities, 

policies, and activities related to efforts to protect the nation 

against terrorism to ensure appropriate protection of privacy 

and civil liberties.

The Board’s statute calls for “continual review” of executive branch regulations, policies, 

procedures, information-sharing practices, and other actions related to efforts to protect the nation 

from terrorism. This oversight review should ensure both appropriate protections of privacy and 

civil liberties and that those actions comport with governing privacy and civil liberties laws, 

regulations, and policies.18 When appropriate, the Board will recommend steps to better safeguard 

privacy and civil liberties.

A principal challenge for the Board is to be strategic in selecting its oversight portfolio 

because the Board is a small agency and there are numerous counterterrorism activities across the 

federal government. At present, the Board continues to work on several oversight projects that were 

authorized by the previous quorate Boards. With a new quorum, however, comes new opportunities 

to complete existing projects and set a new agenda for the years to come.

As the Board develops its new agenda, it will continue to consider input from Congress, 

subject matter experts, other stakeholders, and the public alongside its Members. In selecting new 

oversight projects, the Board is mindful of the ever-evolving nature of the threat of terrorism, 

including the federal government’sincreasing focus on domestic terrorism. The Board will consider 

criteria, such as the timeliness and relevance of an issue to policymakers; the potential scale of 

impact on individuals’ privacy and civil liberties; future trends and novel uses of technology for 

both counterterrorism efforts and as tools to enhance privacy; and the potential for enhanced public 

transparency. Additionally, the Board will seek to maintain a diverse portfolio of oversight projects 

covering varying types of counterterrorism activities, in addition to surveillance, and including 

activities conducted by various agencies, both within and outside of the Intelligence Community.

The efficacy of the Board’s oversight continues to rely on the Board’s reputation for expert, 

credible, implementable, fact-based, and constructive recommendations. Continuing to apply the 

Board’s core values is key to maintaining this reputation.

18 Id. § 2000ee(d)(2).
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OBJECTIVE 1.1: Develop and pursue a diverse portfolio of oversight projects while maximizing

impact of each individual project.

Strategies for Accomplishing Objective 1.1:

➢ Continued and enhanced engagement with Congress, stakeholders, and the public to inform the 

Board’s oversight agenda.

➢ Refine a set of criteria and goals for the Board's short- and medium-term oversight agenda to 

maximize the collective impact of projects, including:

• Oversight reviews across a wide range of agencies, both inside and outside the Intelligence 

Community;

• Oversight reviews examining large-scale programs as well as shorter-term, focused reviews 

of specific activities or authorities;

• Oversight reviews that assess the use for counterterrorism purposes – and application to 

enhance privacy and civil liberties safeguards – of new and emerging technologies; and

• A mix of both classified reviews and unclassified oversight reviews to serve the Board’s 

transparency mission.

OBJECTIVE1.2:Conduct oversight with rigor and integrity, and issue recommendations designed

to enhance privacy and civil liberties protections in federal counterterrorism regulations, policies, 

procedures, and activities.

Strategies for Accomplishing Objective 1.2:

➢ Maintain and strengthen lines of communication with the executive branch agencies PCLOB 

oversees, including ensuring timely and thorough responses by those agencies to PCLOB’s 

information requests.

➢ Perform oversight duties rigorously, thoroughly, meticulously, and respectfully.

➢ Assess the impact of counterterrorism programs and activities on individuals’ privacy and civil 

liberties, including the extent to which activities may infringe upon the exercise of First 

Amendment and other rights, or unduly burden particular racial groups, underserved 

communities, religious groups, politically disfavored groups, and other individuals.

➢ Improve PCLOB staff skills for conducting investigations, establish and implement best 

practices, and pursue methods to improve the efficiency and effectiveness of oversight 

projects.

➢ Issue recommendations that are constructive and meaningfully consider relevant contexts and 

operational needs.
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OBJECTIVE 1.3: Promote and monitor implementation of Board recommendations.

Strategies for Accomplishing Objective 1.3:

➢ Assess the status of implementation of Board and staff-level recommendations.

➢ Publicly report, to the maximum extent consistent with the protection of classified information

and applicable law, steps agencies have taken to implement Board and staff-level 

recommendations.

STRATEGIC GOAL 2: Provide effective and timely advice to ensure that liberty 

concerns are appropriately considered in the development and 

implementation of laws, regulations, and policies related to 

efforts to protect the nation against terrorism.

The Board’s statute also charges it with advising the President and executive branch

departments, agencies, and elements to ensure they appropriately consider privacy and civil 

liberties when designing, developing, and implementing laws, regulations, and policies related to 

efforts to protect the nation against terrorism.19

The Board works to provide expert, practicable, and timely advice to requesting agencies.

Agencies are more willing to engage the Board for advice when they have trust in the Board’s

expertise, protection of sensitive and classified information, and ability to weigh privacy and civil 

liberty equities alongside operational challenges, national security concerns, and institutional 

context. Meanwhile, the Board depends on early consultation— ideally at the design or early 

development stage of a new initiative—and collaborative engagement to provide timely, 

meaningful, and implementable advice.

As an example of the Board’s advice function, the Board has provided advice on IC 

elements’ significant revisions of Attorney General-approved Guidelines for handling U.S. person 

information under Executive Order 12333.20 The Board hopes to further engage in these and other 

advice engagements and provide independent, expert, and actionable advice on how to safeguard 

privacy and civil liberties equities by design.

19 42 U.S.C. § 2000ee(d)(1).

20 See Executive Order 12333, § 2.3.
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OBJECTIVE 2.1: Serve as a source of trusted, independent, and expert advice to the President and 

executive branch departments, agencies, and elements on how to include privacy and civil liberties 

safeguards in the design and planning stages of counterterrorism efforts.

Strategies for Accomplishing Objective 2.1:

➢ Continue to provide timely advice to the President and executive branch departments, 

agencies, and elements when requested and on the Board’s own initiative, when practicable.

➢ Promote and raise awareness of the Board’s advice function within and outside of the 

Intelligence Community.

➢ Maintain respectful and trustworthy relationships between other agencies and the Board’s 

Members and staff.

➢ Safeguard classified information and other information protected by applicable law and 

respect appropriate privileges and confidences.

➢ Serve as an expert source and thought leader for other agencies on emerging technologies –

both their use for counterterrorism purposes and as mechanisms to safeguard privacy and civil 

liberties – and other new and novel approaches to countering terrorism.

OBJECTIVE 2.2: Promote the protection of privacy and civil liberties in the design of counterterrorism programs.

Strategies for Accomplishing Objective 2.2:

➢ Encourage executive branch agencies to engage with the Board early in the development or 

consideration of new legislation, regulations, policies, programs, guidelines, or proposals that 

implicate privacy and civil liberties equities.

➢ Engage with government and stakeholders to identify and assess opportunities for advice 

projects.

➢ Conduct rigorous analyses and assess how privacy and civil liberties safeguards can be 

effectively integrated into the counterterrorism activity, policy, or procedure at the outset.

➢ Provide timely, clear, feasible, and practicable advice.

➢ Monitor and regularly assess whether the Board’s advice has been implemented appropriately.
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OBJECTIVE 2.3: Maintain and enhance meaningful engagement with governmental privacy and

civil liberties officers.

Strategies for Accomplishing Objective 2.3:

➢ Regularly engage with governmental privacy and civil liberties officers to identify

opportunities for advice or other opportunities to safeguard privacy and civil liberties.

➢ Continue to provide guidance to privacy and civil liberties officers as they draft semi-annual

reports to make them as useful as possible to Congress, agency heads, and the Board.

STRATEGIC GOAL 3: Strengthen the Board’s capabilities and knowledge regarding 

advanced and emerging technologies, their potential impacts 

on, and potential to safeguard, privacy and civil liberties, and 

their potential uses to perform oversight.

The nation and the world are experiencing a dramatic expansion of the capabilities of 

existing technologies, as well as the emergence of novel technologies that offer the potential for 

even more drastic change. Artificial intelligence and machine learning have made significant strides 

in their ability to analyze enormous amounts of data; intelligent, networked devices collect even 

more data; quantum technologies have moved from theoretical to being built in laboratories; and 

many more. These technologies can offer key capabilities for the nation in its efforts to combat 

terrorism, potentially implicating individuals’ privacy and civil liberties, and, at the same time, 

offer innovative and novel opportunities for privacy and civil liberties safeguards.

Accordingly, over the next four years, the Board will work to identify and review federal 

government use of new technologies for counterterrorism purposes and assess the potential for 

recommendations that utilize technology-enabled privacy and civil liberties protections. The Board 

will also endeavor to recruit expert staff, including technologists, to fully understand new 

technologies and meaningfully assess their uses and impacts.
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Just as these tools and approaches offer the potential for increased effectiveness and abilities 

for counterterrorism efforts, they also may be helpful in the Board’s own activities. As a result, the 

Board will assess whether and how technologies may support is own work, including oversight 

reviews. And, to the extent such avenues are viable, the agency may consider procurement and 

implementation opportunities.

OBJECTIVE 3.1: Rigorously analyze the use of new and emerging technologies in efforts to

protect the nation against terrorism and the implications of such uses for privacy and civil liberties.

Strategies for Accomplishing Objective 3.1:

➢ Consult with experts within and outside the government to identify counterterrorism 

implementations of advanced and emerging technologies that raise significant concern for 

privacy and civil liberties. Identify appropriate oversight reviews to assess the government’s 

use of new and emerging technologies in counterterrorism activities, and conduct rigorous 

oversight, as outlined in Objective 1.2.

➢ Assess the potential for technologies to differentially impact particular racial and other 

groups, and make recommendations, as appropriate, to address any such equity issues.

➢ Provide thoughtful, technically informed guidance on these issues through the Board’s advice

function.

OBJECTIVE 3.2: Assess the potential for new and emerging technologies to enhance privacy and 

civil liberties safeguards in the operation of counterterrorism programs and activities and

recommend implementation of such technological approaches where appropriate.
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Strategies for Accomplishing Objective 3.2:

➢ Consult with private sector entities, including private companies, non-government 

organizations, and think tanks, on what technologies might be available as privacy and civil 

liberties enhancement tools. 

➢ In developing recommendations as part of the Board’s oversight reviews and advice projects, 

consider and assess the potential for the use of privacy-enhancing technologies. 

➢ Where appropriate, recommend use of technological approaches to enhance privacy and civil 

liberties.

OBJECTIVE 3.3: Ensure that the Board receives the technical input needed to conduct effective

oversight and provide informed advice on issues related to advanced and emerging technologies and

assess whether and how advanced technological tools and approaches may contribute to the Board’s 

own work.

Strategies for Accomplishing Objective 3.3:

➢ Solicit input on new technologies and their implications for privacy and civil liberties from 

experts inside and outside of government, including through public events and other forms 

of public engagement.

➢ Seek to ensure that Board engagement with other executive branch agencies includes

technical experts and operators, in addition to legal and privacy officials.

➢ Recruit and hire staff, including technologists, with technical expertise and knowledge.

➢ Consult with other agencies or offices, including oversight bodies in other countries, on their 

use of technologies such as artificial intelligence in oversight activities.

➢ Consult with private sector entities, including non-government organizations and think tanks, 

on what tools might be available to assist the PCLOB in conducting oversight. 

➢ Research commercial and non-commercial technical solutions for AI-assisted audit and 

review.
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STRATEGIC GOAL 4: Further promote transparency regarding Board activities and 

executive branch counterterrorism efforts that impact privacy and 

civil liberties to the greatest extent possible, consistent with the 

protection of classified information and applicable law.

The Board is committed to enhancing transparency about the federal government’s efforts to 

protect the nation from terrorism. The Board’s enabling statute directs the Board to “make its 

reports, including its reports to Congress, available to the public” and to “hold public hearings and 

otherwise inform the public of its activities.”21 The Board intends to continue to interact with 

experts within government, non-governmental organizations, academia, the private sector, and the 

public at large, including holding public events as appropriate. These interactions help inform the 

Board’s oversight agenda and identify potential privacy and civil liberties risks. 

Additionally, the Board may request “public interest” declassification of information where 

appropriate and encourage the agencies it oversees, including elements of the Intelligence 

Community, to meaningfully enhance their own transparency efforts.

Also, the Board will continue its constructive interactions with Congress and provide the 

Board’s subject matter expertise to the Legislative Branch where appropriate. The Board is required 

by statute to submit semi-annual reports to designated committees of the Congress and to publicly 

release these reports to the extent consistent with the protection of classified information and 

applicable law. Board Members also have testified before Congress and stand ready to do so in the 

future.

22 Board Members and staff will continue to communicate with Members of Congress and 

congressional staff about the Board’s work, activities, and agenda.

The Board will seek to engage with the public, and the privacy and civil liberties and national 

security policy communities in particular, to stay abreast of a wide range of viewpoints. Board 

Members and staff will continue the past practice of speaking at government and non-government 

hosted events, as well as writing and publishing shorter individual articles where appropriate.

Additionally, the Board will continue to hold public forums, inviting panelists from within and 

outside of government, and hold meetings with and attend events held by outside organizations.

Finally, the Board will engage with international allies and stakeholders where appropriate. 

In the past, Board Members have participated in the Privacy Shield Review Process as well as 

internationally hosted events. This international presence will allow the Board to continue to

leverage its subject matter expertise in dialogue with international stakeholders and encourage 

mutually informative discussions of challenges, best practices, and international views on 

counterterrorism activities.

21 Id. § 2000ee(f)(2).

22 Id. § 2000ee(d)(4).
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OBJECTIVE 4.1: Make the Board’s work available to the public and other stakeholders to the 

maximum extent possible, consistent with the protection of classified information and other 

applicable law.

Strategies for Accomplishing Objective 4.1:

➢ Issue public reports, to the extent consistent with the protection of classified informationand

applicable law.

➢ Regularly inform the public about the Board’s work, consistent with the necessary 

protection of classified information and other applicable law.

➢ Publicly identify the Board’s oversight review projects, to the extent consistent with the 

protection of classified information and other applicable law.

➢ Encourage agencies to make public (or permit the Board to make public) advice 

engagements with the Board.

➢ Encourage and support other agencies’ efforts to increase transparency and inform the 

public about authorities and activities within the Board’s jurisdiction.

➢ Where appropriate, request “public interest” declassification of information pursuant to 

Executive Order 13526 on Classified National Security Information and raise with agencies 

instances where the Board considers information within its jurisdiction to be overly 

classified.

➢ Pursue transparency in a manner that safeguards classified information and respects 

appropriate privileges and confidences. 

OBJECTIVE 4.2: Continue regular formal and informal interactions with Congress.

Strategies for Accomplishing Objective 4.2:

➢ Provide semi-annual reports to the designated congressional committees.

➢ Provide testimony to Congress on issues within the Board’s expertise.

➢ Provide advice and feedback on draft legislation as appropriate.

➢ Periodically meet with Members of Congress and congressional staff to discuss the Board’s 

work and agenda.
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OBJECTIVE 4.3: Engage directly with the public about the Board’s work and issues within the 

Board’s jurisdiction.

Strategies for Accomplishing Objective 4.3:

➢ Identify appropriate speaking opportunities at public events for Board Members and staff 

hosted by other government and non-government entities.

➢ Regularly engage with representatives of non-governmental organizations, academics, the 

private sector, the public, and other stakeholders.

OBJECTIVE 4.4: Identify appropriate opportunities to engage with international counterparts and 

stakeholders.

Strategies for Accomplishing Objective 4.4:

➢ Engage as appropriate with international counterparts responsible for national security 

oversight in countries with comparable commitments to the rule of law.

➢ Identify appropriate opportunities to engage with international stakeholders and experts.

STRATEGIC GOAL 5: Continue to enhance the Board’s institutional strength and 

capacity.

The Board relies on strong administrative, managerial, and organization capabilities to 

operate efficiently as a small independent federal agency. The Board’s operational staff is smaller 

than most federal agencies, and as such utilizes shared-service providers for certain activities. These 

providers assist the Board’s full-time operational staff with critical functions, such as human 

resources, financial management, and cybersecurity. The Board will continue to review these 

shared-service agreements to make sure that they provide appropriate support for the Board’s 

operations and value for taxpayer dollars.
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As the agency enters its second decade, the Board will assess whether and how it should 

seek to expand staffing to enable the Board to best serve its mission and operate efficiently as an 

agency. One of the Board’s top priorities is to recruit and retain an expert staff, with the goal of 

developing staff with a broad range of subject matter expertise in intelligence, counterterrorism and 

national security, privacy and civil liberties, oversight and investigations, technology, and more.

Over the next four years, the Board will enhance opportunities for staff professional development 

and retention.

Additionally, the Board will strive to build a model Equal Employment Opportunity 

program, and implement the agency’s diversity, equity, inclusion, and accessibility goals. From 

recruiting a diverse staff, to expanding the Board’s reach and opportunities to individuals from 

historically underserved communities and initiating data collection to devise and implement 

equitable and inclusive policies and procedures, the Board will serve as a model employer and 

oversight body. 

The Board will also continue to prioritize fiscal management and security. Over the last 

strategic plan cycle, the Board strengthened its financial management by developing new 

procedures, enhancing internal controls, appointing a Chief Financial Officer and hiring a full-time 

accountant, and transitioning to new shared-service providers for financial services, human 

resources, and procurement services. This dedication to achieving excellence in financial 

management led to a remarkable achievement: an unmodified (clean) audit opinion over the 2019 

financial statements from the Board’s external auditors, and clean financial statement audit opinions 

for two more consecutive years - a rare accomplishment for any federal agency. 

Additionally, the Board received recognition from the National Insider Threat Task Force for 

achieving full operating capability in the Board’s Trusted Access Program, and the agency’s Chief 

Security Officer was selected to serve a three-year term on the Joint Office of Director of National 

Intelligence/Office of Under Secretary of Defense for Intelligence. The PCLOB will continue to 

ensure a good working relationship on security-related matters and will work to solidify the agency’s

Operations Security and Enterprise Risk Management programs.

Finally, the Board will continue to mature and deploy the agency’s Continuous Diagnostics 

and Mitigation (“CDM”) platform to enhance network security and responsiveness. The CDM 

platform provides increased visibility of cybersecurity vulnerabilities and assists the Office of the 

Chief Information Officer (“OCIO”) in prioritizing mitigation efforts. The OCIO will seek to 

leverage cloud and shared-service providers to support mission objectives and enhance network 

security operations.
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OBJECTIVE 5.1: Optimize the Board’s use of shared-service providers.

Strategy for Accomplishing Objective 5.1: Continue to monitor and assess the performance of the

Board’s shared-service arrangements to ensure that each delivers excellent performance, 

responsiveness, and value for taxpayer dollars, and adjust as needed.

OBJECTIVE 5.2: Recruit and retain a diverse workforce equipped with an array of skills relevant 

to the Board’s mission.

Strategies for Accomplishing Objective 5.2:

➢ Implement the agency’s Equity Action Plan and Diversity, Equity, Inclusion, and 

Accessibility (“DEIA”) Strategic Plan to establish relationships with, expand the Board’s 

reach to, and recruit individuals from historically underserved communities. 

➢ Identify any gaps in subject matter expertise among current staff and develop training and 

other development opportunities to enhance skills and expertise. 

➢ Recruit highly qualified permanentstaff and work with detailees from other federal agencies

as available.

➢ Assess agency practices, policies, guidance, and workforce plans to promote a diverse and 

inclusive workplace that supports and develops each individual employee and enhances 

retention.

➢ Maintain a professional and collegial workplace environment, including considering 

mentorship opportunities and workplace flexibilities.

OBJECTIVE 5.3: Continue to strengthen the Board’s financial management capabilities and

ensure responsiblestewardship of taxpayer funds.

Strategies for Accomplishing Objective 5.3:

➢ Undergo regular financial audits, using findings and recommendations to further refine

internal controls and accounting practices.

➢ Continue to conduct agency-wide planning that is linked and responsive to the budget

process.
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OBJECTIVE 5.4: Maintain a high standard of personnel and information security.

Strategies for Accomplishing Objective 5.4:

➢ Achieve the highest standards of security for the Board’s cleared personnel, including

through implementation of Trusted Workforce 2.0 and solidifying the Operations Security 

Program, physical space, and classified systems.

➢ Leverage the Board’s FISMA audit and Network Penetration Tests to further refine 

cybersecurity practices, policies, and documentation, and conduct annual FISMA audits.

➢ Continue to maintain compliance with Cybersecurity and Infrastructure Security Agency 

(“CISA”) mandates.

➢ Regularly train staff on cybersecurity, counterintelligence, and physical security threats.

➢ Collaborate with federal partners on cybersecurity solutions, threat indicators, and best 

operations securitypractices.

OBJECTIVE 5.5: Continue to refine the Board’s internal policies and governance processes.

Strategy for Accomplishing Objective 5.5: Review Board policies and procedures and revise or 

develop new policies and procedures, as necessary.
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CONCLUSION

This Strategic Plan establishes the roadmap for the continued success of the Privacy and 

Liberties Oversight Board in fulfilling its mission to provide expert advice and to conduct robust

oversight of counterterrorism efforts under a re-constituted quorum. 

Thanks to the efforts of past Members and staff, the Board is prepared to continue to fulfill 

its statutory mission during the period of this Strategic Plan. The newly quorate Board looks 

forward to drawing on its full complement of authorities to complete existing oversight and advice 

projects and identify new areas ripe for the Board’s oversight and advice. 

As the Board continues to mature, so too do its long-term goals and priorities. The next four

years will see more substantive growth with the primary goal of maintaining and expanding on that

record. The Board’s record and reputation will guide the Board’s work moving forward.

The Board looks forward to working with other executive branch agencies, Congress, the 

public, and other stakeholders to help protect privacy and civil liberties interests in counterterrorism 

efforts over the next four years.