Privacy Impact Assessment (PIA) 

for the 

iComplaints 

May 20, 2021 

For PIA Certification Updates Only: This PIA was reviewed on Enter date by Name of reviewer 

certifying the information contained here is valid and up to date. 

Contact Point 

Contact Person/Title: Steven Jefferson 

Contact Email: Steven.Jefferson@ed.gov 

System Owner 

Name/Title: Lee Flowe, Director Shared Services Systems Support Division 

Principal Office: Office of Finance and Operations 

Please submit completed Privacy Impact Assessments to the Privacy Office at 

privacysafeguards@ed.gov 

FY 2020 
 

 

 

 

 

 

 

 

 

 

Please complete this Privacy Impact Assessment (PIA) on how personally identifiable 

information (PII) is collected, stored, protected, shared, and managed electronically by your 

system. You may wish to consult with your ISSO in completing this document. 

If a question does not apply to your system, please answer with N/A. 

1. Introduction 

1.1. Describe the system including the name, acronym, and a brief description of the program 

or purpose for the system. 

The Electronic Case Management Platform (ECAMP) was developed to support the 

Office of Finance and Operations (OFO) strategy of streamlining information 

technology (IT) operations to better align with the U.S. Department of Education’s 

(Department) goal of IT modernization, standardize the use of IT shared services, and 

reduce the overall cybersecurity footprint. The ECAMP will combine separate case 

management systems or modules, each with separate small contracts with Tyler 

Technologies, Inc. (formerly MicroPact), a cloud service provider (CSP). 

iComplaints is a web-based application that is platform-independent of other user 

operating systems (i.e., iOS, Windows). iComplaints is supported via a Software-as-aService (SaaS) platform, known as Entellitrak. Entellitrak is a configurable data tracking 

and management platform for case management (CM) and business process management 

(BPM). It provides pre-built, executable business process management system (BPMS) 

based configurations (process templates) focused on a particular process domain or a 

vertical industry sector and supports storing data in either an Oracle database or 

Microsoft structured query language (SQL) server database. iComplaints is accessed via 

a web-based interface, utilizing a role-based security and access model. The system 

provides administration and tracking information to the Department. 

iComplaints is used to support requirements outlined at 29 CFR § 1614. This regulatory 

provision requires all Federal agencies to track and report to the Equal Employment 

Opportunity Commission (EEOC) information concerning the status, processing, and 

disposition of Federal sector EEO complaints (under Title VII of the Civil Rights Act) so 

as to adjudicate and issue final decisions and arrive at final disposition of EEO 

complaints. iComplaints is the Department’s system managed by the Office of EEO 

Services (OEEOS) that provides all the functionality required to collect, track, manage, 

process, and report on information regarding the processing of the agency’s Federal 

sector EEO complaints and cases. 

Fiscal Year 2020 Privacy Impact Assessment -Page 1 
 

 

 

 

 

 

 

 

 

1.2. Describe the purpose for which the personally identifiable information (PII)1 is collected, 

used, maintained or shared. 

Information is collected so that the Department can develop an impartial and appropriate 

factual record of all Federal sector EEO complaints, including a record of the actions 

taken during the processing of the complaint. The purpose of this is to adjudicate EEO 

complaints in a timely manner, order relief if appropriate, and prepare reports mandated 

by the EEOC. 

1.3. Is this a new system, or one that is currently in operation? 

Currently Operating System 

1.4. Is this PIA new, or is it updating a previous version? 

New PIA 

iComplaints migrated to the Entellitrak SaaS platform, so a new PIA is required. 

1.5. Is the system operated by the agency or by a contractor? 

Contractor 

1.5.1. If the system is operated by a contractor, does the contract or other acquisitionrelated documents include privacy requirements? 

N/A

Yes 

2. Legal Authorities and Other Requirements 

If you are unsure of your legal authority, please contact your program attorney. 

2.1. What specific legal authorities and/or agreements permit and regulate the collection and 

use of data by the system? Please include name and citation of the authority. 

The Equal Employment Act of 1972, 42 USC 2000e-16, prohibits employment 

discrimination. The Federal Sector Equal Employment Opportunity Regulations, 29 

1 The term “personally identifiable information” refers to information which can be used to distinguish or trace an 

individual's identity, such as their name, social security number, biometric records, etc. alone, or when combined 

with other personal or identifying information which is linked or linkable to a specific individual, such as date and 

place of birth, mother's maiden name, etc. OMB Circular A-130, page 33 

Fiscal Year 2020 Privacy Impact Assessment -Page 2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

CFR Part 1614, implement the Federal workplace discrimination laws. The Equal 

Employment Opportunity Management Directive 110 (EEO MD 110) provides Federal 

agencies with EEOC policies, procedures, and guidance relating to the processing of 

employment discrimination complaints governed by the EEOC’s regulations at 29 CFR. 

Part 1614. 

SORN 

2.2. Is the information in this system retrieved by an individual’s name or personal identifier 

such as a Social Security Number or other identification? 

Yes 

2.2.1. If the above answer is YES, this system will need to be covered by Privacy Act 

System of Records Notice(s) (SORN(s)).2 Please provide the SORN name, number, 

Federal Register citation and link, or indicate that a SORN is in progress. 

N/A

EEOC/GOVT-1 Equal Employment Opportunity in the Federal Government 

Complaint and Appeals Records, 81 FR 81116 (November 17, 2016). 

2.2.2. If the above answer is NO, explain why a SORN was not necessary. For 

example, the information is not retrieved by an identifier, the information is not 

maintained in a system of records, or the information is not maintained by the 

Department, etc. 

N/A

Click here to enter text. 

Records Management 

If you do not know your records schedule, please consult with your records liaison or send 

an email to RMHelp@ed.gov 

2.3. What is the records retention schedule approved by National Archives and Records 

Administration (NARA) for the records contained in this system? Please provide all 

relevant NARA schedule numbers and disposition instructions. 

2 A System of Records Notice (SORN) is a formal notice to the public that identifies the purpose for which PII is 

collected, from whom and what type of PII is collected, how the PII is shared externally (routine uses), and how to 

access and correct any PII maintained by ED. https://connected.ed.gov/om/Documents/SORN-Process.pdf 

Fiscal Year 2020 Privacy Impact Assessment -Page 3 
 

 

 

 

 

 

 

 

 

GENERAL RECORDS SCHEDULE 2.3, Employee Relations Records, Item 111 

EEO Discrimination Complaint Case Files – Formal Process. 

Temporary. Destroy 7 years after resolution of case, but longer retention is authorized if 

required for business use. 

GENERAL RECORDS SCHEDULE 5.7, Agency Accountability Records, Item 050 

Mandatory Reports to External Federal Entities Regarding Administrative Matters 

Temporary. Destroy 6 years after report submission or oversight entity notice of 

approval, as appropriate, but longer retention is authorized if required for business use. 

2.4. Is the PII contained in this system disposed of appropriately, and in accordance with the 

timelines in the records disposition schedule? 

Yes 

3. Characterization and Use of Information 

Collection 

3.1. List the specific PII elements (e.g., name, email, address, phone number, date of birth, 

Social Security, etc.) that the system collects, uses, disseminates, or maintains. 

The PII elements collected are: 

• Complainant’s name, personal email address, home address, employee pay grade, 

job series, phone number, date of birth, race, and disability status. Documents 

submitted by complainant such as charge of discrimination, personal interview 

statement, and correspondence. 

• Employer’s name, work phone number, and supervisor’s pay plan (if known). 

Documents submitted by employer such as statement of position, 

correspondence, statements of witnesses, documentary evidence such as 

personnel files, records of earnings, employee benefit plans, seniority list, job 

titles and descriptions, applicant data, organizational charts, collective bargaining 

agreements, and petitions to revoke or modify subpoenas. 

• Information gathered in the course of the investigation and during a hearing, if 

relevant, such as witness statements, investigator’s notes, investigative plan, 

report of initial and exit interview, investigator’s analyses of evidence and 

charge, subpoenas, decisions and letters of determination, conciliation 

Fiscal Year 2020 Privacy Impact Assessment -Page 4 
 

 

 

 

 

 

 

 

 

 

 

 

 

agreements, correspondence, and any additional evidence gathered during the 

course of the investigation. 

3.2. Does the system collect only the minimum amount required to achieve the purpose 

stated in Question 1.2? 

Yes 

The system collects the minimum contact information so as to communicate with 

relevant parties. The additional information collected is the minimum necessary to 

investigate and adjudicate the complaint. 

3.3. What are the sources of PII collected (e.g., individual, school, another agency, 

commercial sources, etc.)? 

The individuals who are party to the EEO complaint, the Department, another Federal 

agency (e.g., EEOC, Merit Systems Protection Board), and EEO Investigators. 

3.4. How is the PII collected from the stated sources listed in Question 3.3 (e.g., paper form, 

web page, database, etc.)? 

The majority of the PII collected is provided by the complainant by completing the EEO 

Pre-Complaint Intake Form. This form can be submitted electronically through email or 

provided in hard copy to an EEO specialist. Additional PII mentioned in section 3.1 is 

compiled through the course of the limited inquiry and investigation. 

3.5. How is the PII validated or confirmed to ensure the integrity of the information 

collected?3 Is there a frequency at which there are continuous checks to ensure the PII 

remains valid and accurate? 

The PII is validated as it is being collected by either the complainant completing the 

EEO Pre-Complaint Intake Form and the ongoing communication between the EEO 

Specialist and the complainant whose information is collected to ensure that updated and 

accurate PII is being maintained. 

Use 

3.6. Describe how the PII is used to achieve the purpose stated in Question 1.2 above. 

3 Examples include restricted form filling, account verification, editing and validating information as it’s collected, 

and communication with the individual whose information it is. 

Fiscal Year 2020 Privacy Impact Assessment -Page 5 
 

 

 

 

 

 

 

 

 

 

 

 

The purpose of the collection is to process and adjudicate EEO complaints, associate 

filers with their respective complaints, to avoid mishandling a complaint (i.e., an 

improper disclosure of complaint matters to the wrong complainant or mix-up of 

complaint matters), and to maintain current contact information for complainants, 

witnesses, and representatives. Data are also being collected to process complaints in a 

timely manner, develop adequate factual records, issue decisions that are consistent with 

acceptable legal standards, explain the reasons for decisions, and to give complainants 

adequate and timely notice of their rights. Data may also be used for reporting and 

statistical purposes, for example Department officials could request the number of 

complaints filed against a Responsible Management Official (RMO). When used for 

statistical purposes, personal identifiers will be removed. 

3.7. Is the system using PII for testing/researching new applications or information systems 

prior to deployment or for training employees? 

No 

3.7.1. If the above answer is YES, what controls are in place to minimize the risk and 

protect the data? 

N/A

Click here to enter text. 

Social Security Numbers 

It is the Department’s Policy that, in order to collect Social Security Numbers, the System Owner 

must state the collection is: 1) authorized by law, 2) necessary for an agency purpose, and 3) 

there is no reasonable alternative. 

3.8. Does the system collect Social Security Numbers? Note that if the system maintains 

Social Security Numbers but does not explicitly collect them, answer 3.8.1 to address the 

purpose for maintaining them. 

No 

3.8.1. If the above answer is YES, explain the purpose for its collection, and how the 

SSN will be used. 

N/A

Click here to enter text. 

Fiscal Year 2020 Privacy Impact Assessment -Page 6 
 

 

 

 

 

 

 

 

 

 

 

3.8.2. Specify any alternatives considered in the collection of SSNs and why the 

alternatives were not selected. 

N/A

Click here to enter text. 

4. Notice 

4.1. How does the system provide individuals with notice about the collection of PII prior to 

its collection (e.g., direct notice, such as a Privacy Act Statement (if applicable) or 

public notice, such as a SORN, PIA,)? If notice is not provided, explain why not. 

The Privacy Act statement provided in 4.2 is part of the package that the EEO specialist 

provides to the complainant. This PIA and a SORN are also published at 

www.ed.gov/notices, which provides public notice. 

4.2. Provide the text of the notice or the link to the webpage where the notice is posted if 

notice is provided other than by SORN or PIA. 

N/A

A Privacy Act statement is provided prior to applicants entering information into the system. 

Public notices are also provided through this PIA as well as a SORN. 

4.3. What opportunities are available for individuals to consent to uses (including new uses 

of previously collected PII), decline to provide PII, or opt out of the project? 

The disclosure of PII is voluntary and individuals who submit a complaint may decline 

to provide requested information but doing so may result in the dismissal of their 

complaint because of failure to respond or proceed in a timely fashion. 

4.4. Is the notice referenced in Question 4.1 reviewed and revised when there are changes in 

the practice, policy, or activities that affect the PII and privacy to ensure that individuals 

are aware of and can consent to, where feasible, these changes? 

Yes 

5. Information Sharing and Disclosures 

Internal 

5.1. Will PII be shared internally with other ED principal offices? If the answer is NO, please 

skip to Question 5.4. 

Fiscal Year 2020 Privacy Impact Assessment -Page 7 
 

 

 

 

 

 

 

 

 

 

 

 

 

Yes 

5.2. What PII will be shared and with whom? 

N/A

Any information collected as part of the complaint process is shared with the 

Department’s Office for Civil Rights (OCR). 

5.3. What is the purpose for sharing the specified PII with the specified internal 

organizations? 

N/A

All data would be shared with OCR for the purpose of litigating the case on behalf of the 

Department. 

External 

5.4. Will the PII contained in the system be shared with external entities (e.g., another 

agency, school district, the public, etc.)? If the answer is NO, please skip to Question 

6.1. 

Yes 

The information will be shared with the EEOC pursuant to 29 CFR § 1614. 

5.5. What PII will be shared and with whom? List programmatic disclosures only.

4 

Note: If you are sharing Social Security Numbers externally, please specify to 

whom and for what purpose. 

N/A

The shared PII is part of an EEO Complaint File (including the EEO Investigative 

Report). The information is shared with the complainant, and the EEOC via the Federal 

Sector EEO Portal (FEDSEP). https://egov.eeoc.gov/FedSep/jsp/secure/login.jsf 

5.6. What is the purpose for sharing the PII with the specified external entities? 

N/A

To adjudicate Title VII of the Civil Rights Act, Federal sector EEO complaints. 

4 If this information is covered by Privacy Act System of Records Notice (SORN) please list only relevant 

programmatic disclosures listed under the Routine Uses section. 

Fiscal Year 2020 Privacy Impact Assessment -Page 8 
 

 

 

 

 

 

 

 

5.7. Is the sharing with the external entities authorized? 

N/A

Yes 

5.8. Is the system able to provide and retain an account of any disclosures made and make it 

available upon request? 

N/A

Yes 

Click here to enter text. 

5.9. How is the PII shared with the external entity (e.g., email, computer match, encrypted 

line, etc.)? 

N/A

Information is not disclosed directly from iComplaints. An OEEOS staff member 

retrieves information from iComplaints and provides it via email, encrypted line, or hard 

copy. 

5.10. Is the sharing pursuant to a Computer Matching Agreement (CMA), 

Memorandum of Understanding (MOU), or other type of approved sharing agreement 

with another agency? 

N/A

No 

5.11. Does the project place limitation on re-disclosure? 

N/A

Yes 

6. Redress 

6.1. What are the procedures that allow individuals to access their own information? 

At the conclusion of an EEO Investigation, the complainant is provided with a copy of 

the report of investigation (ROI). In addition, the complainant can submit a Privacy Act 

request at any point in the process to obtain their information. 

6.2. What procedures are in place to allow the subject individual to correct inaccurate or 

erroneous information? 

Fiscal Year 2020 Privacy Impact Assessment -Page 9 
 

 

 

 

 

 

 

 

 

 

 

The complainant receives a copy of the report of investigation which allows them to 

correct or update any inaccurate or erroneous information. If an individual wishes to 

amend the content of a record in the system of records, the individual may contact the 

system manager according to the instructions in the SORN. 

6.3. How does the project notify individuals about the procedures for correcting their 

information? 

Both the SORN and this PIA, as well as the Department’s regulations, at 34 CFR 5b7, 

provide information and procedures for amending records. 

7. Safeguards 

If you are unsure which safeguards will apply, please consult with your ISSO. 

7.1. Does the principal office work with their CSO/ISSO to build privacy & security into the 

system and build privacy extensions to the extent feasible? 

Yes 

7.2. Is an Authority to Operate (ATO) required? 

Yes 

7.3. Under NIST FIPS Pub. 199, what is the security categorization of the system: Low, 

Moderate, or High? 

N/A

Moderate 

7.4. What administrative, technical, and physical safeguards are in place to protect the 

information? 

iComplaints is hosted outside of the Department’s network on a FedRAMP-certified 

CSP, Tyler Federal. The system is provided as a SaaS and is required to complete 

routine testing of their environment to ensure the confidentially, integrity, and 

availability of the information in the system and services provided. The CSP enforces 

security controls over the physical facility where the system is located in adherence with 

FedRAMP standards. 

Fiscal Year 2020 Privacy Impact Assessment -Page 10 
 

 

 

 

 

 

 

 

iComplaints utilizes role-based authentication to ensure only authorized users can access 

information, and they can only access the information needed to perform their duties. 

Authentication to the server is permitted only over secure, encrypted connections. A 

firewall is in place which allows only specific trusted connections to access the data. 

iComplaints has an ATO in place and complies with all National Institute of Standards 

and Technology (NIST) standards. 

Physical safeguards for the data centers are detailed within the system security plan and 

are assessed as part of the FedRAMP assessment. Tyler Federal does not consume, 

process, or view the customers’ data; no hard copies are made. 

MicroPact/Tyler Federal does not access customer production applications without 

specific approval from the system owner (possibly for troubleshooting purposes). The 

customer manages application-level access and accounts. Multiple layers of 

cryptographic mechanisms are in place. There is role-based access control within the 

application. 

7.5. Is the information in the system appropriately secured in accordance with the IT 

security requirements and procedures as required by Federal law and policy? 

Yes 

Click here to enter text. 

7.6. Has a risk assessment been conducted where appropriate security controls to protect 

against that risk have been identified and implemented? 

Yes 

The system is currently being assessed by a third party. An initial assessment has been 

completed by the ISO and Plan of Action and Milestones (POAMs) have been created to 

address and control deficiencies. 

7.7. Please describe any monitoring, testing or evaluation conducted on a regular basis to 

ensure the security controls continue to work properly at safeguarding the PII. 

MicroPact/Tyler Federal performs monitoring, testing, and evaluation of their software. 

MicroPact/Tyler Federal is responsible for ensuring access controls are working as 

defined in the software. 

Fiscal Year 2020 Privacy Impact Assessment -Page 11 
 

 

 

 

 

 

 

 

 

 

 

 

 

As a part of their continuous monitoring plan, MicroPact/Tyler Federal evaluates and 

tests a selection of controls internally on a scheduled basis. Assessments are conducted 

annually by MicroPact/Tyler Federal’s third-party organization as part of FedRAMP 

continuous monitoring requirement; results are reported within the security assessment 

report. Additionally, MicroPact/Tyler Federal supports multiple customer assessments 

each year and evaluates those results. Security documentation is reviewed by the 

information system security officer (ISSO) and the information system owner (ISO) at 

least annually and updated as required by changes to the system, security posture, or 

security requirements. 

The system production environment has multiple monitoring tools in place. 

Infrastructure logs are audited. Application-level audit logs can be run by the customer 

from the administrative module. MicroPact/Tyler Federal also has a continuous 

monitoring plan in place, which schedules the evaluation/testing of select controls 

internally. There are a number of reviews conducted by the iComplaints administrator to 

ensure only authorized users are accessing system data. 

8. Auditing and Accountability 

8.1. How does the system owner assess and ensure that the PII is used in accordance with 

stated practices in this PIA? 

The system owner ensures the iComplaints administrator completes reviews of audit logs on 

a regular basis to ensure there is no misuse or malicious activity with the system or data. 

The system owner periodically reviews audit reports provided by the iComplaints 

administrator regarding information processing and maintains the access control list for who 

can read/write any PII. The ISO also works directly with the Department’s privacy office on 

privacy compliance documentation to ensure all information in this PIA is up to date and 

accurate. Ultimately, the iComplaints system application(s) undergo yearly OMB Circular A123, Appendix A (Management’s Responsibility for Enterprise Risk Management and 

Internal Control) assessment, and NIST Special Publication 800-53 system security control 

self-assessments. 

8.2. Does the system owner continuously monitor and audit the privacy controls to ensure 

effective implementation? 

Yes 

8.3. What are the privacy risks associated with this system and how are those risks 

mitigated? 

Fiscal Year 2020 Privacy Impact Assessment -Page 12 
 

 

 

 

 

 

This PIA details the privacy controls and safeguards implemented for this system in 

order to mitigate privacy risk. These controls and safeguards work to protect the data 

from privacy threats and mitigate the risks to the data. To address privacy risks, 

iComplaints has several mitigations in place. For example, iComplaints has an 

agreement of OFO Rules of Behavior by system users and an account approval process 

to provide role-based accounts which limit the read/write capability of the user. The 

main privacy risk identified is unauthorized access to the PII contained in the 

iComplaints application. The risk has been mitigated through privacy training for both 

contractors and Department staff, restricting access to PII to those individuals with a 

direct business need for the information, and robust security controls such as the use of 

firewalls, intrusion detection systems, and event monitoring systems provided by the 

applications CSP. 

Fiscal Year 2020 Privacy Impact Assessment -Page 13