FedRAMP 

Privacy Impact Assessment 

01P

. 

FedRAMP 

Intelliworx 

Intelliworx Cloud 

Version 9.1 

November 22, 2019 
Intelliworx Cloud Privacy Impact Assessment 

Version 9.1 November 22, 2019 

Prepared by 

SecureIT 

SECURE 

Street Address 1818 Library Street 

Suite/Room/Building Suite 500 

City, State, ZIP Reston, VA 20190 

Prepared for 

Intelliworx 

INTELLIWORX 

Street Address 21400 Ridgetop Circle 

Suite/Room/Building Suite 210 

City, State, ZIP Sterling, VA 20166 

Record of Changes 

Date Description 

9/30/2016 

Sec 1.2 clarity rewrites; and added Voice recordings to list of Pll examples 

Sec 2 clarity rewrites; Sec 3.1-3. Added NIST control identifiers and edits to questions 

Removed Acronyms and referenced FedRAMP Master Acronyms and Glossary resource 

document 

Revision History 

Detail specific changes in the table below. 

Date Version Description Author 

8/7/2017 1.0 Initial Version SecureIT 

6/20/2018 1.1 Review for effectiveness Laurence Kirby 

7/24/2018 1.2 Boundary review Laurence Kirby 

2/11/2019 9 2019 review and version numbering change Mike Howlett 

11/21/2019 9.1 Revised original specifically for FERC Laurence Kirby 

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How to contact us 

For questions about FedRAMP, or for technical questions about this document including how to 

use it, contact infoaledramp.gov. 

For more information about the FedRAMP project, see www.fedramp.gov. 

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Table of Contents 

1 PRIVACY OVERVIEW AND Point of Contact (POC) 1 

1.1 Applicable Laws and Regulations 1 

1.2 Personally Identifiable Information (PII) 1 

2 Privacy Designation 2 

3 Privacy Impact Assessment Talking Points 2 

3.1 Pll Mapping of Components (SE-1, DM-1) 3 

3.2 Prospective Pll Use 4 

3.3 Sources of Pll and Purpose 4 

3.4 Access to Pll and Sharing 5 

3.5 Pll Safeguards and Liabilities 7 

3.6 Contracts, Agreements, and Ownership 9 

3.7 Accuracy of the Pll and Redress 10 

3.8 Maintenance and Administrative Controls 11 

3.9 Business Processes and Technology 13 

3.10 Privacy Policy 13 

3.11 SIGNATURES 14 

4 ACRONYMS 14 

List of Tables 

Table 1-1— Intelliworx Privacy POC 1 

Table 1-2 Intelliworx Laws and Regulations 1 

Table 3-1 Pll Mapped to Modules 3 

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1 PRIVACY OVERVIEW AND POINT OF CONTACT (POC) 

The Table 1-1 — Intelliworx Privacy POC individual is identified as the Intelliworx Privacy 

Officer and POC for privacy at Intelliworx. 

Table 1-1— Intelliworx Privacy POC 

Name Laurence Kirby 

Title Privacy Officer 

CSP / Organization Intelliworx 

Address 21400 Ridgetop Circle, Sterling, VA 20166 

Phone Number 703-260-6339 

Email Address Laurence.kirby@intelliworxit.com 

1.1 APPLICABLE LAWS AND REGULATIONS 

The FedRAMP Laws and Regulations can be found on: www.fedramp.gov. 

Table 1-2 Intelliworx Laws and Regulations include additional laws and regulations specific to 

Intelliworx. These will include laws and regulations from the Federal Information Security 

Management Act (FISMA), Office of Management and Budget (OMB) circulars, Public Law 

(PL), United States Code (USC), and Homeland Security Presidential Directives (HSPD). All 

applicable Laws and Regulations are referenced in Attachment Intelliworx Al2 Laws and 

Regulations v1.0 located on MAX.gov. 

Table 1-2 Intelliworx Laws and Regulations 

Identification 

Number Title Date Link 

N/A N/A N/A N/A 

1.2 PERSONALLY IDENTIFIABLE INFORMATION (PII) 

Personally Identifiable Information (PIT) as defined in OMB Memorandum M-17-12 refers to 

information that can be used to distinguish or trace an individual's identity, either alone or when 

combined with other personal or identifying information that is linked or linkable to a specific 

individual. Information that could be tied to more than one person (e.g., date of birth) is not 

considered PIT unless it is made available with other types of information that together could 

render both values as PII (for example, date of birth and street address). A non-exhaustive list of 

examples of types of PII includes: 

• Social security numbers 

• Passport numbers 

• Driver's license numbers 

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• Biometric information 

• DNA information 

• Bank account numbers 

• Voice recordings 

PIT refers to information that can be traced back to an individual person. 

2 PRIVACY DESIGNATION 

Cloud Service Providers (CSPs) perform an annual analysis to determine if PIT is collected by 

any of the system components. Clouds that do not collect PIT and would like to opt out of hosting 

privacy information may elect to do so and are not required to fill out the Privacy Impact 

Assessment (PIA) Questions. If a CSP is willing to host PIT, the Privacy Impact Assessment 

Questions should be answered given the current knowledge of the CSP. A CSP is not required to 

solicit customers for the information. 

Federal cloud customers (i.e., data owner/system owners) are required to perform their own PIAs 

and may share this information with the CSP if they so desire (for informational purposes and/or 

to work with the CSP to develop processes and procedures for managing their PIT). 

Threshold Analysis 

Check one. 

El Opt out. This cloud will not host privacy information. 

IZ This cloud is willing to host privacy information. 

Select the cloud layers that are represented by the Intelliworx system. Select all that 

apply. 

▪ This cloud includes Software as a Service (SaaS). 

▪ This cloud includes Platform as a Service (PaaS). 

El This cloud includes Infrastructure as a Service (IaaS). 

3 PRIVACY IMPACT ASSESSMENT TALKING POINTS 

According to NIST SP 800-122, Appendix D, 

There must be no personal data record-keeping systems whose very existence is secret. 

Additionally, NIST SP 800-122, Appendix D states, 

There should be a general policy of openness about developments, practices, and policies 

with respect to personal data. Means should be readily available of establishing the 

existence and nature of personal data and the main purposes of their use, as well as the 

identity and usual residence of the data controller. 

In light of the NIST guidance, PIA talking points have been developed for the purpose of 

ensuring full disclosure between stakeholders. 

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Identifiers in parenthesis after a section title indicate NIST SP 800-53, Appendix J privacy 

controls that are related to the particular talking point. These mappings to Appendix J privacy 

controls are not considered a replacement for Appendix J controls. 

3.1 PII MAPPING OF COMPONENTS (SE-1, DM-1) 

General Service (GS) Supervisory employees (i.e., G515s, G514s, and GS13s) are required by 

the Office of Government Ethics (OGE) regulation to submit a Confidential Financial Disclosure 

Report, OGE Form 450, annually. Employees will be able to electronically file Form 450 using 

the Financial Disclosure (FD)online, a financial disclosure filing system. 

The FDonline module is a cloud-based, multi-tenant, software as a service (SaaS) - that sits on 

the Intelliworx platform - which allows applicable government employees and ethics officers to 

efile and review the annual OGE Form 450. The Intelliworx platform allows customer agencies 

to streamline and automate workflows in any number of mission areas. The platform consists of 

modules. The module discussed in this PIA is FDonline. Each module has been analyzed to 

determine if any elements of that module collect and/or store PIT. The type of PIT collected 

and/or stored by Intelliworx and the functions that collect it are recorded in Table 3-1. 

Table 3-1 Pll Mapped to Modules 

Modules 

Does this 

Component 

Collect or Store 

PII? 

(Yes/No) 

Type of Pll Reason for 

Collection of Pll Safeguards 

(FDonline) Yes 

Federal employee 

full name, 

employment 

information, financial 

information (e.g., 

assets, income and 

valuation of assets) 

for self and 

spouse/family 

Required to submit 

OGE Form 450 

Implementation of 

the NIST 800-53 

Rev 4 controls for a 

FedRAMP 

Moderate system 

(e.g., access 

controls, 

encryption, border 

protection, 

security 

monitoring, 

security awareness 

training). All 

modules are 

located within the 

Amazon Web 

Services (AWS) 

GovCloud 

Infrastructure as a 

Service (laaS). 

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3.2 PROSPECTIVE PII USE 

Respond to the following questions: 

1. Are there any data fields in the platform or application that have been targeted for the 

collection or storage of PII? If yes, please name those fields. (SE-1, DM-1, IP-1) 

Yes. The Intelliworx system (FDonline module) collects the following PIT for the inherent 

purposes of onboarding new hires and filing financial disclosure forms: 

• Full name 

• Email address 

• Demographics (e.g., race, nationality, ethnicity) 

• Employment: work address, e-mail address grade, title, work phone 

• Types and amounts of salaries, investments, and assets for self and spouse/family 

• Creditor names, city, state, country 

2. If PIT fields are used, can individuals "opt-out" of PIT fields by declining to provide PII or 

by consenting only to a particular use (e.g., allowing basic use of their personal 

information, but not sharing with other government agencies)? (IP-1) 

Within the FDonline module, individuals are not able to opt out of providing PIT or consenting 

to only a particular use. The PII collected and used is required by the OGE. Declining to 

provide PII effectively declines employment. 

CI Yes Explain the circumstances of being able to opt-out of PIT fields (either for 

specific data elements or specific uses of the data). (IP-1) 

El No It is not possible to opt-out. PII will be used only for the purpose for which it is 

collected. 

3.3 SOURCES OF PII AND PURPOSE 

3. Does Intelliworx have knowledge of existing federal agencies that provide PIT that gets 

imported into the system? (AP-2) 

Yes, federal agencies that are customers and users of the Intelliworx system (FDonline 

module) provide PII as input to the system. 

4. Has any agency that is known to provide PIT to the system provided a stated purpose for 

populating the system with PIT? (AP-1, AP-2) 

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Not explicitly. However, federal agency customers populating the system (through FDonline) 

with PII is integral to the business processes of the Intelliworx system. 

5. Does Intelliworx currently populate the system with PIT? If yes, where does the PIT come 

from and what is the purpose? (AP-1, AP-2) 

Intelliworx only populates the Intelliworx system with PIT during the initial onboarding of 

customers if the federal agency provides the data to be loaded into the system. 

The FDonline module can be populated by flat files provided by FERC. However, FERC 

employees will complete OGE 450 form electronically by accessing FDonline. 

The collection of PIT is integral to the business processes of the Intelliworx system. 

6. Will any third party sources be providing PIT that will be imported into the system (if 

known)? Please explain. (AP-1, AP-2) 

The individual who is onboarding to FERC and completing the OGE 450 form provides PII to 

be imported into the Intelliworx system. 

3.4 ACCESS TO PH AND SHARING 

7. What third-party organizations will have access to the PIT (if known)? Who establishes the 

criteria for what PII can be shared? (AP-1, AP-2, AR-8, IP-1, UL-2) 

The FDonline module does not provide PII to any third-party organizations. 

FERC establishes the criteria for granting system account access to the PII managed by 

Intelliworx. 

8. What Intelliworx personnel roles will have access to PIT fields (e.g., users, managers, system 

administrators, developers, contractors, other)? Explain the need for Intelliworx personnel to 

have access to the PIT. (AR-8, UL-2) 

Intelliworx utilizes a role-based approach for Intelliworx system account management 

activities. Access to the Intelliworx system, and the PIT fields contained within, is limited to 

Intelliworx personnel with an application, infrastructure, or security administrator role 

supporting the Intelliworx system. Individuals are only granted access to functionality 

necessary to accomplish assigned tasks and responsibilities, such as application support and 

system administration. 

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'Role 

Internal 

or 

External 

Privileged 

(P), NonPrivileged 

(NP), or Sensitivity 

No Level 

Logical 

IIIIIIIIIIIIILIL 

Access 

Intelliworx 

Infrastructure 

Administrators 

Internal P Moderate 

Full Infrastructure 

Access 

Limited 

Application Access 

No Security 

Systems Access 

Support and manage (e.g., create, 

remove, modify, modify access to, 

update, patch) all infrastructure 

systems: Amazon Web Services (AWS) 

GovCloud, Linux servers, MySQL 

(Structured Query Language) 

databases, Tomcat, Hypertext Transfer 

Protocol daemon (HTTPd), Splunk, 

RADIUS, and Palo Alto firewalls. 

Maintain an account in the application 

for the administration and support of 

server-wide functions in the 

application (e.g., scheduling jobs, 

troubleshooting email notifications). 

Intelliworx 

Security 

Administrators 

Internal P Moderate 

Limited 

Infrastructure 

Access 

No Application 

Access 

Full Security 

Systems Access 

monitoring. 

Operate, support, and manage (e.g., 

create, remove, modify, modify access 

to, update) all security systems as 

needed. Perform vulnerability and 

compliance activities, review system 

integrity checks and malicious code 

In the case of a security investigation, 

security administrators may be given 

heightened access to all infrastructure 

systems and applications. 

Intelliworx 

Application 

Administrators 

Internal P Moderate 

No Infrastructure 

Access 

Full Application 

Access 

No Security 

Systems Access 

Support and manage the application. 

Create users, objects, modify 

workflows, modify configurations, and 

perform troubleshooting. Intelliworx 

application administrators have access 

to all data. 

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9. For Intelliworx support staff, how is access to the PIT determined? Are criteria, procedures, 

controls, and responsibilities regarding access documented? Does access to PIT require 

manager approval? (IP-2) 

Intelliworx personnel are granted access to the Intelliworx system based on role, and only have 

access to functionality that is necessary to accomplish assigned tasks and responsibilities, such 

as application support and system administration. Access and authorization requests are 

documented, authorized, and approved by the individual's manager and the Intelliworx 

Security Officer prior to account creation. 

10. Do other systems that interconnect to the system share, transmit, or access the PII in the 

system? If yes, explain the purpose for system to system transmission, access, or sharing of 

PIT. (UL-2) 

No. Other systems do not share, transmit, or access the PIT in the system. 

3.5 PII SAFEGUARDS AND LIABILITIES 

11. What controls are in place to prevent the misuse (e.g., browsing) of PIT by those having 

access? (AR-2) 

Intelliworx individuals are provided access to the Intelliworx system in accordance with 

established account provisioning and management processes that take into account personnel 

screening requirements from the agency. Additionally, Intelliworx provides security awareness 

training to all employees and displays a warning banner each time an individual logs onto the 

system, describing that unauthorized or improper use may result in disciplinary action and 

civil and criminal penalties. 

12. Who will be responsible for protecting the privacy rights of the individuals whose PII is 

collected, maintained, or shared on the system? Have policies and/or procedures been 

established for this responsibility and accountability? (AR-1, AR-2) 

The Intelliworx Privacy Officer is responsible for protecting the privacy rights of the 

individuals whose PIT is within the Intelliworx system. Prior to being granted system access, 

Intelliworx requires that internal users acknowledge the Intelliworx Rules of Behavior, 

including the requirements for protection of information. As part of the Intelliworx customer 

onboarding process, the federal agency customer administrator must acknowledge the 

Intelliworx Rules of Behavior, including the reference to the Privacy Act and requirements for 

protection of information. 

Each agency's Privacy Officer is accountable for the data owned by the agency and for making 

Intelliworx aware of the agency's policies regarding the collection, maintenance, and sharing 

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of PIT. The agencies are responsible for the data that they extract from the system and for 

following their own privacy policies and procedures. 

13. Does Intelliworx provide annual security training include privacy training? Does Intelliworx 

require their contractors that have access to the PIT to take the training? (AR-5) 

Yes. Intelliworx includes privacy training as part of the annual security awareness training 

provided to Intelliworx support personnel. 

Intelliworx does not have contractors supporting the Intelliworx system. 

All contractor employees and subcontractor employees requiring access to FERC information 

and information systems will be required to sign and acknowledge FERC Rules of Behavior 

relating to access to FERC information and information systems, complete FERC Cyber 

Security Awareness Training (CSAT) and annual refresher training as required, complete 

FERC general privacy training and annual refresher training as required, complete any 

additional cyber security or privacy training (e.g., role-based information security, Information 

Technology Security Training requirements), and build an Information Technology Security 

Awareness and Training program. 

14. Who is the privacy officer responsible for assuring safeguards for the PII? (AR-1) 

Laurence Kirby maintains the role of Privacy Officer and is responsible for assuring 

safeguards for the PIT within the Intelliworx system. 

15. What is the magnitude of harm to the individuals if privacy related data is disclosed, 

intentionally or unintentionally? (AR-2) 

Due to the PIT collected, the impact level is moderate. The loss of confidentiality, integrity, or 

availability could be expected to have a serious adverse effect on organizational operations, 

organizational assets, or individuals. 

16. What involvement will contractors have with the design and maintenance of the system? Has 

a contractor confidentiality agreement or a Non-Disclosure Agreement (NDA) been 

developed for contractors who work on the system? (AR-3) 

Intelliworx does not have contractors supporting the Intelliworx system. 

In accordance with the contract between FERC and HRworx, LLC (e.g., Intelliworx), the NDA 

clause in the contract states that "the Contractor [Intelliworx] and all personnel assigned to the 

contract that require access to the FERC network are required not to divulge to any 

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unauthorized person non-public or confidential information obtained from FERC in 

performance of their duties under the contract." Intelliworx will be required to sign a NonDisclosure/Confidentiality Agreement prior to commencement of work. 

17. Is the PH owner advised about what federal agencies or other organizations share or have 

access to the data? (AR-I) 

Not applicable. Data is not shared through the Intelliworx system nor the FDonline module. 

3.6 CONTRACTS, AGREEMENTS, AND OWNERSHIP 

18. NIST SP 800-144 states, "Organizations are ultimately accountable for the security and 

privacy of data held by a cloud provider on their behalf." Is this accountability described in 

contracts with customers? Why or why not? (AR-3) 

No. FERC's accountability for the security and privacy of the PIT held by Intelliworx has not 

been described in the contract. However, FERC does not relinquish responsibility for the 

security and privacy of the data (e.g., PT!), but is accountable for the security and privacy of 

the data collected and stored in the FDonline module. 

19. Do contracts with customers establish who has ownership rights over data including PIT? 

(AR-2, AR-3) 

Yes. Contracts establish that all clients own their PIT data and that Intelliworx owns their 

intellectual property and proprietary documentation, marked as such. 

The contract between FERC and Intelliworx states that "All documentation, electronic data 

and information collected or generated by the Contractor in support of this contract will be 

considered Government property and will be returned to the Government at the end of the 

performance period." 

20. Do contracts with customers require that customers notify Intelliworx if the customer intends 

to populate the service platform with PIT? Why or why not? (AR-3) 

No. The Intelliworx platform is a software application platform that allows customer agencies 

to streamline and automate workflows in any number of mission areas. The platform consists 

of modules. Each module has been analyzed to determine if any elements of that module 

collect and/or store PIT. 

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21. Do Intelliworx contracts with customers establish record retention responsibilities for both 

the customer and Intelliworx? (AR-2, AR-3) 

Yes. Record retention responsibilities are specified by OGE (FDonline) and are included in 

contracts with customers. 

Record retention responsibilities are provided in question 27 below. 

22. Is the degree to which Intelliworx will accept liability for exposure of PII clearly defined in 

agreements with customers? (AR-3) 

In accordance with the contract between FERC and Intelliworx, under the Cyber Security and 

Privacy Incident Reporting and Data Breaches section, Intelliworx will be required to prevent 

and remedy data breaches, provide FERC with all necessary information and cooperation, and 

take all other reasonable and necessary steps and precautions to enable FERC to satisfy its data 

breach reporting duties under applicable law, regulation, or policy in the event, if any, that a 

breach occurs. 

3.7 ACCURACY OF THE PH AND REDRESS 

23. Is the PII collected verified for accuracy? Why or why not? (DI-1) 

There is automated formatting validation within the software. The information is entered 

directly from the employee. In addition, the Ethics Division in the FERC General and 

Administrative Law office verifies stock and retirement funds by researching information 

provided against the prohibited securities list. Additional verification is conducted online to 

identify other stock and retirement funds that are prohibited. 

In addition, FERC's Human Resources department verifies information provided by the 

employee. 

24. Is the PH current? How is this determined? (DI-1) 

The PII is considered to be current as it is entered directly by the individual at the time of 

onboarding or filing. Individuals are responsible for entering accurate PII and maintaining 

currency of the data submitted. 

25. Is there a process for individuals to have inaccurate PII that is maintained by the system 

corrected or amended, as appropriate? 

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Filers within the Intelliworx: FDonline module are required to update their PIT on an annual basis 

when reporting their financial assets. Individual filers can work with the FERC designated ethics 

administrator to request access to their records and reopen a filing if PII needs to be updated for 

the current filing year. 

3.8 MAINTENANCE AND ADMINISTRATIVE CONTROLS 

26. If the system is operated in more than one site, how is consistent use of the PIT maintained in 

all sites? Are the same controls used? 

The Intelliworx system operates within and leverages the AWS GovCloud Infrastructure as a 

Service (IaaS) environment. Intelliworx utilizes the AWS GovCloud IaaS multiple availability 

zone functionality as the alternate processing site for the Intelliworx system. Both primary and 

secondary availability zones are within the Intelliworx system FedRAMP authorization 

boundary where the same controls are implemented and assessed. 

27. What are the retention periods of PIT for this system? Under what guidelines are the retention 

periods determined? Who establishes the retention guidelines? (AR-2, AR-3, DM-2) 

The data retention requirement for the onboarding module is mandated by Office of Personnel 

Management (OPM). OPM requires onboarding data to be purged within ninety (90) days, 

with the exception of user activity/events. The requirements are published in the OPM 

Entrance on Duty (EOD) Requirements Specifications, section 4.4.3 User Actions Audit Trail 

and section 4.5.3 Temporary Account Termination: https://www.opm.gov/policy-dataoversight/data-analysis-documentation/enterprise-human-resources-integration/entrance-onduty/requirements.pdf. 

The following general records schedule is adhered to at FERC as it relates to the below records. 

GENERAL RECORDS SCHEDULE 2.8: Employee Ethics Records 

This schedule covers records documenting the activities of executive branch agency ethics 

program offices. 

Item Record Description Disposition 

Instruction 

Disposition 

Authority 

070 

Confidential financial 

disclosure reports. Executive 

Branch Confidential 

Financial Disclosure Reports 

(OGE Form 450) and 

Confidential Certificates of 

No New Interests 

Reports for 

individuals 

not 

subsequently 

confirmed by 

the U.S. 

Senate. 

Temporary. 

Destroy 1 year 

after nominee 

ceases to be 

under 

consideration for 

the position or 

when no longer 

needed for active 

DAA-GRS2014- 

00050011 

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Legal Citation: 

5 CFR 

2634.604 

investigation, 

whichever is later. 

This disposition 

instruction is 

mandatory; 

deviations are not 

allowed 

071 OGE Form 450 continued 

All other 

reports. 

Legal 

Citation: 5 

CFR 

2634.604 

Temporary. 

Destroy 6 years 

after receipt of the 

OGE Form 450 

by the agency. 

DAA-GRS-2014- 

00050012 

28. What are the procedures for disposition of the PII at the end of the retention period? How 

long will any reports that contain PII be maintained? How is the information disposed (e.g., 

shredding, degaussing, overwriting, etc.)? Who establishes the decommissioning procedures? 

(AR-2, DM-2) 

Once data has reached the six (6) year maximum retention period within FDonline, records are 

moved to a queue where customers (e.g., data owners) must designate whether the record can 

be purged or if the record needs to be held. 

The Intelliworx system does not maintain reports that contain PII as there is no need or 

business process that necessitates this. 

In accordance with the contract between FERC and Intelliworx, when the information is no 

longer required, this information, data, and/or equipment will be returned to Government 

control, destroyed, or held until otherwise directed. Destruction of items will be accomplished 

by following NIST SP 800-88 Revision 1, Guidelines for Media Sanitization. The disposition 

of all data will be at the written direction of the Contracting Officer's Representative (COR). 

This may include documents returned to Government control, destroyed, or held as specified 

until otherwise directed. Items returned to the Government will be hand carried or sent by 

certified mail to the COR. 

29. Is the system using new technologies that contain PII in ways that have not previously 

deployed (e.g., smart cards, caller-ID, biometrics, PIV cards, etc.)? 

No. 

30. How does the use of this technology affect privacy? Does the use of this technology 

introduce compromise that did not exist prior to the deployment of this technology? 

Not applicable. 

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31. Is access to the PII being monitored, tracked, or recorded? (AR-4) 

All login activities to the Intelliworx system are logged. Additionally, infrastructure logs 

related to privileged functions, administrator activity, and data changes and deletions are 

automatically input into the Splunk Security Information and Event Management (STEM) tool 

for automated monitoring and analysis to detect suspicious activity and indicators of 

inappropriate or unusual activity. Application security logs are available for review by 

Intelliworx Security Officers via SQL from the database. 

32. If the system is in the process of being modified and a SORN exists, will the SORN require 

amendment or revision? (TR-2) 

The system is not being modified The applicable system of records notice for this system is 

OGE/GOVT-2 Executive Branch Confidential Financial Disclosure Reports Privacy Act 

SORN. 

3.9 BUSINESS PROCESSES AND TECHNOLOGY 

33. Have the talking points found herein resulted in circumstances that requires changes to 

business processes? 

No. 

34. Does the outcome of these talking points require that technology or operational changes be 

made to the system? 

No. 

3.10 PRIVACY POLICY 

35. Is there a system privacy policy and is it provided to all individuals whose PIT you collect, 

maintain or store? (IP-1, TR-1, TR-3) 

Intelliworx has not established a privacy policy for the Intelliworx system. 

36. Is the privacy policy publicly viewable? If yes, provide the URL. (TR-1, TR-3) 

Intelliworx has not established a privacy policy for the Intelliworx system. 

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'acy Oft, 

Laurence Kirby 

intelliworx Cloud Privacy Impact Assessment 

Version 9.1 November —, 2019 

3.11 SIGNATURES 

The information found herein has been documented by Secure/rand has been reviewed by the 

IntelliworA, Chief Privacy Officer for accuracy. 

CHRISTINA Di44411Y IV CHRISTINA 

HANDLEY HANDLEY 0.0e: 2019,1 2 n4 11:0405 -05•00. _ 

FERC Senior Agency Official for Privacy Signature 

Name Christina Ilandky Date 11/22/2019 

Date 1112212019 

0 

Date 11/22/2019 

4 ACRONYMS 

The master list of FecIRAMP acronym and glossary definitions fbr all FedRAMP templates is 

available on the Fek1RAMP website Documents page under Program Overview Documents. 

Please send suggestions about corrections, additions, or deletions to irA,!citft.-driuripziiv, 

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