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Federal Trade Commission 

Privacy Impact Assessment

LinkedIn

Updated May 2019 
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SECTION 1.0 – SPECIFIC PURPOSE OF THE FTC’S USE OF APPLICATION

1.1 – What is the specific purpose of the agency’s use of the application, and how does

that use fit with the agency’s broader mission?

LinkedIn is a popular professional networking website. The Federal Trade Commission maintains the 

official FTC LinkedIn company page using an FTC-approved LinkedIn account administered by 

authorized FTC staff members. The official FTC LinkedIn page permits the Agency to reach users 

who may not be regular visitors to FTC websites. It includes links to FTC job postings on government 

websites and relevant FTC news and resources.

 

1.2 – Is the agency’s use of the application consistent with all applicable laws,

regulations, and polices?

Yes. 

Former President Obama’s January 21, 2009 memorandum on Transparency and Open 

Government and the OMB Director’s December 8, 2009 Open Government Directive call on 

federal departments and agencies to harness new technologies to engage with the public. Using 

tools like LinkedIn helps the FTC to meet the federal guidance outlined in the directive and 

memorandum including the goals of transparency, participation, and collaboration.

With respect to the information that the FTC will disseminate through its LinkedIn account, the 

FTC Act authorizes the FTC to prevent unfair and deceptive acts and practices in interstate 

commerce and, in furtherance of this mission, to gather, compile, and make information available 

in the public interest. See 15 U.S.C. 45, 46(a), (f).

In accordance with federal guidance, if the FTC links to LinkedIn from an FTC website, the FTC 

will inform consumers (i.e. via an exit script) that they are leaving the FTC site and that the 

Commission’s privacy policy no longer applies. The FTC also posts a privacy notice on LinkedIn, 

as feasible. 

SECTION 2.0 – IS THERE ANY PII THAT IS LIKELY TO BECOME AVAILABLE TO

THE AGENCY THROUGH THE USE OF THE APPLICATION?

2.1 – What PII will be made available to the FTC?

Users may choose to provide information about themselves on LinkedIn, such as their name, 

username, contact information, current and previous job experience, education, interests, links to other 

social media accounts, etc. Users can select additional settings to make their LinkedIn profiles 

partially or completely private: depending on the users’ privacy settings, some or all of the 

information they share on LinkedIn may be available to the FTC. While the FTC may post links to job 

openings at the Agency, the Commission will not collect resumes and applications through LinkedIn. 

The FTC may, read, review, or rely upon information that LinkedIn users make available to the 

public or to the FTC as authorized or required by law. The privacy impact of the FTC’s use of 

this platform is low, as the FTC does not routinely use LinkedIn to solicit, collect, maintain, or 
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disseminate PII from members of the public. In specific circumstances, the FTC may collect 

limited information (e.g. usernames or handles) about members of the public (e.g., if messages 

or posts directed to the FTC or its employees on LinkedIn are deemed as threatening or violent, 

or where the content may reveal some other potential law enforcement violation). The FTC may 

also occasionally produce reports or summaries of its use of this social media platform that 

include PII posted publicly (i.e., usernames): for instance, it may do so if needed to comply with 

social media records retention guidelines from the National Archives and Records 

Administration (NARA). In such instances, the collection of PII in these summaries will be 

reduced as much as is feasible. 

LinkedIn provides aggregate analytic data to page administrators, called Insights, including date 

of visit, impressions, clicks, interactions, and new followers acquired. Insights does not reveal 

the individual identities or profiles of visitors to the page. Additional analytics may include reach 

(how many times an update is seen), and engagement (clicks, comments, and “likes”). Aggregate

analytic data are used to receive feedback and potentially improve consumer experience when 

visiting the site. Access to Insights is limited to authorized administrators of the official FTC 

page.

2.2 – What are the sources of PII?

The sources of PII made available to the FTC via LinkedIn are LinkedIn users who make PII 

available to the public and/or to the FTC on the platform. See also 2.1 above. 

2.3 – Do the FTC’s activities trigger the Paperwork Reduction Act (PRA) and, if so, how

will the agency comply with the statute?

Per the OMB memorandum, Social Media, Web-Based Interactive Technologies, and the 

Paperwork Reduction Act, the FTC’s use of LinkedIn as outlined in Section 1.1 is not a webbased interactive technology involving information collection that would trigger the PRA.

SECTION 3.0 THE FTC’S INTENDED OR EXPECTED USE OF PII

Section 3.1 – Generally, how will the agency use the PII described in Section 2.0?

Generally, the purpose of the FTC’s company page and administrative account for that page is to 

disseminate information to other registered and non-registered LinkedIn users or visitors. See also 

2.1 above. 

Section 3.2 – Provide specific examples of the types of uses to which the PII may be subject.

For example, the FTC uses LinkedIn to post information about available jobs at the agency and to 

disseminate information about scams. See also 2.1 above. 
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SECTION 4.0 SHARING OR DISCLOSING OF PII

Section 4.1 – With what entities or persons inside or outside the agency will the PII be

shared, and for what purposes will the PII be disclosed?

PII posted on the FTC’s LinkedIn page is available publicly. See also 2.1 above, since in limited 

instances, PII posted on LinkedIn may need to be specifically provided to others at the agency, to

other law enforcement agencies, or to NARA.

Section 4.2 – What safeguards are in place to prevent expansion of use beyond those

authorized under law and described in this PIA?

Only authorized FTC staff members have administrative access to manage the FTC’s LinkedIn 

accounts. Each staff member responsible for managing a social media account must sign and 

comply with the Commission’s internal Rules of Behavior, prior to beginning account 

administration. 

The FTC’s LinkedIn Company Page is registered using an official FTC email account. 

Administrators are not permitted to use personal accounts to manage the FTC page. 

Furthermore, FTC administrators are directed to use FTC-authorized devices to manage their 

accounts.

The FTC also provides ethical guidance to its staff on best practices when using LinkedIn, 

personally and professionally, to ensure against the inadvertent collection or disclosure of 

nonpublic information, including personal information about themselves or other individuals.

SECTION 5.0 - MAINTENANCE AND RETENTION OF PII

Section 5.1 – How will the FTC maintain the PII, and for how long?

In general, this does not apply, as the FTC does not routinely use LinkedIn to solicit, collect, 

maintain, or disseminate PII from members of the public. In the limited instances in which the 

FTC does so (see 2.1 above), any PII collected will be securely stored in accordance with FTC 

policy. See, for instance, the Data Center Privacy Impact Assessment. 

Section 5.2 – Was the retention period established to minimize privacy risk?

In general, this does not apply, as the FTC does not routinely use LinkedIn to solicit, collect, 

maintain, or disseminate PII from members of the public. In the limited instances in which the 

FTC does so (see 2.1 above), any PII collected will be retained and disposed of in accordance with 

NARA’s General Records Schedule (GRS) 6.4, item 020, Public Comments and Communications 

Not Requiring Formal Action, or other records schedules that may apply. 
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SECTION 6.0 – HOW THE AGENCY WILL SECURE PII

Section 6.1 – Will the FTC’s privacy and security officials coordinate to develop methods of

securing PII?

In general, this does not apply, as the FTC does not routinely use LinkedIn to solicit, collect, 

maintain, or disseminate PII from members of the public. Regarding the limited instances in 

which the FTC does so (see 2.1 above), privacy and security officials routinely coordinate to 

develop methods to secure all agency PII. 

SECTION 7.0 – IDENTIFICATION AND MITIGATION OF OTHER PRIVACY RISKS

Section 7.1 – What other privacy risks exist, and how will the agency mitigate those risks?

The privacy impact of the FTC’s use of this platform is low, as the FTC does not routinely use 

LinkedIn to solicit, collect, maintain, or disseminate PII from members of the public.

LinkedIn, itself, is a third-party service that may use cookies or other tracking technology. In an 

effort to help consumers understand how their information is used by LinkedIn, the FTC posts a 

privacy notice on its LinkedIn page indicating that LinkedIn’s policy rather than FTC policy 

applies on the site. Furthermore, if the FTC links to LinkedIn from an FTC website, the FTC will 

inform consumers (i.e., via an exit script) that they are leaving the FTC site and that the 

Commission’s privacy policy no longer applies. The FTC encourages members of the public to 

read LinkedIn’s privacy policy to understand what information LinkedIn may be collecting from 

them, and to read the federal-compatible terms of service (TOS) with LinkedIn.

SECTION 8.0 – CREATION OR MODIFICATION OF A SYSTEM OF RECORDS

Section 8.1 – Will the FTC’s activities create or modify a “system of records” under the

Privacy Act of 1974?

No. The FTC does not collect PII from LinkedIn in a manner that would require the FTC to create 

or modify a system of records under the Privacy Act of 1974.