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Federal Trade Commission

Privacy Impact Assessment

Epiq Class Action ClaimsMatrix and

Online Claim Submission Website

 (ECA)

October 2016 
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Table of Contents

1 System Overview .................................................................................................................... 1

2 Data Type, Sources, and Use .................................................................................................. 2

3 Data Access and Sharing ........................................................................................................ 3

4 Notice and Consent ................................................................................................................. 5

5 Data Accuracy and Security.................................................................................................... 7

6 Data Retention and Disposal ................................................................................................... 9

7 Website Privacy Evaluation .................................................................................................... 9

8 Privacy Risks and Evaluation ............................................................................................... 10

9 Approval and Signature Page ................................................................................................ 13
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1 System Overview

1.1 Describe the project/system and its purpose. 

The Federal Trade Commission’s (FTC) Bureau of Consumer Protection (BCP) brings law 

enforcement actions that can result in the recovery of redress money from defendants that is to be 

returned to injured consumers or businesses. The FTC distributes money pursuant to a distribution 

plan that is either approved by a court or an administrative law judge or delegated to the FTC’s 

discretion. The FTC Redress Administration Office (RAO) is responsible for administering and 

coordinating redress activities, and Epiq Class Action (ECA), an FTC claims administration 

contractor, supports RAO’s activities. This PIA explains what personally identifiable information 

(PII) RAO and ECA collect throughout the redress administration process, who is allowed to use this 

information and for what purposes, and what steps are taken to identify, secure, and reduce any 

privacy risks to that information. 

ECA’s ClaimsMatrix system stores consumer and business data provided by RAO or obtained 

directly from individuals who submit redress claims in a proprietary database. The ECA 

ClaimsMatrix system also has a public interface that permits individuals and businesses to complete 

and submit an electronic claim form via a website. ECA uses the data from the system to fulfill its 

role as the redress claims administrator, which includes the following duties: (i) to intake and process 

claims filed; (ii) to answer questions from FTC and other authorized parties; (iii) to answer questions 

from claimants and potential claimants as to eligibility and status of materials filed; (iv) to route 

claims to the claims administrator; and (v) to issue and track payments to authorized claimants. 

ECA maintains physical systems in their secure on-site location in Kansas City, KS, and their secure 

off-site location in Las Vegas, NV. 

1.2 What specific legal authority allows for the collection, maintenance, or 

dissemination of information for this project/system? 

The FTC collects this information in order to provide redress to injured consumers as part of its law 

enforcement activities pursuant to the FTC Act, 15 U.S.C. §§ 41-58, and other applicable statutes. 
2 Data Type, Sources, and Use 

2.1 Specify in the table below what types of personally identifiable information (PII) 1 

may be collected or maintained in the system/project. Check all that apply. 

PII Elements: Tllis is not i11te11ded to be a11 exllaustive list. SpecifY otller categories of PII as 

needed. 

[8J Full Name D Biometric Identifiers (e.g., D User ID 

D Date ofBiiih finge1print, voiceprrnt) D Intemet Cookie Contailling 

[8J Home Address D Audio Recordrngs PII 

[8J Phone Number(s) D Photographic Identifiers D Employment Status, 

D Place ofBllih (e.g., image, x-ray, video) History, or Information 

0 Age D Certificates (e.g., bllih, D Employee Identification 

D Race/ethnicity death, man-iage, etc.) Number (EIN) 

D Alias D Legal Documents, Records, D Salary 

O sex Notes (e.g., divorce decree, D Military Status/Records/ ID 

[8J Email Address criminal records, etc.) Number 

D Work Address D Vehicle Identifiers (e.g., [8J IP/MAC Address 

D Taxpayer ID license plates) D Investigation Repo1t or 

D Credit Card Number D Frnancial Infonnation (e.g., Database 

D Facsimile Number account number, PINs, D Driver's License/State ID 

D Medical Information passwords, credit report, Number (or foreign countiy 

D Education Records etc.) equivalent) 

D Social Security Number D Geolocation Information [8J Other (Please Specify): 

D Mother's Maiden Name D Passpo1t Number Business name, unique 

claimant ID, customer 

account number 

2.2 What types of information other than PII will be collected, disseminated, or 

maintained by the project/system? Provide a general description below and be sure 

to include all data elements. 

The claimant info1mation that is collected, used, disseminated, or maintained either within RAO or 

within ECA's ClaimsMat:rix prop1ietaiy database varies depending upon the redress matter. In 

routine redress matters, the data elements selected in 2.1 are collected and maintained. Additional 

non-PIT data elements include: business name (if needed), transaction data, transaction dates, product 

type, company selling product, loss amount, and notes of claimant contact with ECA, including any 

subsequent change requests, updates, con ections, etc. These notes may potentially contain PIT; for 

example, a customer may call to update their ClllTent address or phone number, etc. 

In instances where a consumer calls ECA regarding a redress matter, the Epiq Interactive Voice 

Response and Contact Center systems record the number from which the individual calls and the 

date/time/length of call. In addition, all consumer calls to live agents are recorded, including any 

I Per OMB M-07-16, personally identifiable info1mation (PII) refers to rnfo1mation which can be used to distrnguish 

or trace an rndividual 's identity, such as their name, social secw-ity number, biometi·ic records, etc. alone, or when 

combined with other personal or identifying rnfo1mation which is linked or linkable to a specific individual, such as 

date or place ofbll-th, mother's maiden name, etc. 

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escalations that may take place. Details of calls may be summarized in the Epiq claims management 

system by claims processing staff. 

2.3 What is the purpose for collection of the information listed above? 

Claimant info1mation is collected, used, disseminated, or maintained by RAO staff and ECA to 

identify potential claimants, to validate claimants and their claims, and to distribute redress payments 

to appropriate claimants. 

ECA's system is used to maintain claimant info1mation for verification and record-keeping purposes 

relating to redress in FTC matters, as well as to calculate and distribute redress payments. These 

activities may include printing and mailing claim fo1ms, processing claims and coITections submitted 

by claimants, issuing checks or other fo1ms of payment, and providing consumer education. 

Data collected by ECA in a specific FTC matter may also be used by the FTC and ECA to identify 

potentially fraudulent claims submitted in other FTC redress matters. For each redress matter 

managed by ECA on behalf of the FTC, ECA sends a complete list of claims filed to the FTC prior to 

the scheduled distr·ibution. In an effo1t to identify potentially fraudulent claims, the FTC may analyze 

that information, refer back to data received in all redress matters past and present, and provide 

inf01mation regarding potentially fraudulent claims back to ECA. 

2.4 What are the sources of the information in the system/project? How is the 

information collected? 

Source of Data Tvoe of Data Provided & How It Is Collected 

Individual Members of Initial source data is found in defendants' files and in consumer 

the Public complaints submitted to the FTC and n·ansf eITed to ECA; this 

includes the data elements listed in 2.1. Claimants also provide data 

directly to ECA via phone or mail as prut of the redress 

administr·ation process. 

Third pruty Mailing address updates and coITections may be provided by thirdpruty data sources such as the United States Postal Se1vice (USPS) 

and Lexis/Nexis. 

3 Data Access and Sharing 

3.1 In the table below, specify the systems/applications and groups (both FTC and nonFTC) that will have access to or share data in the system/project. 

FTC staff do not have direct access to ECA's databases; ECA shru·es claimant info1mation and reports 

with the FTC via secure encrypted mail. RAO staff, managers, and supe1visors ofECA staff who 

have access to claimant info1mation have completed FTC-approved background checks and 

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clearance. In addition, all ECA employees who have access to claimant information receive 

background checks conducted by ECA. 

Data Will Be Accessed 

Bv and/or Provided To: 

How and W/ty the Data Will Be Accessed/Sllared 

FTC RAO Staff & ECA Authorized ECA IT professionals have access to the data for the 

Staff purpose of impo1ting, validating, updating, and storing claimant 

data. ECA claims processors have access to data for the purpose of 

validating eligibility, communicating with claimants, and updating 

their contact inf 01mation. Both FTC and ECA management staff 

need to access the data for reporting purposes, as well as to 

supe1vise technology and processor resources, and ensuring 

accuracy and adherence to data handling standards. 

Claimants No external entities other than claimants will have direct access to 

claimant info1mation. Individual claimants may submit information 

directly on the claims website; once submitted, however, claimants 

cannot view or change their information online. 

Other External Parties The FTC may shai·e claimant info1mation with law enforcement and 

other government agencies, comts, and defendants, or as othe1wise 

authorized by law. RAO and ECA securely download and transmit 

required data in response to auth01ized requests. 

3.2 Do contractors and/or thir d party service providers have access to data in the 

project/system? If yes, explain what privacy requirements are in place to ensure 

that data is properly protected. 

ECA employs fo1mal, documented procedures to facilitate secmity awai·eness training, including a 

specific course related to PIT. This training is managed and implemented by ECA's Security Team 

and Human Resources. Additionally, all users involved with this and other Federal Info1mation 

Secmity Management Act (FISMA) moderate client data ai·e required to use ECA's Electronic 

Governance Risk and Compliance ( eGRC) po1tal to read and acknowledge all relevant policies and 

control standards. 

3.3 If you answered "yes" to 3.2, describe the privacy incident response plan maintained 

by the contr actor's organization or thir d party service provider. 

ECA has developed a comprehensive Incident Response Plan ("IRP") to help suppo1t continuity of 

critical ECA business operations in the event of an incident. The plan contains a framework for 

responding to info1mation secmity incidents, which include but are not limited to system intrnsions, 

system misuse, or any situation where confidentiality of sensitive data, integrity of data, or 

availability of business c1itical systems may have been compromised. The plima1y goal of the IRP is 

to restore no1mal se1vice operation as quickly as possible and to minimize the adverse impact on 

business operations and FTC data. In the event an incident is identified either by ECA's IT staff or 

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in-place utilities, ECA has a response team in place to quickly respond and rectify the situation. An 

added layer of security is provided by Mandiant Managed Incident Response and Managed Defense 

solutions to address Advanced Persistent Threats (e.g., state sponsored hacking). Mandiant uses a 

multi-layered approach that includes individual agents installed on all endpoints in the environment, 

network listeners staged at all egress points in the environment, and centralized appliances to 

coordinate the service. Numerous layers of security controls are in place. Breach notification 

timeframe is governed by contractual and legal requirements; Epiq must immediately report to the 

FTC all breaches of FTC materials and information. Mandiant also provides support to ECA in the 

event of a security breach, providing first responders, forensic investigators and Incident managers. 

 Not Applicable. 

4 Notice and Consent

4.1 How are individuals provided with notice prior to the collection of their PII? If 

notice is not provided, explain why. 

For redress cases that require ECA to collect claimant information via a claim form, a Privacy Act 

statement is included on both paper and web-based forms, which are compliant with the Paperwork 

Reduction Act (PRA) and contain an Office of Management and Budget (OMB) document control 

number. The Privacy Act statement explains the authority, purpose, and routine uses of the 

information to be collected, whether it is voluntary or mandatory for the claimant to provide the 

information, and any consequences if the information is not collected (e.g., the FTC may be unable to 

pay the individual his or her redress claim). 

Those claimants who submit consumer complaints to the FTC via the FTC online complaint form – as 

described in the Sentinel Network Services PIA – or via the FTC telephone complaint system (1-877-

FTC-HELP), receive a similar Privacy Act statement at the time they submit their complaint. Their 

relevant consumer complaint information is then forwarded to ECA for processing. All claimants 

who receive a Privacy Act statement also are provided a physical mailing address and telephone 

number to update and provide additional information about themselves, their eligibility to file a claim, 

and their claimant status. 

In some cases, the FTC may receive claimant information from a defendant’s customer list, and 

redress may be provided without the claimant having to take any action. In those instances, claimants 

are not provided with a Privacy Act statement; such claimants can learn about the FTC’s collection, 

use, and disclosure of their information through the FTC’s privacy policy, as noted below. In 

addition, all redress checks include a mailing address and/or telephone number for consumers to 

contact ECA should they have any questions or concerns about their information. 

 Notice is provided via (check all that apply): 

Privacy Act Statement ( Written Oral)

FTC Website Privacy Policy

Privacy Notice (e.g., on Social Media platforms) 

 Login banner 

Other (explain):________________________________________________________ 

Notice is not provided (explain): 
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4.2 Do individuals have the opportunity to decline to provide information or to consent 

to particular uses of their information (other than required or authorized uses)? 

When the FTC uses information provided by a defendant to mail a check to an injured consumer, the 

individual does not have the opportunity to decline the FTC’s use of their information. In those cases, 

redress distributions are mailed directly to the consumer – using customer information provided by 

the defendant – without the consumer having to take any action. This use of personal information 

poses minimal risks to privacy and allows the FTC to provide refunds efficiently and effectively to as

many injured consumers as possible. 

In cases where there is a claims process, individuals can decline to provide their information. 

Consumers who choose to submit a claim do not have the right to limit their consent to particular uses 

of their information. They consent to their information being used as described in the applicable 

SORN (see Section 8.3) and Privacy Act statement. The consumer exercises this consent by choosing 

to complete, sign, and submit a claim form. 

 

4.3 Are there procedures in place to allow individuals access to their personally 

identifiable information? Explain. 

Claimants can submit their claim through the ECA web portal, but they cannot access, view, or edit 

their claim online once it has been submitted. Instead, ECA initially enters the claimant data 

verbatim from hard copy and online forms submitted by the claimant; alternatively, ECA may create 

a claim record from information submitted to them by the RAO. If a claimant’s information is 

incomplete, ECA mails a letter to the claimant informing the individual that their claim is incomplete 

due to missing or incorrect information; the claimant is sent a new blank copy of the claim form to 

update their information and complete the claims process. 

Claimants can access their claim record by contacting ECA via telephone or hardcopy mail. Before 

making requested changes to a claimant’s information, ECA will confirm the claimant’s identity by 

asking a series of questions, including the claim record tracking number, name, mailing address on 

file, or phone number, and instructing the claimant to forward their change request in writing along 

with supporting documentation if needed. ECA accepts written documentation via fax, mail, or 

email. Finally, claimants can obtain access to their own information through a Privacy Act request

filed with the FTC’s Freedom of Information Act (FOIA) Office. 

4.4 Are there procedures in place to allow individuals the ability to correct inaccurate 

or erroneous information? What is the process for receiving and responding to 

complaints, concerns, or questions from individuals? Explain. 

As stated above in Section 4.3, claimants can request corrections to any inaccurate information by 

contacting ECA, validating their identity, and forwarding the change request in writing along with 

any supporting documentation as necessary. Claimants also can file a Privacy Act request through 
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the FTC’s FOIA Office to obtain access to their own information. The FTC FOIA Office will work 

with the claimant to respond to any complaints, concerns, or questions. 

5 Data Accuracy and Security

5.1 Are there procedures in place to ensure that the information maintained is accurate, 

complete, and up-to-date? 

Various steps are taken to validate the accuracy and timeliness of collected data based on its original 

source. For example, prior to the contractor mailing a claim form, a redress check, or consumer 

education material, claimant addresses are standardized and cross-checked against data sources, such 

as the U.S. Postal Service (USPS) National Change of Address Database and USPS records regarding 

street names and address ranges. All resulting additions, deletions, and address changes to the data 

set are approved by the RAO and reconciled against the original source data. 

In many instances, claimant data obtained from defendants’ files can be used to mail redress checks 

directly to injured consumers and businesses. In other cases, individuals are contacted to provide or 

verify their information. For example, claim forms may be mailed to a known set of claimants 

requesting that they validate their address, loss amount, and entitlement to redress. In other cases, 

claim forms will be made available to previously unknown claimants via case-specific redress 

notification and outreach. Claimants provide claim information, including their address, injury 

amount, and entitlement to redress, under penalty of perjury. 

The redress contractor reviews claimant names, check distributions, and claim form responses to 

confirm that the loss amounts claimed are consistent with the established case-specific claim 

parameters. Outreach material, redress checks, and claim forms always include an FTC website 

address for additional information, and a telephone number and mailing address for consumers to 

contact the redress contractor to have their questions answered and/or to update their information. 

5.2 Are there administrative procedures and technical safeguards in place to protect the 

data in the system/project? What controls are in place to ensure proper use of the 

data? Please specify.

Data in the system will be accessed only by authorized RAO and ECA staff to review and determine 

claimant eligibility for redress. The data will be accessed via secure login, and access will only be 

made available to authorized staff on a need-to-know basis. Data usage is in accordance with the uses 

described in the executed contract between the FTC and ECA to support the FTC’s redress activities. 

Prior to maintaining and disseminating claimant data, RAO staff removes all unnecessary information 

from the claimant data file and encrypts all data transmitted to ECA via email. ECA encrypts 

claimant data at rest. In addition, the FTC instructs ECA to collect the least amount of claimant 

information necessary.

If personal information is collected through a web site, page, or online form accessible through the 

Internet, appropriate Transport Layer Security (TLS) encryption algorithm is used to protect all 

external communications. 
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ECA employs a significant number of layered technical controls to help prevent the misuse or 

improper disclosure or access to consumer data. These controls include, but are not limited to the 

following: 

• ECA websites are hosted within a FISMA accredited boundary; 

• ECA websites are maintained on a separate network segment from the consumers’ specific 

claims data;

• When appropriate, claimants are provided a unique claim identifier and PIN to verify that 

they are a member of the redress pool; 

• Consumer data is encrypted when transmitting between the web server and client based 

computing device; 

• Administrative controls include lockout after a number of failed attempts, server event 

logging, and standard web logging, including collection of IP addresses for security and 

performance troubleshooting. 

The ECA ClaimsMatrix system uses a defense-in-depth strategy to protect system resources against 

attacks by utilizing security technologies and services that maintain the Availability, Integrity, 

Authentication, Confidentiality, and Non-Repudiation requirements outlined in National Institute of 

Standards and Technology (NIST) Special Publication 800-53. 

Audit trails maintain a record of authorized and unauthorized system events both by system and 

application processes and by user activity of systems and applications. Audit logging is continuous, 

and logs are archived to provide access for review. In conjunction with other processes and controls, 

such as incident response capabilities and user identification and authentication, audit trails can assist 

in detecting security violations, network performance problems, and flaws in applications. Audit 

trails can provide a means to help accomplish several security-related objectives, including individual 

accountability, reconstruction of events, intrusion detection, and problem analysis. The ECA systems 

are periodically reviewed by FTC staff as well. 

 

5.3 Has the system/project undergone the appropriate security risk assessment and 

received authority to operate?

Yes, ECA has undergone the appropriate security risk assessment and received authority to operate. 

ECA employs both information security and physical security for the privacy-related information it 

collects. ECA is categorized as a moderate system using Federal Information Processing Standard 

(FIPS) 199, Standards for Security Categorization for Federal Information and Information Systems. 

The claims administration contractor has received an Authorization to Operate (ATO), which was 

issued in accordance with FISMA following guidance provided by NIST. Contractor systems are 

routinely reviewed by the FTC to ensure compliance with FISMA. 
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5.4 Is PII used in the course of system testing, training, or research? If so, what steps 

are taken to minimize and protect PII during this process? 

Development and User Acceptance Testing (UAT) environments are physically and logically separate 

from that of production, and UAT mirrors production as closely as possible at both the hardware and 

software levels. This structure allows performance testing and valid user acceptance testing to be 

performed without the risk of disruption to production or client environments. FTC data is not used 

in lower environments except in cases of a data specific issue. In such cases, FTC approval is be 

obtained prior to use, to minimize and protect PII during such use, and data would be deleted 

immediately upon remediation of the data specific issue. 

 Not Applicable 

6 Data Retention and Disposal

6.1 Specify the period of time that data is retained in the system/project. What are the 

specific procedures for disposing of the data at the end of the retention period? 

All data is stored within ECA’s secure, layered environment; in order to mitigate potential risks, all 

communication in and out of ECA’s systems is encrypted and signed using Federal Information 

Processing Standard (FIPS) 140-2 approved libraries. Full backups of all production data are 

routinely conducted. Encrypted backups are replicated to an off-site datacenter through a dedicated, 

secure connection, for business continuity purposes. 

All records and documentation, including any notes, recordings, and audit logs pertaining to FTC 

claim matters, will be maintained by ECA for the duration of the claims process in accordance with 

General Records Schedules 3.1 and 4.2. At the end of the claim closure period, ECA shall transfer a 

trustworthy electronic copy of the records and documentation to RAO. After review and approval of 

RAO, ECA shall then destroy all records and documentation in its possession associated with the 

matter, in accordance with NARA, OMB, and NIST regulations and guidelines. RAO maintains 

records in accordance with the FTC’s NARA-approved records retention schedule, N1-122-09-1. 

7 Website Privacy Evaluation

7.1 Does the project/system employ the use of a website? If so, describe any tracking 

technology used by the website and whether the technology is persistent or 

temporary (e.g., session cookie, persistent cookie, web beacon). Describe the 

purpose of using such tracking technology. 

 Not Applicable 

ECA does not host any permanent websites on behalf of the FTC. However, ECA may host a 

temporary website in a particular redress matter when the FTC determines it is appropriate and 

necessary to support online electronic claim submission. Persistent tracking technologies will not be 

used on these temporary, matter-specific redress sites. Temporary session cookies will be used for 

user session verification and will be terminated at the end of the visit. These cookies do not store any 
PII, and the info1mation they obtain cannot be directly conelated to an individual claimant. See the 

FTC's Cookie Page for more info1mation. ECA staff reviews each tempora1y website for compliance 

with the privacy requirements. 

In compliance with the Privacy Act of 1974, the E-Government Act of2002, guidance issued by 

OMB, and the FTC's own Privacy Policy, the FTC mandates that ECA limit the collection of 

info1mation from website visitors to the info1mation necessa1y to assess and improve user experience, 

respond to consumer concerns, and administer redress. 

To the extent that ECA's web hosting provider collects standard web log data, such as IP address, 

date and time of visit, and other required information, for cyber security and management rep011ing, 

such collection is needed to ensure compliance with FISMA, 44 U.S.C. § 3541 et seq. 

8 Privacy Risks and Evaluation 

8.1 Considering the type of information collected and sources of collection, what 

privacy risks were identified and how were these risks mitigated? 

Risk Mitif!a.tion Stra.te!!V 

Personally identifiable 

info1mation is 

maintained by both RAO 

andECA. 

In order to minimize privacy risks, in the vast majority of redress 

matters, the info1mation stored by RAO and ECA is limited to name, 

contact info1mation, and claim information, possibly coupled with 

validation under penalty of pe1jmy . Comprehensive data security 

plans have been implemented to protect all data, including frequent, 

automated scans of info1mation systems as well as policies and 

procedures to limit access to sensitive data and to ensure compliance 

with data privacy standards. 

To ensure the secmity of the data, the systems use TLS enc1yption 

between the server and each ECA user. Each FTC or ECA user 

must use a secure password to gain access to the system as a whole, 

and then only users authorized to work on a pa1ticular redress matter 

have access to that matter's data. 

Individuals are provided 

with access to their own 

info1mation. 

Various steps are taken to ensure that individuals only are able to 

access their own info1mation. Individuals can only submit their 

info1mation through the ECA-hosted website for a specific redress 

matter. They cannot access or alter previously entered inf 01mation. 

Alternatively, if an individual seeks access to their info1mation 

through the FTC's FOIA office, the iisk of unauthorized disclosure 

is mitigated by procedures for asking the individual to ve1ify his or 

her identity in writing, or, if the individual has authorized a 

representative to have access, to provide proof of such authorization 

in w1iting. 

Individuals may provide 

unnecessary PII or data 

When submitting a claim fo1m, a claimant may inadve11ently 

provide PII, including sensitive PII or health inf 01mation, that is not 

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that is inaccurate or 

incomplete. 

be required or requested for claims processing or verification. To 

mitigate this, claims forms do not include open-text comments 

fields. Furthermore, fields are limited to the minimum information 

necessary to process a claim to reduce the risks of a user 

accidentally providing unnecessary information. SSNs are not 

collected on claim forms.

As to the risk that data provided might not be accurate, complete, or 

timely, it is important to note that individuals voluntarily provide 

claim information on the website so that they may receive redress. 

The process of filing claims is made as easy as possible for 

individuals. Claims have the ability to validate and verify claimant 

information and to update any inaccurate information. To the extent 

claimant information is provided via defendant’s records, ECA and 

the FTC make every effort to confirm the information received is 

accurate, such as cross-checking with U.S. Postal Service address 

lists.

 

8.2 Does the project/system employ the use of automated privacy controls or enhanced 

capabilities designed to support privacy? Explain. 

ECA’s architecture prevents direct access to the data sets. ECA employees wishing to access the 

systems must use two-factor authentication. Technical management communications for all systems 

within the Client Data Environment (CDE) are firewalled to a specified Virtual Local Area Network 

(VLAN). Individual drives on the Storage Area Network (SAN) are self-encrypting, ensuring 

physical possession of the hard drive will not endanger customer data.

All remote access occur over Virtual Private Network (VPN) connections, require use of two-factor 

authentication with a physical or soft token for management approved users, and is authenticated 

over a secure VPN. 

ECA’s login policy is configured to enforce sessions and workstations to automatically lock after a 

period of inactivity. The user's password is required to unlock the workstation and two-factor 

authentication is required to reconnect to the secure environment. System lockout occurs after five

invalid login attempts. 

Additionally, PII can be masked to end users depending on the level of classification. 

 

8.3 Has a Privacy Act System of Records Notice (SORN) been published in the Federal 

Register for this system/project? If so, list the applicable SORN(s). 

Consumers are assigned a unique ID for identification, tracking, and reporting purposes. As such, the 

redress contractor databases are covered by existing Privacy Act SORNs for nonpublic FTC program 

records, FTC-I-1, and for computer system user and identification access records, FTC-VII-3. 
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8.4 How does the project/system ensure that the information is collected, used, stored, 

or disseminated in accordance with stated practices in this PIA? 

ECA has account management policies and controls in place to manage ClaimsMatrix system 

accounts, including the establishment, activation, modification, and termination of system accounts. 

ECA account management activities include:

• Identification of account types;

• Conditions for group membership; 

• Identification of authorized users specifying access privileges;

• Requirement of appropriate approvals for requests to establish accounts; 

• Establishing, activating, modifying, disabling, and removing accounts; 

• Specifically authorizing and monitoring use of the guest/anonymous and temporary 

accounts;

• Notifying account managers when temporary accounts are no longer required and when 

users are terminated, transferred, or access requirements change;

• Deactivating temporary accounts and accounts of terminated users as required; 

• Granting access to the system based on valid access authorization; intended system usage, 

and other attributes as required by the organization; 

• Reviewing accounts quarterly, at a minimum.

The collection, use, and disclosure of information from the ECA claims administration system has been 

reviewed to ensure consistency with the FTC’s Privacy Policy. 
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9 Approval and Signature Page 

Prepared By:

__________________________________ Date: ______________ 

Nicole V. Fleming 

Bureau of Consumer Protection (BCP)

Reviewed By:

__________________________________ Date: ______________ 

Katherine Race Brin

Chief Privacy Officer (CPO)

__________________________________ Date: ______________ 

Alexander C. Tang, Attorney 

Office of the General Counsel (OGC)

__________________________________ Date: ______________ 

Jeffrey M. Smith

Chief Information Security Officer (CISO)

__________________________________ Date: ______________ 

Jeffrey D. Nakrin

Director, Records and Filing Office

Approved By: 

__________________________________ Date: ______________ 

Raghav Vajjhala 

Chief Information Officer (CIO)