Federal Trade Commission

Privacy Impact Assessment

Financial Disclosure Online

(FDOnline)

Reviewed January 2023 
Table of Contents

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

2 Data Type, Sources, and Use .................................................................................................. 3

3 Data Access and Sharing ........................................................................................................ 5

4 Notice and Consent ................................................................................................................. 7

5 Data Accuracy and Security.................................................................................................... 8

6 Data Retention and Disposal ................................................................................................. 10

7 Website Privacy Evaluation .................................................................................................. 10

8 Privacy Risks and Evaluation ............................................................................................... 11
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1 System Overview

1.1 Describe the project/system and its purpose.

The Federal Trade Commission (FTC) is committed to preserving the public’s trust by

adhering to the various laws and ethics regulations that guide the performance of each FTC 

employee’s official duties. The Ethics Team within the FTC Office of General Counsel

(OGC) is responsible for helping agency employees maintain these high standards of ethical

behavior. They are responsible for ensuring that FTC staff receive the appropriate ethics

training and disclose any potential conflicts of interest to their supervisors and to the Ethics

Team. Ensuring that FTC employees perform their duties while adhering to the agency’s 

strong guidelines and principles is an important part of the FTC’s mission of protecting

consumers. Failure to do so may result in costly ethics violation fines, loss of public trust, 

and irreparable damage to the agency’s reputation.

The Ethics Team utilizes the Financial Disclosure Online (FDOnline) system so that FTC

employees (including new hires before they are officially employed, if required by the Ethics 

Team) can file their OGE-450 Confidential Financial Disclosure (new entrant and annual) 

reports in an automated system. The FDOnline system will allow the Ethics Team to manage 

the tracking, reviewing, certification and storage of all OGE-450 Confidential Financial 

Disclosure reports in one system. Previously, the Ethics Team manually processed hardcopy 

reports, a cumbersome and time-consuming process. Converting to a centralized, e-tracking 

system not only improves efficiencies and decreases inaccuracies but also permits the Ethics 

Team’s limited resources to be redirected to other duties, including conflicts review, 

educational outreach, etc. FDOnline’s automation function also helps the Ethics Team respond 

in a timely manner (as required by law) to personnel actions that trigger federal ethics 

requirements.

FDOnline is owned and operated by HRworx, a commercial third party entity which the 

FTChas contracted with for use of the FDOnline system. FDOnline is hosted on the Amazon 

WebServices (AWS) GovCloud.1

FDOnline’s primary function is to automate the confidential financial disclosure process:

• FDOnline facilitates the electronic filing, review, and certification of the

confidential financial disclosure report (OGE Form 450). The OGE Form 450 is

an OGE-owned document used throughout the Executive Branch. All FTC

employees at the GS-14 and GS-15 levels are required to complete the OGE Form

450. In certain cases, with consultation from the Ethics Team, managers may

designate employees at lower grade levels to file the OGE Form 450 based on the 

nature of their official duties. FDOnline saves the information provided in the form 

each year so employees are only required to update information as appropriate. Only

the certified, final version of the report is retained by FDOnline. FDOnline

automatically notifies employees of the filing deadline and issues reminders via email

as the target date approaches. These automatic notifications include a link to a 

1 AWS GovCloud (US) is designed to allow U.S. government agencies and customers to move sensitive workloads

into the cloud by addressing their specific regulatory and compliance requirements.
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program that walks employees through the entire filing process, ensuring both the 

accuracy and timely submission of reports. (The notifications do not contain any

sensitive PII in case they are misdirected or forwarded.)

• FDOnline automates the management of certified OGE Form 450 reports. For

example, FDOnline helps the Ethics Team maintain an accurate record of when and

which employees have submitted their reports, as well as whether the reports have

been reviewed and certified in a timely manner by reviewing officials. FDOnline also

ensures the reports are securely stored in a central repository. Specifically, access is

limited to the filer, the reviewing officials (i.e., FTC supervisors), and the Ethics 

Team. The Ethics Team may also disclose OGE Form 450 reports to other authorized 

FTC employees as appropriate (e.g., in connection with FTC personnel or Inspector 

General matters). The U.S. Office of Government Ethics (OGE) periodically

inspects/audits the ethics programs of federal agencies, including the FTC’s ethics

program. Accordingly, the FTC may share information contained in FDOnline with

OGE.

The secondary purpose of FDOnline is to automate other aspects of the FTC’s federal 

ethics program: 

• FDOnline automates the tracking of ethics training. All new FTC employees must 

receive initial ethics orientation. FTC employees at the GS-14 and GS-15 levels must

receive one hour of live federal ethics training every three years and one hour of 

paper/electronic training during the interim years. FTC managers have designated

certain FTC employees at lower GS levels to meet the same annual ethics training

requirements as GS-14 and GS-15 employees. Senior staff, including political 

appointees and career members of the Senior Executive Service, must receive one 

hour of live federal ethics training every year. FDOnline is capable of automating the 

process of tracking this information by individual employee (e.g., by sending training 

notifications and reminders to employees, logging employee attendance, etc.).

• FDOnline automates other employee requests for ethics guidance and approval.

The system may be used to submit, approve, and log requests for outside 

employment, free attendance to widely-attended gatherings, and non-federal source

travel reimbursement. For example, the FDOnline may also be used to log and store 

the FTC’s Ethics K-9 Korner Consent and Release Form (used when employees 

submit photos of their pets for use in the agency’s ethics educational campaigns).

FDOnline also may be used to store final guidance provided to employees on a 

varietyof ethics subjects (regardless of whether the final guidance is captured in an 

email or formal legal memorandum). 

In order for FTC employees to use FDOnline, the Ethics Team must first send a request to 

the helpdesk to add the employee to the FDOnline OKTA App. Once the employee has 

been added to the FDOnline OKTA App, the Ethics Team creates an account for the 

employee by setting up a filing. The employee can log in using their PIV Card and the single 

sign-on, SSO. If an employee is unable to use their FTC PIV Card, the employee can log in 

using a username and password along with a one-time code (second authentication factor) 

sent to the user’s e-mail address. The employee then proceeds to fill out the designated 
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forms through a series of question and answer prompts and certifies that the information

provided is accurate. Once the employee has made this certification, they arenot able to 

make any further updates or changes to their forms unless the Ethics administrator reopens 

the filing and allows them to edit the information provided. The filing may be reviewed by 

the employee’s supervisor, as necessary, then approved and recertified by the Ethics

administrator.

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

dissemination of information for this project/system?

Ethics in Government Act of 1978, 5 U.S.C. app.; Ethics Reform Act of 1989, Pub. L. 

101-194; 5 CFR parts 735 & 2634, and other applicable ethics-related laws, rules, and

Executive Orders.

2 Data Type, Sources, and Use

2.1 Specify in the table below what types of personally identifiable information (PII)2

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

PII Elements: This is not intended to be an exhaustive list. Specify other categories of PII as

needed.

Full Name Biometric Identifiers (e.g., User ID

Date of Birth fingerprint, voiceprint) Internet Cookie Containing

Home Address Audio Recordings PII

Phone Number(s) Photographic Identifiers Employment Status,

Place of Birth (e.g., image, x-ray, video) History, or Information

Age Certificates (e.g., birth, Employee Identification

Race/ethnicity death, marriage, etc.) Number (EIN)

Alias Legal Documents, Records, Salary

Sex Notes (e.g., divorce decree, Military Status/Records/ ID

Email Address (FTC) criminal records, etc.) Number

Work Address Vehicle Identifiers (e.g., IP/MAC Address

Taxpayer ID license plates) Investigation Report or

Credit Card Number Financial Information (e.g., Database

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

Medical Information passwords, credit report, Number (or foreign country

Education Records etc.) equivalent)

Social Security Number Geolocation Information Other (Please Specify):

Mother’s Maiden Name Passport Number information pertaining to

employee’s spouse and

dependent children

FDOnline maintains the following types of PII collected via the OGE Form 450: the filing

employee’s name (last, first, and middle initial); FTC email address; FTC position/title; GSlevel; agency name; business address; and work phone number. Financial information

2 Per OMB Circular A-130, personally identifiable information (PII) means information that can be used to

distinguish or trace an individual’s identity, either alone or when combined with other information that is linked or

linkable to a specific individual.
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maintained in FDOnline includes only a listing of assets (e.g., names of securities or mutual 

funds held) and financial reports. Specific account numbers, account values, PINs, or credit

reports are not included. 

Additional PII maintained in the system by the FTC Ethics Team includes: employee name,

employee office/organization code, GS-level, and potentially the name of an employee’s pet 

(for FTC’s K-9 Korner photo consent form). The signatures of the filing employee and the 

initial reviewer and/or the final reviewing official are also included in FDOnline. 

FDOnline maintains system security log information which includes the user name and the 

action performed. Session dates and times are not currently logged. 

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 information collected by FDOnline with respect to the OGE Form 450 report

includes: the date the report was submitted; the date the report was certified by the initial

reviewer and/or the final reviewing official (reviewing officials include FTC supervisors

and/or Ethics Team members); reportable assets or sources of income for the filing

employee, his/her spouse, and dependent children; reportable liabilities (debts) for the filing

employee, his/her spouse, and dependent children; reportable outside employment positions 

for the filing employee; reportable agreements or arrangements for the filing employee (e.g., 

continued participation in a retirement plan with a former employer); and, reportable gifts or

travel reimbursements for the employee, his/her spouse, and dependent children. 

The information collected by FDOnline with respect to other aspects of the FTC’s 

ethics program includes: date of employee request; date of approval/response by the Ethics

Team;a description of the outside employment activity (including identity of employer and

compensation information); a description of the widely attended gathering (including, 

identification of the sponsor and the individual who extended the offer of free attendance); a 

description of non-federal source travel information (including, identification of the sponsor 

and monetary details about what has been offered to the FTC employee); facts conveyed to

the Ethics Team by the employee in order to obtain legal guidance; and legal guidance issued 

by Ethics Team to the employee.

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

The OGE Form 450 is owned by OGE and certain federal employees are required by law to 

provide the information collected therein. Information from the form is maintained in

FDOnline and used for review by the FTC Ethics Team to determine compliance with

applicable government conflict of interest laws and regulations. Using records identifiable

by employee is necessary to provide guidance on an individual basis and to ensure 

consistency with guidance issued by the Ethics Team.
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2.4 What are the sources of the information in the system/project? How is the

information collected?

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

FTC Employees (OGE

Form 450 filers)

FTC employees required to complete the OGE Form 450 will access

FDOnline through a web application and enter their information into

the system. They are required to proceed through a question and

answer form that, when completed, renders the completed Form 450.

FTC Employees

(Managers/Supervisors)

FTC employees who serve as reviewing officials of OGE Form 450

reports will also access FDOnline via the web application and enter

information into the system as necessary (such review is required to

certify the reports).

FTC Employees (Ethics

Team)

The FTC’s Ethics Team also accesses FDOnline (concerning the

OGE Form 450 and otherwise as discussed above) to review and

certify completed forms. This may include providing additional

information about the employee or correcting inaccurate information

provided by the filing employee.

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.

Data Will Be Accessed

By and/or Provided To: How and Why the Data Will Be Accessed/Shared

FTC Employees GS-14 and GS-15 level employees have access to FDOnline to draft

and submit their OGE Form 450 reports. Reviewing officials (i.e.,

designated supervisors and the FTC’s Ethics Team) have access to

the reports in order to ensure they are timely submitted, complete,

and to address potential conflicts of interest. FTC supervisors will

only have access to the OGE Forms they are required to review and

certify; supervisors have the ability to see all information entered by

their employees. This is important because supervisors familiar with

the specific work/projects assigned to their subordinates are key to

spotting potential conflicts and ensuring they do not lead to actual

conflicts. The FTC’s Ethics Team will have access to all

information in FDOnline, which includes reports generated by the

system that includes employee PII. Other FTC employees may

access FDOnline to complete other forms (e.g., OGE Form 450-A) as

appropriate.

U.S. Office of

Government Ethics 

(OGE)

OGE staff cannot directly access FDOnline to review FTC

information, nor does the FTC directly share forms in FDOnline

withOGE. However, OGE periodically audits/inspects federal 

agencies, including the FTC, and OGE staff may request to review 

the information contained in FDOnline for auditing purposes. The 

FTC Ethics Team may produce reports to provide to OGE as part of 

its compliance activities.
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Data Will Be Accessed

By and/or Provided To: How and Why the Data Will Be Accessed/Shared

HRworx HRworx manages and supports FDOnline. HRworx uses a rolebased approach for FDOnline management activities; only those

authorized to access the information and have valid credentials can

review FTC data in the system. Access to FDOnline and the PII

fields contained within is limited to HRworx personnel with an

Application, Infrastructure, or Security Administrator role

supporting the FDOnline system. Application administrators have

access to the system to perform support and technical support

functions. Infrastructure administrators have access to the data in

order to perform maintenance to the system. Security administrators

have access to the system to monitor and investigate any security

related issues.

3.2 Do contractors and/or third 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.

HRworx manages and supports FDOnline. HRworx uses a role-based approach for FDOnline 

management activities. HRworx employees are required to undergo security awareness 

training at the time of hire and annually after that. This is further supplemented with rolebased and targeted training covering such topics as privacy and phishing. System security

logs capture all actions.

HRworx does not currently have any subcontractors supporting FDOnline. If, in the future,

HRworx opts to allow subcontractors access to data in FDOnline, they will be subject to 

the same training requirements as all HRworx employees. The FDOnline system does not

provide PII to any third-party organizations. 

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

by the contractor’s organization or third party service provider.

HRworx’s incident response plan is communicated to employees as part of its training

curriculum. All employees are responsible for recognizing and reporting suspicious events 

and circumstances (particularly those involving government PII) to the security team. As

part of its analysis, HRworx must determine the type and severity of the incident and

communicate any potential risks to the customer (FTC) security/privacy officials as

necessary.
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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.

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): A Privacy Act Statement is included on the OGE Form 450 as it

appears within the FDOnline system. Additionally, an explanation of the requirement to file the

OGE Form 450 report is provided in writing by the FTC Human Capital Management Office

(HCMO) during the hiring process. OGE Form 450 and FTC Form 474 (outside employment

approval) filing requirements are also discussed orally during ethics orientation (mandatory for all

new hires) and during annual ethics training (required for a subset of FTC employees). All

standardized forms used by the FTC’s Ethics Team contain a written Privacy Act Statement.

Specifically, written Privacy Act Statements are found on: OGE Form 450 report; FTC Form 474;

the Initial Ethics Orientation web-based confirmation portal (each new hire must personally

confirm he/she attended ethics orientation), and the Ethics K-9 Korner Consent and Release Form

(used when employees submit photos of their pets for future use in ethics educational campaigns).

Notice is not provided (explain): Additional information entered into FDOnline by the Ethics

Team may be derived from informal email exchanges between FTC employees and the FTC’s

Ethics Team (those internal messages do not contain Privacy Act Statements).

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)?

FTC employees at the GS-14 and GS-15 levels are legally mandated to complete the OGE 

Form 450. Likewise, employees who engage in certain outside activities3

, are legally

required to obtain approval from their supervisors and the FTC’s Ethics Team. As such, FTC

employees must provide their information for use in FDOnline to meet financial disclosure

requirements. An employee who willfully falsifies the information on his or her report,

willfully omits information, or willfully fails to file may be subject to civil penalties and/or

criminal prosecution. FTC disciplinary actions may also be imposed if the employee does 

not fully respond or cooperate with the Ethics Team in attempting to certify the employee’s

filing.

All new hires must attend ethics orientation and a subset of employees have been designated

(by law and/or FTC policy) for annual ethics training. This is mandatory and a condition of

their employment with the FTC. Employees are legally required to obtain advance approval

of non-federal-source reimbursement and free attendance to widely attended gatherings from

3 All FTC employees are required to obtain approval from their supervisor and the FTC Ethics Team prior to

engaging in certain non-FTC related activities. This includes any compensated activity outside of the FTC; any

service as officer/director/trustee (regardless of compensation); any personal service to a for-profit entity; and any

provision of a professional service (operating in the same field of work that the employee engages in at the FTC).

All these outside activities are subject to FTC approval.
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the FTC’s Ethics Team. In contrast, employees normally otherwise have the option to

contact the Ethics Team for legal guidance (such contact is encouraged by the Ethics Team to

avoid inadvertent violations).

Employees do have the option to decline to provide their information for use by the Ethics 

Team in certain FTC ethics educational awareness initiatives involving voluntary employee 

participation. For example, employees may choose whether or not to submit photos of their 

pets for use in FTC’s K-9 Korner activities; this is strictly voluntary and at the discretion of 

the FTC employee. 

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

identifiable information? Explain.

FTC employees will access the FDOnline system to file and view their own OGE Form 450 

reports. FTC employees may also contact the FTC’s Ethics Team to access or update other

information about themselves. 

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. 

Employees who submit the OGE Form 450 are required to update their report on an annual 

basis. Once the filing has been digitally signed or “certified,” the filing employee can no 

longer make additional changes or updates to their form. Individual filers can contact the

FTC Ethics Team to request access to their records and reopen a filing if anything needs to

be updated. After a filing has been reopened, the employee can log in with his/her

credentials and make any corrections/updates. With respect to other employee information in

the system, FTC employees may contact an FTC Ethics Team member and request that

his/her information be updated/corrected. The FTC Ethics Team will update the information.

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?

Filers of the OGE Form 450 report are responsible for entering accurate information into

FDOnline. The FTC’s Ethics Team conducts an in-depth review of the contents of a subset 

of OGE Form 450 reports each year. All OGE Form 450 reports are reviewed by a 

supervisor or an FTC Ethics Team member for accuracy and completion. All requests for 

outside employment approval (FTC Form 474) are reviewed by supervisors and an FTC 

ethics attorney. All other information in FDOnline is entered into the system by the FTC’s 

Ethics Team. There are various safeguards in place to ensure accuracy. For instance, only 

final legal guidance/documents that have undergone the appropriate review within the Ethics

Team are entered into the system. Likewise, attendance data for annual ethics training and 
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ethics orientation for new hires is cross-checked with lists generated by FTC Human Capital

Management Office (HCMO).

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.

Only authorized FTC Ethics Team administrators have access to all the information in

FDOnline. FTC system administrators and employees will login to the system using their

FTC PIV card. If an employee is unable to access the system with their PIV card, they may 

login by using their user name, password, and one tmie code (second authentication factor) 

sent to the user’s email address. The system also logs user activity and notes when an

authorized change has been made to a specific filing. Filing employees only have access to

their own accounts and forms. 

Supervisors reviewing an employee’s filing have access to only their designated employee’s

information. Once reports are finalized, they may not be altered or changed. 

Access to FDOnline and the PII fields contained within the system are limited to HRworx

personnel with an Application, Infrastructure, or Security Administrator role supporting the 

FDOnline system. Individuals are only granted access to functionality 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 HRworx Security Officer prior to account creation. 

HRworx individuals are provided access to the FDOnline system in accordance with

established account provisioning and management processes. These individuals login to the

system using a two-factor authentication process. Additionally, HRworx 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. 

The HRworx Security Officer also maintains the role of Privacy Officer and is responsible

for assuring safeguards for the PII within FDOnline. The Security Officer has the

responsibility of performing a security impact analysis for significant changes to the system

and also provides guidance to other FDOnline support personnel on the proper protection of 

sensitive information, through established policies and procedures. FDOnline stores all data

in an encrypted MySQL database and allows access to the database via the application

(which has its own authentication) or an Intelliworx/HRworx infrastructure administrator.

System users access the system via an HTTPS connection. 

FDOnline operates within and leverages the AWS GovCloud Infrastructure as a Services

(IaaS) environment. HRworx uitilizes the AWS GovCloud IaaS multiple availability zone 

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

secondary availability zones are within the FDOnline system FedRAMP authorization

boundary where the same controls are implemented and assessed.
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5.3 Has the system/project undergone the appropriate security risk assessment and

received authority to operate?

Yes, FDOnline has undergone a security risk assessment and received an authority to operate.

The system is categorized as a moderate system using Federal Information Processing Standards 

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

Systems.

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?

Not Applicable

No live PII or production data are used for testing or any other purposes. 

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?

The information contained in FDOnline will be disposed of in accordance with NARA GRS

2.8 (Employee Ethics Records). 

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. 

Authorized FTC employees access FDOnline via a web application that uses temporary

session cookies. Use of the temporary session cookie is necessary to move the user

continuously through the system without requiring them to reenter their credentials at each

step.
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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 Mitigation Strategy

Information contained in

system/project may be

inaccurate or incomplete.

The FTC’s Ethics Team is able to review data in FDOnline and

correct errors. The FTC’s Ethics Team will perform quality

monitoring periodically and can identify, review, correct, and log

inaccuracies to prevent recurrence (e.g., although all OGE Form 450

reports are tracked, logged, and reviewed by a supervisor, a subset

of OGE Form 450 reports are also carefully reviewed by the FTC’s 

Ethics Team each year for accuracy).

Individuals who have

access to PII could

exceed their authority

and use the data for

unofficial/unauthorized

purposes.

The FTC’s Ethics Team strictly manages access control and limits

the use and access of all data to purposes for which it was collected.

Designated reviewing officials (i.e., FTC supervisors) only have

access to the OGE Form 450 reports for which they are officially

responsible. The Ethics Team shall be responsible for managing and

immediately updating system accounts for reviewing officials to

revoke access to filings for any employee they no longer supervise

or, if the reviewing official leaves FTC service, cancelling his or her

system account and login credentials to prevent continued system

access. Only the FTC’s Ethics Team has full access to the system.

A system log is maintained that reflects who accessed the data at any

given time, and whether the data was tampered with or edited.

Specifically, all login activities to the FDOnline system are logged.

Additionally, logs related to privileged functions, administrator

activity, and data changes and deletions are automatically input into

the Splunk Security Information and Event Management (SIEM) 

tool for automated monitoring and analysis to detect suspicious

activity and indicators of inappropriate or unusual activity.

An individual may enter

a financial account

number or other

sensitive PII in a free

text field.

The FTC’s Ethics Team has the ability to access individual records

and delete information as necessary, including financial account

numbers. This and other forms of sensitive PII are not required by

the system. If employees opt to provide such information, the FTC’s

Ethics Team will instruct the employee to remove it or the FTC’s

Ethics Team will delete it (advising the employee that such

information should not be submitted in the future).

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

capabilities designed to support privacy? Explain.

The user customarily logs into the system using their PIV card. When a user is unable to 

access the system with their PIV card, a user may login using their user name, password and 

second authentication factor (one-time code) sent to the user’s e-mail address. FDOnline

automatically locks the user out of his/her account after three failed password attempts. They 

will then be instructed to reset their password via a link sent to their e-mail address. The 

system also logs user activity and notes when an authorized change is made to a specific 

filing.
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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).

The SORN for the FTC’s Ethics Program, FTC-II-7, expressly covers paper and electronic

records maintained by the Ethics Program. Further, this system corresponds to the systems

described and covered by the Government-wide SORNs issued by OGE for agency ethics 

program records. See OGE/GOVT-1 (Executive Branch Personnel Public Financial 

disclosure Reports and Other Name-Retrieved Ethics Program Records); OGE/GOVT-2 

(Executive Branch Confidential Financial Disclosure Reports). See also VII-3 -- Computer 

Systems User Identification and Access Records – FTC (i.e., for user name, IP address, email address).

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?

Data in FDOnline is encrypted both at rest and in transit with FIPS 140-2 

validated encryption. 

The FTC will maintain PII and other information within FDOnline in accordance with

FTC regulations, policies, and procedures. Only authorized employees will have access to 

the system, and the system automatically logs user interaction for each filing. All FTC

employees are required to undergo annual privacy and security training and periodic ethics 

training.