Federal Trade Commission

Privacy Impact Assessment

ServiceNow Administrative

E-Filing Application

August 2020

Reviewed January 2023
Table of Contents

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

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

3 Data Access and Sharing ......................................................................................................... 4

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

5 Data Accuracy and Security .................................................................................................... 6

6 Data Retention and Disposal ................................................................................................... 8

7 Website Privacy Evaluation ..................................................................................................... 8

8 Privacy Risks and Evaluation .................................................................................................. 9
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1 System Overview

1.1 Describe the project/system and its purpose.

The Federal Trade Commission (FTC) has updated its system for receiving and managing 

electronic filings in FTC administrative proceedings under Part 3 of its Rules of Practice, by 

incorporating a web-based application developed on the ServiceNow platform.1 Part 3 sets 

forth the procedures for competition and consumer protection cases tried before an 

Administrative Law Judge (ALJ) of the FTC, and appeals of the ALJ’s initial decision to the 

full Commission. During Part 3 proceedings, electronic filings and public documents are 

received and served electronically. 

Administrative E-Filing, or Admin E-Filing, allows users to submit public and nonpublic 

pleadings and motions in Part 3 administrative litigations before the ALJ and the 

Commission. Submitting these documents electronically speeds up the process for 

circulating these filings to the relevant offices within the Commission and reduces costs 

incurred for scanning and courier fees. 

In order to use the Administrative E-Filing application, a user (i.e., lawyers representing 

respondents or third parties in the Part 3 matter) must register with a unique user ID and 

password. The user’s name, company name, work address, work telephone number, work 

email address, and bar admission number (if applicable) are required to register. The user is 

then required to enter a Notice of Appearance in a specific administrative litigation.2

 Once 

the Notice of Appearance has been approved, the user may submit filings electronically 

through the system for that specific matter. 

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

dissemination of information for this project/system?

The information in this system is collected, maintained and disseminated pursuant to the FTC 

Act, 15 U.S.C. §§ 41-58, the Rules of Practice, 16 C.F.R. §§ 0.1 et seq., and other laws and

regulations the Commission enforces. 

1 For more information about ServiceNow, refer to the Privacy Impact Assessments available online. 2 Instructions and links to file documents in adjudicative proceedings are available online. 
2 

2 Data Type, Sources, and Use

2.1 Specify in the table below what types of personally identifiable information (PII)3 

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

Date of Birth

Home Address

Phone Number(s) 

Place of Birth

Age

Race/ethnicity

Alias

Sex

Email Address

Work Address

Taxpayer ID

Credit Card Number

Facsimile Number

Medical Information

Education Records 

Social Security Number 

Mother’s Maiden Name 

Biometric Identifiers (e.g., 

fingerprint, voiceprint)

Audio Recordings

Photographic Identifiers 

(e.g., image, x-ray, video)

Certificates (e.g., birth, 

death, marriage, etc.)

Legal Documents, Records, 

Notes (e.g., divorce decree, 

criminal records, etc.)

Vehicle Identifiers (e.g., 

license plates)

Financial Information (e.g., 

account number, PINs, 

passwords, credit report, 

etc.)

Geolocation Information

Passport Number

User ID

Internet Cookie Containing 

PII

Employment Status, 

History, or Information

Employee Identification 

Number (EIN)

Salary

Military Status/Records/ ID 

Number

IP/MAC Address

Investigation Report or 

Database

 Driver’s License/State ID 

Number (or foreign country 

equivalent)

Other (Please Specify): 

Login and logout times, 

Company name, Bar 

admission jurisdiction, 

 Bar admission number (if 

applicable), 

 User password4

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 user is able to enter the title of the filing being submitted and upload a copy of the 

document being filed. This information will be retained in the system for 90 days after the 

filing has been successfully submitted. After 90 days, this information will be deleted from 

the system.

3 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. 

4 Passwords for FTC users are authenticated through the Active Directory system; passwords for external users are 

collected and stored in OKTA, another third-party commercial identity and access management solution service 

used by the FTC. A separate PIA is maintained for the agency’s use of OKTA. 
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2.3 What is the purpose for collection of the information listed above?

It is necessary to collect this information (i.e., Notices of Appearance) from filers in order to 

submit public and nonpublic pleadings and motions in Part 3 administrative litigations. The 

user’s registration information is collected and maintained in order to authenticate the user in 

the system. As noted in 2.2, the system also collects non-PII from users (i.e., pleadings and 

other documents filed on behalf of users or their clients) for purposes of Part 3 administrative 

litigation.

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

Filing individual

(External non-FTC user)

The filer must register with the Admin E-Filing system by 

providing their name, company name, work address, work 

telephone number, and work email address, and bar 

admission number (if applicable). The filer must also 

submit the Notice of Appearance form. The filer enters the 

“Document Title” for the E-Filing submission and select 

the confidentiality status of the submission. 

Login credentials are maintained in the OKTA identity 

management system. 

FTC employees and 

contractors 

As with the external user, an FTC staff person filing must 

also submit the Notice of Appearance form (see 2.3), enter 

the “Document Title” for the E-Filing submission, and 

select the confidentiality status if the submission.

The FTC Review and Administration team inputs the 

docket information and reviews/updates the status of 

filings.

The FTC user’s login information (user ID, time of login 

and logout), as well as roles and access permission levels, 

are maintained within the ServiceNow system. 
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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 and contractors FTC staff in the Records and Information 

Management (RIM) office and Office of the 

Secretary (OS) access the E-Filing application to 

review and process the filing. Authorized users in 

these offices have access to all documents 

submitted.

FTC staff in the Office of Administrative Law 

Judges (ALJ) performs the initial adjudicative 

factfinding in the agency’s administrative 

complaint proceedings. They have access to all the 

data in the system in order to review the 

information as well as to upload documents. 

FTC staff in their roles as complaint counsel have 

limited access to the application to submit 

documents for Commission and/or ALJ 

consideration. 

FTC support contractors also have access to all the 

information in the E-Filing application in order to 

review and process the data. 

ServiceNow Administrators For troubleshooting and maintenance purposes, 

authorized ServiceNow system administrators have 

access to data in E-Filing. 

Non-FTC parties

(Respondent/Third parties 

appearing in Part 3 matters) 

External respondents and third parties may have 

access to E-Filing in order to submit documents for 

Commission and/or ALJ consideration. They will 

only have access to those documents that they (the 

non-FTC party) submit.
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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.

Yes, FTC contractors will have access to data in the system. Contractors must use FTCissued laptops to access the system, using their PIV cards. All FTC contractors are required 

to sign non-disclosure agreements (NDA), complete security and privacy training prior to 

obtaining access to any FTC systems, and complete annual security and privacy training to 

maintain network access and access to those systems.

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.

FTC contractors with access rights to the ServiceNow E-Filing application are subject to the 

same rules and policies as FTC staff, including adherence to the FTC Breach Notification 

Response Plan. 

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): Every external user is required to sign the FTC Rules of 

Behavior (ROB) prior to use of the Application. 

 Notice is not provided (explain): 

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)?

No. Users who do not register to use the system are not able to file electronically using the 

Admin E-Filing system. Additionally, users who decline to accept the Rules of Behavior 

(ROB) cannot register for system access and are therefore unable to use the system.
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4.3 Are there procedures in place to allow individuals access to their personally 

identifiable information? Explain. 

Yes. Individuals can log into their account and access limited personal information about 

themselves, such as their password and security questions. They do not have the ability to 

change their profile information or access log details about their activity. An individual may 

make a Privacy Act request to the FTC for access to additional information maintained about 

them in the ServiceNow Admin E-Filing application. See Commission Rule 4.13 (Privacy 

Act request procedures). Access to the information under the Privacy Act may be subject to 

certain exemptions. See Commission Rule 4.13(m). Individuals may also file Freedom of 

Information Act (FOIA) requests for agency records about them (if they are not exempt from 

disclosure to them under those laws). Additionally, individuals may contact the FTC with 

any complaints, questions or concerns via phone or email available on www.ftc.gov or 

contact the Chief Privacy Officer directly.

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. 

Yes. The FTC provides a process for individuals to correct or amend any inaccurate PII 

maintained by the FTC, including any information that may be stored in the ServiceNow 

Admin E-Filing application. As stated above in 4.3, individuals can file requests with the 

FTC under the FOIA and the Privacy Act for access to any agency records that may be about 

them and are not exempt from disclosure to them under those laws. Additionally, individuals 

may contact the FTC with any complaints, questions, or concerns via phone or email 

available on www.ftc.gov or contact the Chief Privacy Officer directly.

The FTC’s Privacy Policy provides links to the FTC’s SORNs, which include information 

about how to correct or amend records. Where appropriate, the FTC disseminates corrected 

or amended PII to other authorized users of that PII, such as external information sharing 

partners. 

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?

It is incumbent upon the person submitting the filing to ensure that the information contained 

therein is accurate and up to date. Additionally, all Notices of Appearances submitted 

through the system are reviewed by the FTC OS administrator. Additionally, all other filings 

submitted through the E-Filing application are reviewed by the RIM office and OS reviewers;
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filings that are not in compliance are returned/rejected.

5 Once the RIM office and OS 

reviewers return a filing due to non-compliance, then the system sends a notification to the 

filer detailing the reason for rejection. The rejected filing is deleted from the system 

immediately.

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.

Yes, below are some examples of administrative procedures, technical safeguards, and 

controls in place to protect and ensure proper use of data in ServiceNow Admin E-Filing 

application. 

The principle of least privilege is used to grant access to FTC staff and contractors, and user 

actions are tracked in the system audit logs. All FTC positions are assigned a risk designation 

that has associated criteria for personnel screening. All potential FTC staff, contractors, and 

volunteers are subject to background investigations and suitability reviews in accordance 

with OPM guidance. 

All authorized users are required to use two-factor authentication to access the application. 

Authorized FTC users of the application must use their PIV cards along with a PIN to access 

data in the system. External users must authenticate with a registered username and password 

and agree to receive a one-time passcode (OTP) by voice or use an OTP token authenticator 

app on their smartphone in order to use the application. Additional safeguards for FTC users 

include role-based access controls at the application level to control who has access to what 

data in the application. 

Supervisors and/or Contracting Officer’s Representatives (CORs) must identify and approve 

employee requests to access network applications and specify the appropriate user role and 

level of access privileges. 

The system automatically disposes of the following PII elements 90 days after a document 

has been uploaded to the system: Bar admission jurisdiction, Bar admission number, and 

work address. 

5.3 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 

5 Examples of why a filing may be rejected due to noncompliance may include the following: Filing before the 

Commission with the wrong caption before the ALJ or vice versa; not appropriately labeling the filing (public or 

confidential); submitting a filing when the relevant hearings is stayed; or when the filing does not comply with the 

Commission’s Part 3 and Part 4 Rules.
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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? 

Electronic input source records (filings) will be retained in the Administrative E-Filing 

Application for 90 calendar days in accordance with National Archives and Records 

Administration (NARA) GRS 5.2, item 020, Intermediary Records. 

During this time, the filings will be uploaded, validated, and stored within ServiceNow. 

Documents that do not meet the administrative filings requirements will be rejected and 

deleted from the system immediately. 

The metadata associated with a Notice of Appearance (NOA) will be maintained for 90 days 

until the corresponding proceeding is closed in order to allow users to further submit filings 

beyond the initial 90-day period. 

Help desk and related customer service desk operation records will be retained per NARA 

GRS 5.8, item 010, Technical and administrative help desk operational records, for 1 year 

after resolution of request, or when no longer needed for business use, whichever is 

appropriate. 

In order to dispose of the data, the authorized FTC administrator submits a ServiceNow 

request for the deletion of the data. The ServiceNow O&M Contractor performs the task of 

manually deleting the defined data from the E-Filing application. 

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.

Yes, the application does employ the use of a Website. ServiceNow utilizes session-based 

cookies to enable core site functionality. ServiceNow refers to these as “required” cookies. 

ServiceNow may use required cookies to authenticate user access to various areas of the site. 

Other cookies allow ServiceNow to enhance the user’s browsing experience, tailor content to 

the user’s preferences, and make user interactions with ServiceNow more meaningful. 
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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

Misuse of data by 

authorized users 

Prior to receiving access to the FTC’s network, all users must 

agree to the FTC Rules of Behavior, which includes 

consenting to monitoring and restrictions on data usage. 

Unauthorized system 

access

All FTC users must have an FTC account and 

governmentissued personal identity verification (PIV) card to 

access ServiceNow. FTC’s user identity management 

processes include authentication with enterprise directory to 

control and manage access restrictions to authorized 

personnel on an 

official need-to-know basis. The FTC utilizes a combination 

of technical and operational controls to reduce risk in the 

ServiceNow environment, such as encryption, passwords, 

audit logs, firewalls, malware identification, and data loss 

prevention policies. As a FedRAMP-approved cloud service 

provider, ServiceNow undergoes regular reviews of its 

security controls. 

External users will be required to authenticate using twofactor 

authentication: username/password and OTP passcode 

delivered to user (voice or token authenticator app on their 

smartphone).

Data leakage Non-FTC ServiceNow system administrators are not allowed

to review, audit, transmit, or store FTC data, which minimizes 

privacy risks from the vendor source. 

Eavesdropping The users interact with the Admin E-Filing application over 

the TLS protocol (https), an authenticated protected channel.

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

capabilities designed to support privacy? Explain. 

The Admin E-Filing application inherits all privacy controls from the parent ServiceNow 

application. This includes an automatic logoff after 15 minutes of inactivity, deactivating 

users after 35 days of account inactivity, and locking user accounts after 3 incorrect password 

attempts. External users can only view and access information and data that they have 
10 

submitted into the application. External users can only file attachments after their Notice of 

Appearance (NOA) has been approved by an OS administrator. 

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).

Information collected about users from their Notices of Appearances is considered part of 

FTC VII-3 -- Computer Systems User Identification and Access Records – FTC. Pleadings 

or other filings and documents submitted by users through the system are part of FTC I-1 -

Nonpublic Investigational and Other Nonpublic Legal Program Records – FTC. To the 

extent such pleadings or other documents are placed on the public record of the Part 3 

administrative proceeding (i.e., posted on the FTC’s public web site), such materials are part 

of FTC I-6 -- Public Records -- FTC. These SORNs may be read and downloaded at 

https://www.ftc.gov/site-information/privacy-policy/privacy-act-systems. 

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? 

The administrative and technical controls described in section 5.2 of this document provide 

assurance that the collection, use, and maintenance of the information will be conducted as 

described in this PIA. This PIA aligns with the FTC’s existing privacy policies and 

procedures, and is subject to periodic review by the Office of the Chief Privacy Officer 

(OCPO), in consultation with relevant program staff and other relevant agency officials.