Privacy and Civil Liberties Impact Assessment 

for the

Treasury Worker and Visitor Entry System (TWAVES)

and Other Access Approval Processes

February 28, 2020

Bureau Reviewing Official

Ryan Law

Deputy Assistant Secretary for Privacy, 

Transparency, and Records

Departmental Offices

U.S. Department of the Treasury
Section 1: Introduction

It is the policy of the Department of the Treasury (“Treasury” or “Department”) and its Bureaus 

to conduct a Privacy and Civil Liberties Impact Assessment (“PCLIA”) when personally

identifiable information (“PII”) is maintained in a system or by a project. PCLIAs are required 

for all systems and projects that collect, maintain, or disseminate PII, regardless of the manner in 

which the information is retrieved.

This assessment is being completed pursuant to Section 208 of the E-Government Act of 2002

(“E-Gov Act”), 44 U.S.C. § 3501, Office of the Management and Budget (“OMB”) 

Memorandum 03-22, “OMB Guidance for Implementing the Privacy Provisions of the EGovernment Act of 2002,” and Treasury Directive 25-07, “Privacy and Civil Liberties Impact

Assessment (PCLIA),” which requires Treasury Offices and Bureaus to conduct a PCLIA before:

1. developing or procuring information technology (“IT”) systems or projects that collect, 

maintain or disseminate PII from or about members of the public, or

2. initiating a new collection of information that: a) will be collected, maintained, or 

disseminated using IT; and b) includes any PII permitting the physical or online 

contacting of a specific individual, if identical questions have been posed to, or identical 

reporting requirements imposed on, 10 or more persons. Agencies, instrumentalities, or 

employees of the federal government are not included.

This PCLIA provides the following information regarding the system or project:

(1) an overview of its purpose and functions;

(2) a description of the information collected;

(3) a description of the how information is maintained, used, and shared;

(4) an assessment of whether the system or project is in compliance with federal 

requirements that support information privacy; and

(5) an overview of the redress/complaint procedures available to individuals who may be 

affected by the use or sharing of information by the system or project.

The PCLIA has been conducted for the Treasury Worker and Visitor Entry System (TWAVES)

on February 22, 2018. Treasury Worker and Visitor Entry System (TWAVES) and Social 

Impact Partnership to Pay for Results Act Grants Management System (SIPPRA) are minor 

subdivisions in the Treasury Salesforce General Support System. TWAVES, along with 

SIPPRA relies on the Treasury Salesforce GSS for security. The Salesforce GSS and SIPPRA 

are covered by a separate PCLIA. For additional information regarding the Treasury Salesforce 

GSS and SIPPRA (Social Impact Partnership to Pay for Results Act Grants Management 

System), see Salesforce GSS /SIPPRA PCLIA].

Section 2: Definitions

Agency – means any entity that falls within the definition of the term “executive agency”' as defined in 31 U.S.C. § 

102.

Certifying Official – The Bureau Privacy and Civil Liberties Officer(s) who certify that all requirements in TD and 

TD P 25-07 have been completed so a PCLIA can be reviewed and approved by the Treasury Deputy Assistant 

Secretary for Privacy, Transparency, and Records.

Collect (including “collection”) – means the retrieval, receipt, gathering, or acquisition of any PII and its storage or 
presence in a Treasury system. This term should be given its broadest possible meaning.

Contractors and service providers – are private companies that provide goods or services under a contract with the 

Department of the Treasury or one of its bureaus. This includes, but is not limited to, information providers, 

information processors, and other organizations providing information system development, information technology 

services, and other outsourced applications.

Data mining – means a program involving pattern-based queries, searches, or other analyses of 1 or more electronic 

databases, where – (a) a department or agency of the federal government, or a non-federal entity acting on behalf of 

the federal government, is conducting the queries, searches, or other analyses to discover or locate a predictive 

pattern or anomaly indicative of terrorist or criminal activity on the part of any individual or individuals; (b) the

queries, searches, or other analyses are not subject-based and do not use personal identifiers of a specific individual, 

or inputs associated with a specific individual or group of individuals, to retrieve information from the database or 

databases; and (c) the purpose of the queries, searches, or other analyses is not solely – (i) the detection of fraud, 

waste, or abuse in a government agency or program; or (ii) the security of a government computer system.

Disclosure – When it is clear from its usage that the term “disclosure” refers to records provided to the public in

response to a request under the Freedom of Information Act (5 U.S.C. § 552, “FOIA”) or the Privacy Act (5 U.S.C.

§ 552a), its application should be limited in that manner. Otherwise, the term should be interpreted as synonymous 

with the terms “sharing” and “dissemination” as defined in this manual.

Dissemination – as used in this manual, is synonymous with the terms “sharing” and “disclosure” (unless it is clear 

from the context that the use of the term “disclosure” refers to a FOIA/Privacy Act disclosure).

E-G overnment – means the use of digital technologies to transform government operations to improve 

effectiveness, efficiency, and service delivery.

Federal information system – means a discrete set of information resources organized for the collection, 

processing, maintenance, transmission, and dissemination of information owned or under the control of a federal 

agency, whether automated or manual.

Final Rule – After the NPRM comment period closes, the agency reviews and analyzes the comments received (if 

any). The agency has the option to proceed with the rulemaking as proposed, issue a new or modified proposal, or 

withdraw the proposal before reaching its final decision. The agency can also revise the supporting analyses 

contained in the NPRM (e.g., to address a concern raised by a member of the public in response to the NPRM).

Government information – means information created, collected, used, maintained, processed, disseminated, or 

disposed of by or for the federal government.

Individual – means a citizen of the United States or an alien lawfully admitted for permanent residence. If a 

question does not specifically inquire about or an issue does not clearly involve a Privacy Act system of records, the 

term should be given its common, everyday meaning. In certain contexts, the term individual may also include 

citizens of other countries who are covered by the terms of an international or other agreement that involves 

information stored in the system or used by the project.

Information – means any representation of knowledge such as facts, data, or opinions in any medium or form, 

regardless of its physical form or characteristics. This term should be given the broadest possible meaning. This 

term includes, but is not limit to, information contained in a Privacy Act system of records.

Information technology (IT) – means any equipment or interconnected system or subsystem of equipment, used in 

the automatic acquisition, storage, analysis, evaluation, manipulation, management, movement, control, display, 

switching, interchange, transmission, or reception of data or information by the executive agency, if the equipment 

is used by the executive agency directly or is used by a contractor under a contract with the executive agency that 

requires the use: (i) of that equipment; or (ii) of that equipment to a significant extent in the performance of a service 

or the furnishing of a product. It includes computers, ancillary equipment (including imaging peripherals, input, 

output, and storage devices necessary for security and surveillance), peripheral equipment designed to be controlled 

by the central processing unit of a computer, software, firmware and similar procedures, services (including support
services), and related resources; but does not include any equipment acquired by a federal contractor incidental to a 

federal contract. Clinger-Cohen Act of 1996, 40 U.S.C. § 11101(6).

Major Information system – embraces “large” and “sensitive” information systems and means “a system or 

project that requires special management attention because of its importance to an agency mission; its high 

development, operating, or maintenance costs; or its significant role in the administration of agency programs,

finances, property, or other resources.” OMB Circular A-130, § 6.u. This definition includes all systems that contain 

PII and are rated as “MODERATE or HIGH impact” under Federal Information Processing Standard 199.

National Security systems – a telecommunications or information system operated by the federal government, the 

function, operation or use of which involves: (1) intelligence activities, (2) cryptologic activities related to national 

security, (3) command and control of military forces, (4) equipment that is an integral part of a weapon or weapons 

systems, or (5) systems critical to the direct fulfillment of military or intelligence missions, but does not include 

systems used for routine administrative and business applications, such as payroll, finance, logistics, and personnel 

management. Clinger-Cohen Act of 1996, 40 U.S.C. § 11103.

Notice of Proposed Rule Making (NPRM) – the Privacy Act (Section (J) and (k)) allow agencies to use the 

rulemaking process to exempt particular systems of records from some of the requirements in the Act. This process 

is often referred to as “notice-and-comment rulemaking.” The agency publishes an NPRM to notify the public that 

the agency is proposing a rule and provides an opportunity for the public to comment on the proposal before the 

agency can issue a final rule.

Personally Identifiable Information (PII) –any information that can be used to distinguish or trace an individual’s 

identity, either alone or when combined with other personal or identifying information that is linked or linkable to a 

specific individual.

Privacy and Civil Liberties Impact Assessment (PCLIA) – a PCLIA is:

(1) a process conducted to: (a) identify privacy and civil liberties risks in systems, programs, and other 

activities that maintain PII; (b) ensure that information systems, programs, and other activities comply 

with legal, regulatory, and policy requirements; (c) analyze the privacy and civil liberties risks 

identified; (d) identify remedies, protections, and alternative or additional privacy controls necessary to 

mitigate those risks; and (e) provide notice to the public of privacy and civil liberties protection 

practices.

(2) a document that catalogues the outcome of that privacy and civil liberties risk assessment process.

Protected Information – as the term is used in this PCLIA, has the same definition given to that term in TD 25-10, 

Section 4.

Privacy Act Record – any item, collection, or grouping of information about an individual that is maintained by an 

agency, including, but not limited to, the individual’s education, financial transactions, medical history, and criminal 

or employment history and that contains the individual’s name, or the identifying number, symbol, or other 

identifying particular assigned to the individual, such as a finger or voice print or a photograph. 5 U.S.C. § 552a 

(a)(4).

Reviewing Official – The Deputy Assistant Secretary for Privacy, Transparency, and Records who reviews and 

approves all PCLIAs as part of her/his duties as a direct report to the Treasury Senior Agency Official for Privacy.

Routine Use – with respect to the disclosure of a record outside of Treasury (i.e., external sharing), the sharing of 

such record for a purpose which is compatible with the purpose for which it was collected 5 U.S.C. § 552a(a)(7).

Sharing – any Treasury initiated distribution of information to government employees or agency contractors or 

grantees, including intra- or inter-agency transfers or exchanges of Treasury information, regardless of whether it is 

covered by the Privacy Act. It does not include responses to requests for agency records under FOIA or the Privacy 

Act. It is synonymous with the term “dissemination” as used in this assessment. It is also synonymous with the
term “disclosure” as used in this assessment unless it is clear from the context in which the term is used that it refers 

to disclosure to the public in response to a request for agency records under FOIA or the Privacy Act.

System – as the term used in this manual, includes both federal information systems and information technology.

System of Records – a group of any records under the control of Treasury from which information is retrieved by 

the name of the individual or by some identifying number, symbol, or other identifying particular assigned to the 

individual. 5 U.S.C. § 552a (a)(5).

System of Records Notice – Each agency that maintains a system of records shall publish in the Federal Register 

upon establishment or revision a notice of the existence and character of the system of records, which notice shall 

include: (A) the name and location of the system; (B) the categories of individuals on whom records are maintained 

in the system; (C) the categories of records maintained in the system; (D) each routine use of the records contained 

in the system, including the categories of users and the purpose of such use; (E) the policies and practices of the 

agency regarding storage, retrievability, access controls, retention, and disposal of the records; (F) the title and 

business address of the agency official who is responsible for the system of records; (G) the agency procedures 

whereby an individual can be notified at her/his request if the system of records contains a record pertaining to him;

(H) the agency procedures whereby an individual can be notified at her/his request how she/he can gain access to 

any record pertaining to him contained in the system of records, and how she/he can contest its content; and (I) the 

categories of sources of records in the system. 5 U.S.C. § 552a (e)(4).

System Owner – Official responsible for the overall procurement, development, integration, modification, or 

operation and maintenance of a system.

Section 3: System Overview

Section 3.1: System/Project Description and Purpose

This PCLIA covers the Treasury Worker and Visitor Entry System (TWAVES). TWAVES is 

the Treasury system used to collect information from prospective Treasury visitors for 

transmission to the Executive Office of the President (the White House) so theUnited States 

Secret Service (USSS) can conduct a background check before the visitor is allowed access to 

the Main Treasury Building or the Freedman’s Bank (Annex) Building (collectively, “Main 

Treasury”). The Main Treasury Building and Annex are next door to and diagonally across the 

street from the White House, respectively. Because of its proximity to the White House, the 

USSS must clear prospective visitors before they enter Main Treasury.

The Treasury visitor approval process involves three different systems.

1. The Workers and Visitors Entry System (WAVES).

The White House uses WAVES to obtain and process information required for USSS to clear 

prospective visitors to the White House (including the old and new Executive Office buildings) 

and Main Treasury.

2. The Treasury WAVES Request System (TWRS).

TWRS is the existing portal into which Treasury employees directly input prospective Main 

Treasury visitors’ data into the WAVES. The term “Treasury” in the name of the system 

reflects the location of the direct portal into WAVES, but WAVES and TWRS are actually

operated by the White House. Prior to creation of TWAVES, Treasury employees collected and 

manually input or uploaded spreadsheets into TWRS containing the information USSS requires 

from prospective visitors. This process continues in certain circumstances where use of 

TWAVES is not feasible due to emergency or short term turnaround requests for access.
3. The Treasury Worker and Visitor Entry System (TWAVES).

TWAVES supports the mission of the Department by facilitating prospective visitors’ access to 

Main Treasury while ensuring the safety and security of Treasury employees and other 

occupants of the building, as well as sensitive Treasury information to which adversaries might 

seek access. TWAVES is the system that Treasury uses to allow prospective visitors’ to input 

their own information into a Treasury portal for automatic delivery to USSS via TWRS for 

USSS review.

Treasury maintains two portals within TWAVES to process and deliver requests to WAVES 

for USSS processing: (1) the Internal TWAVES portal (to which only Treasury employees 

have access); and (2) the External TWAVES portal (a website that prospective visitors access 

to input their information required by the White House and USSS). Therefore, TWAVES is 

one information system that has two separate places (portals) where data can be input, but both 

portals (Internal and External TWAVES) are part of the same system. Both TWAVES portals 

are used to collect personally identifiable information (PII) necessary to conduct background 

investigations for prospective visitors to Main Treasury. USSS also uses this PII to 

authenticate cleared visitors after they receive access approval and arrive for a meeting or 

event at Main Treasury.

The visitor approval process typically begins when the Treasury employee responsible for setting up 

an appointment, obtains the name and email address of a prospective Main Treasury visitor. 

Treasury employee receives the prospective visitor’s name and email address via email, text, or 

telephone. In some cases, the Treasury employee searches and retrieves the prospective visitor’s 

name and email address needed to generate a Main Treasury access request. The Treasury employee 

then uses the name and email address to create a visitor record and initiates the appointment request 

via the Internal TWAVES portal. This TWAVES portal then generates and sends an automated

email to the prospective visitor with a unique link to the External TWAVES portal (public–facing 

website).

INTERNAL TWAVES PORTAL SUMMARY

• ONLY TREASURY EMPLOYEES HAVE ACCESS

• TREASURY EMPLOYEE RECEIVES PROSPECTIVE VISITOR’S NAME AND EMAIL 

ADDRESS. 

• TREASURY EMPLOYEE INPUTS VISITOR’S NAME AND EMAIL ADDRESS INTO INTERNAL 

TWAVES

• INTERNAL TWAVES AUTOMATICALLY SENDS AN EMAIL TO THE PROSPECTIVE VISITOR 

WITH A LINK TO EXTERNAL TWAVES WHERE THEY WILL INPUT THEIR OWN 

INFORMATION

When the visitor receives the automated email from the Internal TWAVES portal and opens the 

link, they access the External TWAVES portal where they are prompted to provide the 

information USSS requires (first name, last name, Social Security number, country of birth, 

citizenship, gender and date of birth) to conduct a background investigation. Every 5 seconds, 

TWRS uses a relay server (a device that routes information between two servers) to remove all 

information input into the external TWAVES portal. Therefore, with the exception of the 

visitor’s name and email address (retained for 30 days to ensure that multiple/repeated requests 

are not submitted for the same person), all information input into the External TWAVES portal 

is removed from that system within 5 seconds of completion of the form by a prospective 

visitor and is sent to USSS (via TWRS). Treasury never sees the prospective visitor’s 

information while it is in the External TWAVES portal. After the prospective visitor submits 
their information via the External TWAVES portal, TWAVES generates an email notification 

to the Treasury email account of the employee who started the appointment process. This email 

only contains the name of the prospective visitor and notice that they completed the USSS form

in the External TWAVES portal.

EXTERNAL TWAVES PORTAL SUMMARY

• PROSPECTIVE MAIN TREASURY VISITORS RECEIVE AN EMAIL WITH A LINK TO THE 

EXTERNAL PORTAL

• PROSPECTIVE VISITOR ENTERS ALL INFORMATION REQUIRED BY USSS INTO THIS 

PORTAL

• EVERY FIVE SECONDS, THE USSS TWRS SYSTEM SWEEPS ALL DATA OUT OF THE 

EXTERNAL TWAVES PORTAL AND UPLOADS IT TO THE USSS WAVES SYSTEM

• TREASURY EMPLOYEES NEVER SEE THE DATA SUBMITTED BY THE PROSPECTIVE 

VISITOR IN THE EXTERNAL PORTAL

• ANY RETRIEVAL OF THE VISITOR INFORMATION INPUT INTO EXTERNAL TWAVES BY A 

PERSONAL IDENTIFIER HAPPENS IN USSS WAVES, NOT IN A TREASURY SYSTEM

In certain circumstance, the TWAVES portals are not used to collect the required information 

from prospective visitors. This usually occurs when visitor access is required on short notice, 

thus making it impossible to complete the Internal and External TWAVES processes. In these 

situations, Treasury personnel collect all of the required information via email or telephone and 

manually input the data into TWRS.

Information is also sometimes collected from visitors using Cvent Event Management Software

(Cvent) owned by a privately owned vendor. When Cvent is used to collect the information 

required for visitor access, all of the required information is entered on the Cvent site by the 

prospective visitor. It is then downloaded to a spreadsheet by Treasury employees and uploaded 

to TWRS.

After USSS receives a prospective visitor’s request for access, USSS runs clearancechecks using 

the information in WAVES. While waiting for USSS to make a determination, the Treasury 

employee who set up the appointment can access TWRS at any time to check on the status of a 

request. After USSS makes a final decision, TWRS generates an automated email and sends it to 

the Treasury employee who set up the appointment. If the visitor is granted access, no more 

steps are taken within the system until the visitors arrives for the scheduled Treasury meeting or 

event. If USSS rejects the request, the Treasury employee may instruct the prospective visitor 

that they have the option to resubmit their information.

Estimated Number of Individuals Whose Personally Identifiable Information is 

Maintained in the System or by the Project

☒ 0 – 999 ☐ 1,000 – 9,999 ☐ 10,000 – 99,999

☐ 100,000 – 499,999 ☐ 500,000 – 999,999 ☐ 1,000,000+

Section 3.2: Authority to Collect

o 5 U.S.C. 301 - Department regulations for the operations of the department, conduct of employees, 

distribution and performance of its business, the custody, use, and preservation of its records, papers, and 

property.

o 31 U.S.C. 321 - General authorities of the Secretary establish the mission of the Department of theTreasury.

o Executive Order 9397, Numbering System for Federal Accounts Relating to Individual Persons (1943)

(requiring the federal government to use the SSN when creating accounts for individual persons),
o Executive Order 13478, Amendments to Executive Order 9397 Relating to Federal Agency Use of Social 

Security Numbers (amending EO 9397 to rescind the requirement that federal agencies exclusively use the 

SSN, thus allowing agencies to opt to use other identifiers when feasible).

o 18 U.S.C. 3056A(3), establishes a “permanent police force” under the USSS Uniformed Division, and 

provides the USSS authority to protect the Treasury Building and grounds.

Section 4.1: Relevant and Necessary

The Privacy Act requires “each agency that maintains a system of records [to] maintain in its 

records only such information about an individual as is relevant and necessary to accomplish a 

purpose of the agency required to be fulfilled by statute or by executive order of the President.” 5

U.S.C. § 552a (e)(1). It allows federal agencies to exempt records from certain requirements 

(including the relevant and necessary requirement) under certain conditions5 U.S.C. §552a (k). 

The proposed exemption must be described in a Notice of Proposed Rulemaking (“NPRM”). In 

the context of the Privacy Act, the purpose of the NPRM is to give the public notice of a Privacy 

Act exemption claimed for a system of records and solicit public opinion on the proposed 

exemption. After addressing any public concerns raised in response to the NPRM, the agency 

must issue a Final Rule. It is possible for some, but not all, of the records maintained in the 

system or by the project to be exempted from the Privacy Act through the NPRM/Final Rule

process.

Section 4.1(a) Please check all of the following that are true:

1. ☐None of the PII maintained in the system or by the project is part of a Privacy Act system of records;

2. ☒ All of the PII maintained in the system or by the project is part of a system of records and none of it is 

exempt from the Privacy Act relevant and necessary requirement;

3. ☐ All of the PII maintained in the system or by the project is part of a system of records and all of it is 

exempt from the Privacy Act relevant and necessary requirement;

4. ☐ Some, but not all, of the PII maintained in the system or by the project is part of a system of records and 

the records to which the Privacy Act applies are exempt from the relevant and necessary requirement; and

☐ Some, but not all, of the PII maintained in the system or by the project is part of a system of records and none 

of the records to which the Privacy Act applies are exempt from the relevant and necessary requirement.

Section 4.1(b) ☒ Yes ☐ No ☐ N/A With respect to PII maintained in the system or by the project that is 

subject to the Privacy Act’s relevant and necessary requirement, was an assessment conducted prior to collection 

(e.g., during Paperwork Reduction Act analysis) to determine which PII types (see Section 4.2 below) were

relevant and necessary to meet the system’s or project’s mission requirements?

Section 4.1(c) ☐ Yes ☐ No ☒ N/A With respect to PII currently maintained in the system or by the project that 

is subject to the Privacy Act’s relevant and necessary requirement, is the PII limited to only that which is relevant 

and necessary to meet the system’s or project’s mission requirements?

Section 4.1(d) ☐ Yes ☐ No ☒ N/A With respect to PII maintained in the system or by the project that is subject 

to the Privacy Act’s relevant and necessary requirement, is there a process to continuously reevaluate and ensure

that the PII remains relevant and necessary?

Treasury does not control the process for vetting prospective Main Treasury visitors. The White House (in 

conjunction with the United States Secret Service (USSS)) determined the PII required to conduct a 

background check to determine whether a prospective visitor will be allowed access to Main Treasury. 

Treasury does not conduct the initial, current, or continuous evaluation of the relevance and necessity of the 

information collected to conduct background checks. Treasury, however, has no reason to doubt that the 

information required is only that which is required to vet prospective visitors. 

Section 4.2: PII and/or information types or groupings

To perform their various missions, federal agencies must necessarily collect various types of 

information. The checked boxes below represent the types of information maintained in the 
system or by the project. Information identified below is used by the system or project to fulfill 

the purpose stated in Section 3.3 – Authority to Collect.

Biographical/General Information

☒ Name (First and Last) ☒ Gender ☐ Group/Organization 

Membership

☒ Date of Birth ☐ Race ☐ Military Service Information

☐ HomePhysical/Postal 

Mailing Address

☐ Ethnicity ☐ Personal Home Phone orFax 

Number

☐ Zip Code ☐ Personal Cell Number ☐ Alias (including nickname)

☐ Business Physical/Postal 

Mailing Address

☐ Business Cell Number ☐ Business Phone or Fax Number

☒ Personal e-mail address ☐ Nationality ☐ Mother’s Maiden Name

☒ Business e-mail address ☒ Country of Birth ☐ Spouse Information

☐ Personal Financial 

Information (including loan

information)

☒ City and State of Residence ☐ Children Information

☐ Business Financial 

Information (including loan

information)

☐ Immigration Status ☐ Information about other 

relatives.

☐ Marital Status ☒ Citizenship ☐ Professional/personal references 

or other information about an

individual’s friends, associates or 

acquaintances.

☐ Religion/Religious 

Preference

☐ Device settings or preferences

(e.g., security level, sharing 

options, ringtones).

☐ Global PositioningSystem 

(GPS)/Location Data

☐ Sexual Orientation ☐ User names, avatars etc. ☐ Secure Digital (SD) Card or 

Other Data stored on a card or other

technology

☐ Cell tower records (e.g.,logs. 

user location, time etc.)

☐ Network communications data ☐ Cubical or office number

☐ Contact lists and directories

(known to contain personal 

information)

☐ Contact lists and directories

(not known to contain personal 

information, but uncertain)

☐ Contact lists and directories

(known to contain only business 

information)

☐ Education Information ☐ Resume or curriculum vitae ☐ Other (please describe)

☒ Other (please describe): Travel 

Information (travel in the past 30 

days, travel start and end dates, 

names of locations visited, and the 

dates visited).

☐ Other (please describe): ☐ Other (please describe):

Identifying Numbers

☒ Full Social Security number ☐ Health Plan Beneficiary Number

☐ Truncated/Partial Social Security number(e.g., 

last 4 digits)

☐ Alien Registration Number

☐ Personal Taxpayer Identification Number ☐ Business Taxpayer Identification Number (If

known: ☐ sole proprietor; ☐ non-sole proprietor)

☐ Personal Credit Card Number ☐ Business Credit Card Number (If known: ☐ sole 

proprietor; ☐ non-sole proprietor)

☐ Personal Vehicle Identification Number ☐ Business Vehicle Identification Number (If

known: ☐ sole proprietor; ☐ non-sole proprietor)

☐ Personal License Plate Number ☐ Business License Plate Number (If known: ☐

sole proprietor; ☐ non-sole proprietor)
☐ File/Case ID Number (individual) ☐ File/Case ID Number (business) (If known: ☐

sole proprietor; ☐ non-sole proprietor)

☐ Personal Professional License Number ☐ Business Professional License Number (If

known: ☐ sole proprietor; ☐ non-sole proprietor)

☐ Employee Identification Number ☐ Patient ID Number

☐ Business Bank Account Number ☐ Personal Bank Account Number

☐ Commercially obtained internet 

navigation/purchasing habits ofindividuals

☐ Government obtained internet 

navigation/purchasing habits ofindividuals

☐ Business License Plate Number (non-soleproprietor)☐ Driver’s License Number

☐ Personal device identifiers or serial numbers ☐ Other Identifying Numbers (please 

describe):

☐ Passport Number and Passport information 

(including full name, passport number, DOB,POB, 

sex, nationality, issuing country photograph and

signature) (use “Other” if some but not all elements 

are collected)

☐ Other Identifying Numbers (please 

describe):

Medical/Emergency Information Regarding Individuals

☐ Medical/Health Information ☐ Worker’s Compensation Act 

Information

☐ Patient ID Number

☐ Mental Health Information ☐ Disability Information ☐ Emergency Contact Information 

(e.g., a third party to contact in case

of emergency)

☐ Other (please describe):

Biometrics/Distinguishing Features/Characteristics of Individuals

☐ Physical description/ 

characteristics (e.g., hair, eye

color, weight, height, sex, gender 

etc.)

☐ Signatures ☐ Vascular scans

☐ Fingerprints ☐ Photos ☐ Retina/Iris Scans

☐ Palm prints ☐ Video ☐ Dental Profile

☐ Voice audio recording ☐ Scars, marks, tattoos ☐ DNA Sample or Profile

☐ Other (please describe): ☐ Other (please describe): ☐ Other (please describe):

Specific Information/File Types

☐ Taxpayer Information/Tax 

Return Information

☐ Law Enforcement Information ☐ Security Clearance/Background 

Check Information

☐ Civil/Criminal History 

Information/Police Records

(government source)

☐ Credit History Information 

(government source)

☐ Bank Secrecy Act Information

☐ Civil/Criminal History 

Information/Police Records

(commercial source)

☐ Credit History Information 

(commercial source)

☐ NationalSecurity/Classified 

Information

☐ Protected Information (as 

defined in Treasury Directive 25-

10)

☐ Case files ☐ Personnel Files

☐ Information provided under a 

confidentiality agreement

☐ Information subject to the 

terms of an international or other

agreement

☐ Other (please describe):
Audit Log and Security Monitoring Information

☐ User ID assigned to or 

generated by a user of Treasury IT

☐ Date and time an individual 

accesses a facility, system, or

other IT

☐ Files accessed by a user of 

Treasury IT (e.g., web navigation

habits)

☐ Passwords generated by or 

assigned to a user of Treasury IT

☐ Internet or other queries run 

by a user of Treasury IT

☐ Contents of files accessed by a 

user of Treasury IT

☐ Biometric information used to 

access Treasury facilities or IT

☐ Video of individuals derived 

from security cameras

☐ Public Key Information (PKI).

☐ Information revealing an 

individual’s presence in a

particular location as derived from 

security token/key fob, employee

identification card scanners or 

other IT or devices

☐ Still photos of individuals 

derived from security cameras.

☐ Internet Protocol (IP) Address

☐ Other (please describe): ☐ Other (please describe): ☐ Other (please describe):

Section 4.3: Sources of information and the method and manner of collection

Prospective Main Treasury Visitors

Specific PII identified in Section 4.2 that was acquired from this source: All data is 

collected from this source.

Manner in which information is acquired from source by the Treasury project/system: (select 

all that apply):

☒ From a paper or electronic form provided to individuals, the public or members of a particular

group Name, (First, Middle, Last), Date of Birth, SSN, citizenship, personal/business email address, 

country of birth, gender, and the names of countries visited in the past 30 days and the dates those 

countries were visited (including travel start and end dates in each country).

☐ Received in paper format other than a form.

☐ Delivered to the project on disk or other portable device and uploaded to the system.

☐ Accessed and downloaded or otherwise acquired via the internet

☒ Email/Telephone: In some instances, all information required by the White House is collected in this 

manner (when collected in Cvent or directly from the prospective visitor for direct input into TWRS). On 

some occasions, only name and email address are collected in this manner (when using TWAVES).

☐ Scanned documents uploaded to the system.

☐ Bulk transfer

 ☒ Extracted from particular technology: All information required by the White House is sometimes 

collected via the privately owned Cvent Event Registration Software for upload to TWRS by Treasury 

Operations personnel.

☐ Fax
Section 4.4: Privacy and/or civil liberties risks related to collection

When Federal agencies use a form to obtain information from an individual that will be 

maintained in a system of records, they must inform the individual of the following: “(A) the 

authority (whether granted by statute, or by executive order of the President) which authorizes 

the solicitation of the information and whether disclosure of such information is mandatory or 

voluntary; (B) the principal purpose or purposes for which the information is intended to be 

used; (C) the routine uses which may be made of the information as published pursuant to 

paragraph (4)(D) of this subsection; and (D) the effects on her/him, if any, of not providing all or 

any part of the requested information.” 5 U.S.C § 522a(e)(3).

Section 4.4(a) ☒ Yes ☐ No Is any of the PII maintained in the system or by the project collected directly from 

an individual?

Section 4.4(b) ☒ Yes ☐ No ☐ N/A Was the information collected from the individual using a form (paper or 

electronic)?

Section 4.4(c) ☒ Yes ☐ No ☐ N/A If the answer to Section 4.4(b) was “yes,” was the individual notified (on the 

form in which the PII was collected or on a separate form that can be retained by the individual) about the 

following at the point where the information was collected (e.g., in a form; on a website).

☒ The authority (whether granted by statute, or by Executive order of the President) which authorizes 

the solicitation of the information.

☒ Whether disclosure of such information is mandatory or voluntary.

☒ The principal purpose or purposes for which the information is intended to be used.

☒ The individuals or organizations outside of Treasury with whom the information may be/ will be 

shared.

☒ The effects on the individual, if any, if they decide not to provide all or any part of the requested 

information.

Treasury personnel are advised that no personally identifiable information (including name or email address) 

should ever be collected from a prospective visitor without first providing to them orally or in writing the full 

contents of the Privacy Act Statement. 

Use of Social Security Numbers

Social Security numbers (“SSN”) are commonly used by identity thieves to commit fraudulent 

acts against individuals. The SSN is one data element that has the ability to harm the individual 

and requires more protection when used. Therefore, and in an effort to reduce risk to individuals 

and federal agencies, OMB Memorandum M-07-16, Safeguarding Against and Responding to 

the Breach of Personally Identifiable Information, (May 22, 2007) (later superseded in 2016, by 

M-17-12) required agencies to reduce the use of SSNs in agency systems and programs and to 

identify instances in which the collection is superfluous. In addition, OMB mandated agencies 

to explore alternatives to agency use of SSNs as personal identifiers for Federal employees and 

members of thepublic.

In addition, the Privacy Act provides that: “It shall be unlawful for any Federal, State or local 

government agency to deny to any individual any right, benefit, or privilege provided by law 

because of such individual’s refusal to disclose his social security account number.” Pub. L. No. 

93–579, § 7. This provision does not apply to: (1) any disclosure which is required by federal 

statute; or (2) any disclosure of an SSN to any federal, state, or local agency maintaining a 

Notice of Authority, Principal Uses, Routine Uses, and Effect of not Providing 

Information
system of records in existence and operating before January 1, 1975, if such disclosure was 

required under statute or regulation adopted prior to such date to verify the identity of an 

individual. Id. at § 7(a)(2)(A)-(B).

Section 4.4(d) ☒ Yes ☐ No ☐ N/A Does the system or project maintain SSNs?

Section 4.4(e) ☐ Yes ☒ No ☐ N/A Are there any alternatives to the SSNs as a personal identifier? If yes, 

please provide a narrative explaining why other alternatives to identify individuals will not be used.

Section 4.4(f) ☒ Yes ☐ No ☐ N/A Will individuals be denied any right, benefit, or privilege provided by law 

because of such individual's refusal to disclose their SSN? If yes, please check the applicable box::

☒ SSN disclosure is required by Federal statute or Executive Order; or

☐ the SSN is disclosed to any Federal, state, or local agency maintaining a system of records in 

existence and operating before January 1, 1975, and disclosure was required under statute or regulation 

adopted prior to such date to verify the identity of an individual. If checked, please provide the name of 

the system of records in the space provided below;

Section 4.4(g) ☒Yes ☐ No ☐ N/A When the SSN is collected, are individuals given notice whether disclosure 

is mandatory or voluntary, the legal authority such number is solicited, and what uses will be made of it? If yes,

The White House requires the collection of Social Security numbers (SSNs). The White House requires each 

prospective visitor’s SSN to reduce the risk that adverse information found during a background check will be

associated with the visitor by mistake (thus resulting in an adverse determination by USSS that affects the 

visitor’s Main Treasury access request). For example, derogatory information (i.e., information indicating that 

the individual presents a risk if access is allowed) with respect to someone with the same name as the 

prospective visitor could result in rejection of the visitor’s access request. In some cases (e.g., where the SSN is 

available), the SSN allows USSS to determine that derogatory information is actually associated with the visitor 

or someone else. Its collection, therefore, protects the individual in some circumstances, but may also protect 

the safety of Treasury and White House employees(as well as structures and sensitive information) in other 

circumstances by positively identifying derogatory information with the individual, thus resulting in denial of 

access.

First Amendment Activities

The Privacy Act provides that Federal agencies “maintain no record describing how any 

individual exercises rights guaranteed by the First Amendment unless expressly authorized by 

statute or by the individual about whom the record is maintained or unless pertinent to and within 

the scope of an authorized law enforcement activity.” 5 U.S.C. § 552a(e)(7).

Section 4.4(h) ☐ Yes ☒ No Does the system or project maintain any information describing how an individual 

exercises their rights guaranteed by the First Amendment?

Section 4.4(h) If the system or project maintains information describing how an individual exercises their 

rights guaranteed by the First Amendment, do any of the following exceptions apply (the information may be 

maintained if any of the exceptions apply)?

☒ N/A (system or project does not maintain any information describing how an individual exercises their rights 

guaranteed by the First Amendment so no exceptions are needed)

☐ The individual about whom the information was collected or maintained expressly authorizes its 

collection/maintenance.

☐ The information maintained is pertinent to and within the scope of an authorized law enforcement 

activity.

☐ There is a statute that expressly authorizes its collection.

☐ N/A, the system or project does not maintain any information describing how any individual 

exercises their rights guaranteed by the First Amendment.
The system/project does not maintain any information describing how any individual exercises their rights

guaranteed by the First Amendment. Therefore, no privacy or civil liberties risks were identified in responding to 

this section.

Section 5: Maintenance, use, and sharing of the information

The following sections require a clear description of the system’s or project’s use of information.

Section 5.1: Describe how and why the system or project uses the information it

collects and maintains

Please describe all of the uses of the information types and groupings collected and maintained 

by the system or project (see Section 4.2), including a discussion of why the information is used 

for this purpose and how it relates to the mission of the bureau or office that owns the system.

The information collected via the TWAVES portals and submitted directly through TWRS is used to submit 

and process Main Treasury appointment requests and to create records to allow the USSS to initiate the 

necessary security checks on behalf of the White House to grant physical visitor access to Main Treasury. 

This supports the Department’s mission by facilitating public access to Treasury facilities while maintaining 

the necessary physical and information security requirements.

The Privacy Act requires that Federal agencies “collect information to the greatest extent 

practicable directly from the subject individual when the information may result in adverse 

determinations about an individual’s rights, benefits, and privileges under Federal programs.” 5

U.S.C. § 552a(e)(2).

Section 5.1(a) ☐ Yes ☒ No Is it possible that the information maintained in the system or by the project may 

be used by Treasury to make an adverse determination about an individual’s rights, benefits, and privileges 

under federal programs (e.g., decisions about whether the individual will receive a financial benefit, get a 

clearance or access to a Treasury facility, obtain employment with Treasury)?

Section 5.1(b) ☒ Yes ☐ No Is it possible that Treasury will share information maintained in the system or by 

the project with a third party external to the Department that will use the information to make an adverse

determination about an individual’s rights, benefits, and privileges under federal programs?

Section 5.1(c) ☒ Yes ☐ No ☐ N/A If information could potentially be used to make an adverse determination 

about an individual’s rights, benefits, and privileges under federal programs, does the system or project collect 

information (to the greatest extent practicable) directly from the individual?

In all processes, Treasury collects the information directly from the individual (the prospective visitor). The 

information collected in the External TWAVES portal, through Cvent, and manually in certain circumstances is 

only shared with the White House and USSS to enable USSS to make Main Treasury access determinations. The 

decision to allow or deny access to Treasury facilities based on the PII collected is the sole responsibility of the 

White House (after the USSS background check).

Data Mining

As required by Section 804 of the Implementing the 9/11 Commission Recommendations Act of

2007 (“9-11 Commission Act”), Treasury reports annually to Congress on its data mining 

activities. For a comprehensive overview of Treasury’s data mining activities, please review the 

Department’s Annual Privacy reports available at: http://www.treasury.gov/privacy/annualreports.

Collecting Information Directly from the Individual When Using it to Make Adverse 

Determinations About Them
Section 5.1(d) ☐ Yes ☒ No Is information maintained in the system or by the project used to conduct “datamining” activities as that term is defined in the Implementing the 9-11 Commission Act?

No data-mining activities are conducted using the information in the internal and external TWAVES portals.

Therefore, no privacy or civil liberties risks were identified in response to this section.

Section 5.2: Ensuring accuracy, completeness, and timeliness of information

collected, maintained, and shared

Exemption from Accuracy, Relevance, Timeliness, and Completeness Requirements

The Privacy Act requires that Federal agencies “maintain all records which are used by the 

agency in making any determination about any individual with such accuracy, relevance, 

timeliness, and completeness as is reasonably necessary to assure fairness to the individual in the 

determination.” 5 U.S.C § 552a(e)(5). If a particular system of records meets certain 

requirements (including the NPRM process defined in Section 2 above), an agency may exempt 

the system of records (or a portion of the records) from this requirement.

Section 5.2(a) ☐ Yes ☒ No Is all or any portion of the information maintained in the system or by the project:

(a) part of a system of records and (b) exempt from the accuracy, relevance, timeliness, and completeness

requirements in sections (e)(5) of the Privacy Act?

No exemptions are claimed from the accuracy, relevance, timeliness, or completeness requirements. Therefore,

no privacy or civil liberties issues were identified with respect to this section.

Computer Matching

The Computer Matching and Privacy Protection Act of 1988 amended the Privacy Act imposing 

additional requirements when Privacy Act systems of records are used in computer matching 

programs.

Pursuant to the Privacy Act, as amended, there are two distinct types of matching programs. The 

first type of matching program involves the computerized comparison of two or more automated 

federal personnel or payroll systems of records or a system of federal personnel or payroll 

records with non-federal records. This type of matching program may be conducted for any 

purpose. The second type of matching program involves the computerized comparison of two or 

more automated systems of records or a system of records with non-federal records. The 

purpose of this type of matching program must be for the purpose of eligibility determinations or 

compliance requirements for applicants, recipients, beneficiaries, participants, or providers of 

services for payments or in-kind assistance under federal benefit programs, or recouping 

payments or delinquent debts under such federal benefit programs. See 5 U.S.C. § 522a(a)(8).

Matching programs must be conducted pursuant to a matching agreement between the source 

and recipient agencies. The matching agreement describes the purpose and procedures of the 

matching and establishes protections for matching records.

Section 5.2(b) ☐ Yes ☒ No Is any of the information maintained in the system or by the project (a) part of a 

system of records and (b) used as part of a matching program?

Section 5.2(c) ☐ Yes ☐ No ☒ N/A Is there a matching agreement in place that contains the information 

required by Section (o) of the Privacy Act?

Section 5.2(d) ☐ Yes ☐ No ☒ N/A Are assessments made regarding the accuracy of the records that will be 

used in the matching program?

Section 5.2(e) ☐ Yes ☐ No ☒ N/A Does the bureau or office that owns the system or project independently 
verify the information, provide the individual notice and an opportunity to contest the findings, or obtain Data

Integrity Board approval in accordance with Section (p) of the Privacy Act before taking adverse action against 

the individual?

None of the information Treasury collects in TWAVES, through Cvent, or manually for direct input into TWRS is 

used as part of a matching program. Therefore, no privacy or civil liberties risks were identified in response to this 

section.

Ensuring Fairness in Making Adverse Determinations About Individuals

Federal agencies are required to “maintain all records which are used by the agency in making 

any determination about any individual with such accuracy, relevance, timeliness, and 

completeness as is reasonably necessary to assure fairness to the individual in the

determination.” 5 U.S.C. § 552a(e)(5). This requirement also applies when merging records 

from two or more sources where the merged records are used by the agency to make any 

determination about any individual.

Section 5.2(f) ☒ Yes ☐ No With respect to the information maintained in the system or by the project, 

are steps taken to ensure all information used to make a determination about an individual is maintained with

such accuracy, relevance, timeliness, and completeness as is reasonably necessary to assure fairness to the 

individual in the determination?

Treasury does not have the ability to fix incorrect information that the visitor inputs into the External TWAVES 

portal. When the prospective visitor opens the link in the email generated via the Internal TWAVES portal, they 

receive the following notice: “Please note that your prospective visitor request could be delayed if the 

information submitted for approval is incomplete or incorrect. Please verify all data entered before submitting

each request.” If incorrect information is provided, the appointment owner has the option to cancel the record 

and create a new record with the correct information.

If the White House or USSS determine that information Treasury personnel collect from Cvent or manually from 

the prospective visitor and directly input into TWRS is incorrect, the prospective visitor will have the option of 

submitting the information again if adequate time remains before the event.

Merging Information About Individuals

Section 5.2(g) ☐ Yes ☒ No Is information maintained in the system or by the project merged with 

electronic or non-electronic information from internal or external sources (e.g., other files or systems)?

Section 5.2(h) ☐ Yes ☐ No ☒ N/A Once merged, is the information used in making determinations about 

individuals (e.g., decisions about whether the individual will receive a financial benefit or payment, get a 

clearance or access to a Treasury facility, obtain employment with Treasury, etc.)?

Section 5.2(i) ☐ Yes ☐ No ☒ N/A Are there documented policies or procedures for how information is 

merged?

Section 5.2(j) ☐ Yes ☐ No ☒ N/A Do the documented policies or procedures address how to proceed 

when partial matches (where some, but not all of the information being merged matches a particular 

individual) are discovered after the information is merged?

Section 5.2(k) ☒ Yes ☐ No ☐ N/A If information maintained in the system or by the project is used to 

make a determination about an individual, are steps taken to ensure the accuracy, relevance, timeliness, and

completeness of the information as is reasonably necessary to assure fairness to the individual?

No merging is done in TWAVES. Therefore, no privacy or civil liberties risks were identified with respect to 

TWAVES in responding to this section.
Policies and Standard Operating Procedures or Technical Solutions Designed 

to Ensure Information Accuracy, Completeness, and Timeliness

Section 5.2(l) ☒ Yes ☐ No ☐ N/A If information maintained in the system or by the project is used to 

make any determination about an individual (even if it is an exempt system of records), are there 

documented policies or standard operating procedures for the system or project that address the accuracy, 

completeness, and timeliness of the information?

Section 5.2(m) ☒ Yes ☐ No Does the system or project use any software or other technical solutions 

designed to improve the accuracy, completeness, and timeliness of the information used to make an adverse

determination about an individual's rights, benefits, and/or privileges (regardless of if it is an exempt system

of records)?

TWAVES includes instructions via the landing pages in Internal and External TWAVES to ensure the 

accuracy, relevance, timeliness and completeness of PII.

Treasury employees are warned to verify accuracy via the following text on the landing page (before they 

enter the Internal TWAVES portal): “Visitor requests should be submitted 24 hours in advance of an 

appointment. If your prospective visitor is a foreign national, please submit their information at least 72 

hours in advance of the scheduled meeting. Your prospective visitor request could be delayed if the 

information submitted for approval is incomplete or incorrect, so please verify all data entered before 

submitting each request.”

It is also possible that the prospective visitor could input incorrect data in the External WAVES portal, but 

the likelihood is reduced by allowing visitors to input their own information and warning them that failure to 

review their information (in the External TWAVES portal) before submitting the request could delay approval

of their access request.

Cvent users are also advised of the importance of submitting accurate information.

All required information is collected directly from the prospective visitors in all processes.

a

Section 5.2(n) ☐ Yes ☒ No Did Treasury or the bureau receive any guarantee, assurance, or other 

information from any information source(s) regarding the accuracy, timeliness and completeness of the

information maintained in the system or by the project?

Treasury does not receive any express guarantees from prospective visitors regarding the accuracy of the 

data they input via any of these processes, but the individual is warned to ensure the accuracy of their 

information provided to Treasury for submission to the White House and USSS. The prospective visitor can 

also resubmit their request if the USSS finds the information to be inaccurate and, therefore, denies the 

request.

Disseminating Notice of Corrections of or Amendments to PII

Section 5.2(o) ☐ Yes ☒ No ☐ N/A Where feasible and appropriate, is there a process in place for 

disseminating corrections of or amendments to the PII maintained in the system or by the project to all 

internal and external information-sharing partners?

Section 5.2(p) ☐ Yes ☐ No ☒ N/A Where feasible and appropriate, does the process for 

disseminating corrections or amendments include notifying the individual whose information is 

corrected or amended?

All of the PII collected in all Treasury processes is provided voluntarily. If the information is inaccurate or

causes denial of access, the prospective visitor has the option to resubmit the request (if adequate time 

remains before the proposed visit). 

Accuracy, Completeness, and Timeliness of Information Received from the Source
Section 5.3: Information sharing within the Department of the Treasury

Internal Information Sharing

Section 5.3(a) ☐ Yes ☒ No Is PII maintained in the system or by the project shared with other Treasury 

bureaus?

Section 5.3(b) ☒ Yes ☐ No Does the Treasury bureau or office that receives the PII limit access to those 

Treasury officers and employees who have a need for the PII in the performance of their official

duties (i.e., those who have a “need to know”)?

None of the information collected for processing visitor access requests is shared with other Treasury bureaus 

of offices. No privacy and civil liberties risks were identified because there is no internal disclosure of 

information collected pursuant to the relevant processes to other Treasury bureaus and offices. Therefore, no 

privacy or civil liberties were identified in responding to this section.

Memorandum of Understanding/Other Agreements Limiting Treasury’s Internal 

Use/Disclosure of PII Internal Information Sharing

Section 5.3(c) ☐ Yes ☐ No ☒ N/A Is any of the PII maintained in the system or by the project subject to the

requirements of a Memorandum of Understanding or other agreement (e.g., agreement with another federal

or state agency that provided the information to the Treasury or subject to an international agreement or treaty) that 

limits or places conditions on Treasury’s internal use, maintenance, handling, or disclosure of the PII?

There are no MOUs limiting Treasury’s use of the information in the system, but Treasury does not share the 

information internally. Therefore, no privacy or civil liberties issues were identified in response to this section.

Section 5.4: Information sharing with external (i.e., outside Treasury) organizations

and individuals

Section 5.4(a) ☐ Yes ☒ No Is PII maintained in the system or by the project shared with agencies, 

organizations, or individuals external to Treasury?

All Treasury processes are conducted for the purpose of collecting PII required by the White House so USSS can

conduct background checks. This external disclosure is accounted for in the routine uses for the applicable SORN 

(Treasury/DO .216, Treasury Security Access Control and Certificates Systems System of Records).

Accounting of Disclosures

Section 5.4(b) ☐ Yes ☒ No ☐ N/A With respect to records maintained in the system or by the project that 

are subject to the Privacy Act, do you maintain a paper or electronic log or other record of the date, nature, and 

purpose of each disclosure (not including intra-agency disclosures and FOIA disclosures) of a record to any 

person or to another agency (outside of Treasury) and the name and address of the person or agency to whom 

the disclosure is made? See 5 U.S.C § 552a(c).

Section 5.4(c) ☒ Yes ☐ No ☐ N/A If you do not keep a running tabulation of every disclosure at the time it is 

made, are you able to reconstruct an accurate and complete accounting of disclosures so as to be able to respond 

to Privacy Act requests in a timely fashion?

Section 5.4(d) ☐ Yes ☐ No ☒ N/A With respect to records maintained in the system or by the project that are 

subject to the Privacy Act, do you retain the log or other record of the date, nature, and purpose of each 

disclosure, for at least five years or the life of the record, whichever is longer, after the disclosure for which the 

accounting is made?

Section 5.4(e) ☐ Yes ☒ No ☐ N/A With respect to records maintained in the system or by the project that are 

subject to the Privacy Act, does your bureau or office exempt the system of records (as allowed by the Privacy Act
in certain circumstances) from the requirement to make the accounting available to the individual named in the 

record?

Section 5.4(f) ☐ Yes ☐ No ☒ N/A With respect to records maintained in the system or by the project that are 

subject to the Privacy Act, does your bureau or office exempt the system of records (as allowed by the Privacy 

Act in certain circumstances) from the requirement to inform any person or other agency about any

correction or notation of dispute made by the agency of any record that has been disclosed to the person or agency 

if an accounting of the disclosure was made?

Statutory or Regulatory Restrictions on Disclosure

Section 5.4(g) ☐ Yes ☒ No In addition to the Privacy Act, are there any other statutory or regulatory 

restrictions on the sharing of any of the PII maintained in the system or by the project (e.g., 26 U.S.C § 6103

for tax returns and return information)?

With the exception of the Privacy Act, there are no statutory or regulatory restrictions on the PII in the 

system. 

Memorandum of Understanding Related to External Sharing

Section 5.4(h) ☒ Yes ☐ No ☐ N/A Has Treasury (including bureaus and offices) executed a 

Memorandum of Understanding, or entered into any other type of agreement, with any external agencies,

organizations, or individuals with which/whom it shares PII maintained in the system or by the project?

TWAVES maintains a Master Service Agreement with the company that hosts the application. This 

agreement details the services provided by the host company. PII is not shared with the host company’s 

personnel (see below). TWAVES shields its data from the host company by encrypting data both at rest and

in transit. The host and its personnel cannot see the data processed by the application.

Memorandum of Understanding Limiting Treasury’s 

Use or Disclosure of PII

Section 5.4(i) ☐ Yes ☒ No Is any of the PII maintained in the system or by the project subject to the 

requirements of a Memorandum of Understanding or other agreement (e.g., agreement with another 

federal or state agency, an international agreement or treaty, or contract with private vendor that provided 

the information to Treasury or one of its bureaus) that limits or places conditions on Treasury’s internal 

use or external (i.e., outside Treasury) sharing of the PII?

None of the PII in the system is subject to the terms of an MOU that limits or places conditions on 

Treasury’s internal or external use. Therefore, no privacy or civil liberties issues were identified in 

responding to this section.

Memorandum of Understanding Limiting External Party’s 

Use or Disclosure of PII

Section 5.4(j) ☐ Yes ☒ No Is any of the PII maintained in the system or by the project subject tothe 

requirements of a Memorandum of Understanding or other agreement in which Treasury limits or places

conditions on an external party’s use, maintenance, handling, or disclosure of PII shared by Treasury?

None of the PII in the system is subject to the terms of an MOU in which Treasury limits or places conditions 

on an external third party’s use. Therefore, no privacy or civil liberties issues were identified in responding

to this section.

Section 5.4(k) ☐ Yes ☒ No Is information from the system or project shared externally?

External Recipient’s 

Name

The White House and the 

United States Secret 

Service

N/A N/A

Purpose of the Sharing 

PII Shared

Conducting background 

checks on prospective 

visitors to Main

Treasury.

N/A N/A

External Information Sharing Chart
Content of Applicable 

Routine Use/Citation to the 

SORN

To the United States 

Secret Service (USSS) 

and the White House to 

grant or deny access to 

individuals seeking 

access to Treasury

facilities or cyber assets.

N/A N/A

Applicable Statutory or 

Regulatory or Restrictions

on Information Shared

N/A N/A N/A

Name and Description of 

Relevant MOUs or Other 

Agreements Containing 

Sharing Restrictions 

Imposed on Treasury by an 

External Source or 

Source/Originating Agency 

(including description of 

restrictions imposed on use, 

maintenance, and

disclosure of PII)

N/A N/A N/A

Name and Description of 

Relevant MOUs or Other 

Agreements Containing 

Restrictions Imposed by

Treasury on External

N/A N/A N/A

Sharing Partner (including 

description of restrictions 

imposed on use,

maintenance, and 

disclosure of PII)

 N/A N/A N/A

Method(s) Used to Transfer 

PII (e.g., paper/ oral 

disclosures/magnetic 

disk/portable device/email 

fax/other (please describe if 

other)

Every 5 seconds, the 

USSS TWRS uses a relay 

server to extract all 

information input into 

the External TWAVES 

portal. Therefore, all 

information input into 

external TWAVES is 

removed from that 

system within 5 seconds 

and is automatically sent

to USSS (via TWRS).

Information manually 

input into TWRS is 

automatically uploaded to 

White House WAVES.

N/A N/A

Section 5.4(l) ☐ Yes ☐ No ☒ N/A Is the individual’s consent obtained, where feasible and appropriate, 

prior to any new disclosures of previously collected records in a system of records (those not expressly

authorized by the Privacy Act or contained in the published SORN (e.g., in the routine uses))?

There are no new disclosures. 

Obtaining Consent Prior to New Disclosures Not Included in the SORN or Authorized 

by the Privacy Act
Section 6: Compliance with federal information management

requirements

Responses to the questions below address the practical, policy, and legal consequences of 

failing to comply with one or more of the following federal information management 

requirements (to the extent required) and how those risks were or are being mitigated: (1) the 

Privacy Act System of Records Notice Requirement; (2) the Paperwork Reduction Act; (3) the 

Federal Records Act; (4) the E-Gov Act security requirements; and (5) Section 508 of the

Rehabilitation Act of 1973.

Section 6.1: Privacy Act System of Records Notice (SORN)

For collections of PII that meet certain requirements, the Privacy Act requires that the agency 

publish a SORN in the Federal Register.

System of Records

Section 6.1(a) ☐ Yes ☒ No Does the system or project retrieve records about an individual using an 

identifying number, symbol, or other identifying particular assigned to the individual? (see items selected in 

Section 4.2 above)

Section 6.1(b) ☒ Yes ☐ No ☐ N/A Was a SORN published in the Federal Register for this system of

records?

Treasury/DO .216, Treasury Security Access Control and Certificates Systems System of Records is 

published in the Federal Register.

Section 6.2: The Paperwork Reduction Act

The PRA requires OMB approval before a Federal agency may collect standardized data from 10 

or more respondents within a 12 month period. OMB requires agencies to conduct a PIA (a 

Treasury PCLIA) when initiating, consistent with the PRA, a new electronic collection of PII for 

10 or more persons (excluding agencies, instrumentalities, or employees of the federal 

government).

Paperwork Reduction Act Compliance

Section 6.2(a) ☐ Yes ☒ No Does the system or project maintain information obtained from individuals and 

organizations who are not federal personnel or an agency of the federal government (i.e., outside the federal 

government)?

Section 6.2(b) ☐ Yes ☐ No ☒ N/A Does the project or system involve a new collection of information in

identifiable form for 10 or more persons from outside the federal government?

Section 6.2(c) ☐ Yes ☐ No ☒ N/A Did the project or system complete an Information Collection Request 

(“ICR”) and receive OMB approval?

Treasury is not the “sponsor” of the information collection activities conducted via this system and, for that

reason, is not required to prepare an Information Collection Request.

Section 6.3: Records Management - NARA/Federal Records Act Requirements

Records retention schedules determine the maximum amount of time necessary to retain 

information in order to meet the needs of the project or system. Information is generally either 

disposed of or sent to the NARA for permanent retention upon expiration of this period.
NARA Records Retention Requirements

Section 6.3(a) ☒ Yes ☐ No Are the records used in the system or by the project covered by NARA’s 

General Records Schedules (“GRS”) or Treasury/bureau Specific Records Schedule (SRS)?

Section 6.3(b) ☒ Yes ☐ No Did NARA approved a retention schedule for the records maintained in the 

system or by the project?

Section 6.3(c) ☐ Yes ☐ No ☒ N/A If NARA did not approve a retention schedule for the records 

maintained in the system or by the project and the records are not covered by NARA’s GRS or 

Treasury/bureau SRS, has a draft retention schedule (approved by all applicable Treasury and/or Bureau 

officials) been developed for the records used in this project or system?

Section 6.4: E-Government Act/NIST Compliance

The completion of Federal Information Security Management Act (“FISMA”) Security 

Assessment & Authorization (SA&A) process is required before a federal information system 

may receive Authority to Operate (“ATO”). Different security requirements apply to National 

Security Systems.

Federal Information System Subject to FISMA Security Assessment and Authorization

Section 6.4(a) ☒ Yes ☐ No ☐ N/A Is the system a federal information system subject to FISMA requirements?

Section 6.4(b) ☒ Yes ☐ No ☐ N/A Has the system or project undergone a SA&A and received ATO?

Access Controls and Security Requirements

Section 6.4(c) ☒ Yes ☐ No Does the system or project include access controls to ensure limited access to 

information maintained by the system or project?

In accordance with the TWAVES System Security Plan and NIST 800-53 rev.4 requirements, the system develops, 

disseminates, and reviews an organizational access control policy that addresses purpose, scope, roles, 

responsibilities, management commitment, coordination among organizational entities, and compliance to 

personnel with system level access to TWAVES.

User roles and responsibilities are documented in two sections: The roles and responsibilities identified are 

defined in accordance with the Department of the Treasury policy.

The policies are disseminated to all users of the TWAVES application that have associated IT security roles and 

responsibilities; using a secured common collaboration site with notifications of new or updated security 

documentation being facilitated via email.

Treasury collects data for transfer to the White House. These are “intermediary records” that are governed 

by General Records Schedule (GRS) 5.2, item 020 and, accordingly, are destroyed after creation of the final 

document or file (in particular, the visitor request file that is established in the USSS TWRS/WAVES). 

Treasury employees are instructed to delete any additional Treasury records that may have been created 

when collecting information from prospective visitors after notice is received from USSS that entry has been 

allowed or declined.

A limited set of data (visitor name and email address) are retained in Treasury’s (TWAVES) system for a 

longer period (30 days), for the business purpose of minimizing duplicate visitor requests in the External 

TWAVES portal (e.g., two visitor requests for the same visitor by two different Treasury employees involved 

in setting up the meeting).
TWAVES develops, documents, and disseminates procedures to facilitate the implementation of the access control 

policy and associated access controls to personnel with system level access to the application. Access control 

policies and procedures are documented within Treasury’s Access Control and Account Management Plan (ACAMP); which is disseminated to all users of the TWAVES Application who have associated IT security roles and 

responsibilities via Treasury’s SharePoint site.

Security Controls When Sharing Internally or Externally

Section 6.4(e) ☒ Yes ☐ No ☐ N/A Are all Treasury/bureau security requirements met in the method of

transferring information (e.g., bulk transfer, direct access by recipient, portable disk, paper) from the Treasury 

project or system to internal or external parties?

All internal traffic within TWAVES is encrypted and adheres to FIPS 140-2 requirements (AES-128 or -256)

Monitoring of Individuals

Section 6.4(f) ☒ Yes ☐ No Will this system or project have the capability to identify, locate, and monitor 

individuals or groups of people?

Audit capabilities are performed by Cloud Service Provider (CSP) and adhere to NIST 800-53 rev 4 

requirements to ensure proper use of the TWAVES system. Audit trails and logs are maintained by Salesforce

(the contractor that maintains the system). Alerts are sent via Treasury email to designated contacts. No audit 

information is maintained within TWAVES.

Audit Trails

Section 6.4(g) ☒ Yes ☐ No Are audit trails regularly reviewed for appropriate use, handling, and disclosure of 

PII maintained in the system or by the project inside or outside of the Department?

Audit capabilities are performed by the CSP and adhere to NIST 800-53 rev 4 requirements to ensure proper

use of the TWAVES system. Audit trails and logs are maintained by the CSP. Alerts are sent via Treasury email 

to designated contacts. No audit information is maintained within TWAVES.

Section 6.5: Section 508 of the Rehabilitation Act of 1973

When Federal agencies develop, procure, maintain, or use Electronic and Information 

Technology (“EIT”), Section 508 of the Rehabilitation Act of 1973 (as amended in 1998) 

requires that individuals with disabilities (including federal employees) must have access and use 

(including privacy policies and directives as well as redress opportunities) that is comparable to 

that which is available to individuals who do not have disabilities.

Section 6.5(a) ☒ Yes ☐ No Will the project or system involve the development, procurement, maintenance or 

use of EIT as that term is defined in Section 508 of the Rehabilitation Act of 1973 (as amended in 1998)?

Section 6.5(b) ☒ Yes ☐ No ☐ N/A Does the system or project comply with all Section 508 requirements, 

thus ensuring that individuals with disabilities (including federal employees) have access and use (including 

access to privacy and civil liberties policies) that is comparable to that which is available to individuals who do 

not have disabilities?

TWAVES is accessible by both disabled and non-disabled users. The end user uses their own equipment

which should be appropriately configured for their needs. The same is true if the user manually sends their data 

to a Treasury employee for input into TWRS.

Applicability of and Compliance With the Rehabilitation Act
Section 7: Redress

Access Under the Freedom of Information and Privacy Act

Section 7.0(a) ☒ Yes ☐ No Does the agency have a published process in place by which individuals may seek 

records under the Freedom of Information Act and Privacy Act?

Treasury FOIA and Privacy Act disclosure regulations can be found at 31 C.F.R. Part 1, Subtitle A, Subparts

A and C.

Privacy Act Access Exemption

Section 7.0(b) ☐ Yes ☒ No Was any of the information that is maintained in system of records and used in the 

system or project exempted from the access provisions of the Privacy Act?

None of the records in this system of records (the email address and name of the visitor) are exempt from the 

Privacy Act access requirements.

Additional Redress Mechanisms

Section 7.0(c) ☐ Yes ☒ No With respect to information maintained by the project or system (whether or not 

it is covered by the Privacy Act), does the bureau or office that owns the project or system have any additional 

mechanisms other than Privacy Act and FOIA remedies (e.g., a customer satisfaction unit; a complaint process) 

by which an individual may request access to and/or amendment of their information and/or contest adverse 

determinations about denial of their rights, benefits, and privileges under federalprograms (e.g., decisions about 

whether the individual will receive a financial benefit, get a clearance or access to a Treasury facility, obtain 

employment with Treasury)?

If audit logs indicate cause for concern of improper use of TWAVES, users are allowed to explain their

system usage before any adverse action is taken, as per Treasury policy.

Approval Signature

Ryan Law

Deputy Assistant Secretary

Office of Privacy, Transparency, and Records 

Departmental Offices

U.S. Department of the Treasury