Privacy and Civil Liberties Impact Assessment Template

Privacy and Civil Liberties Impact Assessment

for the

WORKPLACE.GOV COMMUNITY CLOUD (WC2)

January 30, 2018

Reviewing Official

Ryan Law

Deputy Assistant Secretary for Privacy, Transparency, and Records

Department of the Treasury

Bureau Certifying Official

Timothy H. Skinner 

Bureau Privacy and Civil Liberties Officer

Office for Privacy, Transparency, and Records

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. 

This PCLIA is being conducted for the Workplace.gov Community Cloud (WC2) IaaS for the 

first time. A Privacy Threshold Analysis (PTA) was initially completed for WC2 and its 

predecessor system, Treasury.gov. 

This PCLIA covers the Workplace.gov Community Cloud (WC2), including the Treasury 

Application and Platform Services (APS). The following major applications will also be hosted 

on WC2 but maintain their own Authority to Operate (ATO):

 Entry on Duty System (EODS)

 USA Spending.gov (USAS)

 Office of the Fiscal Assistant Secretary (OFAS) Section 1603
Individual PCLIAs were completed for these applications, which can be found on the Treasury 

Privacy and Civil Liberties Impact Assessment page at: 

https://www.treasury.gov/privacy/PIAs/Pages/default.aspx.

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-Government – 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

The purpose of WC2 is provide a community cloud infrastructure for Treasury systems and 

applications to host data and utilize shared resources. The WC2 platform allows Treasury 

customers to focus on the operational and business aspects of their web presence such as 

usability, information architecture and content authoring without having to re-invent and 

configure the technical infrastructure each time. The primary function of the WC2 system is to 

allow for customers to consume cloud Platform as a Service (PaaS) and Software as a Service 

(SaaS). PII is used to identify and authenticate users and to address the requirements of specific 

applications. It supports the mission of the Department by providing a cloud platform for its user 

to access infrastructure resources more effectively and efficiently.
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

 The authorities supporting the collection of PII related to the identification and authentication of users 

and monitoring of employee system usage on WC2 are:

o 31 U.S.C. 321, General authorities for the Secretary establishes the mission of the Department of 

Treasury.

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.

Section 4: Information Collection

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 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? 

Section 4.1a: The records collected regarding an internal Treasury user’s activities while logged into the 

system are covered by Treasury .015, Treasury General Information Technology Access Account Records. 

WC2 itself is not publically accessible so the system has no public users. 

Contact information collected voluntarily from members of the public who communicate with Treasury are 

covered by Treasury .017—Correspondence and Contact Information. Records collected from federal 

employees and contractors to allow them to obtain credentials necessary for access to federally controlled 

information systems is covered by GSA/GOVT-7 - Personal Identity Verification Identity Management System 

(PIV IDMS) September 28, 2006 71 FR 56983. These SORNs may be found at: 

https://www.treasury.gov/privacy/issuances/Pages/default.aspx

Section 4.1b-d: Internally, the PII maintained in this system is limited to only that which is necessary for 

identification and authentication of users who require access to the WC2 Platform. These users are limited to 

Treasury employees and contractors. For public users, the only PII collected is that which is voluntarily 

submitted by the user for general contact and communication purposes and is limited to publicly available 

contact information.

The PII maintained in the system is continuously re-evaluated as part of the continuous monitoring process for 

WC2. Annual security assessments are performed including an annual Privacy Requirements review and 

necessary updates. Additionally, in accordance with the WC2 System Security Plan, updates to privacy 

documentation are required after any significant change to the system mission or purpose that results in 

changes to the type or manner in which PII is collected. 

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 ☐ Gender ☐ Group/Organization 

Membership

☐ Date of Birth ☐ Race ☐ Military Service Information

☐ Home Physical/Postal 

Mailing Address

☐ Ethnicity ☐ Personal Home Phone or Fax 

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 or County of Birth ☐ 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 Positioning System 

(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): ☐ 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 of individuals

☐ Government obtained internet 

navigation/purchasing habits of individuals

☐ 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)

☐ National Security/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 Treasury 

user authorized to use Treasury IT.

☒ 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): See 

other audit log capabilities 

discussed in Section 6.4(f).

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

_____________________

Other

☐ Other (please describe: ______________ ☐ Other (please describe: _______________

☐ Other (please describe: ______________ ☐ Other (please describe: _______________

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

Name, business 

Email and User ID

Passwords 

generated by or 

assigned to a user 

of Treasury IT and 

date and time an 

individual accesses 

a facility, system, 

or other IT

Specific PII identified 

in Section 4.2 that was 

acquired from this 

source: new 

user/account 

onboarding.

Specific PII identified 

in Section 4.2 that was 

acquired from this 

source: MS Active 

Directory.

Manner in which 

information is acquired 

from source by the 

Treasury 

project/system: (select 

all that apply):

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

☐ From a paper or 

electronic form provided 

to individuals, the public 

or members of a 

particular group

Please identify the form 

name (or description) 

and/or number (e.g., 

OMB Control Number): 

Treasury WC2 User 

Access or Change 

Request

_________________

Please identify the form 

name (or description) 

and/or number (e.g., 

OMB Control Number): 

_________________

☒ Email ☐ Email 

☐ Other: Please 

describe:

_________________

☒ Other: Please 

describe:
User logins are recorded 

by MS Active Directory 

with timestamp for 

auditing and security 

purposes.

Passwords are generated 

by WC2 Administrators. 

Users of WC2 are 

notified of their password 

via email. Passwords are 

stored in MS Active 

Directory.

Internet or other 

queries run by a 

user of Treasury IT

Internet Protocol (IP 

Address)

Specific PII identified in 

Section 4.2 that was 

acquired from this 

source: Sophos UTM 

Firewall.

Specific PII identified in 

Section 4.2 that was 

acquired from this 

source: Sophos UTM 

Firewall.

Manner in which 

information is acquired 

from source by the 

Treasury project/system: 

(select all that apply):

Manner in which 

information is acquired 

from source by the 

Treasury project/system: 

(select all that apply):

☒ Other: Please describe:

Network traffic and 

activity is logged via 

Sophos UTM Firewall and 

stored via Splunk for audit 

and security purposes.

☒ Other: Please describe:

Network traffic and 

activity, including IP 

address, is logged via 

Sophos UTM Firewall and 

stored via Splunk for audit 

and security purposes.

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

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

Information

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.

No Privacy and Civil Liberties risks were identified. Users are notified of the above via access agreements and 

WC2 rules of behavior (which describe the things users can and cannot do while using the system), as well as 

organizational warning banners prior to accessing the WC2 Platform (which warn users that they are on a 

government system and describes limitations on privacy while using the system).

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) 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 the public. 

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 

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, 

please explain what means are used to provide notice. 

Social Security Numbers are not collected or maintained by WC2. Therefore, no privacy or civil liberties issues 

were identified in response to this question.

First Amendment Activities

The Privacy Act provides that Federal agencies may “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 or project does not maintain any information describing how an individual exercises their rights 

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

this question.

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 and maintained in the system is used for the following purposes: (1) to identify and 

authenticate internal Treasury users of the WC2 platform, (2) to address requirements of specific 

applications, and (3) to facilitate communication between the Department and public users. 

The following types of information are collected: names, business email address (though users may choose to 

provide a personal email address), user ID assigned to users of Treasury IT, passwords assigned to users of 

Treasury IT, date/time a user accessed a facility or system, Internet or other queries run by user, and IP 

address.

Names are collected for multiple purposes. Internal users are verified via their name prior to receiving 

Treasury generated credentials. Additionally, names are used to create Treasury IT email addresses. 

Furthermore, names of public users are collected on a voluntary basis if the user wishes to submit a contact 

request. Collecting the names of public users helps facilitate open and effective communication between the 

Department and the public. This usage is consistent with the Department of Treasury’s mission because it 

allows the bureau to identify internal users for security purposes as well as communicate effectively with the 

general public to establish transparency and good governance.

As noted in Section 4.2, the system also collects and maintains business email addresses (though users may 

choose to provide a personal email address). This information is provided on a voluntary basis from public 

users and is collected via electronic form if the user wishes to submit a contact or information request. 

Collecting the business (or personal) email addresses of public users helps Department employees respond to 

public inquiries. This usage is consistent with the Department of Treasury’s mission because it allows the 

bureau to communicate effectively with the general public to establish transparency and good governance.

As additionally noted in Section 4.2, the system also collects and maintains user IDs assigned to users of 

Treasury IT, passwords assigned to users, date/time a user accessed a facility or system, internet or other 

queries run by users, and Internet Protocol (IP) address. User IDs are generated for authorized Treasury IT 

users and are stored in MS Active Directory for identification and authentication purposes. User IDs are also 

assigned passwords, which are stored in MS Active Directory. Collecting and maintaining user IDs and 

passwords allows the Department to ensure that access to the system is both authorized and secure. 

The system collects and maintains date/time a user accesses a facility or system, internet or other queries run 

by the user, and IP address for audit and security purposes. By collecting this information, the Department 

reviews user activities to ensure that IT assets and PII are protected and user activity is efficient, secure and 

mission focused. Additionally, this information provides useful metrics about system usage, maintenance, and 

general flow of operations. This usage is consistent with the Department of Treasury’s mission because it 

allows the bureau to protect internal IT assets, as well as track user activities for security, audit, and 

operational purposes.

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

Determinations About Them

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? 

Information collected regarding a user’s activities while logged into the system, including internet or other 

queries run by the user are used for audit and security purposes. If an employee committed criminal activities 

while logged into a Treasury system, they may be referred to the Department of Justice for prosecution. 

Treasury users who engage in activities that violate Treasury Rules of Behavior may also lose their access 

privileges under certain circumstances. The logs that collect user activity information are tied to the user 

account set up for a specific user. Users are identified and authenticated before they are allowed to access and 

use the system. Therefore, the information comes directly from the individual to the extent that it tracks their 

system activities. No adverse determinations are made based solely on user logs. An individual suspected of 

improper use is given an opportunity to explain when possible, unless doing so would impede or otherwise 

hinder a criminal investigation.

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.

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 privacy and civil liberties risks were identified because the information in the system is not used to conduct 

data-mining.

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? 

 The records collected regarding a user’s activities while logged into the system are covered by 

Treasury .015, Treasury General Information Technology Access Account Records. 

 Contact records collected voluntarily from members of the public who communicate with Treasury are 

covered by Treasury .017—Correspondence and Contact Information. 
 Records collected from federal employees and contractors to allow them to obtain credentials 

necessary for access to federally controlled information systems is covered by GSA/GOVT-7 -

Personal Identity Verification Identity Management System (PIV IDMS) September 28, 2006 71 FR 

56983. These SORNs may be found ahttps://www.treasury.gov/privacy/issuances/Pages/default.aspx.

 None of these SORNs exempt the records from the accuracy, relevance, timeliness, and completeness 

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

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 records in the system are used as part of a matching program. Therefore, no privacy or civil liberties 

issues were identified in response to this question.

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?

Information collected regarding a user’s activities while logged into the system, including internet or other 

queries run by the user, are used for audit and security purposes. The information is electronically captured

based on the system user’s activities. Other information maintained in the system (business email and name) is 

collected directly from the individual. No adverse determinations are made based solely on user logs. An 

individual suspected of improper use is given an opportunity to explain when possible, unless doing so would 

impede or otherwise hinder a criminal investigation.

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 privacy or civil liberties risks were identified because no merging is done.

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)? 
Information collected regarding an internal Treasury user’s activities while logged into the system, including 

internet or other queries run by the user are collected electronically and used for audit and security 

purposes. The system only logs activities associated with the individual who was identified and authenticated 

using a particular user’s credential. To the extent the information is electronically captured, it is a technical 

solution that ensures accuracy of the individual user’s activities.

Information captured for audit and security purposes is collected and maintained in accordance with Audit 

and Accountability requirements detailed in NIST Special Publication 800-53, revision 4.

Other information maintained in the system (business or personal email, and name) is collected directly from 

the individual (members of the public), but is not used to make determinations about them. 

Accuracy, Completeness, and Timeliness of Information Received from the Source

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? 

System users do not guarantee the accuracy of the information they provide, but they do have an incentive to 

provide accurate, timely and complete information since they will be denied access to the system without it. 

If any information provided is inaccurate, untimely, or incomplete, Treasury will follow up with the user to 

get accurate information before allowing them access to the system.

Members of the public who submit information to Treasury in order to get information from Treasury also do 

not expressly guarantee that the information they provide is accurate. They do, however, have an incentive to 

provide accurate information so they can get the information from Treasury that they requested. If the 

information is inaccurate or incomplete, the impact is that the public user may not receive the requested 

contact or information, or may be prompted to re-submit their request with accurate information so that their 

query can be addressed. Therefore the risk is low and acceptable.

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? 

Corrections or amendments to PII maintained in the system follow the Department’s Change Control policy 

and are documented in Change Requests (CR) as per DO IT policy. If an internal user’s information is 

altered, WC2 administrators will verify and confirm the changes with the affected individual to ensure 

accuracy.

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”)?

All PII is stored securely in the WC2 system which requires specific permissions for access. Only individuals 

granted specific access will be given access to PII. Access is granted on a least-privilege basis as per DO IT 

policy. 
Memorandum of Understanding/Other Agreements Limiting Treasury’s Internal 

Use/Disclosure of PII

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. Therefore, no privacy or civil 

liberties issues were identified in response to this question.

Internal Information Sharing Chart

Information from the system is not currently shared with other Treasury bureaus and offices. If internal 

disclosure becomes necessary in the future, this PCLIA will be updated to reflect that change. Therefore, no 

privacy or civil liberties issues were identified in response to this question.

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

and individuals

External Information Sharing

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? 

The WC2 platform provides data separation from Amazon by encrypting data both at rest and in transit. 

Amazon resources/personnel will have no visibility of the data processed by the WC2 platform. Also, if the user 

logs reflect possible criminal activity by a system user, the information could potentially be shared with the 

Department of Justice. Such a determination would not be based solely on the information in the user log. An 

individual suspected of improper use is given an opportunity to explain when possible, unless doing so would 

impede or otherwise hinder a criminal investigation. Records may also be shared externally as allowed by the 

routine uses described in the applicable SORNs.

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

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?

If the user logs reflect possible criminal activity by a system user, the information could potentially be shared 

with the Department of Justice. Such a determination would not be based solely on the information in the 

user log. An individual suspected of improper use is given an opportunity to explain when possible, unless 

doing so would impede or otherwise hinder a criminal investigation. If such disclosures occur in the future, 

Treasury will maintain a log of all such disclosures to DOJ and other external sources as allowed by the 

routine uses described in the applicable SORNs.

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)? 

There are no statutory restrictions on any of the PII in the system other than the Privacy Act. Therefore, no 

privacy or civil liberties issues were identified in response to this question.

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? 

WC2 maintains an MOU/ISA with AWS, the Cloud Service Provider for this System. The MOU states that all 

data at rest and in transit for the WC2 platform is encrypted with FIPS 140-2 compliant encryption, 

providing strict data separation from AWS and WC2. AWS has no visibility on any data hosted in WC2.

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? 

There are no MOUs limiting Treasury’s use or disclosure of the information in the system. Therefore, no 

privacy or civil liberties issues were identified in response to this question.

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 to the 

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? 

There is an MOU/ISA with AWS, the cloud service provider for this system, which limits the cloud service 

provider’s access, use or disclosure of the information in the system by requiring encryption of all data both 

at rest and in transit. WC2 ensures that there is complete data separation; AWS has no visibility of any data 

hosted on WC2.

External Information Sharing Chart

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

No sharing with DOJ or any other external parties has occurred yet. AWS is the service provider so the 

information is housed in the AWS cloud, but is subject to the terms of a Treasury MOU/ISA with AWS that limits 

that access. Records may also be shared externally as allowed by the routine uses described in the applicable 

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

by the Privacy Act

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))? 

The system does not disclose externally any records that are not listed in the routine uses stated in the

applicable SORNs. Therefore, no privacy or civil liberties risks were identified. 

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? 

Records maintained in the system are retrieved by a personal identifier and are covered by the following 

SORNs:

 The records collected regarding a user’s activities while logged into the system are covered by 

Treasury .015, Treasury General Information Technology Access Account Records. 

 Contact records collected voluntarily from members of the public who communicate with Treasury 

are covered by Treasury .017—Correspondence and Contact Information. 

 Records collected from federal employees and contractors to allow them to obtain credentials 

necessary for access to federally controlled information systems is covered by GSA/GOVT-7 -

Personal Identity Verification Identity Management System (PIV IDMS) September 28, 2006 71 

FR 56983. 

 These SORNs may be found at: https://www.treasury.gov/privacy/issuances/Pages/default.aspx

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? 

The PRA is does not apply because information is only collected regarding federal IT users. The PRA contains 

an exemption for information collections limited to government employees.

None of the information collected from members of the public is subject to the PRA requirements because basic 

requests of this nature are exempt from the PRA requirements. 

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?

There is a general records schedule for user logs. GRS 3.1, Item 020 (IT operations and maintenance 

records) indicates a three year retention period.

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 WC2 System Security Plan and NIST 800-53 rev.4 requirements, WC2 has 

developed, disseminated, and reviewed 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 WC2. 

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

defined in accordance with the Department of Treasury policy. The policies have been disseminated to all 

users of the WC2 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. Updates to policies will be disseminated in the same fashion, if and when they occur.

WC2 has developed, documented, and disseminated procedures to facilitate the implementation of the access 

control policy and associated access controls to personnel with system level access to WC2. Access control 

policies and procedures are documented within Treasury’s Access Control and Account Management Plan 

(AC-AMP).

Security Risks in Manner of Collection

Section 6.4(d) ☐ Yes ☒ No In Section 4.3 above, you identified the sources for information used in the 

system or project and the method and manner of collection. Were any security, privacy, or civil liberties risks 

identified with respect to the manner in which the information is collected from the source(s)? 

No security, privacy or civil liberties risks were identified.

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 WC2 is encrypted and adheres to Federal Information Processing Standards (FIPS)

140-2 requirements. Password protection and encryption decisions for data shared externally are made on a 

case by case basis depending on the associated risk.

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? 

Splunk captures audit logs and generates reports that describe user activity. This includes information that 

establishes what type of event occurred, when the event occurred, where the event occurred, the source of the 

event, the outcome of the event, and the identity of any individuals or subjects associated with the event. 

Windows and Red Hat, security events that are turned on for this solution contain all required content to 

meet NIST 800-53 rev 4 requirements. 

Events audited by operating system settings on instances for WC2 are: 

Microsoft Windows Events:

• Account Logon Events – Success or Failure

• Account Management – Success or Failure

• Directory Service Access – Failure

• Logon Events - Success or Failure

• Object Access - Success or Failure

• Policy Change – Success

• Privilege Use - Success or Failure

• Process Tracking - Success or Failure

• System Events - Success or Failure
Red Hat Events:

• Date/Time changes

• User/Group Account Modifications

• Network information Modifications (hostname, system locale)

• Access Control Modifications

• Login/Logout Events

• Session Initiation Events

• File Access – Failure

• Privileged Command Execution

• Successful File System Mounts

• File Deletion Events

• Kernel Module Loading and Unloading

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? 

WC2 reviews and analyzes information system audit records at least weekly for indications of audit collection 

anomalies. Weekly reviews of audit records are performed through Splunk for audit collection anomalies. 

Anomalies or inappropriate or unusual activity in the logs include multiple failed access attempts from the 

same individual. Individual solution components are configured to overwrite security logs as required. Logs 

within the environment are automatically forwarded to the Splunk indexer in near-real time. The Splunk 

indexer maintains storage capacity for up to 6 years of online storage. This capacity was increased as 

required by Treasury organizational retention requirements and FedRAMP guidance from half a terabyte to 

two terabytes. Splunk has the capability of notifying administrators of audit collection anomalies.

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.

Applicability of and Compliance With the Rehabilitation Act

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? 

No privacy or civil liberties risks were identified. Internal users with disabilities that require access shall be 

equipped for access and use to the WC2 environment in accordance with Treasury requirements regarding

Section 508 of the Rehabilitation Act of 1973 (as amended in 1998). External users of sites hosted on WC2 

platform use personal devices, which should be fitted for their specific needs, but the website is designed to 

accommodate devices that address those needs.

Section 7: Redress

Access Under the Freedom of Information Act 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? 

The Treasury/bureaus FOIA and PA 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? 

No exemptions are claimed in the applicable SORNs.

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 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)? 

As mentioned above, users are allowed to explain their system usage before any adverse action is taken. An 

individual suspected of improper use is given an opportunity to explain when possible, unless doing so would 

impede or otherwise hinder a criminal investigation..