Privacy and Civil Liberties Impact Assessment 

for 

Treasury PKI Key Recovery System (TPKRS)

March 19, 2019 

Reviewing Official 

Timothy H. Skinner 

Bureau Privacy and Civil Liberties Officer 

Office of Privacy and Civil Liberties 

Department of the Treasury 

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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. 

A PCLIA was not previously conducted for this system. 

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, 

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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). 

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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. 

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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 Treasury Enterprise Identity Credential and Access Management (TEICAM) Office works 

with Treasury offices, Bureaus, and other stakeholders to advance Treasury’s capability and 

improve IT key initiatives, particularly for decrypting email data needed for a variety of PKIenabled initiatives. TPKRS is a new system that will provide Treasury Bureaus with the ability 

to enable the decryption of encrypted email messages for authorized personnel. Overall, the 

system allows Treasury Bureaus to significantly enhance the protection of data by enabling the 

use of Secure/Multipurpose Internet Mail Extensions (S/MIME) without compromising the ability 

to access that information for authorized purposes. TPKRS is a specialized system in that it 

provides specific information management resources and support operations to current Treasury 

email services at a number of participating Treasury Bureaus. 

TPKRS leverages Zeva’s DecryptNaBox and MobileDecrypt solutions. The DecryptNabox 

solution eliminates inefficiencies associated with traditional email decryption processes as well 

as removes the need to have direct access to private encryption keys of email users. The 

MobileDecrypt solution will allow users to read encrypted email messages on government-issued 

mobile devices without the need for direct access to smart card credentials or user private keys. 

TPKRS securely stores and handles a non-exportable escrow of Treasury private encryption keys 

and certificates from the Treasury Operational Certification Authority (TOCA) Public Key 

Infrastructure (PKI) to facilitate the use of S/MIME on government furnished equipment. 

Therefore, the system leverages the use of sensitive but unclassified information because it deals 

with certificates that contain Personally Identifiable Information (PII). 

The certificates being stored contain the following PII information: 

• Name 

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• Universal Unique Identifier (UUID); 

• Treasury personnel work email; and 

• Federal Agency Smart Credential Number (FASC-N). 

TPKRS does not collect or generate any new PII. The system obtains user PKI public certificates 

by sourcing them from Treasury’s public Lightweight Directory Access Protocol (LDAP). 

Private keys are escrowed from Treasury’s TOCA KED using three layers of encryption during 

transport. As described in the PCLIA document, there is PII data in PKI certificates; however, 

the PII found in the certificates is already available in the public domain. 

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 

OMB M-12-18 – Managing Government Records Directive (requiring the management of all permanent and 

temporary email records in readable electronic format to facilitate transfer to the National Archives and 

Records Administration). 

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 conditions. 5 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 

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☐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 necessaryrequirement. 

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? 

Treasury certificates used by TPKRS are referenced in Treasury SORNs: TREASURY .216 Reasonable 

Accommodations Records and TREASURY .012 Fiscal Service Public Key Infrastructure (PKI) System. Yes, 

the team evaluated the information needed to implement TPKRS and determined that the PII maintained on the 

digital certificates (which house the PII) were the minimum required to achieve the TPKRS mission goals. 

Decryption is not possible without the information maintained on the certificates. The system is subject to 

reevaluation of the PII controls during the annual security assessments and authorization (SA&A) process 

which includes ensuring all PII maintained is still relevant and necessary. 

Section 4.2: PII and/or information types or groupings 

To perform their 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. 

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☐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 

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☐Personal device identifiers or serial numbers ☒ Other Identifying Numbers (please describe): 

Federal Agency Smart Card Credential Number 

(FASC-N) 

☐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): 

Universally unique identifier (UUID). 

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) 

☐ 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 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 

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☐ 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): 

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 

Treasury Certificate Authority 

Specific PII identified in Section 4.2 that was acquired from this source: Certificate Authority. 

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 

Please identify the form name (or description) and/or number (e.g., OMB ControlNumber): 

☐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 

☐Scanned documents uploaded to the system. 

☐Bulk transfer 

☐ Extracted from particular technology (e.g., radio frequency identification data (RFID) devices, video or 

photographic cameras, biometric collection devices). 

☐Fax 

☐Extracted from notes of a phone interview or face to face contact 

☒ Other: Please describe: 

Extracted from Treasury Certificate Authority 

For PIV purposes, the CA will only accept requests from the USAccess Card Management Service (CMS), as it

has sole authorization to perform PIV management functions on this system. 

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

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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. 

TPKRS imports Treasury certificate from the Treasury Operational Certification Authority (TOCA). TPKRS

does not collect any data directly from individuals. 

Use of Social Security Numbers 

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

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

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

individuals and federal agencies, government-wide initiatives aimed at eliminating unnecessary 

collection, use, and display of SSN have been underway since OMB required agencies to review 

their SSN practices in 2007. 

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 

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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 below explaining why other alternatives to identify individuals will not be used. 

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

law if the individual refuses 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 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 below how the notice is provided. 

TPKRS does not maintain SSNs. 

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(g) ☐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. 

TPKRS does not maintain information describing how any individual exercises their rights guaranteed by the 

First Amendment. 

12 
 

 

 

 

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 PII collected and maintained in TPKRS, is used only for decrypting emails. Federal regulations require 

that agencies have a capability to decrypt official records which include email. Therefore, the primary 

objective of TPKRS is to retrieve email records on the Treasury network. Situations in which this is required 

may include: support of federal investigations or expiration/loss of PIV (revocation of certificates). The 

purpose of TPKRS directly aligns to the mission of the Treasury PKI Program within the TEICAM Office, 

where collection and maintenance of keys is part of their mission as well as ensuring appropriate personnel 

are able to obtain government encrypted messages when needed. 

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? 

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. 

13 
 

 

 

 

 

 

 

 

 

 

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? 

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? 

None of the information maintained in TPKRS is exempt 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? 

14 
 

 

 

 

 

 

 

 

 

 

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 maintained in TPKRS is used as part of a matching program. 

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 ☒ N/A. 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 use information in TPKRS to make any determinations about individuals. Certificates (which

contain the PII) are used only to decrypt emails. 

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? 

The information maintained in TPKRS is not merged with electronic or non-electronic information from internal 

or external sources (e.g., other files or systems). 

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 

15 
 

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)? 

Treasury does not use information in TPKRS to make any determinations about individuals. 

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? 

Treasury does not use information in TPKRS to make any determinations about individuals. If a particular 

certificate contained inaccurate information, it might affect the ability to decrypt a message, but would not be 

used to the detriment of any individual. 

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? 

The Treasury Operational Certification Authority (TOCA), managed by the Bureau of Fiscal Service (Fiscal 

Service) receives its updates from USAccess system components, managed by the General Services 

Administration (GSA). In turn, these components receive updates of major data elements (e.g., name, 

organization, etc.) from HR Connect (HRC) while other data elements (e.g., UPN, mail) come from the bureau. 

In either case, all data elements are synchronized by the Treasury hosted PIV Data Synchronization (PDS) 

solution component. The PDS also publishes this data to the Treasury Enterprise Directory Service (TEDS). 

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”)? 

TPKRS does not share any of the PII in the certificates with any of the Treasury bureaus. Access to the PII in

the certificates is limited based on need to know. 

Memorandum of Understanding (MOU)/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? 

TPKRS does not get any data from outside federal agencies which would limit or put conditions on internal 

usage of PII. 

16 
 

 

 

 

 

 

 

 

Internal Information Sharing Chart 

Internal Recipient’s 

Name (e.g., bureau or 

office) 

Fiscal Services/DO – MOU still being drafted 

Purpose of the Sharing Certificate sharing (PKI) 

PII Shared Public Key Certificate, which contains: 

- Name 

- Treasury government E-mail address 

- Federal Agency Smart Credential Number (FASC-N) 

- Universal Unique Identifier (UUID) (an employee ID number) 

Applicable Statutory or - PKI security (NIST 800-63) 

Regulatory or - NIST 800-53, TDP 85-01, and DO 910 

Restrictions on - Treasury Certificate Policy (CP) 

Information Shared 

Applicable Restrictions 

Imposed by Agreement 

on Information Shared 

(e.g., by Treasury 

agreement with the 

party that provided the 

information to Treasury) 

- Certificates will only be used for agreed upon purpose 

- TPKRS will not share PII data with any other systemexternal/internal without 

approval from system owners/AO 

Name and Description 

of MOU or Other 

Agreement Restricting 

Treasury’s Internal Use, 

Maintenance, Handling, 

or Sharing of PII 

Received 

TPKRS MOU (draft in progress) 

Method of PII Transfer 

(e.g., paper/oral 

disclosures/magnetic 

disk/portable 

device/email/fax/other 

(please describe if other) 

Electronic transfer via certificate services between FS and TPKRS 

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? 

TPKRS does not share any PII externally. 

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? 

17 
18 

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? 

TPKRS does not disclose any PII data externally for any reason. 

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 any no statutory or regulatory restrictions on the sharing of any of the PII maintained in TPKRS, but

none of the PII is shared. 

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? 

There are no MOUs with any external agencies, organizations, or individuals, restricting the sharing of any of 

the PII maintained in TPKRS, but none of the PII is shared. 

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? 

No, the certificates belong to the Department of the Treasury. There are no sources of data which are owned 

externally. 

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? 

Yes, currently Zeva contractors physically maintain and administer TPKRS. These contractors are required to 

acknowledge and sign a Confidentiality and Non-Disclosure Agreement (NDA) that places conditional access to 

certain government documents or materials containing PII. These contractors are also required to review and 

sign the TPKRS Rules of Behavior (RoB) document, which reinforces conditions stated in the NDA, regarding 

the use and handling of PII. 

External Information Sharing Chart 
 

 

 

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

TPKRS will not disclose PII internally or externally. 

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))? 

TPKRS will not disclose PII internally or externally. 

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? 

The PII on the certificates is not retrieved in TPKRS using a personal identifier. The records are, however, 

covered by the following Treasury SORNs: TREASURY .216 Reasonable Accommodations Records and 

TREASURY .012 Fiscal Service Public Key Infrastructure (PKI) System. 

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)? 

19 
 

 

 

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? 

TPKRS does not collect any records directly from individuals. 

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? 

TPKRS does not create any new records, but uses copies of records from another system of records. The GRS 

that covers copies of records from another system is the GRS 5.2, item 010 for Transitory Records. 

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? 

TPKRS has completed the SA&A process and is subject to FISMA requirements. The ATO date is 10/18/2017 

and expires 10/18/2020. 

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? 

The system is protected by trusted role based access control and enforces least privileges to ensure limited 

access to the system and data to only those permissions needed to perform duties. 

Security Risks in Manner of Collection 

20 
 

 

 

 

 

 

 

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)? 

N/A 

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? 

Yes, the certificate data transfer is protected using FIPS 140-2 validated encryption through a VPN tunnel 

established between Fiscal Service and TPKRS. 

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? 

The system has the capability to monitor Treasury personnel and contractors’ activities to ensure system use 

that is consistent with the TPKRS Rules of Behavior. TPKRS does not monitor any activities of members of the 

public. 

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? 

The PKI Policy Management Authority (PMA) has a compliance audit mechanism in place to 

perform audit log review in accordance with the Treasury Certificate Policy (CP). A full backup of 

the certificate management database and audit logs is performed each month during the Monthly 

Certificate Revocation List (CRL) publication. 

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? 

The ISSO and ISSM met with the Records Management Office and confirmed that TPKRS has low impact as the

system is not assessed or viewable by the user community. 

21 
 

 

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 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? 

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)? 

22 
 

 

Responsible Officials 

Timothy H. Skinner 

Bureau Privacy and Civil Liberties Officer 

U.S. Department of the Treasury 

Fred Asomani-Atinkah 

TEICAM-Treasury Enterprise Identity Credential & Access Management Office 

U.S. Department of the Treasury 

Approval Signature 

Timothy H. Skinner 

Bureau Privacy and Civil Liberties Officer 

U.S. Department of the Treasury 

23