Privacy and Civil Liberties Impact Assessment 

for the 

External Facing Web Applications

Foreign Credit Reporting System (FCRS)

September 27, 2019

Reviewing Official 

Timothy H. Skinner

Bureau Privacy and Civil Liberties Officer

Departmental Offices

Department of the Treasury

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Section 1: Introduction 

PCLIAs are required for all systems and projects that collect, maintain, or disseminate personally identifiable 

information (PII). The system owner completed this assessment 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 E-Government 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 (not including agencies, instrumentalities, or employees of 

the federal government). 

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

PCLIA when PII is maintained in a system or by a project. 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. 

Section 2: System Overview 

Section 2.1: System/Project Description and Purpose 

The Foreign Credit Reporting System (FCRS) system is a public, front facing website with a backend database to 

store all of the FCRS financial data and reports as well as metrics pertaining to the system. The FCRS web site 

allows specific federal users to access the FCRS application to share credit data and reports 

https://fcrs.treas.gov/FCRS_PublicSite/. External Federal Users of FCRS are: The Office of Management and 

Budget, Aid Agency, Export-Import Bank of the United States (EXIM), Overseas Private Investment Corporation 

(OPIC), United States Department of Agriculture (USDA), Department of Defense (DOD), and the Financial 

Management Service (FMS), as well as members and staff of the Congress. The information in the reports in the 

system do not contain PII. 

Treasury uses PII in the FCRS application to build system accounts for external government agencies. PII includes: 

name, email, system user name, and phone number of the individuals who login. The PII listed is not shared; it is 

used only to maintain application accounts where external agencies can gather reports as needed. Use of this PII 

supports the mission of the Department by creating user accounts in the FCRS system to allow users to login. No 

PII is shared internally or externally unless Treasury discovers that a system user is misusing the system. 

1. ☒ A PCLIA is being done for this system for the first time. 

2. This is an update of a PCLIA previously completed and published under this same system or project 

name. The date the earlier PCLIA was published was March 15, 2013 

☐

3. This is an update of a PCLIA previously completed and published for a similar system or project that is 

undergoing a substantial modification or migration to a new system or project name. The name of that 

previous PCLIA was [Name the PCLIA here] and the date of its publication was [provide here the date the 

earlier PCLIA was published]. 

☐

4. 

Section 2.2: Authority to Collect 

Federal agencies must have proper authority before initiating a collection of information. The authority is sometimes 

granted by a specific statute, by Executive order (EO) of the President or other authority. 

The information may also be collected pursuant to a more general requirement or authority. All Treasury systems 

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and projects derive general authority to collect information from: 

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

Treasury 

- 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 2.3: Privacy Act Applicability; SORN Requirement Under certain circumstances, federal agencies are allowed to exempt a system of records from certain provisions in 

the Privacy Act. This means that, with respect to information systems and papers files that maintain records in that 

system of records, the agency will not be required to comply with the requirements in Privacy Act provisions that 

are properly exempted. If this system or project contains records covered by the Privacy Act, the applicable Privacy 

Act system of records notice(s) (SORNs) (there may be more than one) that cover the records in this system or 

project must list the exemptions claimed for the system of records (it will typically say: “Exemptions Claimed for 

the System” or words to that effect). 

Section 2.3(a) 

1. ☐ The system or project does not retrieve records about an individual using an identifying number, 

symbol, or other identifying particular assigned to the individual. A SORN is not required with respect to 

the records in this system. 

2. ☒ The system or project does retrieve records about an individual using an identifying number, symbol, 

or other identifying particular assigned to the individual. A SORN is required with respect to the records in 

this system. 

3. A SORN was identified in the original PCLIA and a determination was made during this current 

PCLIA update that modifications [choose one] 

☐

☐ were ☐ were not required to th at SORN. The current 

applicable SORN is: 

4. A SORN(s) was not identified or required in the original PCLIA, but a determination was made during 

this current PCLIA update that a SORN(s) is now required. The applicable SORN(s) is: 

☐

5. ☒ A SORN was published and no exemptions are taken from any Privacy Act requirements. 

TREASURY .015, General Information Technology Access Account Records. 

6. Exemptions are claimed from the following Privacy Act provisions in the applicable SORN(s): [List 

here all exemptions taken in the applicable SORN; Hint: it’s at the end of the SORN]: 

☐

Section 3: Information Collection 

Section 3.1: 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 

accomplished 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 F inal 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 3.1(a) Exemption Claimed from this Requirement? 

1. ☒ The PII maintained in this system or by this project is not exempt from 5 U.S.C. § 552a(e)(1), the 

Privacy Act’s requirement that an agency “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 accomplished 

by statute or by executive order of the President.” 

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2. ☐ The PII maintained in this system or by this project is exempt from 5 U.S.C. § 552a(e)(1), because 

OCTS/OFAC’s systems deal with enforcement, designation, blocking, and other investigations. 

Section 3.1(b) Continuously Assessing Relevance and Necessity 

1. The PII in the system is not maintained in a system of records. Therefore, the Privacy requirements do 

not apply. [Explain here what you do to ensure relevance and necessity despite the fact that the Privacy 

Act does not apply]. 

☐

2. The PII in the system is maintained in a sy stem of records, but the agency exempted these records 

from the relevance and necessity requirement. 

☐

3. ☒ The system owner conducted an assessment prior to collecting PII for use in th e system or project to 

determine which PII data elements and types (see Section 3.2 below) were relevant and necessary to meet 

the system’s or project’s mission requirements. In conducting the “relevance and necessity” analysis that 

is documented in this PCLIA, the system owner reevaluated the necessity and relevance of all PII data 

elements and determined that they are still relevant and necessary. Every time this PCLIA is updated, this 

ongoing assessment will be revisited. If it is determined at any time that certain PII data elements are no 

longer relevant or necessary, the system owner will update this PCLIA to discuss how the data element(s) 

were removed from the system and no longer collected. 

4. ☒ With respect to PII currently maintained (as of the time this PCLIA is being done) in the system or by 

the project, the PII [choose one] ☒ is ☐ is not limited to only that which is relevant and necessary to meet 

the system’s or project’s mission requirements. During the PCLIA process, the system always undergoes a 

review to ensure the continuing relevance and necessity of the PII in the system. 

5. ☒ With respect to PII maintained in the system or by the project, there [choose one] ☒ is is not a 

process in place to continuously reevaluate and ensure that the PII remains relevant and necessary. During 

the PCLIA process, the system always undergoes a review to ensure the continuing relevance and necessity 

of the PII on the system. If a determination is made that particular PII is no longer relevant and necessary 

in between PCLIA updates, this PCLIA will be updated at that time. 

☐

Section 3.2: PII and/or information types or groupings 

The checked boxes below represent the types of information maintained in the system or by the project that are 

relevant and necessary for the information system or project to fulfill its mission. PII identified below is used by 

the system or project to fulfill the purpose stated in Section 2.2 above– Authority to Collect. 

Biographical/general information 

☒ Name ☐ Nationality ☐ Country of Birth 

☐ Age ☐ Citizenship ☐ Immigration Status 

☐ Date of birth ☐ Ethnicity ☐ Alias (including nickname) 

☐ Home physical/postal mailing 

address 

☐ Gender ☐ City or County of Birth 

☐ Zip Code ☐ Race ☐ Military Service Information 

☒ Personal home phone, cell phone, 

or fax number (business phone) 

☐ Personal e-mail address ☒ Other (please describe): 

Business email____________ 

☐ Country or city of residence ☒ Other (please describe): Role in 

organization 

☒ Other (please describe): User name 

(system) 

Other information 

☐ Resume or curriculum vitae ☐ Cubical or office 

number 

☐ Veteran’s preference 

☐ Religion/Religious Preference ☐ Education Information [please 

describe] 

☐ Spouse Information 

☐ Professional/personal references 

or other information about an 

individual’s friends, associates or 

acquaintances. 

☐ Contact lists and directories 

(known to contain at least some 

personal information). 

☐ Retirement eligibility information 

☐ Sexual Orientation ☐ Marital Status ☐ Information about other relatives. 

☐ Group/Organization Membership ☐ Information about children ☐ Other (please describe): 

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

Identifying numbers assigned to individuals 

☐ Full Social Security number ☐ Personal device identifiers or serial 

numbers 

☐ Vehicle Identification Number 

☐ Truncated Social Security Number 

(e.g., last 4 digits) 

☐ Internet Protocol (IP) Address ☐ Driver’s License Number 

☐ Employee Identification Number ☐ Personal Bank Account Number ☐ License Plate Number 

☐ Taxpayer Identification Number ☐ Health Plan Beneficiary Number ☐ Professional License Number 

☐ File/Case ID Number ☐ Credit Card Number ☐ Other (please describe): 

☐ Alien Registration Number ☐ Patient ID Number ☐ Other (please describe): 

☐ Passport Number and information 

(nationality, date and place of 

issuance, and expiration date) 

☐ 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 (obtained 

from government source) 

☐ Civil/Criminal History 

Information/Police Records (obtained 

from commercial source) 

☐ Credit History Information 

(government source) 

☐ Protected Information (as defined 

in Treasury Directive 25-10) 

☐ Credit History Information 

(commercial source) 

☐ Bank Secrecy Act Information 

☐ Information provided under a 

confidentiality agreement 

☐ Case files ☐ Personnel Files 

☐ Business Financial Information 

(including loan information) 

☐ Personal Financial Information (e.g., 

loan information) 

☐ Information subject to the terms of an 

international or other agreement 

☐ Passport information (state which 

passport data elements are collected if 

not all) 

☐ Other (please describe): 

______________________ 

☐ Other (please describe): 

______________________ 

Audit Log and Security Monitoring Information 

☒ User ID assigned to or generated 

by a user of Treasury IT 

☒ Files and folders accessed by a user 

of Treasury IT 

☐ Biometric information used to access 

Treasury facilities or 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 

☒ Files accessed by a user of 

Treasury IT (e.g., web navigation 

habits) 

☒ Date and time an individual accesses 

a facility, system, or other IT 

☐ Information revealing an individual’s 

presence in a particular location as 

derived from security token/key fob, 

employee identification card scanners or 

other IT. 

☐ Public Key Information (PKI). ☐ Still photos of individuals derived 

from security cameras. 

☐ Purchasing habits or preferences 

☐ Internet Protocol (IP) Address ☐ Video of individuals derived from 

security cameras 

☐ Commercially obtained internet 

navigation/purchasing habits of 

individuals 

☐ Global Positioning System ☐

(GPS)/Location Data 

Secure Digital (SD) Card or Other 

Data stored on a card or other 

technology 

☐ Device settings or preferences (e.g., 

security level, sharing options, ringtones). 

☐ Network communications data ☐ Cell tower records (e.g., logs. user 

location, time etc.) 

☐ Other (please describe): 

_____________________ 

Medical/Emergency Information Regarding Individuals 

☐ Medical/Health Information ☐ Worker’s Compensation Act 

Information 

☐ Emergency Contact Information (e.g., 

a third party to contact in case of 

emergency 

☐ Mental Health Information ☐ Information regarding a disability ☐ Patient ID Number) 

☐ Sick leave information ☐ Request for an accommodation 

under the Americans with Disabilities 

Act 

☐ Patient ID Number 

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Other: [Explain here]. 

 

Detailees. Discuss here how/why PII is collected from this source. 

☐ Other employment-related positions. [name the position here and discuss how/why PII is 

ollected from this source.]. 

☐ Other_______________ ☐ Other________________ ☐ Other__________________ 

Biometrics/Distinguishing Features/Characteristics of Individuals 

☐ Physical description/ characteristics 

(e.g., hair, eye color, weight, height, 

sex, gender etc.) Identify which are 

collected: ________________ 

☐ Signatures ☐ Palm prints 

☐ Fingerprints ☐ Photos/Video (identify which: 

_____________) 

☐ Voice audio recording 

☐ Other (please describe): 

______________________ 

☐ Other (please describe): 

_______________________ 

☐ Other (please describe): 

_______________________ 

Identifying numbers for sole proprietors (including business information). 

☐ Sole proprietor business credit card 

number 

☐ Business Phone or Fax Number ☐ Business Physical/Postal Mailing 

Address 

☐ Sole proprietor business 

professional license number 

☐ Sole proprietor business file case 

number 

☐ Sole proprietor business taxpayer 

identification number 

☐ Sole proprietor business license 

plate number 

☐ Sole proprietor business vehicle 

identification number 

☐ Sole proprietor business bank account 

number 

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

3.3 Sources from which PII is obtained 

1. Members of the Public 

☐ Members of the Public (i.e., including individuals who are current federal employees who are providing the 

information in their “personal” capacity (unrelated to federal work/employment). All of the following are 

members of the public. Please check relevant boxes (based on the context of collection and use in this system) for 

members of the public whose information is maintained in the system (only check if relevant to the purpose for 

collecting and using the information): 

☐ Members of the general public (current association with the federal government, if any, is 

irrelevant to the collection and use of the information by the system or project). 

☐ Retired federal employees. Discuss here how/why PII is collected from this source. 

☐ Former Treasury employees. Discuss here how/why PII is collected from this source. 

☐ Federal contractors, grantees, interns, detailees etc. Discuss here how/why PII is collected from 

this source. 

☐ Federal job applicants. Discuss here how/why PII is collected from this source 

☐

2. Current Federal Employees, Interns, and Detailees 

☒ Current Federal employees providing information in their capacity as federal employees (for 

example, PII collected using OPM or Treasury forms related to employment with the federal 

government)

☐ Interns. 

☐

c

3. Treasury Bureaus (including Departmental Offices) 

☐ Other Treasury Bureaus: [name the bureau(s) here and identify the bureau/office information 

system from which the PII originated) and how/why PII is collected from this source]. 

4. Other Federal Agencies 

☐ Other federal agencies: the Office of Management and Budget, Aid Agency, Export-Import Bank of 

the United States (EXIM), Overseas Private Investment Corporation (OPIC), United States Department of 

Agriculture (USDA), Department of Defense (DOD), and the Financial Management Service (FMS). As 

documented in the system purpose, PII is collected from federal users to build system accounts in FCRS 

so Treasury can upload foreign credit reports into the system. 

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☐ State and local agencies: [name the State and local agencies here and explain how/why PII is collected 

from this source]. 

5. Private Sector 

☐ Private sector organizations (for example, banks and financial organizations, data brokers or 

other commercial sources): [name the private sector organizations here and explain how/why PII 

is collected from these sources]. 

6. Other Sources 

☐ Other sources not covered above (for example, foreign governments). 

Section 3.3: Privacy and/or civil liberties risks related to collection 

When Federal agencies request 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 [the individual], if any, of not providing all or any part of the requested 

information.” 5 U.S.C § 522a(e)(3). This is commonly called a Privacy Act Statement. The OMB Guidelines also 

note that subsection (e)(3) is applicable to both written and oral (i.e., interview) solicitations of personal 

information. Therefore, even if a federal employee or contractor has a fixed list of questions that they orally ask the 

individual in order to collect their information, this requirement applies. 

Section 3.3(a) 

1. None of the PII in the system was collected directly from an individual to whom it pertains. [Explain 

here if the third-party/agency from which you obtained the PII actually collected the PII directly from the 

individuals about whom it pertains. Be prepared to discuss below how you ensure the information 

received from the third-party is still accurate, complete and timely for the purposes for which you will use 

it)]. 

☐

☐ Some or ☒ all of the information in this system was collected directly from an individual to whom it pertains. 

That individual is the system user for whom Treasury creates the system account. The other information in the 

system is not PII. 

Section 3.3(b) 

1. ☐ None of the PII in the system was collected directly from the individuals to whom it pertains. 

Therefore, a Privacy Act Statement is not required. here 

2. ☐ Some ☒ All of the PII in the system was collected directly from the individual to whom it pertains. 

Therefore, a Privacy Act Statement was posted at the point where the PII was collected directly from the 

individual. That Privacy Act Statement was provided to the individual ☐ on the form in which the PII 

was collected ☐ on a separate sheet of paper that the individual could retain; or ☐ in an audio recording 

or verbally at the point where the information was collected (e.g., on the phone) or ☒ in the email in which 

the user is asked to send the required information. 

3. The Privacy Act Statement contained the following: 

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

authorizes the solicitation of the information. 

b. ☒ Whether disclosure of such information is mandatory or voluntary. 

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

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

be shared. 

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

requested information. 

Section 3.3(d) Use of Full Social Security Numbers 

Treasury is committed to eliminating unnecessary collection, use, and display of full Social Security numbers 

(“SSN”) and redacting, truncating, and anonymizing SSNs in systems and documents to limit their accessibility to 

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individuals who do not have a need to access the full SSN in order to perform their official duties. Moreover, 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 3.3(e) Justification for Collection of Social Security Numbers 

1. ☒ N/A No full SSNs are maintained in the system or by the project. 

2. ☐ Full SSNs are maintained in the system or by the project and the following approved Treasury uses of 

SSNs apply: 

Section 3.3(f) Controls implemented to limit access to and or improper disclosure of full Social Security 

Numbers 

1. ☒ Full SSNs are not maintained in the system or by the project. 

2. ☐ Full SSNs are maintained in the system or by the project and the following controls are put in place to 

reduce the risk th at the SSN will be seen or used by someone who does not have a need to use the SSN in 

order to perform their official duties (check ALL that apply): 

a. The entire SSN data field is capable of suppression (i.e., being turned off) and the data field 

is suppressed when the SSN is not required for particular system users to perform their official 

duties. 

☐

b. ☐ do not require the SSN to perform their official duties.☐ Within the system, an alternative 

number (e.g., an Employee ID) is displayed to all system users who do not require the SSN to 

perform their official duties. The SSN is only linked to the alternative number within the 

system and when reporting outside the system (to an agency that requires the full SSN). The 

SSN is not visible to system users (other than administrators). 

c. ☐ The SSN is truncated (i.e., shortened to the last 4 digits of the SSN) when displayed to all 

system users for whom the last four digits (but not the full) SSN are necessary to perform their 

official duties. 

d. ☐ Full or truncated SSNs are only downloaded to spreadsheets or other documents for sharing 

within the bureau or agency when disclosed to staff whose official duties require access to the 

full or truncated SSNs for the particular individuals to whom they pertain. No SSNs (full or 

truncated) are included in spreadsheets or documents unless required by each recipient to whom 

it is disclosed in order to perform their official duties (e.g., all recipients have a need to see the 

SSN for each employee in the spreadsheet). 

e. ☐ Other: [Please describe]. 

Section 3.3(g) Denial of rights, benefits, or privileges for refusing to disclose Social Security Number 

1. ☒ N/A No SSNs are maintained in the system or by the project. 

a. Full SSNs are collected, but no individual will be denied any right, benefit, or privilege 

provided by law if the individual refuses to disclose their SSN for use in the system or project. 

If the individual chooses not to provide their SSN [please describe here what will happen 

(something less than denial of a privilege etc.) if the individual chooses not to provide their 

SSN].

☐

☐ Full SSNs are collected, and the individual will be denied the following right, benefit, 

or privilege provided by law if they refuse to disclose their SSN: [please identify here the right, 

benefit, or privilege if the individual will be denied if they choose not to provide their SSN]. 

Denial of this right, benefit or privilege does not violate the law because: [choose one of the two 

boxes below]:☐ SSN disclosure is required by the following Federal statute or Executive 

Order;; OR 

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b. ☐ The SSN is disclosed to a Federal, state, or local agency that maintains a system of records 

that was 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. 

Section 3.3(h) Records describing how individuals exercise First Amendment rights 

The Privacy Act requires 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). 

1. ☒ N/A. The system or project does not maintain information describing how an individual exercises their 

rights guaranteed by the First Amendment. 

2. ☐ The system or project does maintain information describing how an individual exercises their rights 

guaranteed by the First Amendment. If you checked this box, please check the box below that explains 

Treasury’s authorization for collecting this information: 

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

its collection/maintenance. The individual about whom the information was collected or 

maintained expressly authorized its collection by [explain here how the individual expressly 

authorizes collection] (for example, individuals may expressly authorize collection by requesting 

in writing that Treasury share information with a third party, e.g., their Congressman]; 

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

enforcement activity because [generally discuss here the nature and purpose of the information 

collected and the law enforcement activity]; 

c. ☐ The following statute expressly authorizes its collection: [provide here the name of and 

citation to the statute and the language from that statute that expressly authorizes collection] 

[your response MUST contain all three if you use a statute as the basis for the collection]. 

Section 4: Maintenance, use, and sharing of the information 

Section 4.1: Ensuring accuracy, completeness, and timeliness of information collected, maintained, and shared 

when it is used to make determinations about individuals 

The Privacy Act and Treasury policy require that Treasury bureaus and offices take additional care when collecting 

and maintaining information about individuals when it will be used to make determinations about those individuals 

(e.g., whether they will receive a fe deral benefit). This includes collecting information directly from the individual 

where practicable and ensuring that the information is accurate, relevant, timely and complete to assure fairness to 

the individual when making a determination about them. This section addresses the controls/protections put in 

place to address these issues. 

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 3.1 above), an agency may 

exempt the system of records (or a portion of the records) from this requirement. Exemptions may be found at the 

bottom of the relevant SORN next to the heading: “Exemptions Claimed for this System.” 

Section 4.1(a). Exemption from the accuracy, relevance, timeliness, and completeness requirements in 

section (e)(5) of the Privacy Act 

1. ☒ None of the information maintained in the system or by the project that is part of a system of 

records is exempt from the accuracy, relevance, timeliness, and completeness requirements in section 

(e)(5) of the Privacy Act. 

2. ☐ All ☐ Some of the PII maintained in the system or by the project is part of a system of records and 

is exempt from the accuracy, relevance, timeliness, and completeness requirements in section (e)(5) of 

the Privacy Act. The exemption claimed for these records is appropriate because [please see 

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Appendix B which contains sample justifications for this exemption and provide the appropriate bases 

here [more than one bases may apply]. 

3. ☐ The PII maintained in the system or by the project is not: (a) part of a system of records as defined 

in section (e)(5) of the Privacy Act; or (b) used to make adverse determinations about individuals 

(defined in the Privacy Act as U.S. Citizens and legal permanent residents). Instead, the information 

is used to [describe how the information is used and why this use does not involve adverse 

determinations]. hat you read the rest of the options before checking this box☐ None of the 

information maintained in the system or by the project is part of a system of records as defined in 

section (e)(5) of the Privacy Act, but the information in the system is used to make adverse 

determinations about individuals (defined in the Privacy Act as U.S. Citizens and legal permanent 

residents). Despite the fact that the Privacy Act does not apply, the following protections are in place 

to ensure fairness to the individual: explain here . 

Section 4.1(b) Protections in place despite exemption from the accuracy, relevance, timeliness, and 

completeness requirements 

1. ☒ None of the information maintained in the system or by the project that is part of a system of 

records is exempt from the accuracy, relevance, timeliness, and completeness requirements in section 

(e)(5) of the Privacy Act. 

2. ☐ For all information maintained in the system or by the project that is part of a system of records 

that is exempt from the accuracy, relevance, timeliness, and completeness requirements in section 

(e)(5) of the Privacy Act, the following efforts are made to ensure accuracy, relevance, timeliness, and 

completeness to the extent possible without interfering with the (check one) ☐ law enforcement ☐

intelligence ☐ other [describe here] mission requirements for which the system or project was created 

[choose ALL that apply]: 

a. ☐ The exempt information is not actually used to make any adverse determinations about 

individuals. 

b. ☐ The exempt information is not actually used to make any adverse determinations about 

individuals without additional research and investigation to ensure accuracy, relevance, 

timeliness, and completeness. 

c. ☐ Individuals and organizations to whom PII from the system or project is disclosed (as 

authorized by the Privacy Act) determine its accuracy, relevance, timeliness, and completeness 

in a manner reasonable for their purposes before they use it to make adverse determinations 

about individuals. 

a. ☐ Individuals about whom adverse determinations are made using PII from this system or 

project are given an opportunity to explain or modify their information (check one) ☐ before ☐

after the adverse determination is made. During this process, individuals are allowed to: 

[discuss here 

d. ☐ Other: (please describe): 

3. ☐ No additional efforts are made to ensure accuracy, relevance, timeliness, and completeness to the 

extent possible because it would interfere with mission requirements. 

Section 4.1(c) Collecting information directly from the individual when using it to make adverse 

determinations about them 

Section 552a(e)(2) of the Privacy Act requires that Federal agencies that maintain records in a system of records 

are required to collect information to the greatest extent practicable directly from the individual when the 

information about them may result in adverse determinations about their rights, benefits, and privileges under 

Federal programs. Agencies may exempt a system of records from this requirement under certain circumstances 

and if certain conditions are met. 

1. ☒ The records maintained by this system or project are not used to make any adverse determinations 

about individuals. 

2. ☐ The records maintained by this system or project are used to make adverse determinations about 

individuals and [check all that apply]: 

a. ☐ These records were exempted from the Privacy Act provision that requires collection directly 

from the subject individual to the greatest extent practicable. Exemption of these records is 

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proper because [explain here why the records were exempted; sample responses are provided in 

Appendix B of this template]. 

b. ☐ These records were not exempted from the requirement to collect information directly from 

the individual to the greatest extent practicable and [check the relevant box below and provide the 

information requested]. 

i. ☐ All records used to make an adverse determination are collected directly from the 

individual about whom the decision is made. ☐ A combination of records collected from 

third parties and directly from the individual about whom the determination is made are used 

to make the determination because [please explain here why third-party data is required to 

make this determination; e.g., third-party data is required to verify the accuracy of the 

information provided by the individual seeking a privilege or benefit]. 

ii. ☐ None of the records used to make adverse determinations are collected directly from the 

individual about whom determinations are made because seeking the information directly 

from the individual might [select ALL that apply]: 

☐ alert the individual to the fact that their conduct is being observed or investigated; 

☐ cause the individual to alter or modify their activities to avoid detection; 

☐ create risks to witnesses or other third parties if the individual is alerted to the fact 

that their conduct is being observed or investigated; 

☐ Other: (please describe here). 

Section 4.1(d) Additional controls designed to ensure accuracy, completeness, timeliness and fairness to 

individuals in making adverse determinations 

Administrative Controls. Individuals about whom information is collected are given the following 

opportunities to amend/correct/update their information to ensure it is accurate, timely and complete to the 

extent reasonably necessary to assure fairness when it is used to make a determination about them ☒ The PII 

collected for use in the system or project is NOT used to make adverse determinations about an individual’s 

rights, benefits, and privileges under federal programs. 

1. ☐ The records maintained in the system or by the project are used to make adverse determinations and 

(select one) ☐ are ☐ are not exempt from the access provisions in the Privacy Act, 5 U.S.C. 552a(d). 

2. Treasury has published regulations in place describing how individuals may seek access to and 

amendment of their records under the Privacy Act. The Treasury/bureaus FOIA and Privacy Act 

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

3. ☐ Individuals who provide their information directly to Treasury for use in the system or by the project 

are provided notice of the adverse determination and an opportunity to amend/correct/ update their 

information [choose one] ☐ before ☐ after it is used to make a final, adverse determination about 

them. This is accomplished by: [describe here how this process works and the protections in place, 

including redress/appeals processes; if notice is provided after an adverse determination is made, 

explain here why notice could not be provided before a determination was made, and the protections in 

place]. 

4. ☐ Individuals who provide their information directly to Treasury for use in the system or by the project 

are expressly told at the point where the information is collected that they need to keep their 

information accurate, current and complete because it could be used to make adverse determinations 

about them. This is accomplished by: [describe here how/where/when individuals are told they need to 

keep their information updated before it is used to make adverse decisions about them; include the 

exact language provided to the individuals]. 

5. ☐ All manual PII data entry by federal employees/contractors is verified by a supervisor or other data 

entry personnel before it is uploaded to the system (e.g., PII entered into the system from paper records 

is double-checked by someone else before it’s uploaded to the system). This is accomplished by: 

[describe here how this process works]. 

☐ Other: [please describe here]. 

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☒ No additional technical controls are available to ensure accuracy, relevance, timeliness and completeness. 

Section 4.2 Data-Mining 

 

 

 

 

 

 

 

 

 

 

 

 

 

Technical controls. The system or project also includes additional technical controls to ensure that PII is 

maintained with such accuracy, relevance, timeliness and completeness as is reasonably necessary to assure 

fairness to the individual when it is used to m ake a d etermination about them. The following additional 

protections are relevant to this system or project: 

1. ☐ Automated data feeds are used to refresh/update the information in the system (where the system is 

reliant on updates from another system). These automated data feeds occur: [state here the frequency 

of updates] and [state here what happens when the data is updated and why the system is reliant on 

another system for its data]. 

2. ☐ Technical and/or administrative controls put are in place to ensure that when information about an 

individual is acquired from multiple sources for maintenance in a single file about a particular 

individual, it all relates to the same individual . This is accomplished by: [describe here the method or 

process used to ensure that information merged about an individual from multiple sources for inclusion 

in a single file, all relates to the same person]. 

3. ☐ Address verification and correction software (software that validates, updates and standardizes the 

postal addresses in a database). 

4. ☐ Other: [please describe here] 

As required by Section 804 of the Implementing Recommendation of the 9/11 Commission 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 Act and Data Mining 

reports available at: http://www.treasury.gov/privacy/annual-reports. 

Section 4.2(a) Is the PII maintained in the system used to conduct data-mining? 

1. ☒ The information maintained in this system or by this project is not used to conduct “data-mining” 

activities as that term is defined in the 9-11 Commission Act. Therefore, no privacy or civil liberties issues 

were identified in responding to this question. 

2. ☐ The information maintained in this system or by this project is used to conduct “data-mining” activities 

as that term is defined in the 9-11 Commission Act. This system is included in Treasury’s annual report to 

Congress which can be found on the external Treasury privacy website. [NEED LINK]. 

3. ☐ The information maintained in this system or by this project is used to conduct “data-mining” activities 

as that term is defined in the 9-11 Commission Act, but this system is not included in Treasury’s annual 

report to Congress which can be found on the external Treasury privacy website. This system will be 

added to the next Treasury Data-mining report to Congress. 

Section 4.3 Computer Matching 

The Computer Matching and Privacy Protection Act (CMPPA) of 1988 amended the Privacy Act by imposing 

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

Pursuant to the CMPPA, 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 (the agency 

providing the records) and recipient agency (the agency that receives and uses the records to make determinations). 

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The matching agreement describes the purpose and procedures of the matching and establishes protections for 

matching records. 

Section 4.3(a) Records in the system used in a computer matching program 

1. ☐ The PII maintained in the system or by the project is not part of a Privacy Act system of records. 

2. ☒ The information maintained in the system or by the project is part of a Privacy Act system of records, 

but is not used as part of a matching program. 

3. ☐ The information maintained in the system or by the project is part of a Privacy Act system of records 

and is used as part of a matching program. [Explain here whether a Matching Agreement was executed 

and published as required by the CMPPA/Privacy Act; if no Matching Agreement was executed, please 

explain here why]. 

Section 4.3(b) Is there a m atching agreement? 

1. ☒ N/A 

2. ☐ There is a matching agreement in place that contains the information required by Section (o) of the 

Privacy Act. 

☐ There is a matching agreement in place, but it does not contain all of the information required by Section (o) of 

the Privacy Act. The following actions are underway to amend the agreement to ensure that it is compliant: 

Section 4.3(c) What procedures are followed before adverse action is taken against an individual who is the 

subject of a matching agreement search? 

1. ☒ N/A 

2. ☐ The bureau or office that owns the system or project conducted an assessment regarding the accuracy 

of the records that are used in the matching program and the following additional protections were put in 

place: 

a. ☐ The results of that assessment were independently verified by [explain how and by whom 

accuracy is independently verified; include the general activities involved in th e verification process]. 

b. ☐ Before any information subject to the matching agreement is used to suspend, terminate, reduce, 

or make a final denial of any financial assistance or payment under a Federal benefit program to an 

individual: 

i. ☐ The individual receives notice and an opportunity to contest the findings; OR 

ii. ☐ The Data Integrity Board approves the proposed action with respect to the financial 

assistance or payment in accordance with Section (p) of the Privacy Act before taking adverse 

action against the individual. 

3. ☐ No assessment was made regarding the accuracy of the records that are used in the matching program. 

Section 4.4: Information sharing with external (i.e., outside Treasury) organizations 

and individuals 

Section 4.4(a) PII shared with/disclosed to agencies, organizations or individuals outside 

Treasury 

1. ☒ PII maintained in the system or by the project is not shared with agencies, organizations, or individuals 

external to Treasury. 

2. ☐ PII maintained in the system or by the project is shared with the following agencies, organizations, or 

individuals external to Treasury: [For each recipient, provide the following: (1) name of organization/type 

of individual; (2) the PII shared; (3) the purpose of the sharing; (4) identify any statutes that limit use or 

sharing of the information; (5) identity any applicable MOU]. 

3. ☐ All external disclosures are authorized by the Privacy Act (including routine uses in the applicable 

SORN). 

Section 4.4(b) Accounting of Disclosures 

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An accounting of disclosures is a log of all external (outside Treasury) disclosures of records made from a system of 

records that has not been exempted from this accounting requirement. This log must either be maintained regularly 

or be capable of assembly in a reasonable amount of time after an individual makes a request. Certain system of 

records may be exempted from releasing an accounting of disclosures (e.g., in law enforcement investigations). 

Section 4.4(c) Making the Accounting of Disclosures Available 

1. ☐ The records are not maintained in a system of records subject to the Privacy Act so an accounting is not 

required. 

2. ☒ No external disclosures are made from the system. 

3. ☐ The Privacy Act system of records maintained in the system or by the project is exempt 

from the requirement to make the accounting available to th e individual named in th e record. 

Exemption from this requirement was claimed because: [please state here why the records in 

this system of records were exempted from this requirement]. 

4. ☐ The Privacy Act system of records maintained in the system or by the project is not exempt 

from the requirement to make the accounting available to th e individual named in th e record 

and a log is maintained regularly. The log is maintained for at least five years and includes 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. 

5. ☐ The Privacy Act system of records maintained in the system or by the project is not exempt from the 

requirement to make the accounting available to the individual named in the record and a log is not 

maintained regularly, but is capable of being constructed in a reasonable amount of time upon request. The 

information necessary to reconstruct the log (i.e., date, nature, and purpose of each disclosure) is 

maintained for at least five years. 

Section 4.4(c) Obtaining Consent Prior to New Disclosures Not Authorized by the 

Privacy Act 

Records in a system of records subject to the Privacy Act may not be disclosed by "any means of 

communication to any person or to another agency" without the prior written request or consent of the 

individuals to whom the records pertain. 5 U.S.C. Sec. 552a(b). However, the Act also sets forth twelve 

exceptions to this general restriction. These 12 exceptions may be viewed at: 

https://www.justice.gov/usam/eousa-resource-manual-139-routine-uses-and-exemptions 

Unless one of these 12 exceptions applies, the individual to whom a record pertains must provide their 

consent, where feasible and appropriate, before their records may be disclosed to anyone who is not 

listed in one of the 12 exceptions. One of these 12 exceptions also allows agencies to include in a notice 

published in the Federal Register, a list of routine uses. Routines uses are disclosures outside the agency 

that are compatible with the purpose for which the records were collected. 

Section 4.4(g) Obtaining Prior Written Consent 

1. ☒ The records maintained in the system of records are only shared in a manner consistent with 

one of the 12 exceptions in the Privacy Act, including the routine uses published in the Federal 

Register. 

2. ☒ If a situation arises where disclosure (written, oral, electronic, or mechanical) must be made 

to anyone outside of Treasury who is not listed in one of the 12 exceptions in the Privacy Act 

(including the published routine uses), the individual’s prior written consent will be obtained 

where feasible and appropriate. 

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Section 5: 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 5.1: The Paperwork Reduction Act 

The PRA requires OMB approval before a F ederal agency may collect standardized data from 10 or more 

respondents within a 1 2-month period. OMB also 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). 

Section 5.1(a) 

1. ☐ The system or project maintains information obtained from individuals and organizations who are not 

federal personnel or an agency of the federal government (i.e., outside the federal government).☐The 

project or system involves a new collection of information in identifiable form for 10 or more persons from 

outside the federal government. 

2. ☐ The project or system completed an Information Collection Request (“ICR”) and received OMB 

approval. 

☒ The project or system did not complete an Information Collection Request (“ICR”) and receive OMB approval 

because: FCRS does not collect information from 10 or more respondents within a 12-month period. 

Section 5.2: 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 National Archives 

and Records Administration (NARA) for permanent retention upon expiration of this period. If the system has an 

applicable SORN(s), check the “Policies and Practices for Retention and Disposal of Records” section. 

Section 5.2(a) 

1. ☒ The records used in the system or by the project are covered by a NARA’s General Records 

Schedule (GRS). The GRS is 3.2, Item 30 for System Access Records (Temporary, destroy 

when business use ceases.) 

2. ☐ The records used in the system or by the project are covered by a NARA approved Treasury 

bureau Specific Records Schedule (SRS). The SRS [please provide here the specific schedule 

name and identifying number]. 

3. ☐ On [please state the date on which NARA approval was sought] the system owner sought 

approval from NARA for an SRS and is awaiting a response from NARA. [State here the 

retention periods you proposed to NARA]. 

Section 5.3: 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). 

Section 5.3(a) 

1. ☒ The system is a federal information system subject to FISMA requirements. 

2. ☒The system last completed an SA&A and received an ATO on: 30 June, 2019 

3. ☐This is a new system has not yet been authorized to operate. The expected to date for receiving ATO is 

[please state here the expected date on which you expect authorization will be granted]. 

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________________________________ 

 

 

 

 

4. ☐The system or project maintains access controls to ensure that access to PII maintained is limited to 

individuals who have a need to know the information in order to perform their official Treasury duties. 

5. ☐ All Treasury/bureau security requirements are met when disclosing and transferring information (e.g., 

bulk transfer, direct access by recipient, portable disk, paper) from the Treasury system or project to 

internal or external parties. 

6. ☒ This system or project maintains an audit log of system users to ensure they do not violate the system 

and/or Treasury/bureau rules of behavior. 

7. ☒ This system or project has the capability to identify, locate, and monitor individuals or groups of people 

other than the monitoring of system users to ensure that they do not violate the system’s rules of behavior. 

FCRS is located at the BFS TIC (Trusted Internet Connection) which ensures unauthorized Denial of 

Service/malicious attacks are not made on systems. Monitoring does not violate privacy as logs will only 

contain public Proxy information, time/date of connections and activity seen. Minimal logs are kept to 

properly track incidents, and to monitor health of Treasury systems in this environment. 

Section 5.4: 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. 

1. Section 5.4(a) ☐ The project or system will not 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)? 

2. ☒ The project or system will 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)? If checked: 

3. ☒ The system or project complies 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. 

4. ☐ The system or project is not in compliance with all Section 508 requirements. The following actions 

are in progress to ensure compliance: [please describe here the efforts underway to ensure compliance]. 

Timothy H. Skinner 

Bureau Privacy and Civil Liberties Officer 

Privacy, Transparency, & Records 

Departmental Offices 

Department of the Treasury 

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