1 

Privacy and Civil Liberties Impact Assessment

Privacy and Civil Liberties Impact Assessment

for the

Reasonable Accommodations Tracker

December 7, 2021

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 Department of the Treasury (“Treasury”) policy is to fully comply with the reasonable 

accommodations requirements of the Rehabilitation Act of 1973, as amended, 29 U.S.C. sec. 791 

et seq. (Act); 29 C.F.R. pts. 1614, 1630. Treasury is committed to providing reasonable 

accommodations to employees who are qualified individuals with disabilities and to ensuring that 

they enjoy access to all employment opportunities at Treasury. Reasonable accommodation is a 

cooperative, interactive process between the individual with a disability and Treasury. Treasury 

processes requests for reasonable accommodations and, where required by law, provides 

reasonable accommodations in a prompt, fair, and efficient manner. 

The Reasonable Accommodations Tracker (RA Tracker) is an information system/application, 

and provides support to the Treasury Equal Employment Opportunity (EEO) Office. The EEO 

Office uses the RA Tracker to process and ensure that reasonable accommodation requests are 

addressed promptly, thoroughly, and in strict compliance with the Equal Employment 

Opportunity Commission’s (EEOC) regulations. 
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Furthermore, RA Tracker is used to report information related to Treasury-wide reasonable 

accommodations requests. RA Tracker is also used to provide aggregate data through generated 

reports and data required to report annually to the Office of Personal Management (OPM) and 

EEOC. The RA Tracker system is a minor application that resides on Treasury’s MicroPact 

General Support System (GSS). Treasury MicroPact GSS supports iComplaints EEO Case 

Management System and the RA Tracker, both of which are software as a service (SaaS). 

Treasury is updating the RA PCLIA to account for the two new authorities added to the modified 

Treasury .016 - Reasonable Accommodations Records System of Records Notice (SORN). 

Treasury added Title VII of the Civil Rights Act of 1964, as amended to protect employees and 

job applicants from employment discrimination based on race, color, religion, sex, and national 

origin. 

Additionally, Executive Orders (EO) 14042, Ensuring Adequate COVID Safety Protocols for 

Federal Contractors (September 09, 2021) and EO 14043, Requiring Coronavirus Disease 2019 

Vaccination for Federal Employees (September 09, 2021) were added to the SORN as authorities

that may result in employees and job applicants filing Title VII claims.

Finally, edits were made to the existing routine uses consistent with the Office of Management 

Budget’s (OMB) requirements and Treasury’s standard routine uses. Additional amendments 

were made to delete the existing routine uses B, E, and H to avoid redundancy (after inclusion of 

the new routine uses).

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 6/3/2020. 

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. 

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 EO or other authority. The information 

may also be collected pursuant to a more general requirement or authority. The following specific 

authorities authorize Reasonable Accommodations Tracker System to collect information:

All Treasury systems and projects derive general authority to collect information from:

• The Rehabilitation Act of 1973, §§ 501 and 504;

• Americans with Disabilities Act Amendments Act (ADAAA); 

• Executive Order 13164 (July 28, 2000); 

• Executive Order 13548 (July 26, 2010);

• Title VII of the Civil Rights Act of 1964, as amended; 

• Executive Order 14042 (September 09, 2021); and 

• Executive Order 14043 (September 09, 2021).
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Statutes that provide specific authority for maintenance of this system are as follows:

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

Department of the Treasury; 

• 5 U.S.C. 301 – Departmentalregulations;

• 44 U.S.C. 3101; EO 9397, as amended by EO 13487; and 44 U.S.C. 3534. 

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) Please check ALL statements below that apply to your system or project 

and provide any additional information requested. Please read all possible responses before 

selecting an answer.

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.

☐ 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 

that SORN. [If modifications were made, generally describe them here]. The current 

applicable SORN is: 

3. ☐ 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:

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

requirements.

• Treasury .016 - Reasonable Accommodations Records - 86 FR 59271 (October 

26, 2021) and 

• Treasury .015 - General Information Technology Access Account Records - 81 FR 

78266 (Nov. 7, 2016)

5. ☐ 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]: The citation to the applicable Notice of Proposed Rulemaking and/or Final 
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Rule is[provide here the Federal Register Citation to the NPRM and Final Rule (if a Final 

Rule was required)]. 

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 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 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.”

2. ☐ The PII maintained in this system or by this project is exempt from 5 U.S.C. 

§ 552a(e)(1), because [See Appendix B for a list of acceptable bases for claiming this 

exemption and cut and paste here all that apply].

Section 3.1(b) Continuously Assessing Relevance and Necessity ☐ 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 system of records, but the agency exempted 

these records from the relevance and necessity requirement. [Explain here what you do to 

ensure relevance and necessity to the extent possible despite the fact the records are 

exempt from this requirement]. 

3. ☒ The system owner conducted an assessment prior to collecting PII for use in the 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. Every 

time this PCLIA is updated, this 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 was removed from the system and 

is no longer collected.
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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 is 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 is 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)

☒ Business physical/postal mailing address ☒ Gender ☐ City or County of Birth

☒ Zip Code ☐ Race ☐ Military Service 

Information

☒ Business/Personal home phone, cell 

phone, or fax number

☒ Business e-mail address ☐ Country or city of 

residence

☒ Other: Pay Plan (GS, WG, SES), 

Occupation Series, Grade Level. 

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)

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

Number

☒ File/Case ID Number ☐ Credit Card Number ☐ Passport Number and 

information (nationality, date 

and place of issuance, and 

expiration date)

☐ Alien Registration Number ☐ Patient ID Number ☐ 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: 

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: 

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

☒ Sick leave information ☒ Request for an accommodation under the 

Americans with Disabilities Act

☐ 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)

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

Focusing on the context in which the data was collected and used (i.e., why it is collected and 

how it is used), check ALL sources from which PII is collected/received and stored in the 

system or used in the project

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. 

☒ Former Treasury employees. 

☒ Federal contractors, grantees, interns, detailees etc. 

☐ Federal job applicants. 

☐ Other: [Explain here]. 

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)
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☒ Interns. PII is collected directly from the interns applying for the reasonable 

accommodation by entering the information into the RA Tracker. 

☒ Detailees. PII is collected directly from the detailees applying for the reasonable 

accommodation by entering the information into the RA Tracker. 

☐ Other employment-related positions. [name the position here and discuss 

how/why PII is collected from this source.]. 

3. Treasury Bureaus (including Departmental Offices)

☐ Other Treasury Bureaus: 

4. Other Federal Agencies

☐ Other federal agencies: (name each agency here and explain how/why PII is collected 

from this source.). 

5. State and Local Agencies

☐ State and local agencies: (Name the State and local agencies here and explain how/why 

PII is collected from this source). 

6. Private Sector

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

brokers or other commercial sources): (Name the State and local agencies here and 

explain how/why PII is collected from this source.). 

7. Other Sources 

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

(Name the other sources here and explain how/why PII is collected from this source). 

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) Collection Directly from the Individual to whom the PII pertains

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

pertains. [Explain 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 
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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)]. 

2. ☒ All of the information in this system was collected directly from an individual to whom 

it pertains. 

Section 3.3(b) Privacy Act Statements

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. 

2. ☒ 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 login screen on 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 ☐ other [please explain]. 

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(c) 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 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(d) Justification 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: 
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☐ security background investigations; 

☐ interfaces with external entities that require the SSN; 

☐ a legal/statutory basis (e.g. where collection is expressly required by statute); 

☐ when there is no reasonable, alternative means for meeting business requirements; 

☐ statistical and other research purposes; 

☐ delivery of government benefits, privileges, and services; 

☐ for law enforcement and intelligence purposes; 

☐ aging systems with technological limitations combined with funding limitations render 

impracticable system modifications or replacements to add privacy risk reduction tools 

(partial/truncated/redacted or masked SSNs); and

☐ as a unique identifier for identity verification purposes.

Section 3.3(e) 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 that 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). 

d. ☐ 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.

e. ☐ 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). 

f. ☐ Other: [Please describe].

Section 3.3(f) 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.
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2. ☐ 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].

3. ☐ 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 the 

right, benefit, or privilege if the individual will be denied if they choose not to provide 

their SSN: Identify here]. Denial of this right, benefit or privilege does not violate the 

law because: [choose one of the two boxes below]:

a. ☐ SSN disclosure is required by the following Federal statute or Executive 

Order; OR

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(g) 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. In order to process the reasonable 

accommodation request as required by law, Treasury must collect information that 

could, depending on the facts and circumstances of a particular case, be deemed to 

describe how an individual exercises the rights guaranteed by the First Amendment. 

Specifically, a reasonable accommodation request could be made by an individual 

based on a religious belief. Treasury is required to collect information on 

accommodation requests and report annually whether requested accommodations 

were provided or denied within the allowable time frame. This collection meets the 

threshold requirements in Section (e)(7) of the Privacy Act for collection of this 

type of information because the employee expressly consents to providing this 

information when submitting their reasonable accommodation request.

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]; 
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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 federal 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. 

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 that 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). 
14

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.

d. ☐ 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 

e. ☐ 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. 
15

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 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. 

ii. ☐ 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].

iii. ☐ 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

1. 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: 

a. ☐ 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. 

b. ☒ The records maintained in the system or by the project are used to make 

adverse determinations and are not exempt from the access provisions in the 

Privacy Act, 5 U.S.C. 552a(d). 

c. ☒ Treasury has published regulations describing how individuals may seek 

access to and amendment of their records under the Privacy Act. The
16

Treasury/bureaus FOIA and Privacy Act disclosure regulations can be found at 

31 C.F.R. Part 1, Subtitle A, Subparts A and C. 

d. ☒ 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 after it is used to make a 

final, adverse determination about them. This is accomplished by reaching out to 

the reasonable accommodation applicant via email. The email also states that a 

reasonable accommodation representative will contact the applicant. 

e. ☐ 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]: Description. 

f. ☐ 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].

g. ☐ Other: 

2. 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 make a determination about them. The following additional protections are 

relevant to this system or project 

a. ☒ No additional technical controls are available to ensure accuracy, relevance, 

timeliness and completeness. Treasury receives all PII directly through 

interactions with the individual requesting the accommodation and relies on the 

individual to provide accurate data.

b. ☐ 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]. 

c. ☐ 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. 

d. ☐ Address verification and correction software (software that validates, updates 

and standardizes the postal addresses in a database).

e. ☐ Other: [please describe here]

Section 4.2 Data-Mining 
17

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 “datamining” 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. 

3. ☐ The information maintained in this system or by this project is used to conduct “datamining” 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). 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.
18

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. [If 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]: Explain here. e ctio n .(b ) s th e re a m a tch in g a g re e m e n t?

1. ☒ N/A

2. ☐ There is a matching agreement in place that contains the information required by 

Section (o) of the Privacy Act. 

3. ☐ 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 

the 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 notshared 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]. 
19

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

applicable SORN).

Section 4.4(b) Accounting of Disclosures

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). 

Check toward the bottom of the SORN to see whether an exemption was claimed from 5 U.S.C. 

552a(c). The NPRM and/or Final Rule for the system of records will explain why that exemption 

is appropriate.

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 the 

individual named in the 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 the 

individual named in the 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.
20

Section 4.4(d) 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-manual139-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(e) 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. 

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 Federal agency may collect standardized data from 10 

or more respondents within a 12-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)
21

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)

2. ☐The project or system involves a new collection of information in identifiable form for 

10 or more persons from outside the federal government. 

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

received OMB approval.

4. ☒ The project or system did not complete an Information Collection Request (“ICR”) 

and receive OMB approval because Treasury does not obtain information from 

individuals and organizations who/that are not federal personnel or an agency of the 

federal government.

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 the records are covered by GRS 

General Records Schedule 2.3, 20. 

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]. 

4. ☐ The system owner is still in the process of developing a new records schedule 

to submit 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: 6/3/2020

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

receiving ATO is. 

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.
22

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. Only the system 

administrator can add users, assign permissions and roles, review user accounts, update 

reference tables, and view audit data. All other users have specific permissions assigned 

within the site to view specific information for their bureau. Reports regarding internal 

usage of the system by Treasury staff and contractors can be generated for internal 

oversight purposes. Audit logs are regularly monitored in accordance with each bureau 

and office Information Systems 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. 

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.

Section 5.4(a) 

1. ☐ 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)? 

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].
23

Responsible Officials

Approval Signature 

________________________________

Timothy H. Skinner

Bureau Privacy and Civil Liberties Officer

Departmental Office, & Records