Office of Financial Research 

Constituent Relationship Management Tool 

Privacy Impact Assessment 

(“PIA”) 

April, 2015 

 

A. Identification 

System Name: Constituent Relationship Management Tool 

OMB Unique Identifier: N/A 

System Owner: Mario Nardoni, OFR Associate Director, Systems 

Engineering 

Contact: Andrew Krug, Associate Director, Information Security 

Address: FOIA/PA Request 

Disclosure Services 

Department of the Treasury 

Washington, D.C. 20220 

 

Telephone: (202) 622-0930 

Fax: (202) 622-3895 

B. System/Application General Information 

1. Does the system contain any Personally Identifiable Information (“PII”)? 

Yes. 

2. What is the purpose of the system/application? 

The Office of Financial Research (“OFR”) manages an array of interagency, 

public sector, private sector, academic and other external relationships to assist 

with carrying out its mandates under the Dodd-Frank Wall Street Reform and 

Consumer Protection Act (“Act”). The Constituent Relationship Management Tool 

(“CRM”) will assist OFR with: (i) consolidating, storing, and managing individual 

business contact information obtained as a result of professional relationships; (ii)

annotating an individual’s interest and expertise in areas of financial research that 

align with OFR’s mission; and (iii) facilitating strategic or targeted outreach efforts 
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around OFR events, announcements, and publications (including capturing 

interest in or attendance at past OFR events and tracking the actual number of 

times and circumstances in which OFR reached out to the individual). 

 

CRM is designed to serve as an internal, centralized repository of business and 

professional contact information, such as names, professional affiliation, 

telephone numbers and other information. CRM provides a secure and efficient 

means of organizing and managing such information in a manner that will assist 

with OFR’s research based mission. 

3. What legal authority authorizes the purchase or development of this 

application/ system? 

Section 153 of the Dodd-Frank Wall Street Reform and Consumer Protection Act 

of 2010 established the purpose and duties of OFR. In order to fully and more 

efficiently perform the duties delineated in the Act (especially those related to 

supporting the work of the Financial Stability Oversight Council (“Council”) and 

Council member agencies in the areas of data, standardization, applied and 

essential long-term research, and risk measurement and monitoring) OFR staff 

often collaborate with their colleagues in the private and public sector. The CRM 

assists OFR with organizing, retrieving and using contact information essential for 

facilitating such work. 

4. Under which Privacy Act System of Record Notice (“SORN”) does this 

system operate? 

The CRM system operates under Treasury .017 – Correspondence and Contact 

Information, and Treasury .015 – General Information Technology Access 

Account Records (“GITAARS”). 

C. Data in the System 

1. What categories of individuals are covered in the system? 

 

Members of the public including: 

- Academia 

- Business leaders and professionals in the financial industry including 

institutions and regulatory entities 

- Members of OFR federal advisory committees, including the OFR Financial 

Research Advisory Committee. 

2. What are the sources of the information in the system? 

a. Is the source of the information from the individual or is it taken from 

another source? If not directly from the individual, then what other 

source? 
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OFR receives information directly from an individual to whom the information 

pertains. 

b. What Federal agencies are providing data for use in the system? 

None. Federal agencies are not providing data for use in the system. 

c. What State and/or Local agencies are providing data for use in the 

system? 

None. State and/or local agencies are not providing information data for use 

in the system. 

d. From what other third party sources will data be collected? 

None. 

e. What personally identifiable information will be collected from the 

employees, government contractors and consultants, and the public? 

The following information will be collected: 

– Full name 

– Preferred name 

– Organization 

– Business title 

– Functional title 

– Line of business 

– Preferred contact method 

– Business address 

– Business phone number 

– Business email 

– Business mobile phone number 

– Business fax 

– Assistant name, where appropriate 

– Assistant title 

– Assistant email 

– Assistant phone 

– Information regarding memberships in professional societies, affiliation 

with standards and bodies, any teaching positions they may have had, 

or any publications the individual is associated with 

– Alternate contact type 

– Alternate address 

– Alternate phone number 

– Alternate mobile phone number 
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– Travel preferences (for OFR federal advisory committee members 

only). 

3. Accuracy, Timeliness, and Reliability 

a. How will data collected from sources other than Treasury records be 

verified for accuracy? 

Whenever OFR receives information directly from an individual, the individual 

providing the information will serve as verification of the accuracy, timeliness, 

and reliability of the information. In addition, OFR will annually review and 

update each CRM record by contacting the individual in a similar manner. 

b. How will data be checked for completeness? 

The data will be reviewed for completeness when the OFR receives it. If the 

data is incomplete, an OFR employee will attempt to contact the individual to 

ensure completeness. OFR will also review the data on a yearly basis for 

completeness and accuracy. If it is determined that the data is potentially 

incomplete, an OFR employee will attempt to contact the individual to ensure 

completeness. 

c. Is the data current? 

Yes. Each record will contain current contact information, and is verified with 

the individual providing it. Individuals may also inform OFR of changes to their 

information. Records are also reviewed and updated during the annual record 

review process. In addition, if it is determined during the annual review that 

data is no longer current, it will be deleted. 

d. What steps or procedures are taken to ensure the data is current and not 

out-of-date? 

OFR will receive contact information directly from the individual. OFR will 

annually review and update each CRM record as necessary and appropriate 

and may, from time to time, receive requests directly from individuals to 

update their records in the system. OFR may also choose to remove a contact 

record from use because of an inability to update out-of-date or inaccurate 

information. Under these circumstances the record will be changed to an 

“inactive” status in the system. 

 

e. Are the data elements described in detail and documented? If yes, what 

is the name of the document? 
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Yes. Data elements collected and maintained by the system are detailed in the 

following Treasury SORN: Treasury .017 – Correspondence and Contact 

Information. 

D. Attributes of the Data 

1. Is the use of the data both relevant and necessary to the purpose for which 

the system is designed? 

Yes. The data is necessary to facilitate efficient communication and 

correspondence between OFR and its professional contacts to assist OFR in 

performing its research functions as delineated in the Act. It also relevant to 

OFR’s efforts to identify opportunities for engagement or collaboration with such 

contacts. 

2. Will the system derive new data or create previously unavailable data about 

an individual through aggregation from the information collected? If so, 

how will this be maintained? 

No. 

3. Will the new data be placed in the individual’s record? 

 No new data will be created. 

4. Can the system make determinations about employee/public that would not 

be possible without the new data? 

No. No new data will be created 

5. How will the new data be verified for relevance and accuracy? 

No new data will be created. 

6. If the data is being consolidated, what controls are in place to protect the 

data from unauthorized access or use? 

OFR utilizes a role-based access control architecture to protect data in the CRM 

from unauthorized access or use. Access requests receive a two-pronged review 

and assessment. OFR reviews the business role and responsibilities of the 

requestor and also reviews whether or not the requestor has a current “need-toknow” the information. 

7. If processes are being consolidated, are the proper controls remaining in 

place to protect the data and prevent unauthorized access? 
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Processes are not being consolidated at this time. 

8. How will the data be retrieved? Does the personal identifier retrieve data? If 

yes, explain and list the identifiers that can be used to retrieve information 

on the individual. 

Data is retrieved using record retrieval and search functionality within CRM. 

Personal identifiers can be used to retrieve data. Data can be retrieved by any of 

the following fields: 

– Full name 

– Preferred name 

– Organization 

– Business title 

– Functional title 

– Line of business 

– Business address 

– Business phone 

– Business email 

– Business mobile phone 

– Business fax 

– Assistant name 

– Assistant title 

– Assistant email 

– Assistant phone 

– Information regarding memberships in professional societies, affiliation 

with standards and bodies, teaching positions, publications an 

individual is associated with 

– Alternate address 

– Alternate phone 

– Alternate mobile phone 

9. What kinds of reports can be produced on individuals? What will be the use 

of these reports? Who will have access to them? 

The CRM permits authorized users to query the system and compile multiple 

records for internal OFR reporting purposes. For example, OFR will produce a 

report which identifies individuals who are researchers who also have an interest 

in a particular topic being considered for an OFR publication. OFR will also run 

reports to provide targeted correspondence, or to send materials to individuals 

interested an OFR conference or discussion topic. This capability is not used to 

report on specific individuals for the purpose of granting a right, benefit, or 

privilege, or otherwise making a determination about a single individual. 
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E. Maintenance and Administrative Controls 

1. If the system is operated in more than one site, how will the consistent use 

of the system and data be maintained in all sites? 

The system is operated at a single site located in Washington, DC. 

2. What are the retention periods of the data in the system? 

Paper records collected in this system are retained in accordance with the 

National Archives and Records Administration’s General Records Schedule 12, 

item 2a. 

3. What are the procedures for disposition of the data at the end of the 

retention period? How long will the reports produced be kept? Where are 

the procedures documented? 

 

 Records collected in this system are eligible for disposal in accordance with the 

National Archives and Records Administration’s General Records Schedule 12, 

item 2a. Records will be destroyed by shredding, maceration or other similar 

methods. OFR will use Treasury and NARA documented records management 

policies, procedures, and guidelines to comply with applicable federal 

recordkeeping requirements for retention and disposition. 

 

4. Is the system using technologies in ways that Treasury has not previously 

employed (e.g., monitoring software, smart cards, caller-ID)? 

No. 

5. How does the use of this technology affect public/employee privacy? 

This technology does not significantly impact public or employee privacy because 

it does not use technologies in ways that Treasury has not previously employed. 

The information is collected directly from the individual and used for the limited 

purpose of identifying and contacting experts in areas relevant to OFR’s mission. 

6. Will this system provide the capability to identify, locate, and monitor 

individuals? 

The system is not designed for the long term tracking of individuals. Individuals 

may be identified and located through their contact information contained in the 

system, but the system is not configured to monitor nor will it be used to monitor 

individuals. 

7. What kinds of information are collected as a function of the monitoring of 

individuals? 
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None. 

8. What controls will be used to prevent unauthorized monitoring? 

User access is restricted to the data required for the performance of their duties. 

Users also receive (and must acknowledge) OFR Rules of Behavior for the 

appropriate use of OFR information technology and resources and must complete 

annual privacy and security awareness training. Additionally, users logging into 

CRM are prompted with a warning banner noting acceptable system use and 

security requirements. Finally, system use is audited in accordance with OFR IT 

security policies and procedures as described in Section F4 below. 

9. Under which Privacy Act SORN does the system operate? 

 

The CRM operates under Treasury .017 – Correspondence and Contact 

Information, and Treasury .015 – GITAARS. 

10. If the system is being modified, will the Privacy Act SORN require 

amendment or revision? 

The system is not being modified. 

F. Access to Data 

1. Who will have access to the data in the system? 

OFR users, system managers, and system administrators, as well as contractors 

and their sub-contractors acting on behalf of OFR with a need-to-know the data 

contained in the system in order to perform their duties. 

2. How is access to the data by a user determined? 

Users are granted access based on: (i) a demonstrated need-to-know in support 

of their job responsibilities; and (ii) managerial decisions. 

3. Will users have access to all the data on the system or will the user’s 

access be restricted? 

 

Users are restricted to the accessing only the data needed in the performance of 

their duties. Depending on their role in administering, supporting, and maintaining 

the system, some users will be granted access to all of the data while other users 

will be granted restricted access to the data. 

System access and permissions vary. The CRM user roles and responsibilities 

include the following: 
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– Associate Director: CRM owner, add/update records, run reports and 

extracts, change record status, able to view all records and fields. 

– IAR Team: CRM record owners, add/update records, run reports and 

extracts, change record status, able to view all owned records and fields, 

able to view all other records with selective access to restricted fields, able 

to create workflows, fields, and entities and configure screens. 

– Front Office: Add/update records, able to view all records with selective 

access to restricted fields. 

– Research & Data Services: Add/update records, able to view most 

records. Unable to view restricted fields. 

– External Affairs: Add/update records, able to view most records 

– Administration: Add/update records, able to view most records 

– Technology: Add/update records, able to view most records, able to 

create workflows, fields, entities and configure screens. 

4. What controls are in place to prevent the misuse (e.g., unauthorized 

browsing) of data by those having access? 

User access is restricted to the data required for the performance of their duties. 

Users also receive (and must acknowledge) OFR Rules of Behavior for the 

appropriate use of OFR information technology and resources and must complete 

annual privacy and security awareness training. Additionally, users logging into 

CRM are prompted with a warning banner noting acceptable system use and 

security requirements. Moreover, OFR has also implemented controls to prevent 

the misuse of information contained in the CRM system. Finally system access 

and use is audited and monitored in accordance with OFR IT security policies and 

procedures. 

Moreover, event logs and log management systems are secure and access is 

limited to only authorized staff. Audit logs and audit settings are prohibited from 

being tampered with, deleted, or disrupted. Any changes must be approved 

through a formal change request. 

Additionally, users are prompted with a warning banner upon logging into CRM 

noting acceptable use and security requirements of the system. 

5. Are contractors involved with the design and development of the system 

and will / are contractors involved with maintenance of the system? 

Yes. 
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6. Do other systems share data or have access to the data in the system? If 

so, explain. 

No. 

7. Who will be / is responsible for protecting the privacy rights of the public 

and employees affected by the interface? 

There is no public interface. However system users, the system security manager, 

system owner, and the OFR Chief Counsel’s office share responsibility for 

protecting the privacy rights of individuals whose information is maintained in the 

system. 

8. Will other agencies share data or have access to the data in this system 

(e.g., Federal, State, Local, other)? 

No. 

9. How will the data be used by the other agency(s)? 

N/A 

10. Who is responsible for assuring proper use of the data? 

Employees who have access to the system, the system security manager, system 

owner, and the Chief Counsel’s office are responsible for assuring the proper use 

of the data in the system.