Privacy and Civil Liberties Impact Assessment

for the

Visitor Management System

February 17, 2017

Reviewing Official

Ryan Law 

Deputy Assistant Secretary for Privacy, Transparency, and Records

Department of the Treasury

Bureau Certifying Official

Dayo Simms 

Bureau Privacy and Civil Liberties Officer

Department of the Treasury
Section 1: Introduction

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

to conduct a Privacy and Civil Liberties Impact Assessment (“PCLIA”) when personally 

identifiable information (“PII”) is maintained in a system or by a project. PCLIAs are required 

for all systems and projects that collect, maintain, or disseminate PII, regardless of the manner in 

which the information is retrieved.

This assessment is being completed pursuant to Section 208 of the E-Government Act of 2002

(“E-Gov Act”), 44 U.S.C. § 3501, Office of the Management and Budget (“OMB”) 

Memorandum 03-22, “OMB Guidance for Implementing the Privacy Provisions of the EGovernment Act of 2002,” and Treasury Directive 25-07, “Privacy and Civil Liberties Impact 

Assessment (PCLIA),” which requires Treasury Offices and Bureaus to conduct a PCLIA before:

1. developing or procuring information technology (“IT”) systems or projects that collect, 

maintain or disseminate PII from or about members of the public, or

2. initiating a new collection of information that: a) will be collected, maintained, or 

disseminated using IT; and b) includes any PII permitting the physical or online 

contacting of a specific individual, if identical questions have been posed to, or identical 

reporting requirements imposed on, 10 or more persons. Agencies, instrumentalities, or 

employees of the federal government are not included.

This PCLIA provides the following information regarding the system or project: 

(1) an overview of its purpose and functions; 

(2) a description of the information collected; 

(3) a description of the how information is maintained, used, and shared;

(4) an assessment of whether the system or project is in compliance with federal 

requirements that support information privacy; and 

(5) an overview of the redress/complaint procedures available to individuals who may be 

affected by the use or sharing of information by the system or project. 

[Explain here whether a PCLIA is being conducted for this system/project for the first time or 

whether this PCLIA supersedes or supplements a preexisting PCLIA.]

Section 2: Definitions

Agency – means any entity that falls within the definition of the term “executive agency”' as 

defined in 31 U.S.C. § 102.

Certifying Official – The Bureau Privacy and Civil Liberties Officer(s) who certify that all 

requirements in TD and TD P 25-07 have been completed so a PCLIA can be reviewed and 

approved by the Treasury Deputy Assistant Secretary for Privacy, Transparency, and Records.
Collect (including “collection”) – means the retrieval, receipt, gathering, or acquisition of any 

PII and its storage or presence in a Treasury system. This term should be given its broadest 

possible meaning.

Contractors and service providers – are private companies that provide goods or services 

under a contract with the Department of the Treasury or one of its bureaus. This includes, but is

not limited to, information providers, information processors, and other organizations providing 

information system development, information technology services, and other outsourced 

applications.

Data mining – means a program involving pattern-based queries, searches, or other analyses of 

1 or more electronic databases, where – (a) a department or agency of the federal government, 

or a non-federal entity acting on behalf of the federal government, is conducting the queries, 

searches, or other analyses to discover or locate a predictive pattern or anomaly indicative of 

terrorist or criminal activity on the part of any individual or individuals; (b) the queries, searches, 

or other analyses are not subject-based and do not use personal identifiers of a specific 

individual, or inputs associated with a specific individual or group of individuals, to retrieve 

information from the database or databases; and (c) the purpose of the queries, searches, or other 

analyses is not solely – (i) the detection of fraud, waste, or abuse in a government agency or 

program; or (ii) the security of a government computer system.

Disclosure – When it is clear from its usage that the term “disclosure” refers to records provided 

to the public in response to a request under the Freedom of Information Act (5 U.S.C. § 552, 

“FOIA”) or the Privacy Act, its application should be limited in that manner. Otherwise, the 

term should be interpreted as synonymous with the terms “sharing” and “dissemination” as 

defined in this manual. 

Dissemination – as used in this manual, is synonymous with the terms “sharing” and 

“disclosure” (unless it is clear from the context that the use of the term “disclosure” refers to a 

FOIA/Privacy Act disclosure).

E-Government – means the use of digital technologies to transform government operations to 

improve effectiveness, efficiency, and service delivery.

Federal information system – means a discrete set of information resources organized for the 

collection, processing, maintenance, transmission, and dissemination of information owned or 

under the control of a federal agency, whether automated or manual.

Final Rule – After the NPRM comment period closes, the agency reviews and analyzes the 

comments received (if any). The agency has the option to proceed with the rulemaking as 

proposed, issue a new or modified proposal, or withdraw the proposal before reaching its final 

decision. The agency can also make any revisions to the supporting analyses contained in the 

NPRM (e.g., to address a concern raised by a member of the public in response to the NPRM).

Government information – means information created, collected, used, maintained, processed, 

disseminated, or disposed of by or for the federal government.
Individual – means a citizen of the United States or an alien lawfully admitted for permanent 

residence. If a question does not specifically inquire about or an issue does not clearly involve a 

Privacy Act system of records, the term should be given its common, everyday meaning. In 

certain contexts, the term individual may also include citizens of other countries who are covered 

by the terms of an international or other agreement that involves information stored in the system 

or used by the project.

Information – means any representation of knowledge such as facts, data, or opinions in any 

medium or form, regardless of its physical form or characteristics. This term should be given the 

broadest possible meaning. This term includes, but is not limit to, information contained in a 

Privacy Act system of records.

Information technology (IT) – means any equipment or interconnected system or subsystem of 

equipment, used in the automatic acquisition, storage, analysis, evaluation, manipulation, 

management, movement, control, display, switching, interchange, transmission, or reception of 

data or information by the executive agency, if the equipment is used by the executive agency 

directly or is used by a contractor under a contract with the executive agency that requires the 

use: (i) of that equipment; or (ii) of that equipment to a significant extent in the performance of a 

service or the furnishing of a product. It includes computers, ancillary equipment (including 

imaging peripherals, input, output, and storage devices necessary for security and surveillance), 

peripheral equipment designed to be controlled by the central processing unit of a computer, 

software, firmware and similar procedures, services (including support services), and related 

resources; but does not include any equipment acquired by a federal contractor incidental to a 

federal contract. Clinger-Cohen Act of 1996, 40 U.S.C. § 11101(6).

Major Information system – embraces “large” and “sensitive” information systems and means 

“a system or project that requires special management attention because of its importance to an 

agency mission; its high development, operating, or maintenance costs; or its significant role in 

the administration of agency programs, finances, property, or other resources.” OMB Circular A130, § 6.u. This definition includes all systems that contain PII and are rated as “MODERATE 

or HIGH impact” under Federal Information Processing Standard 199. 

National Security systems – a telecommunications or information system operated by the 

federal government, the function, operation or use of which involves: (1) intelligence activities, 

(2) cryptologic activities related to national security, (3) command and control of military forces, 

(4) equipment that is an integral part of a weapon or weapons systems, or (5) systems critical to 

the direct fulfillment of military or intelligence missions, but does not include systems used for 

routine administrative and business applications, such as payroll, finance, logistics, and 

personnel management. Clinger-Cohen Act of 1996, 40 U.S.C. § 11103. 

Notice of Proposed Rule Making (NPRM) – the Privacy Act (Section (J) and (k)) allow 

agencies to use the rulemaking process to exempt particular systems of records from some of the 

requirements in the Act. This process is often referred to as “notice-and-comment rulemaking.” 

The agency publishes an NPRM to notify the public that the agency is proposing a rule and 
provides an opportunity for the public to comment on the proposal before the agency can issue a 

final rule. 

Personally Identifiable Information (PII) – “means, any information that can be used to 

distinguish or trace an individual’s identity, either alone or when combined with other personal 

or identifying information that is linked or linkable to a specific individual. 

Privacy and Civil Liberties Impact Assessment (PCLIA) – a PCLIA is:

(1) a process conducted to: (a) identify privacy and civil liberties risks in systems, 

programs and other activities that maintain PII; (b) ensure that information systems, 

programs and other activities comply with legal, regulatory, and policy requirements; 

(c) analyze the privacy and civil liberties risks identified; (d) identify remedies, 

protections and alternative or additional privacy controls necessary to mitigate those 

risks; and (e) provide notice to the public of privacy and civil liberties protection 

practices.

(2) a document that catalogues the outcome of that privacy and civil liberties risk 

assessment process.

Protected Information – as the term is used in this PCLIA, has the same definition given to that 

term in TD 25-10, Section 4.

Privacy Act Record – any item, collection, or grouping of information about an individual that 

is maintained by an agency, including, but not limited to, the individual’s education, financial 

transactions, medical history, and criminal or employment history and that contains the 

individual’s name, or the identifying number, symbol, or other identifying particular assigned to 

the individual, such as a finger or voice print or a photograph.

Reviewing Official – The Deputy Assistant Secretary for Privacy, Transparency, and Records,

who reviews and approves all PCLIAs as part of her duties as a direct report to the Treasury 

Senior Agency Official for Privacy. 

Routine Use – with respect to the disclosure of a record outside of Treasury (i.e., external 

sharing), the sharing of such record for a purpose which is compatible with the purpose for 

which it was collected (Source: 5 U.S.C. 552a(a)(7).

Sharing – any Treasury initiated distribution of information to government employees or agency 

contractors or grantees, including intra- or inter-agency transfers or exchanges of Treasury 

information, regardless of whether it is covered by the Privacy Act. It does not include responses 

to requests for agency records under FOIA or the Privacy Act. It is synonymous with the term 

“dissemination” as used in this assessment. It is also synonymous with the term “disclosure” as 

used in this assessment unless it is clear from the context in which the term is used that it refers 

to disclosure to the public in response to a request for agency records under FOIA or the Privacy 

Act. 
System – as the term used in this manual, includes both federal information systems and 

information technology.

System of Records – a group of any records (as defined in the Privacy Act) under the control of 

Treasury from which information is retrieved by the name of the individual or by some 

identifying number, symbol, or other identifying particular assigned to the individual.

System of Records Notice – Each agency that maintains a system of records shall publish in the 

Federal Register upon establishment or revision a notice of the existence and character of the 

system of records, which notice shall include: (A) the name and location of the system; (B) the 

categories of individuals on whom records are maintained in the system; (C) the categories of 

records maintained in the system; (D) each routine use of the records contained in the system, 

including the categories of users and the purpose of such use; (E) the policies and practices of the 

agency regarding storage, retrievability, access controls, retention, and disposal of the records; 

(F) the title and business address of the agency official who is responsible for the system of 

records; (G) the agency procedures whereby an individual can be notified at his request if the 

system of records contains a record pertaining to him; (H) the agency procedures whereby an 

individual can be notified at his request how he can gain access to any record pertaining to him 

contained in the system of records, and how he can contest its content; and (I) the categories of 

sources of records in the system.

System Owner – Official responsible for the overall procurement, development, integration, 

modification, or operation and maintenance of a system.

Section 3: System Overview

Section 3.1: System/Project Description and Purpose

Aligning with Homeland Security Presidential Directive 12 (HSPD-12), Federal Identity, 

Credential, and Access Management (FICAM) and NIST guidance, the Department is 

developing an automated Visitor Management System (VMS), allowing Treasury personnel to 

initiate, approve, manage, and audit visitor requests. The VMS solution will provide role-based 

functionality and is a web-based application accessible using a valid Treasury Personal Identity 

Verification (PIV) card for login and authentication. The system enables each Treasury visitor to 

use their PIV card to gain access to Treasury buildings and facilities. VMS enhances bureaulevel visitor management policies and procedures with automated request processing and 

auditing.

Number of Individuals Whose Personally Identifiable Information is Maintained in the 

System or by the Project

☐ 0 – 999 ☒ 1000 – 9,999 ☐ 10,000 – 99,999

☐ 100,000 – 499,999 ☐ 500,000 – 999,999 ☐ 1,00,000+
Section 3.2: Authority to Collect

The authorities for operating this system or performing this project are:

Authority Description

Homeland Security Presidential 

Directive-12.

Office of Management and Budget 

(OMB) memo 11-11,

Federal Information Processing 

Standard (FIPS) 201

Federated Identity, Credential, and 

Access Management (FICAM)

Roadmap

HSPD-12 stipulates that the PIV credential will be 

used for logical and physical access to all Federal 

facilities and computing systems. The Department of 

Treasury, and its Bureaus, is required to build and 

deploy a series of HSPD-12 compliant solutions to 

implement the HSPD-12 directive. Building and 

operating the Visitor Management System (VMS) will 

enable visitors to use their PIV cards for physical 

access to Treasury facilities. VMS is Treasury’s 

HSPD-12 program addressing one of the requirements 

from the FICAM Roadmap and Implementation 

Guidance, which recommends enhanced security of 

the U.S. Federal Government's facilities based on the 

use of standardized, secure identity credentials. VMS 

will provide a convenient and effective manner to 

manage Treasury building access requests for PIV 

credentialed federal personnel and contractors.

Section 4: Information Collection

Section 4.1: Relevant and Necessary

The Privacy Act requires, “each agency that maintains a system of records [to] maintain in its 

records only such information about an individual as is relevant and necessary to accomplish a 

purpose of the agency required to be fulfilled by statute or by executive order of the President.” 5 

U.S.C. § 552a(e)(1). It allows federal agencies to exempt records from certain requirements 

(including the relevant and necessary requirement) under certain conditions. The proposed 

exemption must be described in a Notice of Proposed Rulemaking (“NPRM”). In the context of 

the Privacy Act, the purpose of the NPRM is to give the public notice of a Privacy Act 

exemption claimed for a system of records and solicit public opinion on the proposed exemption, 

After addressing any public concerns raised in response to the NPRM, the agency must issue a 

Final Rule. It is possible for some, but not all, of the records maintained in the system or by the 

project to be exempted from the Privacy Act through the NPRM/Final Rule process.
Section 4.1(a) Please check all of the following that are true:

1. ☐ None of the PII maintained in the system or by the project is part of a Privacy Act 

system of records;

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

and none of it is exempt from the Privacy Act relevant and necessary requirement;

3. ☒ All of the PII maintained in the system or by the project is part of a system of records

and all of it is exempt from the Privacy Act relevant and necessary requirement;

4. ☐ Some, but not all, of the PII maintained in the system or by the project is part of a 

system of records and the records to which the Privacy Act applies are exempt from the 

relevant and necessary requirement; and

5. ☐ Some, but not all, of the PII maintained in the system or by the project is part of a 

system of records and none of the records to which the Privacy Act applies are exempt 

from the relevant and necessary requirement.

Section 4.1(b) ☒ Yes ☐ No ☐ N/A With respect to PII maintained in the system or by the 

project that is subject to the Privacy Act’s relevant and necessary requirement, was an 

assessment conducted prior to collection (e.g., during Paperwork Reduction Act analysis) to 

determine which PII types (see Section 4.2 below) were relevant and necessary to meet the 

system’s or project’s mission requirements? 

Section 4.1(c) ☒ Yes ☐ No ☐ N/A With respect to PII currently maintained in the system or 

by the project that is subject to the Privacy Act’s relevant and necessary requirement, is the PII

limited to only that which is relevant and necessary to meet the system’s or project’s mission 

requirements?

Section 4.1(d) ☒ Yes ☐ No With respect to PII maintained in the system or by the project

that is subject to the Privacy Act’s relevant and necessary requirement, is there a process to 

continuously reevaluate and ensure that the PII remains relevant and necessary? 

The information VMS collects is all governed by the Privacy Act. The relevant and necessary 

requirement has been exempted from this information, as is discussed in the Treasury.007 

system of records. However, Treasury has assessed this information collection and 

determined that the limited contact information maintained and used by VMS is both relevant 

and necessary to comply with the requirements set forth in HSPD-12. 

Section 4.2: PII and/or information types or groupings

To perform their various missions, federal agencies must collect various types of information. 

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

project. Information identified below is used by the system or project to fulfill the purpose stated 

in Section 3.3 – Authority to Collect.

Biographical/General Information 

☒ Name ☐ Gender ☐ Group/Organization 

Membership

☐ Birth Date ☐ Race/Ethnicity ☐ Military Service 

Information
☐ Home Physical/Postal

Mailing Address

☐ Personal Cell Number ☐ Personal Home Phone or 

Fax Number

☒ Business

Physical/Postal Mailing 

Address

☐ Business Cell Number ☒ Business Phone or Fax 

Number

☐ Personal e-mail address ☐ Nationality ☐ Mother’s Maiden Name

☒ Business e-mail address ☐ Country of Birth ☐ Spouse Information

☐ Personal Financial 

Information (including loan 

information)

☐ City or County of Birth ☐ Children Information

☐ Business Financial 

Information (including loan 

information)

☐ Immigration Status ☐ Information about other 

relatives.

☐ Marital Status ☐ Citizenship ☐ Professional/personal 

references or other 

information about an 

individual’s friends, 

associates or acquaintances.

☐ Religion/Religious 

Preference

☐ Passport Information ☐ Global Positioning System 

(GPS)/Location Data

☐ Sexual Orientation ☐ User names, avatars etc. ☐ Secure Digital (SD) Card 

or Other Data stored on a card 

or other technology

☐ Cell tower records (e.g., 

logs. user location, time 

etc.)

☐ Network 

communications data

☐ Cubical or office number

☐ Contact lists and 

directories (known to 

contain personal 

information)

☐ Contact lists and 

directories (not known to 

contain personal 

information, but uncertain)

☐ Contact lists and 

directories (known to contain 

only business information)

☐ Education Information ☐ Device settings or 

preferences (e.g., security 

level, sharing options, 

ringtones).

☐ Alias (including 

nickname)

☐ Resume or curricula 

vitae

☐ Other (please describe): 

______________________

☐ Other (please describe):

______________________

Identifying Numbers 

☐ Full Social Security number ☐ Health Plan Beneficiary Number

☐ Personal Bank Account Number ☐ Business Bank Account Number

☐ Personal Taxpayer Identification Number ☐ Business Taxpayer Identification 

Number (If known: ☐ sole proprietor; ☐ 
non-sole proprietor)

☐ Personal Credit Card Number ☐ Business Credit Card Number (If 

known: ☐ sole proprietor; ☐ non-sole 

proprietor)

☐ Personal Vehicle Identification Number ☐ Business Vehicle Identification Number 

(If known: ☐ sole proprietor; ☐ non-sole 

proprietor)

☐ Personal License Plate Number ☐ Business License Plate Number (If 

known: ☐ sole proprietor; ☐ non-sole 

proprietor)

☐ File/Case ID Number (individual) ☐ File/Case ID Number (business) (If 

known: ☐ sole proprietor; ☐ non-sole 

proprietor)

☐ Personal Professional License Number ☐ Business Professional License Number

(If known: ☐ sole proprietor; ☐ non-sole 

proprietor)

☒ Employee Identification Number ☐ Patient ID Number 

☐ Alien Registration Number ☐ Truncated/Partial Social Security 

number (e.g., last 4 digits)

☐ Commercially obtained internet 

navigation/purchasing habits of individuals

☐ Government obtained internet 

navigation/purchasing habits of individuals

☐ Business License Plate Number (non-soleproprietor)☐ Driver’s License Number

☐ Personal device identifiers or serial 

numbers

☐ Other Identifying Numbers (please 

describe):____________________________

Medical/Emergency Information Regarding Individuals

☐ Medical/Health 

Information

☐ Worker’s Compensation 

Act Information

☐ Patient ID Number

☐ Mental Health 

Information

☐ Disability Information ☐ Emergency Contact 

Information (e.g., a third party 

to contact in case of 

emergency)

☐ Other (please describe): ____________________________________________________

Biometrics/Distinguishing Features/Characteristics of Individuals

☐ Physical description/

characteristics (e.g., hair, 

eye color, weight, height, 

sex, gender etc.)

☐ Signatures ☐ Vascular scans

☐ Fingerprints ☐ Photos ☐ Retina/Iris Scans

☐ Palm prints ☐ Video ☐ Dental Profile
☐ Voice audio recording ☐ Scars, marks, tattoos ☐ DNA Sample or Profile

☐ Other (please describe): 

______________________

☐ Other (please describe): 

_______________________

☐ Other (please describe): 

_______________________

Specific Information/File Types 

☐ Taxpayer 

Information/Tax Return 

Information

☐ Law Enforcement 

Information

☐ Security 

Clearance/Background Check

Information

☐ Civil/Criminal History 

Information/Police Records

(government source)

☐ Credit History 

Information (government 

source)

☐ Bank Secrecy Act 

Information

☐ Civil/Criminal History 

Information/Police Records

(commercial source)

☐ Credit History 

Information (commercial

source)

☐ National 

Security/Classified 

Information

☐ Protected Information 

(as defined in Treasury 

Directive 25-10)

☐ Case files ☐ Personnel Files

☐ Information provided 

under a confidentiality 

agreement 

☐ Information subject to 

the terms of an international 

or other agreement 

☐ Other (please describe): 

______________________

Audit Log and Security Monitoring Information

☒ User ID assigned to or 

generated by a user of 

Treasury IT

☒ Date and time an 

individual accesses a 

facility, system, or other IT

☐ Files accessed by a user of 

Treasury IT (e.g., web 

navigation habits)

☐ Passwords generated by 

or assigned to a user of 

Treasury IT

☐ Internet or other queries 

run by a user of Treasury IT

☐ Contents of files accessed 

by a user of Treasury IT

☐ Biometric information 

used to access Treasury 

facilities or IT

☐ Video of individuals 

derived from security 

cameras

☐ Public Key Information.

☐ Information revealing an 

individual’s presence in a 

particular location as 

derived from security 

token/key fob, employee 

identification card scanners 

or other IT or devices

☐ Still photos of 

individuals derived from 

security cameras.

☐ Internet Protocol (IP) 

Address

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

_____________________
Other

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

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

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

User Name / Contact Information

Specific PII identified in Section 4.2 that was acquired from this source: User or PIV card 

provided.

Manner in which information is acquired from source by the Treasury project/system: 

(select all that apply):

☒ From a paper or electronic form provided to individuals, the public or members of a particular 

group

Please identify the form name (or description) and/or number (e.g., OMB Control VMS Visitor 

on-line request screen (name, work address, work email, work phone number, supervisor name 

and contact phone/email, visitor primary contact name, work email, work phone). 

☐ Received in paper format other than a form.

☐ Delivered to the project on disk or other portable device and uploaded to the system.

☐ Accessed and downloaded or otherwise acquired via the internet

☐ Email 

☐ Scanned documents uploaded to the system.

☐ Bulk transfer

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

video or photographic cameras, biometric collection devices, PIV cards, etc.).

☐ Fax

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

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

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

Information

When federal agencies use a form to obtain information from an individual that will be 

maintained in a system of records, they must inform the individual of the following: “(A) the 

authority (whether granted by statute, or by executive order of the President) which authorizes 

the solicitation of the information and whether disclosure of such information is mandatory or 

voluntary; (B) the principal purpose or purposes for which the information is intended to be 

used; (C) the routine uses which may be made of the information as published pursuant to 
paragraph (4)(D) of this subsection; and (D) the effects on him, if any, of not providing all or any 

part of the requested information.” 5 U.S.C § 522a(e)(3).

Section 4.4(a) ☒ Yes ☐ No Is any of the PII maintained in the system or by the project 

collected directly from an individual? 

Section 4.4(b) ☒ Yes ☐ No ☐ N/A Was the information collected from the individual using 

a form (paper or electronic)?

Section 4.4(c) ☐ Yes ☒No ☐ N/A If the answer to Section 4.4(b) was “yes,” was the 

individual notified (on the form in which the PII was collected or on a separate form that can 

be retained by the individual) about the following at the point where the information was 

collected (e.g., in a form; on a website). The notification to users that all data is being 

collected based on PIV users signing an information awareness notification when they 

accepted their PIV cards. This noticed will be added in Phase II of the project. 

☐ The authority (whether granted by statute, or by Executive order of the President) 

which authorizes the solicitation of the information.

☐ Whether disclosure of such information is mandatory or voluntary.

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

☐ The individuals or organizations outside of Treasury with whom the information 

may be/ will be shared.

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

the requested information.

The VMS currently does not provide notice regarding the data collection, as the data is all 

Treasury business data and employees are already notified and consent to collection under 

HSPD-12 PIV card issuance. A notice will be added to the system during Phase II rollout. 

Use of Social Security Numbers

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

acts against individuals. Therefore, as a matter of policy, federal agencies are required to 

eliminate the use of SSNs (subject to certain exemptions).

In addition, the Privacy Act provides that: “It shall be unlawful for any Federal, State or local 

government agency to deny to any individual any right, benefit, or privilege provided by law 

because of such individual’s refusal to disclose his social security account number.” Pub. L. No. 

93–579, § 7. This provision does not apply to: (1) any disclosure which is required by federal 

statute; or (2) any disclosure of an SSN to any federal, state, or local agency maintaining a 

system of records in existence and operating before January 1, 1975, if such disclosure was 

required under statute or regulation adopted prior to such date to verify the identity of an 

individual. Id. at § 7(a)(2)(A)-(B).
Section 4.4(d) ☐ Yes ☒ No ☐ N/A Does the system or project maintain SSNs?

Section 4.4(e) ☐ Yes ☒ No ☐ N/A Were steps taken to explore alternatives to the SSNs as 

a personal identifier? 

Section 4.4(f) ☐ Yes ☒ No ☐ N/A Will individuals be denied any right, benefit, or 

privilege provided by law because of such individual's refusal to disclose their SSN? If yes, 

please check all of the following that apply (thus making collection for this purpose lawful):

☐ SSN disclosure is required by federal statute;

☐ the SSN is disclosed to any federal, state, or local agency maintaining a system of 

records in existence and operating before January 1, 1975, and disclosure was required 

under statute or regulation adopted prior to such date to verify the identity of an 

individual; or

☐ when the information is collected, individuals are given notice whether that 

disclosure is mandatory or voluntary, by what statutory or other authority such number 

is solicited, and what uses will be made of it.

The VMS system does not collect, maintain, or use SSNs.

First Amendment Activities

The Privacy Act provides that federal agencies, “maintain no record describing how any 

individual exercises rights guaranteed by the First Amendment unless expressly authorized by 

statute or by the individual about whom the record is maintained or unless pertinent to and within 

the scope of an authorized law enforcement activity.” 5 U.S.C. § 552a(e)(7).

Section 4.4(g) ☐ Yes ☒ No Does the system or project maintain any information describing 

how an individual exercises their rights guaranteed by the First Amendment? 

Section 4.4(h) If the system or project maintains information describing how an individual 

exercises their rights guaranteed by the First Amendment, do any of the following exceptions 

(any one of which allows the maintenance of such information) apply?

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

authorizes its collection/maintenance. 

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

law enforcement activity.

☐ There is a statute that expressly authorizes its collection. 

☒ N/A, the system or project does not maintain any information describing how any 

individual exercises their rights guaranteed by the First Amendment.

The VMS system does not collect information related to First Amendment activities. 
Section 5: Maintenance, use, and sharing of the information

The following sections require a clear description of the system’s or project’s use of information.

Section 5.1: Describe how and why the system or project uses the information it 

collects and maintains

Please describe all of the uses of the information types and groupings collected and maintained 

by the system or project (see Section 4.2), including a discussion of why the information is used 

for this purpose and how it relates to the mission of the bureau or office that owns the system. 

The VMS system collects the following information related to each visitor: name, government 

issued work email address, work address, work phone number, who they are requesting to visit 

and their contact information, the PIV card Federal Agency Smart Credential Number FASCN, and certificate. This allows the Physical Security Officer to review and approve, or deny 

access to the requested facility for the requested time period. This process automates existing 

policies and processes in support of the HSPD-12 mandates. If the visit is approved, the PIV 

card information is automatically processed to the appropriate Physical Access System (door 

card readers of the building they are visiting) for the day/time of the approved visit. This 

information is only used to grant access to Treasury facilities. 

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

Determinations About Them

The Privacy Act requires that federal agencies, “collect information to the greatest extent 

practicable directly from the subject individual when the information may result in adverse 

determinations about an individual’s rights, benefits, and privileges under Federal programs.” 5 

U.S.C. § 552a(e)(2).

Section 5.1(a) ☐ Yes ☒ No Is it possible that the information maintained in the system or 

by the project may be used by Treasury to make an adverse determination about an 

individual’s rights, benefits, and privileges under federal programs (e.g., decisions about 

whether the individual will receive a financial benefit, get a clearance or access to a Treasury 

facility, obtain employment with Treasury)? 

Section 5.1(b) ☐ Yes ☒ No Is it possible that Treasury will share information maintained in 

the system or by the project with a third party external to the Department that will use the 

information to make an adverse determination about an individual’s rights, benefits, and 

privileges under federal programs? 

Section 5.1(c) ☐ Yes ☒ No ☐ N/A If information could potentially be used to make an 

adverse determination about an individual’s rights, benefits, and privileges under federal 

programs, does the system or project collect information (to the greatest extent practicable) 
directly from the individual? 

The VMS system does not use information collected to make an adverse 

determination about an individual’s rights, benefits, and privileges under federal 

programs.

Data Mining

As required by Section 804 of the Implementing the 9/11 Commission Recommendations Act of 

2007 (“9-11 Commission Act”), Treasury reports annually to Congress on its data mining 

activities. For a comprehensive overview of Treasury’s data mining activities, please review the 

Department’s Annual Privacy reports available at: http://www.treasury.gov/privacy/annualreports.

Section 5.1(d) ☐ Yes ☒ No Is information maintained in the system or by the project used 

to conduct “data-mining” activities as that term is defined in the Implementing the 9-11 

Commission Act? 

The information in VMS is not used to conduct Data Mining Activities. 

Section 5.2: Ensuring accuracy, completeness, and timeliness of information 

collected, maintained, and shared

Exemption from Accuracy, Relevance, Timeliness, and Completeness Requirements

The Privacy Act requires that federal agencies, “maintain all records which are used by the 

agency in making any determination about any individual with such accuracy, relevance, 

timeliness, and completeness as is reasonably necessary to assure fairness to the individual in the 

determination.” 5 U.S.C § 552a.(e)(5). If a particular system of records meets certain 

requirements (including the NPRM process defined in Section 2 above), an agency may exempt 

the system of records (or a portion of the records) from this requirement.

Section 5.2(a) ☒ Yes ☒ No Is all or any portion of the information maintained in the system 

or by the project: (a) part of a system of records and (b) exempt from the accuracy, relevance, 

timeliness, and completeness requirements in sections (e)(5) of the Privacy Act? 

VMS data are maintained in the Treasury. 007 Personnel Security system of records. 

Treasury.007 is exempt from 5 U.S.C.552a(c)(3), (d)(1), (2), (3), and (4), (e)(1),(e)(4)(G), (H), 

and (I), and (f) of the Privacy Act pursuant to 5 U.S.C.552a(k)(5). (See 31 CFR 1.36.) While 

the system is exempt from the above provisions, including the accuracy, relevance and 

timeliness requirement, VMS relies on accuracy of the data provided by the individual to allow 

Access Approvers to make appropriate decisions based on information the employee provides. 
Computer Matching

The Computer Matching and Privacy Protection Act of 1988 amended the Privacy Act for the 

purpose of imposing additional requirements when Privacy Act systems of records are used in 

computer matching programs. 

Pursuant to the Privacy Act, as amended, there are two distinct types of matching programs. The 

first type of matching program involves the computerized comparison of two or more automated 

federal personnel or payroll systems of records or a system of federal personnel or payroll 

records with non-federal records. This type of matching program may be conducted for any 

purpose. The second type of matching program involves the computerized comparison of two or 

more automated systems of records or a system of records with non-federal records. The 

purpose of this type of matching program must be for the purpose of eligibility determinations or 

compliance requirements for applicants, recipients, beneficiaries, participants, or providers of 

services for payments or in-kind assistance under federal benefit programs, or recouping 

payments or delinquent debts under such federal benefit programs. See 5 U.S.C. § 522a(a)(8).

Matching programs must be conducted pursuant to a matching agreement between the source 

and recipient agencies. The matching agreement describes the purpose and procedures of the 

matching and establishes protections for matching records. 

Section 5.2(b) ☐ Yes ☒ No Is any of the information maintained in the system or by the 

project (a) part of a system of records and (b) used as part of a matching program? 

Section 5.2(c) ☐ Yes ☒ No ☐ N/A Is there a matching agreement in place that contains the 

information required by Section (o) of the Privacy Act? 

Section 5.2(d) ☐ Yes ☒ No ☐ N/A Are assessments made regarding the accuracy of the 

records that will be used in the matching program? 

Section 5.2(e) ☐ Yes ☒ No ☐ N/A Does the bureau or office that owns the system or 

project independently verify the information, provide the individual notice and an opportunity 

to contest the findings, or obtain Data Integrity Board approval in accordance with Section (p) 

of the Privacy Act before taking adverse action against the individual? 

The CMPPA provisions of the Privacy Act do not apply to VMS. 

Ensuring Fairness in Making Adverse Determinations About Individuals

Federal agencies are required to, “maintain all records which are used by the agency in making 

any determination about any individual with such accuracy, relevance, timeliness, and 

completeness as is reasonably necessary to assure fairness to the individual in the

determination.” 5 U.S.C. § 552a(e)(5). This requirement also applies when merging records 

from two or more sources where the merged records are used by the agency to make any 

determination about any individual. 
Section 5.2(f) ☒ Yes ☐ No ☐ N/A Are steps taken to ensure all information used to make 

a determination about an individual is maintained with such accuracy, relevance, timeliness, 

and completeness as is reasonably necessary to assure fairness to the individual in the 

determination?

Merging Information About Individuals

Section 5.2(g) ☒ Yes ☐ No Is information maintained in the system or by the project 

merged with electronic or non-electronic information from internal or external sources (e.g., 

other files or systems)? 

Section 5.2(h) ☒ Yes ☐ No ☐ N/A Once merged, is the information used in making 

determinations about individuals (e.g., decisions about whether the individual will receive a 

financial benefit or payment, get a clearance or access to a Treasury facility, obtain 

employment with Treasury, etc.)? 

Section 5.2(i) ☒ Yes ☐ No ☐ N/A Are there documented policies or procedures for how 

information is merged? 

Section 5.2(j) ☒ Yes ☐ No ☐ N/A Do the documented policies or procedures address how 

to proceed when partial matches (where some, but not all of the information being merged 

matches a particular individual) are discovered after the information is merged?

Section 5.2(k) ☒ Yes ☐ No ☐ N/A If information maintained in the system or by the 

project is used to make a determination about an individual, are steps taken to ensure the 

accuracy, relevance, timeliness, and completeness of the information as is reasonably 

necessary to assure fairness to the individual?

The VMS application receives data from the Bureau of Fiscal Service Single Sign-on Service. 

The user provides the visiting POC name, business email, business phone, requested visit 

location. No matching takes place within the system. The first time a user logs in, a unique 

user ID is created using the FASC-N. No other search is conducted, except to verify that the 

card certificate is still valid by the SAFE system reviewing the Certificate Revocation List 

(CRL) to verify the PIV card is still current. Information is merged in the system according to

standards, policies, and procedures outlined in HSPD-12. 1 VMS is limited to determining 

employee physical access to Treasury facilities and does not, in any way, affect the rights of 

individuals. 

Policies and Standard Operating Procedures or Technical Solutions Designed to Ensure 

Information Accuracy, Completeness, and Timeliness

 1

 For more information please see: 

http://www.smartcardalliance.org/secure/reports/FIPS_201_PACWhite_Paper_FINAL_092105.pdf
Section 5.2(l) ☒ Yes ☐ No ☐ N/A If information maintained in the system or by the 

project is used to make any determination about an individual (regardless of if it is an exempt 

system of records), are there documented policies or standard operating procedures for the 

system or project that address the accuracy, completeness, and timeliness of the information?

Section 5.2(m) ☒ Yes ☐ No ☐ N/A Does the system or project use any software or other 

technical solutions designed to improve the accuracy, completeness, and timeliness of the 

information used to make an adverse determination about an individual's rights, benefits, 

and/or privileges (regardless of if it is an exempt system of records)? 

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

Section 5.2(n) ☒ Yes ☐ No Did the bureau or office receive any guarantee, assurance, or 

other information from any information source(s) regarding the accuracy, timeliness and 

completeness of the information maintained in the system or by the project? 

The VMS system assumes the accuracy of the PIV data, based on HSPD-12 card issuance 

requirements, provided as well as the data provided by the Bureau of the Fiscal Service (BFS)

Single Sign On portal and f5(Enterprise authentication services provided by the BFS Data 

Center General Support System (GSS)) services. The PIV card is issued under by the HSPD-12 

program of Treasury. The HSPD-12 program uses the PIV card issuance process to validate 

all user data The data is encoded onto the PIV card and extracted as part of the authentication 

process. BFS SSO – Single Sign On in conjunction with the f5 device services provide 

authentication services for Treasury Users with valid PIV cards. 

Disseminating Notice of Corrections of or Amendments to PII

Section 5.2(o) ☐ Yes ☐ No ☒ N/A Where feasible and appropriate, is there a process in 

place for disseminating corrections of or amendments to the PII maintained in the system or 

by the project to all internal and external information-sharing partners?

Section 5.2(p) ☐ Yes ☐ No ☒ N/A Where feasible and appropriate, does the process for 

disseminating corrections or amendments include notifying the individual whose information 

is corrected or amended? 

All data within the system is obtained from the PIV card / USAccess or provided by the visit 

requestor. Once a record is created the VMS system does not query USAccess for updates. 

There are mechanisms within USAccess system to address any updates that are required by 

the user or other data owner. Additionally, the VMS is not authorized to query any other 

systems for updates. 

If an employee leaves the organization for any reason their PIV card will no longer permit 

access. If information is updated with in USAccess, the next time a user access the system a 

comparison will occur and any required updates will be performed automatically. Employees 

do not have rights under the Privacy Act to access and amend inaccurate records in VMS, as 

these records are exempt from the access and amendment provisions of the Act. 
Section 5.3: Information sharing within the Department of the Treasury

Internal Information Sharing

Section 5.3(a) ☒ Yes ☐ No Is PII maintained in the system or by the project shared with 

other Treasury bureaus or offices?

Section 5.3(b) ☒ Yes ☐ No Does the Treasury bureau or office that receives the PII limit 

access to those Treasury officers and employees who have a need for the PII in the 

performance of their official duties (i.e., those who have a “need to know”)?

The VMS system uses role based access for data access. Administrators are only provided

limited data access to be able to complete their assigned task. 

Memorandum of Understanding/Other Agreements Limiting Treasury’s Internal 

Use/Disclosure of PII

Section 5.3(c) ☐ Yes ☒ No ☐ N/A Is any of the PII maintained in the system or by the 

project subject to the requirements of a Memorandum of Understanding or other agreement 

(e.g., agreement with another federal or state agency that provided the information to the 

Treasury or subject to an international agreement or treaty) that limits or places conditions 

on Treasury’s internal use, maintenance, handling, or disclosure of the PII? 

There are no Memorandums of Understanding in place that further limit Treasury’s internal 

use or disclosure of the PII in VMS. Treasury collects limited business contact information 

for VMS, and limits access to only those with a need to know to perform their duties. Treasury 

does not disclose this information externally. 

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

and individuals

External Information Sharing

Section 5.4(a) ☐ Yes ☒ No Is PII maintained in the system or by the project shared with 

agencies, organizations, or individuals external to Treasury? 

Accounting of Disclosures

Section 5.4(b) ☒ Yes ☐ No ☐ N/A With respect to records maintained in the system or 

by the project that are subject to the Privacy Act, do you maintain a paper or electronic log 

or other record of the date, nature, and purpose of each disclosure (not including intraagency disclosures and FOIA disclosures) of a record to any person or to another agency 

(outside of Treasury) and the name and address of the person or agency to whom the 

disclosure is made? See 5 U.S.C § 552a(c). 

Section 5.4(c) ☐ Yes ☐ No ☒ N/A If you do not keep a running tabulation of every 
disclosure at the time it is made, are you able to reconstruct an accurate and complete 

accounting of disclosures so as to be able to respond to Privacy Act requests in a timely 

fashion? 

Section 5.4(d) ☐ Yes ☐ No ☒ N/A With respect to records maintained in the system or by 

the project that are subject to the Privacy Act, do you retain the log or other record of the 

date, nature, and purpose of each disclosure, for at least five years or the life of the record, 

whichever is longer, after the disclosure for which the accounting is made? 

Section 5.4(e) ☐ Yes ☐ No ☒ N/A With respect to records maintained in the system or by 

the project that are subject to the Privacy Act, does your bureau or office exempt the system 

of records (as allowed by the Privacy Act in certain circumstances) from the requirement to 

make the accounting available to the individual named in the record? 

Section 5.4(f) ☐ Yes ☐ No ☒ N/A With respect to records maintained in the system or by 

the project that are subject to the Privacy Act, does your bureau or office exempt the system 

of records (as allowed by the Privacy Act in certain circumstances) from the requirement to 

inform any person or other agency about any correction or notation of dispute made by the 

agency of any record that has been disclosed to the person or agency if an accounting of the 

disclosure was made?

the information in VMS is exempt from the accounting of disclosures requirement. 

Statutory or Regulatory Restrictions on Disclosure

Section 5.4(g) ☐ Yes ☒ No In addition to the Privacy Act, are there any other statutory or 

regulatory restrictions on the sharing of any of the information or records maintained in the 

system or by the project (e.g., 26 U.S.C § 6103 for tax returns and return information)? 

Memorandum of Understanding Related to External Sharing

Section 5.4(h) ☐ Yes ☒ No ☐ N/A Has Treasury (including bureaus and offices) executed

a Memorandum of Understanding, or entered into any other type of agreement, with any 

external agencies, organizations, or individuals with which/whom it shares PII maintained in 

the system or by the project? 

The VMS system does not share information externally except in accordance with the routine 

uses outlined in Treasury.007. No external MOU is required. 

Memorandum of Understanding Limiting Treasury’s Use or Disclosure of PII

Section 5.4(i) ☐ Yes ☒ No ☐ N/A Is any of the PII maintained in the system or by the 

project subject to the requirements of a Memorandum of Understanding or other agreement 

(e.g., agreement with another federal or state agency, an international agreement or treaty, or 

contract with private vendor that provided the information to Treasury or one of its bureaus) 

that limits or places conditions on Treasury’s internal use or external (i.e., outside Treasury) 

sharing of the PII? 

Memorandum of Understanding Limiting External Party’s Use or Disclosure of PII
Section 5.4(j) ☐ Yes ☒ No ☐ N/A Is any of the PII maintained in the system or by the 

project subject to the requirements of a Memorandum of Understanding or other agreement in 

which Treasury limits or places conditions on an external party’s use, maintenance, handling, or 

disclosure of PII shared by Treasury? 

External Information Sharing Chart

Section 5.4(k) ☒ N/A 

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

Authorized by the Privacy Act

Section 5.4(l) ☐ Yes ☒ No ☐ N/A Is the individual’s consent obtained, where 

feasible and appropriate, prior to any new disclosures of previously collected records 

in a system of records (those not expressly authorized by the Privacy Act or 

contained in the published SORN (e.g., in the routine uses))? 

The system does not disclose information that is not authorized by the Privacy Act. 

Information is disclosed in accordance with Treasury .007 Personnel Security 

System.2

Section 6: Compliance with federal information management 

requirements

Responses to the questions below address the practical, policy, and legal consequences of 

failing to comply with one or more of the following federal information management 

requirements (to the extent required) and how those risks were or are being mitigated: (1) the 

Privacy Act System of Records Notice Requirement; (2) the Paperwork Reduction Act; (3) the 

Federal Records Act; (4) the E-Gov Act security requirements; and (5) Section 508 of the

Rehabilitation Act of 1973.

Section 6.1: Privacy Act System of Records Notice (SORN)

For collections of PII that meet certain requirements, the Privacy Act requires that the agency 

publish a SORN in the Federal Register.

System of Records

Section 6.1(a) ☒ Yes ☐ No Does the system or project retrieve records about an 

individual using an identifying number, symbol, or other identifying particular assigned to 

the individual? (see items selected in Section 4.2 above) 

Section 6.1(b) ☒ Yes ☐ No ☐ N/A Was a SORN published in the Federal Register for 

 2

 Treasury.007 is available here: https://www.treasury.gov/privacy/issuances/Pages/default.aspx
this system of records? 

VMS is governed by Treasury. 007 Personnel Security SORN. Treasury.007 permits the 

collection of information from Treasury employees and contractor personnel who have 

applied for the HSPD-12 Personal Identity Verification (PIV) Card; to determine whether an 

individual is eligible for logical and physical access to Treasury controlled facilities and 

information systems. 

Section 6.2: The Paperwork Reduction Act

The PRA requires OMB approval before a federal agency may collect standardized data from 10 

or more respondents within a 12 month period. OMB requires agencies to conduct a PIA (a 

Treasury PCLIA) when initiating, consistent with the PRA, a new electronic collection of PII for 

10 or more persons (excluding agencies, instrumentalities, or employees of the federal 

government).

Paperwork Reduction Act Compliance

Section 6.2(a) ☐ Yes ☒ No Does the system or project maintain information obtained from 

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

government (i.e., outside the federal government)? 

Section 6.2(b) ☐ Yes ☒ No ☐ N/A Does the project or system involve a new collection 

of information in identifiable form for 10 or more persons from outside the federal 

government? 

Section 6.2(c) ☐ Yes ☐ No ☒ N/A Did the project or system complete an Information 

Collection Request (“ICR”) and receive OMB approval? 

The PRA requirements do not apply here. VMS does not collect information from members of 

the public. 

Section 6.3: Records Management - NARA/Federal Records Act Requirements

Records retention schedules determine the maximum amount of time necessary to retain 

information in order to meet the needs of the project or system. Information is generally either 

disposed of or sent to the NARA for permanent retention upon expiration of this period.

NARA Records Retention Requirements

Section 6.3(a) ☒ Yes ☐ No Are the records used in the system or by the project covered by 

a General Records Schedules (“GRS”)? 

Section 6.3(b) ☒ Yes ☐ No Did NARA approve a retention schedule for the records 

maintained in the system or by the project?

Section 6.3(c) ☐ Yes ☐ No ☒ N/A If NARA did not approve a retention schedule for the 
records maintained in the system or by the project and the records are not covered by a GRS, 

has a draft retention schedule (approved by all applicable Treasury officials) been developed 

for the records used in this project or system?

The information that VMS maintains is outlined in General Records Schedule 18, Security and 

Protective Service Records (item17)3. The records are maintained as follows:

For areas under maximum security: Destroy 5 years after final entry or 5 years after date of 

document, as appropriate. (GRS 18, 1960, item 17) 

For other areas: Destroy 2 years after final entry or 2 years after date of document, as 

appropriate. (GRS 18, 1960, item 17)

Section 6.4: E-Government Act/NIST Compliance

The completion of Federal Information Security Management Act (“FISMA”) Security 

Assessment & Authorization process is required before a federal information system may receive 

Authority to Operate (“ATO”). Different security requirements apply to National Security 

Systems.

Federal Information System Subject to FISMA Security Assessment and Authorization

Section 6.4(a) ☒ Yes ☐ No ☐ N/A Is the system a federal information system subject to 

FISMA requirements?

Section 6.4(b) ☐ Yes ☒ No ☐ N/A Has the system or project undergone a Security 

Assessment and Authorization and received Authority to Operate? 

The system is currently undergoing an assessment and is projected to receive its ATO by 

early 2017. This PCLIA is a part of the ATO approval process.

Access Controls and Security Requirements

Section 6.4(c) ☒ Yes ☐ No Does the system or project include access controls to ensure 

limited access to information maintained by the system or project?

The VMS system uses role based access to manage access to visitor data and building 

approval functions; this system is an automated process that handles existing

Facility/Personnel security functions. 

There are limited privacy risks presented by VMS access controls. The system contains very 

limited business information and is only available to those employees who have a need to 

know.

Security Risks in Manner of Collection

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

used in the system or project and the method and manner of collection. Were any security, 

privacy, or civil liberties risks identified with respect to the manner in which the information 

is collected from the source(s)? 

 3 https://www.archives.gov/files/records-mgmt/grs/grs18.pdf
VMS presents limited security risks regarding the manner of collection. The system uses 

HSPD-12 approved processes to collect maintain and use limited contact information to 

verify an employee’s ability to enter certain Treasury facilities. 

Security Controls When Sharing Internally or Externally

Section 6.4(e) ☒ Yes ☐ No ☐ N/A Are all Treasury/bureau security requirements met in 

the method of transferring information (e.g., bulk transfer, direct access by recipient, portable 

disk, paper) from the Treasury project or system to internal or external parties? 

Monitoring of Individuals

Section 6.4(f) ☒ Yes ☐ No Will this system or project have the capability to identify, locate, 

and monitor individuals or groups of people? 

VMS identifies whether Treasury employees can access Treasury facilities, therefore, it does 

identify and locate individuals who are attempting to access Treasury facilities. This does not 

create additional risks to privacy, as Treasury employees are notified upon receiving a PIV 

Card that it is to be used for physical access into Federal Facilities. 

Audit Trails

Section 6.4(g) ☒ Yes ☐ No Are audit trails regularly reviewed for appropriate use, 

handling, and disclosure of PII maintained in the system or by the project inside or outside of 

the Department? 

Section 6.5: Section 508 of the Rehabilitation Act of 1973

When federal agencies develop, procure, maintain, or use Electronic and Information 

Technology (“EIT”), Section 508 of the Rehabilitation Act of 1973 (as amended in 1998) 

requires that individuals with disabilities (including federal employees) must have access and use 

(including privacy policies and directives as well as redress opportunities) that is comparable to 

that which is available to individuals who do not have disabilities.

Applicability of the Rehabilitation Act

Section 6.5(a) ☒ Yes ☐ No Will the project or system involve the development, 

procurement, maintenance or use of EIT as that term is defined in Section 508 of the 

Rehabilitation Act of 1973 (as amended in 1998)? 

Compliance With the Rehabilitation Act

Section 6.5(b) ☒ Yes ☐ No ☐ N/A Does the system or project comply with all Section 508

requirements, thus ensuring that individuals with disabilities (including federal employees) 

have access and use (including access to privacy and civil liberties policies) that is comparable 

to that which is available to individuals who do not have disabilities? 
Section 7: Redress

Access Under the Freedom of Information Act and Privacy Act

Section 7.0(a) ☒ Yes ☐ No Does the agency have a published process in place by which 

individuals may seek records under the Freedom of Information Act and Privacy Act? 

The Treasury FOIA Regulations can be found at 31 CFR Part 1, Subpart A.

Privacy Act Access Exemption

Section 7.0(b) ☒ Yes ☐ No Was any of the information that is maintained in system of 

records and used in the system or project exempted from the access provisions of the Privacy 

Act? 

VMS records are exempt from the access provisions of the Privacy Act. 

Additional Redress Mechanisms

Section 7.0(c) ☐ Yes ☒ No With respect to information maintained by the project or 

system (whether or not it is covered by the Privacy Act), does the bureau or office that owns 

the project or system have any additional mechanisms other than Privacy Act and FOIA 

remedies (e.g., a customer satisfaction unit; a complaint process) by which an individual may 

request access to and/or amendment of their information and/or contest adverse 

determinations about denial of their rights, benefits, and privileges under federal programs 

(e.g., decisions about whether the individual will receive a financial benefit, get a clearance or 

access to a Treasury facility, obtain employment with Treasury)?