Occupational Safety and Health 

Review Commission

Privacy Impact Assessment (PIA)

Information System: Occupational Safety and Health Review Commission 

Network and General Support System

Component: Office 365

Date: 7/25/2022

OSHRC Office: Privacy Office

Privacy Analyst: Ron Bailey

Telephone Number: (202) 606-5410

E-mail Address: rbailey@oshrc.gov
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Section 1.0 Information System’s Contents: 

1.1 Action necessitating Privacy Impact Assessment (PIA): 

New information system—Implementation date:

Revised or upgraded information system—Revision or upgrade date:

If this system is being revised—what will be done with the newly derived information: 

Placed in existing information system—Implementation date:

Placed in new auxiliary/ancillary information system—Date:

Other use(s)—Implementation date:

Please explain your response:

New collection of information—Collection date:

This is a revision to a PIA that was last revised on October 4, 2021. OSHRC has redefined the system 

covered by this PIA to be a component of a larger information system, “Occupational Safety and Health 

Review Commission Network and General Support System.”

1.2 Has a Privacy Threshold Assessment (PTA) been done? 

Yes 

Date: September 27, 2018, revised October 4, 2021

No 

If a PTA has not been done, please explain why not: 

If the Privacy Threshold Assessment (PTA) has been completed, please skip to Question 1.10 (The PTA

is attached.)

1.3 Has this information system, which contains information about individuals, e.g., personally 

identifiable information (PII), existed under another name, e.g., has the name been changed or 

modified? 

Yes 

No 

Please explain your response: 

1.4 Has this information system undergone a “substantive change” in the system’s format or operating 

system? 

Yes 

No 

If yes, please explain your response: 

If there have been no changes to the information system’s format or operating system(s), please skip to 

Question 1.6.
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1.5 Has the medium in which the information system stores the records or data in the system changed:

Paper files to electronic medium (computer database); 

From one IT (electronic) information system to IT system, i.e., from one database, operating 

system, or software program, etc. 

Please explain your response:

1.6 What information is the system collecting, analyzing, managing, using, and/or storing, etc.:

Information about OSHRC Employees: 

No OSHRC employee information

OSHRC employee’s name

Other names used, i.e., maiden name, etc. 

OSHRC badge number (employee ID) 

SSN 

Race/Ethnicity 

Gender 

U.S. Citizenship 

Non-U.S. Citizenship 

Biometric data 

Fingerprints 

Voiceprints 

Retina scans/prints 

Photographs 

Other physical information, i.e., hair color, eye color, identifying marks, etc. 

Birth date/age 

Place of birth 

Medical data 

Marital status 

Spousal information 

Miscellaneous family information 

Home address 

Home address history 

Home telephone number(s) 

Personal cell phone number(s):

Personal fax number(s) 

E-mail address(es): OSHRC e-mail address. 

Emergency contact data:

Credit card number(s) 

Driver’s license 

Bank account(s) 

OSHRC personal employment records 

Military records 

Financial history 

Foreign countries visited 

Law enforcement data 

Background investigation history 

National security data 

Communications protected by legal privileges 

Digital signature

Other information:
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Information about OSHRC Contractors: 

No OSHRC contractor information 

Contractor’s name

Other name(s) used, i.e., maiden name, etc. 

OSHRC Contractor badge number (Contractor ID) 

SSN 

U.S. Citizenship 

Non-U.S. Citizenship 

Race/Ethnicity 

Gender 

Biometric data 

Fingerprints 

Voiceprints 

Retina scans/prints 

Photographs 

Other physical information, i.e., hair color, eye color, identifying marks, etc. 

Birth date/Age 

Place of birth 

Medical data 

Marital status 

Spousal information 

Miscellaneous family information 

Home address 

Home address history 

Home telephone number(s) 

Personal cell phone number(s):

Personal fax number(s) 

Personal e-mail address(es):

Emergency contact data:

Credit card number(s) 

Driver’s license number(s)

Bank account(s) 

Non-OSHRC personal employment records

Military records 

Financial history 

Foreign countries visited 

Law enforcement data 

Background investigation history 

National security data 

Communications protected by legal privileges 

Digital signature 

Other information:

Information about OSHRC Volunteers, Visitors, Customers, and other Individuals:

Not applicable

Individual’s name:

Other name(s) used, i.e., maiden name, etc.

OSHRC badge number (employee ID) 

SSN:

Race/Ethnicity 

Gender 
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Citizenship 

Non-U.S. Citizenship 

Biometric data 

Fingerprints 

Voiceprints 

Retina scans/prints 

Photographs 

Other physical information, i.e., hair color, eye color, identifying marks, etc. 

Birth date/Age:

Place of birth 

Medical data 

Marital status 

Spousal information 

Miscellaneous family information 

Home address 

Home address history 

Home telephone number(s) 

Personal cell phone number(s):

Personal fax number(s) 

Personal e-mail address(es):

Emergency contact data:

Credit card number(s) 

Driver’s license number(s) 

Bank account(s) 

Non-OSHRC personal employment records 

Military records 

Financial history 

Foreign countries visited 

Law enforcement data 

Background investigation history 

National security data 

Communications protected by legal privileges 

Digital signature 

Other information:

Information about Business Customers and others (usually not considered “personal 

information”):

Not applicable

Name of business contact/firm representative, customer, and/or others 

Race/Ethnicity 

Gender 

Full or partial SSN:

Business/corporate purpose(s) 

Other business/employment/job description(s) 

Professional affiliations 

Business/office address 

Intra-business office address (office or workstation) 

Business telephone number(s) 

Business cell phone number(s) 

Business fax number(s) 

Business pager number(s) 

Business e-mail address(es) 
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Bill payee name 

Bank routing number(s) 

Income/Assets 

Web navigation habits 

Commercially obtained credit history data 

Commercially obtained buying habits 

Credit card number(s) 

Bank account(s) 

Other information:

1.7 What are the sources for the PII and other information that this information system (or database) is 

collecting:

Personal information from OSHRC employees: 

Personal information from OSHRC contractors:

Personal information from non-OSHRC individuals and/or households: 

Non-personal information from businesses and other for-profit entities: 

Non-personal information from institutions and other non-profit entities: 

Non-personal information from farms: 

Non-personal information from Federal Government agencies: 

Non-personal information from state, local, or tribal governments:

Other sources: 

1.8 Does this information system have any links to other information systems or databases? 

An information system (or database) may be considered as linked to other information systems (or 

databases) if it has one or more of the following characteristics: 

The information system is a subsystem or other component of another information system or 

database that is operated by another OSHRC bureau/office or non-OSHRC entity (like the FBI, 

DOJ, National Finance Center, etc.);

The information system transfers or receives information, including PII, between itself and 

another OSHRC or non-OSHRC information system or database: 

The information system has other types of links or ties to other OSHRC or non-OSHRC

information systems or databases; 

The information system has other characteristics that make it linked or connected to another 

OSHRC or non-OSHRC information system or database; 

The information system has no links to another information system (or database), i.e., it does 

not share, transfer, and/or obtain data from another system. 

Please explain your response: 

1.9 What PII does the information system obtain, share, and/or use from other information systems? 

OSHRC information system and information system name(s):

Non-OSHRC information system and information system name(s):

OSHRC employee’s name: 

(non-OSHRC employee) individual’s name

Other names used, i.e., maiden name, etc.

OSHRC badge number (employee ID)

Other Federal Government employee ID information, i.e., badge number, etc.

SSN:

Race/Ethnicity
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Gender

U.S. Citizenship

Non-U.S. Citizenship

Biometric data

Fingerprints

Voiceprints

Retina scan/prints

Photographs 

Other physical information, i.e., hair color, eye color, identifying marks, etc. 

Birth date/Age 

Place of birth 

Medical data 

Marital status 

Spousal information 

Miscellaneous family information: 

Home address 

Home address history 

Home telephone number(s) 

Personal cell phone number(s) 

Personal fax number(s) 

E-mail address(es): OSHRC e-mail address. 

Emergency contact data 

Credit card number(s) 

Driver’s license 

Bank account(s) 

Non-OSHRC personal employment records 

Non-OSHRC government badge number (employee ID) 

Law enforcement data 

Military records 

National security data 

Communications protected by legal privileges 

Financial history 

Foreign countries visited 

Background investigation history

Digital signature

Other information:

Information about Business Customers and others (usually not considered “personal 

information”):

Not applicable

Name of business contact/firm representative, customer, and/or others

Race/Ethnicity

Gender

Full or partial SSN:

Business/corporate purpose(s)

Other business/employment/job description(s)

Professional affiliations

Intra-business office address (office or workstation)

Business telephone number(s)

Business cell phone number(s)

Business fax number(s)

Business e-mail address(es)
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Bill payee name

Bank routing number(s)

Income/Assets

Web navigation habits

Commercially obtained credit history data

Commercially obtained buying habits

Personal clubs and affiliations

Credit card number(s)

Bank account(s)

Other information:

1.10 Under the Privacy Act of 1974, as amended, 5 U.S.C. § 552a, Federal agencies are required to have 

a System of Records Notice (SORN) for an information system like this one, which contains 

information about individuals, e.g., “personally identifiable information” (PII).

A System of Records Notice (SORN) is a description of how the information system will collect, 

maintain, store, and use the personally identifiable information (PII).

Does a SORN cover the PII in this information system? 

Yes

No 

If yes, what is this SORN: Four SORNs cover different portions of the records that are—or, in the 

future, may be—stored on OneDrive, a Microsoft cloud service included in the Office 365 suite of 

applications to which OSHRC subscribes: Emergency Contact Information, OSHRC-1; Payroll 

and Related Records, OSHRC-4; Office of the General Counsel Records, OSHRC-5; and 

Reasonable Accommodation Records, OSHRC-9.

Section 2.0 System of Records Notice (SORN):

2.1 What is the Security Classification for the information in this SORN, as determined by the OSHRC

Security Officer? The information covered by each of the SORNs is unclassified.

2.2 What is the location of the information covered by this SORN? As to the information addressed

by this PIA, the information covered by these SORNs is located on OneDrive, a Microsoft cloud 

service included in the Office 365 suite of applications.

2.3 What are the categories of individuals in the system of records covered by this SORN? 

Emergency Contact Information, OSHRC-1: Current OSHRC personnel, including Commission 

members, employees, and contractors.

Payroll and Related Records, OSHRC-4: Current and former employees of OSHRC and 

Commission members.

Office of the General Counsel Records, OSHRC-5: Current and former OSHRC attorneys 

(including supervising attorneys), Commission members, and Administrative Law Judges (ALJs); 

Freedom of Information Act requesters; and parties in cases that have been, or presently are, before 

OSHRC.

Reasonable Accommodation Records, OSHRC-9: Current and former OSHRC employees and 

applicants who have requested reasonable accommodations.
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2.4 What are the categories of records1 covered by this SORN?

Emergency Contact Information, OSHRC-1: (1) The names, home telephone numbers and 

addresses, and office telephone numbers of OSHRC personnel; (2) the names of emergency 

contacts, and the contacts’ home telephone numbers and addresses, and office telephone numbers; 

and (3) the relationships between OSHRC personnel and their designated emergency contacts.

Payroll and Related Records, OSHRC-4: (1) Direct deposit records that include the employee’s 

name and signature, address, and telephone number; the type of depositor account selected for 

direct deposit, and the account and routing numbers; and a voided check; (2) tax records that include 

the employee’s name and signature, social security number, marital status, and home address; the 

number of allowances for which the employee qualifies; and further information which may be 

required on state, county, or city withholding certificates; (3) employee retirement estimates that 

include the employee’s name and social security number; (4) records maintained pursuant to the 

Family Medical Leave Act that include the employee’s name, signature, and job description; 

identity of certain family members and, if a child, date of birth; and medical information pertinent 

to leave requests; and (5) records necessary for payroll processing by NFC, including those 

pertaining to time and attendance and leave records, that may include some or all of the information 

specified above, as well as additional information concerning deductions, salary and benefits.

Office of the General Counsel Records, OSHRC-5: (1) The names and locations (city and state) of 

the individuals representing each party; (2) the names of sole proprietors cited by OSHA, as well 

as employees and other witnesses, and information describing those individuals, including job title 

and duties, medical history, and other descriptive information that is relevant to the disposition of 

a case; (3) the names and job titles of the Commissioners and ALJs; (4) the names of FOIA 

requesters, contact information, and information concerning the requests; and (5) the names of 

OSHRC employees and the cases assigned to them, as well as the employees’ contact information.

Reasonable Accommodation Records, OSHRC-9: (1) The employee’s or applicant’s name; (2) 

contact information, including mailing and email addresses, and phone numbers; (3) employment 

information; (4) information concerning disabilities, including descriptions of disabilities and how 

they affect major life activities, medical records, and medical opinions; and (5) information 

concerning religious beliefs, practices and observances. 

* Presently, only a limited number of documents falling within the scope of these SORNs are stored 

on OneDrive. Going forward, however, OSHRC employees and contractors will be encouraged to 

use OneDrive in place of the agency’s local server.

2.5 Under what legal authority(s) does the OSHRC collect and maintain the information covered by 

this SORN?

Emergency Contact Information, OSHRC-1: 29 U.S.C. § 661(e); 44 U.S.C. § 3101.

Payroll and Related Records, OSHRC-4: 5 U.S.C. §§ 301, 5516, 5517, 5520; 26 U.S.C. §§ 6011, 

6109; 29 U.S.C. § 661; 44 U.S.C. § 3101.

Office of the General Counsel Records, OSHRC-5: 5 U.S.C. § 301; 5 U.S.C. § 552; 29 U.S.C. 

§ 661; 44 U.S.C. § 3101.

Reasonable Accommodation Records, OSHRC-9: Section 501 of the Rehabilitation Act of 1973, 

1 This refers to the types of information that this information system or database collects, uses, stores, and disposes 

of when no longer needed. 
9

29 U.S.C. 791; Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq.; 29 CFR part 

1614; E.O. 13548; E.O. 13164.

2.6 What are the purposes for collecting, maintaining, and using the information covered by this 

SORN? 

Emergency Contact Information, OSHRC-1: The purpose of this system is to maintain current 

information on OSHRC personnel to allow office managers or other pertinent agency personnel to 

provide notification about, and/or respond to, emergency conditions.

Payroll and Related Records, OSHRC-4: Records are used by OSHRC and NFC employees to 

maintain adequate payroll information for OSHRC employees and Commission members.

Office of the General Counsel Records, OSHRC-5: This system of records is maintained to assist 

management in making decisions with respect to case processing activities; to assist OSHRC 

attorneys in organizing their work product; and to assist in other matters assigned to the Office of 

the General Counsel, such as processing FOIA requests.

Reasonable Accommodation Records, OSHRC-9: This system is maintained for the purpose of 

considering, deciding, and implementing requests for reasonable accommodations made by 

OSHRC employees and applicants.

2.7 What are the Routine Uses under which disclosures are permitted to “third parties,” as noted in this 

SORN? 

Adjudication and litigation: Routine Use 1 (all SORNs).

Court or Adjudicative Body: Routine Use 1 (all SORNs).

Committee communications:

Compliance with welfare reform requirements:

Congressional inquiries: Routine Use 9 (all SORNs).

Contract services, grants, or cooperative agreements:

Emergency response by medical personnel and law enforcement officials: Routine Use 14

(OSHRC-1 only).

Employment, security clearances, licensing, contracts, grants, and other benefits by OSHRC:

Routine Use 3 (all SORNs).

Employment, security clearances, licensing, contracts, grants, and other benefits upon a request 

from another Federal, state, local, tribal, or other public authority, etc.: Routine Use 4 (all SORNs). 

OSHRC enforcement actions:

Financial obligations under the Debt Collection Act: Routine Use 20 (OSHRC-4 only).

Financial obligations required by the National Finance Center: Routine Uses 14, 15, 16, 17, and 

18 (OSHRC-4 only).

First responders, e.g., law enforcement, DHS, FEMA, DOD, NTIA, etc.:

Government-wide oversight by NARA, DOJ, OPM, and/or OMB: Routine Uses 6, 8, 10, and 

12 (all SORNs).

Labor relations: Routine Use 5 (all SORNs).

Law enforcement and investigations: Routine Use 2 (all SORNs). 

National security and intelligence matters:

Department of State, Department of Homeland Security, and other Federal agencies: Routine 

Use 7 (all SORNs).

Program partners, e.g., WMATA:

Breach of Federal data: Routine Uses 11 and 13 (all SORNs).

Others Routine Use disclosures not listed above:
10

OSHRC-4

• Routine Use 19: To the Federal Retirement Thrift Investment Board to update Section 

401K type records and benefits; to the Social Security Administration to establish social 

security records and benefits; to the Department of Labor, Office of Worker’s 

Compensation to process compensation claims; to the Department of Defense to adjust 

military retirement; to health insurance carriers to process insurance claims; and to the 

Department of Veterans Affairs for the purpose of evaluating veteran’s benefits to which 

the individual may be entitled.

• Routine Use 21: To other federal, state, local or foreign agencies conducting computer 

matching programs to help eliminate fraud and abuse and to detect unauthorized 

overpayments made to individuals. When disclosures are made as part of computer 

matching programs, OSHRC will comply with the Computer Matching and Privacy 

Protection Act of 1988, and the Computer Matching and Privacy Protections Amendments 

of 1990.

• Routine Use 22: To the Office of Child Support Enforcement, Administration for Children 

and Families, Department of Health and Human Services, the names, social security 

numbers, home addresses, dates of birth, dates of hire, quarterly earnings, employer 

identifying information, and state of hire of employees for the purpose of locating 

individuals to establish paternity, identifying sources of income, and for other child support 

enforcement actions as required by the Personal Responsibility and Work Opportunity 

Reconciliation Act of 1996, 42 U.S.C. § 653(n).

• Routine Use 23: To “consumer reporting agencies” as defined in the Fair Credit Reporting 

Act (15 U.S.C. § 1681a(f)) or the Federal Claims Collection Act of 1966 (31 U.S.C. 

§ 3701(a)(3)) in accordance with 31 U.S.C. § 3711(e)(1)(F).

OSHRC-9

• Routine Use 14: To medical professionals, when the requester has signed a limited release, 

authorizing OSHRC to seek additional information directly from the medical provider, or 

when OSHRC has determined that medical information must be reviewed by other medical 

experts to make a reasonable accommodation determination.

2.8 What is the OSHRC’s policy concerning whether information covered by this SORN is disclosed 

to consumer reporting agencies?

Disclosure to consumer reporting agencies is permitted only in OSHRC-4 and only to the extent 

that disclosure would comply with 31 U.S.C. § 3711(e)(1)(F). 

2.9 What are the policies and/or guidelines for the storage, maintenance, and safeguarding of the 

information covered by this SORN?

The information covered by all three SORNs is stored (or, in the future, may be stored) on 

OneDrive, a Microsoft cloud service included in the Office 365 suite of applications. Access to 

Office 365 requires a valid username and password. Office 365 protects data on its OneDrive by 

employing various physical, logical, and data security measures, along with allowing for 

protective user and admin controls. See Office 365’s website for more information. Use of these 

controls allows an OSHRC employee or contractor to share a document, saved on OneDrive, with

only other employees or contractors who require access to perform their work duties. Data is 

therefore protected from external threats and, internally, access is restricted as appropriate.

2.10 How is the information covered by this SORN retrieved or otherwise accessed?
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Emergency Contact Information, OSHRC-1: Electronic records, included in a spreadsheet, can be 

retrieved by name, telephone number, or home address.

Payroll and Related Records, OSHRC-4: Electronic records are retrieved by name.

Office of the General Counsel Records, OSHRC-5: Electronic records are retrieved by case name, 

docket number, name of OSHRC attorney or supervising attorney, or by the names of other 

individuals, such as FOIA requesters.

Reasonable Accommodation Records, OSHRC-9: Records are retrieved manually or electronically 

by an individual’s name.

2.11 What is the records retention and disposition schedule for the information covered by this SORN?

Emergency Contact Information, OSHRC-1: Records are retained until the subject of the record 

no longer works at OSHRC, at which time the paper record is shredded and the electronic file 

containing the record is revised to omit the subject’s name and information.

Payroll and Related Records, OSHRC-4: Records are retained and disposed of in accordance with 

NARA’s General Records Schedule 2.4.

Office of the General Counsel Records, OSHRC-5: Records are maintained in accordance with 

General Records Schedules 4.2 and 5.1, or for as long as needed for business use.

Reasonable Accommodation Records, OSHRC-9: Records are retained and disposed of in 

accordance with NARA’s General Records Schedule 2.1, Item 140 (applicants); and General 

Records Schedule 2.3, Item 20 (employees).

2.12 What are the sources for the information in the categories of records covered by this SORN?

Emergency Contact Information, OSHRC-1: Information in this system of records comes from 

OSHRC personnel.

Payroll and Related Records, OSHRC-4: Information in this system either comes from the 

individual to whom it applies or is derived from information compiled by OSHRC employees 

performing administrative duties.

Office of the General Counsel Records, OSHRC-5: Information in this system is derived from the 

individual to whom it applies or is derived from case processing records maintained by the Office 

of the Executive Secretary and the Office of the General Counsel.

Reasonable Accommodation Records, OSHRC-9: Information contained in the system is obtained 

from OSHRC employees and applicants requesting reasonable accommodations, as well as their 

medical providers.

Section 3.0 Development, Management, and Deployment and/or Sharing of the Information: 

3.1 Who will develop the information system(s) covered by this SORN? 

Developed wholly by OSHRC staff employees: 

Developed wholly by OSHRC contractors: 

Developed jointly by OSHRC employees and contractors:

Developed offsite primarily by non-OSHRC staff: 
12

COTS (commercial-off-the-shelf-software) package: 

Other development, management, and deployment/sharing information arrangements: 

OneDrive is a Microsoft cloud service that allows users to store, protect and share their files with 

others and is included in the Office 365 suite of applications to which OSHRC subscribes.

3.2 Where will the information system be housed? 

OSHRC Headquarters 

American Eagle (web-site)

Tyler Federal, LLC (case tracking system)

Office 365

Other information: 

3.3 Who will be the primary manager(s) of the information system, i.e., who will be responsible for 

assuring access to, proper use of, and protecting the security and integrity of the information? 

OSHRC staff in this bureau/office

OSHRC staff in other bureaus/offices

Information system administrator/Information system developers

Other information system developers, etc:

3.4 What are the OSHRC’s policies and procedures that the information system’s administrators and 

managers use to determine who gets access to the information in the system’s files and/or 

database(s)? 

Access to documents shared on OneDrive is limited to employees and contractors who require 

access to perform their work duties.

3.5 How much access will users have to data in the information system(s)? 

Access to all data:

Restricted access to data, as determined by the information system manager, administrator, 

and/or developer: Access is restricted based on how the owner of the document manages access 

(i.e., the owner of the document has the capability to “share” the document with OSHRC 

employees or contractors who require access to perform their work duties).

Other access policy:

3.6 Based on the Commission policies and procedures, which user group(s) may have access to the 

information at the OSHRC:

Information system managers:

Information system administrators:

Information system developers: 

OSHRC staff in this bureau/office: 

OSHRC staff in other bureaus/offices in OSHRC area offices: 

Contractors: 

Other Federal agencies:

State and/or local agencies:

Businesses, institutions, and other groups:

International agencies:

Individuals/general public: 

Other groups: 

If contractors do not have access to the PII in this system, please skip to Question 3.9.
13

3.7 What steps have been taken to ensure that the contractors who have access to and/or work with the 

PII in the system are made aware of their duties and responsibilities to comply with the 

requirements under subsection (m) “Contractors” of the Privacy Act, as amended, 5 U.S.C. 

§ 552a(m)? 

Contractors who have access to this information—those who work in OSHRC’s information 

technology office, as well as those who work in other offices and require access to information to 

perform their work duties—receive the same Privacy Act and security awareness training, when 

first hired and then annually thereafter, that OSHRC employees receive.

3.8 What steps have been taken to ensure that any Section M contract(s) associated with the information 

system covered by this SORN include the required FAR clauses (FAR 52.224-1 and 52.224-2)? 

OSHRC’s policy is to include up-to-date FAR clauses in each section M contract.

If there are no information linkages, sharing, and/or transmissions, please skip to Section 4.0 Data Quality, 

Utility, Objectivity, and Integrity Requirements: (There are no information linkages, sharing, and/or 

transmissions.)

3.9 If the information system has links to other information systems (or databases), i.e., it shares, 

transmits, or has other linkages, with what other non-OSHRC organizations, groups, and 

individuals will the information be shared? 

(Check all that apply and provide a brief explanation) 

Other Federal agencies:

State, local, or other government agencies:

Businesses:

Institutions:

Individuals:

Other groups:

Please explain your response:

3.10 If this information system transmits or shares information, including PII, between any other 

OSHRC systems or databases, is the other system (or database) covered by a PIA? 

Yes

No

Please explain your response:

3.11 Since this information system transmits/shares PII between the OSHRC computer network and 

another non-OSHRC network, what security measures or controls are used to protect the PII that is 

being transmitted/shared and to prevent unauthorized access during transmission? 

If there is no “matching agreement,” e.g., Memorandum of Understand (MOU), etc., please skip to Section 

4.0 Data Quality, Utility, Objectivity, and Integrity Requirements: (There are no matching 

agreements.)

3.12 What kind of “matching agreement,” e.g., Memorandum of Understanding (MOU), etc., as defined 

by 5 U.S.C. § 552a(u) of the Privacy Act, as amended, is there to cover the information sharing 

and/or transferred with the external organizations? 
14

3.13 Is this a new or a renewed matching agreement? 

New matching agreement 

Renewed matching agreement 

Please explain your response:

3.14 Has the matching agreement been reviewed and approved (or renewed) by the OSHRC’s Data 

Integrity Board, which has administrative oversight for all OSHRC matching agreements?

Yes; if yes, on what date was the agreement approved: 

No 

Please explain your response: 

3.15 Is the information that is covered by this SORN, which is transmitted or disclosed with the external 

organization(s), comply with the terms of the MOU or other “matching agreement?” 

3.16 Is the shared information secured by the recipient under the MOU, or other “matching agreement 

to prevent potential information breaches?” 

Section 4.0 Data Quality, Utility, Objectivity, and Integrity Requirements: 

OMB regulations require Federal agencies to ensure that the information/data that they collect and use 

meets the highest possible level of quality and integrity. It is important, therefore, that the information the 

Commission’s information systems use meets the “benchmark standards” established for the information.

4.1 How will the information that is collected from OSHRC sources, including OSHRC employees and 

contractors, be checked for accuracy and adherence to the Data Quality guidelines? 

The specific procedures for checking and maintaining the quality of information posted on 

oshrc.gov are specified in the agency’s Guidelines for Ensuring and Maximizing the Quality, 

Objectivity, Utility, and Integrity of Disseminated Information & Procedures for the Public to 

Seek Correction of Disseminated Information.

These procedures apply to information such as guides to agency procedures and agency reports. 

They do not apply, however, to some of the other information covered by this PIA, including ALJ 

and Commission decisions:

Consistent with OMB guidelines, these procedures do not apply to the 

dissemination of information relating to adjudicative processes, such as “the 

findings and determinations that an agency makes in the course of adjudications 

involving specific parties.” 67 FR 8452, 8454 (Feb. 22, 2002). The agency agrees 

with OMB’s statement in the Federal Register that there are “well established 

procedural safeguards and rights to address the quality of adjudicatory decisions 

and to provide persons with an opportunity to contest decisions.” Id. Excluded 

categories of information include, but are not limited to, decisions, orders, 

opinions, subpoenas, and briefs. Therefore, the agency will not impose additional 

requirements during its adjudicative proceedings or establish additional rights of 

challenge or appeal through this administrative procedure.

If the Data Quality Guidelines do not apply to the information in this information system (or database), 

please skip to Section 5.0 Safety and Security Requirements:

4.2 If any information collected from non-OSHRC sources, how will the information sources be 

checked for accuracy and adherence to the Data Quality guidelines? 
15

(Please check all that apply and provide an explanation)

Yes, information is collected from non-OSHRC sources: 

Information is processed and maintained only for the purposes for which it is collected:

Information is reliable for its intended use(s):

Information is accurate:

Information is complete:

Information is current:

No information comes from non-OSHRC sources:

Please explain any exceptions or clarifications: Some documents stored on OneDrive may have 

been submitted by parties during the adjudicatory process. As noted above, however, these 

documents are not subject to the Data Quality guidelines.

If the information that is covered by this SORN is not being aggregated or consolidated, please skip to

Question 4.5. 

4.3 If the information that is covered by this system of records notice (SORN) is being aggregated or 

consolidated, what controls are in place to ensure that the information is relevant, accurate, and 

complete? 

4.4 What policies and procedures do the information system’s administrators and managers use to 

ensure that the information adheres to the Data Quality guidelines both when the information is 

obtained from its sources and when the information is aggregated or consolidated for the use by the 

bureaus and offices?

4.5 How often are the policies and procedures checked routinely—what type of annual verification 

schedule has been established to ensure that the information that is covered by this SORN adheres 

to the Data Quality guidelines?

The accuracy of the SORNs is reviewed annually.

Section 5.0 Safety and Security Requirements: 

5.1 How are the records/information/data in the information system or database covered by this SORN 

stored and maintained? 

IT database management system (DBMS)

Storage media including CDs, CD-ROMs, etc.

Electronic tape

Paper files

Other: OneDrive, a Microsoft cloud service included in the Office 365 suite of applications.

5.2 Is the information collected, stored, analyzed, or maintained by this information system or database 

available in another form or from another source (other than a “matching agreement” or MOU, as 

noted above)? 

Yes 

No 

Please explain your response: Paper copies of some of the records are maintained by the system 

manager identified in the SORN. For example, paper copies of certain FOIA records are 

maintained by the Office of the General Counsel, and paper copies of most of the case records are 

maintained by the Office of the Executive Secretary.
16

5.3 What would be the consequences to the timely performance of OSHRC’s operations if this 

information system became dysfunctional? 

If Office 365 became dysfunctional, the inability to access the system would “cause a degradation 

in mission capability to an extent and duration that the organization is able to perform its primary 

functions, but the effectiveness of the functions is noticeably reduced.” See FIPS Publication 199. 

Presently, OSHRC’s various offices would still be able to perform their intended functions, as most 

of the offices’ work product is stored on OSHRC’s local server (see PIA for LAN/WAN). In the 

event that both Office 365 and the agency’s local server became dysfunctional, the availability of 

some paper records would allow the performance of some tasks to continue—such as case and 

FOIA processing, for example—though in less efficient manner. 

Currently, reliance on Office 365 is limited. Over the coming years, however, more of these records

will likely be stored on OneDrive, making the impact of any dysfunction to Office 365 more 

significant. 

5.4 What will this information system do with the information it collects: 

The system will create new or previously unavailable information through data aggregation, 

consolidation, and/or analysis, which may include information obtained through link(s), 

sharing, and/or transferred to/from other information systems or databases; 

The system collects PII, but it will not perform any analyses of the PII data.

5.5 Will the OSHRC use the PII that the information system (or database) collects to produce reports 

on these individuals? 

Yes

No

5.6 What will the system’s impact(s) be on individuals from whom it collects and uses their PII: 

The information will be included in the individual’s records; 

The information will be used to make a determination about an individual; 

The information will be used for other purposes that have few or no impacts on the individuals.

Please explain your response (including the magnitude of any impact[s]): Any impact on the 

individuals from whom PII is collected will be minimal, as the PII is not, for the most part, disclosed 

to individuals or entities outside of the agency or the federal government, and the PII is used only 

to the extent necessary to perform work activities, such as case processing, responding to FOIA 

requests, and administrative tasks. 

5.7 Do individuals have the right to the following? 

They may decline to provide their PII? 

Yes

No

Most of the PII covered by this PIA is from case records (e.g., hearing transcripts and exhibits). 

Admission of these records into evidence and their use is generally not in the control of the PII’s 

subject. Nonetheless, Commission procedural rules (29 C.F.R. § 2200.8(c)(6), (d)(5)) are in place 

to minimize the amount of PII that is in the record. And before releasing such documents to the 

public under FOIA, the documents are reviewed and redacted in accordance with 5 U.S.C. 

§ 552(b)(6) and the Commission’s redaction policy. 

PII provided in the context of a reasonable accommodations request may be necessary for any such 
17

request to be fully processed.

PII from records that include emergency contact information is provided voluntarily by the subject 

of the record, though that subject’s emergency contacts may have their information provided 

without their explicit consent.

Other PII covered by this PIA, such as PII provided by a FOIA requester (typically to allow the 

agency to respond with requested records), is also provided voluntarily.

They may consent to particular uses of their PII? 

Yes

No

Please explain your response(s) (including the potential consequences for refusing to provide PII):

Most of the PII covered by this PIA is from case records (e.g., hearing transcripts and exhibits). 

Admission of these records into evidence and their use is generally not in the control of the PII’s 

subject. Refusal to provide documents including PII could be subject to the Commission’s 

subpoena procedures (29 C.F.R. § 2200.65). However, as noted, Commission procedural rules (29 

C.F.R. § 2200.8(c)(6), (d)(5)) are in place to minimize the amount of PII that is in the record.

As noted, PII provided in the context of a reasonable accommodations request may be necessary 

for any such request to be fully processed.

As to PII from records that include emergency contact information, the contact information would 

typically only be used in emergency situations. Refusal to provide contact information would make 

it more difficult to respond to an emergency that involved the individual who refused to provide 

the contact information.

If individuals do not have the right to consent to the use of their information, please skip to Question 5.10. 

(The PII is used only for the purpose for which it is collected.)

5.8 If individuals have the right to consent to the use of their PII, how does the individual exercise this 

right?

5.9 What processes are used to notify and to obtain consent from the individuals whose PII is being 

collected?

5.10 How will the information be collected and/or input into this information system (or database): 

(Choose all the apply) 

The information system has a link to the OSHRC’s Internet address at www.OSHRC.gov or 

other customer-facing URL;

The information system has a customer-facing web site via the OSHRC Intranet for OSHRC

employees;

The information is collected from the individual by fax; (FOIA requesters)

The information is collected from the individual by e-mail; (FOIA requesters; OSHRC 

employees)

The information is collected from the individual by completing an OSHRC form, license, and/or 
18

other document; (FOIA requesters—form is typically emailed upon completion; OSHRC 

employees and applicants)

The information is collected from the individual by regular mail; and/or (FOIA requesters)

The information concerning individuals is collected by other methods.

Please explain your response: Case records are typically downloaded from the Commission’s efiling/case management system and stored, for work purposes, in an access-restricted shared folder

on OSHRC’s local server (see PIA for LAN/WAN) or saved to OneDrive with appropriate accessrestrictions in place. Other documents, particularly those covered by OSHRC-1, OSHRC-4, and 

OSHRC-9, include information provided by applicants or new hires to the Commission’s Human 

Resources Specialist. 

FOIA requesters may provide their requests and contact information via email, regular mail, or fax.

5.11 How does this system advise individuals of their privacy rights when they submit their PII?

The system contains a link to the OSHRC’s privacy policies for all users at the OSHRC’s 

website www.OSHRC.gov:

A Privacy Notice is displayed on the webpage:

A Privacy Notice is printed at the end of the OSHRC form(s), license(s), and/or other 

Commission document(s): HRM collects information directly from OSHRC employees when 

they submit their bi-weekly payroll and leave data.

The OSHRC Intranet site displays a Privacy Notice:

The collection or input mechanism uses another method to provide individuals with the Privacy 

Notice:

No Privacy Notice is provided: Information is not submitted by individuals directly into this 

system. Privacy Notices are provided, however, when the documents are originally submitted

(through the Commission’s E-File System, for example—see the PIA for that information 

system component).

5.12 If a Privacy Notice is provided, which of the following are included?

Proximity and timing—the privacy notice is provided at the time and point of data collection. 

Purpose—describes the principal purpose(s) for which the information will be used. 

Authority—specifies the legal authority that allows the information to be collected. 

Conditions—specifies whether providing the information is voluntary, and the effects, if any, 

of not providing it. 

Disclosures—specify the routine use(s) that may be made of the information. 

Not applicable, as information will not be collected in this way. 

5.13 Will consumers have access to information and/or the information system on-line via 

www.OSHRC.gov?

Yes

No

5.14 What safeguards and security measures, including physical and technical access controls, are in 

place to secure the information and to minimize unauthorized access, use, or dissemination of the 

information that is stored and maintained in the information system? 

(Check all that apply)

Account name 
19

Passwords 

Accounts are locked after a set period of inactivity 

Passwords have security features to prevent unauthorized disclosure, e.g., “hacking” 

Accounts are locked after a set number of incorrect attempts 

One time password token 

Other security features:

Firewall 

Virtual private network (VPN) 

Data encryption:

Intrusion detection application (IDS) 

Common access cards (CAC) 

Smart cards: 

Biometrics 

Public key infrastructure (PKI) 

Locked file cabinets or fireproof safes 

Locked rooms, with restricted access when not in use 

Locked rooms, without restricted access 

Documents physically marked as “sensitive” 

Guards 

Identification badges 

Key cards 

Cipher locks 

Closed circuit TV (CCTV) 

Other:

5.15 Please explain what staff security training and other measures are in place to assure that the security 

and privacy safeguards are maintained adequately? 

Each OSHRC employee and contractor is required to complete Privacy Act and security awareness 

training annually.

5.16 How often are the security controls reviewed? 

Six months or less

One year

Two years 

Three years

Four years 

Five years 

Other:

5.17 How often are ITC personnel (e.g., information system administrators, information 

system/information system developers, contractors, and other ITC staff, etc.) who oversee the 

OSHRC network operations trained and made aware of their responsibilities for protecting the 

information? 

There is no training

One year 

Two years 

Three years 

Four years 

Five years 

Other:
20

5.18 How often must staff be “re-certified” that they understand the risks when working with personally 

identifiable information (PII)? 

Less than one year

One year

Two years 

Three or more years

Other re-certification procedures:

5.19 Do OSHRC’s training and security requirements for this information system conform to the 

requirements of the Federal Information Security Modernization Act (FISMA)? 

Yes

No

Please explain your response:

A breach notification policy is in place. Additionally, specific to this information system

component, the pertinent SORNs, as well as this PIA, are reviewed on an annual basis. Finally, 

security awareness training, as well as Privacy Act training, is provided annually to all OSHRC 

employees and contractors.

If the Privacy Threshold Assessment (PTA) was completed recently as part of the information system’s 

evaluation, please skip Questions 5.20 through 5.21. (The PTA is attached.)

5.20 What is the potential impact on individuals on whom the information is maintained in the 

information system(s) if unauthorized disclosure or misuse of information occurs? 

(Check one) 

Results in little or no harm, embarrassment, inconvenience, or unfairness to the individual. 

Results in moderate harm, embarrassment, inconvenience, or unfairness to the individual. 

Results in significant harm, embarrassment, inconvenient, or unfairness to the individual. 

Please explain your response:

5.21 What is the impact level for the information system(s) covered by this SORN and is it consistent 

with the guidelines as determined by the FIPS 199 assessment? 

5.22 When was the “Assessment and Authorization” (A&A) completed for the information system(s) 

covered this SORN—please provide the A&A completion date? The agency reauthorized the 

information system, Occupational Safety and Health Review Commission Network and General 

Support System, on November 12, 2020. 

5.23 Has the Chief Information Officer (CIO) and/or the Chief Information Security Officer (CISO) 

designated this information system as requiring one or more of the following: 

Independent risk assessment:

Independent security test and evaluation:

Other risk assessment and/or security testing procedures, etc.:

Not applicable:

As part of the reauthorization package for the Occupational Safety and Health Review Commission 

Network and General Support System, this information system requires a system security and 
21

privacy plan, and an assessment of security and privacy controls. 

5.24 Does this information system use technology in ways that the Commission has not done so 

previously, i.e., Smart Cards, Caller-ID, etc.? No.

5.25 How does the use of the technology affect the privacy of the general public and OSHRC employees 

and contractors? Technology—through access restrictions and username/password requirements—

protects the information from unintended disclosure.

5.26 Does this information system (covered by this SORN) include a capability to identify, locate, and/or 

monitor individuals?

Yes

No

If the information system does not include any monitoring capabilities, please skip to Section 6.0 

Information Collection Requirements under the Paperwork Reduction Act (PRA). (The information 

system does not include monitoring capabilities.)

5.27 If the information system includes the technical ability to monitor an individual’s movements 

identified in Questions 5.24 through 5.26 above, what kinds of information will be collected as a 

function of the monitoring of individuals? 

5.28 What controls, policies, and procedures, if any, does this information system (covered by this 

SORN) contain any controls, policies, and procedures to prevent unauthorized monitoring? 

Section 6.0 Information Collection Requirements under the Paperwork Reduction Act (PRA): 

If this information system or database affects only OSHRC employees, please skip to Section 9.0

6.1 Does the information system or database covered by this SORN solicit information via paperwork 

and/or recordkeeping requirements that effect the general public (non-OSHRC employees), which 

may include any of the following (including both voluntary and required compliance): No. Only 

information provided by FOIA requesters concerns the general public and that information is not 

solicited.

OSHRC forms, licenses, or other documentation;

Participation in marketing, consumer, or customer satisfaction surveys or questionnaires;

Recordkeeping or related activities.

If so, is this information system subject to the requirements of the PRA because it solicits 

information via paperwork and/or recordkeeping requirements

Yes, the information system includes any paperwork and/or recordkeeping requirements 

that non-OSHRC employees and contractors must complete.

No, the information system does impose any paperwork and/or recordkeeping requirements, 

i.e., the information it collects does not constitute an “information collection” as defined 

by the PRA.

If there are no paperwork or recordkeeping requirements (or if only OSHRC employees and contractors are 

the effected groups), this information system is exempt from the requirements of the PRA. Please skip to 
22

Section 7.0 Correction and Redress: (PRA requirements do not apply here.)

6.2 Is there a website that requests information, such as the information necessary to complete an 

OSHRC form, license, authorization, etc.?

Yes

No or Not applicable

Please explain your response:

6.3 If there are one or more PRA information collections that are covered by this SORN that are 

associated with the information system’s databases and paper files, please list the OMB Control 

Number, Title of the collection, and Form number(s) as applicable for the information collection(s):

6.4 Are there are any OSHRC forms associated with the information system(s) covered by this SORN, 

and if so, do the forms carry the Privacy Act notice?

Yes:

No

Not applicable—the information collection does not include any forms.

6.5 Have the system managers contacted the Performance Evaluation and Records Management 

(PERM) staff to coordinate PRA requirements and submission of the information collection to the 

Office of Management and Budget?

Yes

No

Please explain your response: 

Section 7.0 Correction and Redress:

7.1 What are the procedures for individuals wishing to inquire whether this SORN contains information 

about them consistent with OSHRC’s Privacy Act rules under 29 CFR part 2400?

Such inquiries should be addressed to the Privacy Officer, OSHRC, 1120 20th Street NW, Ninth 

Floor, Washington, DC 20036-3457. For an explanation on how such requests should be drafted, 

refer to 29 CFR § 2400.4 (procedures for requesting notification of and access to personal records).

7.2 What are the procedures for individuals to gain access to their own records/information/data in this 

information system that is covered by this SORN consistent with OSHRC’s Privacy Act rules under 

29 CFR part 2400?

Such requests should be addressed to the Privacy Officer, OSHRC, 1120 20th Street NW, Ninth 

Floor, Washington, DC 20036-3457. For an explanation on how such requests should be drafted, 

refer to 29 CFR § 2400.4 (procedures for requesting notification of and access to personal records).

7.3 What are the procedures for individuals seeking to correct or to amend records/information/data 

about themselves in the information system that is covered by this SORN consistent with OSHRC’s 
23

Privacy Act rules under 29 CFR part 2400?

Such requests should be addressed to the Privacy Officer, OSHRC, 1120 20th Street NW, Ninth 

Floor, Washington, DC 20036-3457. For an explanation on the specific procedures for contesting 

the contents of a record, refer to 29 CFR § 2400.6 (procedures for amending personal records), and 

29 CFR § 2400.7 (procedures for appealing).

7.4 Does this SORN claim any exemptions to the notification, access, and correction, and/or 

amendment procedures as they apply to individuals seeking information about them in this SORN, 

and if so, are these exemptions consistent with OSHRC’s Privacy Act rules under 29 CFR part 

2400?

No.

7.5 What processes are in place to monitor and to respond to privacy and/or security incidents? (Please 

specify what is changing if this is an existing SORN that is being updated or revised?)

Safeguards described above and in the SORNs are in place to minimize the potential of a privacy 

and/or security incident. If one does occur, OSHRC has a breach policy in place that requires any 

employee recognizing that a breach has (or may have) occurred to notify appropriate agency 

personnel so that any necessary corrective action can be taken.

7.6 How often is the information system audited to ensure compliance with OSHRC and OMB 

regulations and to determine new needs?

Six months or less 

One year 

Two years 

Three years:

Four years 

Five years 

Other audit scheduling procedure(s):

Section 8.0 Consumer Satisfaction: 

8.1 Is there a customer or consumer satisfaction survey included as part of the public access to the 

information covered by this information system or database?

Yes

No

Not applicable

Please explain your response:

If there are no Consumer Satisfaction requirements, please skip to Section 9.0 Risk Assessment and 

Mitigation: (There are no Consumer Satisfaction requirements.)

8.2 Have any potential Paperwork Reduction Act (PRA) issues been addressed prior to implementation 

of the customer satisfaction survey?

Yes

No
24

Please explain your response:

Section 9.0 Risk Assessment and Mitigation:

9.1 What are the potential privacy risks for the information covered by this system of records notice 

(SORN), and what practices and procedures have you adopted to minimize them?

Risks: Mitigating factors: 

a. Case records containing PII are, or in the 

future may be, stored on OneDrive.

1. Shared documents on OneDrive are 

access-restricted to those employees who 

require access to perform their work 

duties.

2. Commission rules (29 C.F.R. 

§ 2200.8(c)(6), (d)(5)) minimize the 

amount of PII in documents that are 

admitted into evidence.

3. Few of these documents are currently 

stored on OneDrive. OSHRC’s local 

server and the EFS are the primary 

sources of storage for these documents 

(see PIAs for LAN/WAN and EFS). 

Going forward, however, use of the 

OneDrive will be encouraged.

b. Other agency records (including FOIA 

requester records and employee emergency 

contact information) containing PII are, or 

in the future may be, stored on OneDrive.

1. Shared documents on OneDrive are 

access-restricted to those employees who 

require access to perform their work 

duties.

2. Few, if any, of these documents are

currently stored on OneDrive. Rather, 

they are stored on OSHRC’s local server 

(see PIA for LAN/WAN). Going 

forward, however, use of the OneDrive 

will be encouraged.

9.2 What is the projected production/implementation date for the information system(s) or database(s):

Initial implementation: Already implemented.

Secondary implementation: N/A

Tertiary implementation: N/A

Other implementation: N/A

9.3 Are there any ancillary and/or auxiliary information system(s) or database(s) linked to this 

information system that are covered by this SORN, which may also require a PIA? 

Yes

No

If so, please state the application(s), if a PIA has been done, and the completion date for PIA:
Occupational Safety Health & Review 

Commission

Privacy Threshold Analysis (PTA)

Name of Information System: Office 365

Date: 9/27/2018, revised 10/4/2021

OSHRC Office: Privacy Office

Privacy Analyst: Ron Bailey

Telephone Number: 202-606-5410

E-mail Address: rbailey@oshrc.gov
1

Section 1.0 Information System’s Status: 

1.1 Status of the Information System: 

New information system—Implementation date:

Revised or upgraded information system—Revision or upgrade date:

If this system is being revised—what will be done with the newly derived information: 

Placed in existing information system—Implementation date:

Placed in new auxiliary/ancillary information system—Date:

Other use(s)—Implementation date:

Please explain your response:

This is a preexisting system for which a PTA was not performed. For purposes of this PTA analysis, it 

will be treated as a new information system.

If this is a new information system, please skip to Question 1.6.

1.2 Has this information system existed under another name, or has the name been changed or 

modified?

Yes 

No 

Please explain your response:

1.3 Has this information system existed previously or been operated under any other software program, 

information system medium, i.e., electronic database or paper files, and/or other format?

Yes 

No 

Please explain your response:

1.4 Has this information system existed under a system of records notice (SORN) by itself, or was it 

ever part or component of another SORN?

Yes 

No 

Please explain your response:

1.5 Is this information system being changed or upgraded, and if so, what are the purposesfor changing

or upgrading the information system, and/or will any changes now include personally identifiable

information (PII):

Yes 

No 

Please explain your response:

1.6 Why is the information being collected, e.g., what are the information system’s purposes, intended 

uses, and/or functions: OSHRC personnel rely on this cloud-based system to store documents to 

carry out necessary work activities, such as processing matters related to Commission cases, and 

other legal and agency-related matters. 
2

1.7 What information is the system collecting, analyzing, managing, using, and/or storing, etc.:

Information about OSHRC Employees:

No OSHRC employee information

OSHRC employee’s name

Other names used, i.e., maiden name, etc. 

OSHRC badge number (employee ID) 

SSN 

Race/Ethnicity 

Gender 

U.S. Citizenship 

Non-U.S. Citizenship 

Biometric data 

Fingerprints 

Voiceprints 

Retina scans/prints 

Photographs 

Other physical information, i.e., hair color, eye color, identifying marks, etc. 

Birth date/age 

Place of birth 

Medical data 

Marital status 

Spousal information 

Miscellaneous family information 

Home address 

Home address history 

Home telephone number(s) 

Personal cell phone number(s):

Personal fax number(s) 

E-mail address(es): OSHRC e-mail address. 

Emergency contact data:

Credit card number(s) 

Driver’s license 

Bank account(s) 

OSHRC personal employment records 

Military records 

Financial history 

Foreign countries visited 

Law enforcement data 

Background investigation history 

National security data 

Communications protected by legal privileges 

Digital signature

Other information:

Information about OSHRC Contractors: 

No OSHRC contractor information 

Contractor’s name

Other name(s) used, i.e., maiden name, etc. 

OSHRC Contractor badge number (Contractor ID) 

SSN 

U.S. Citizenship 
3

Non-U.S. Citizenship 

Race/Ethnicity 

Gender 

Biometric data 

Fingerprints 

Voiceprints 

Retina scans/prints 

Photographs 

Other physical information, i.e., hair color, eye color, identifying marks, etc. 

Birth date/Age 

Place of birth 

Medical data 

Marital status 

Spousal information 

Miscellaneous family information 

Home address 

Home address history 

Home telephone number(s) 

Personal cell phone number(s):

Personal fax number(s) 

E-mail address(es): OSHRC e-mail address.

Emergency contact data:

Credit card number(s) 

Driver’s license number(s)

Bank account(s) 

Non-OSHRC personal employment records

Military records 

Financial history 

Foreign countries visited 

Law enforcement data 

Background investigation history 

National security data 

Communications protected by legal privileges 

Digital signature 

Other information:

Information about non-OSHRC personnel, including (1) parties, attorneys, and/or 

representatives in OSHRC cases; (2) employees and other personnel who testify or are 

discussed in those cases; and (3) Freedom of Information Act requesters:

Not applicable

Individual’s name:

Other name(s) used, i.e., maiden name, etc.

OSHRC badge number (employee ID) 

SSN: Procedural rules require parties to redact SSNs from exhibits or other materials filed with 

the agency, but sometimes SSNs are left unredacted.

Race/Ethnicity 

Gender 

Citizenship 

Non-U.S. Citizenship 

Biometric data 

Fingerprints 

Voiceprints 
4

Retina scans/prints 

Photographs 

Other physical information, i.e., hair color, eye color, identifying marks, etc. 

Birth date/Age:

Place of birth 

Medical data 

Marital status 

Spousal information 

Miscellaneous family information 

Home address 

Home address history 

Home telephone number(s) 

Personal cell phone number(s):

Personal fax number(s) 

Personal e-mail address(es):

Emergency contact data:

Credit card number(s) 

Driver’s license number(s) 

Bank account(s) 

Non-OSHRC personal employment records 

Military records 

Financial history 

Foreign countries visited 

Law enforcement data 

Background investigation history 

National security data 

Communications protected by legal privileges 

Digital signature 

Other information: Given the nature of litigation, all of the possible types of personal 

information that could be included in a case record cannot be specified. 

Information about Business Customers and others (usually not considered “personal 

information”):

Not applicable

Name of business contact/firm representative, customer, and/or others 

Race/Ethnicity 

Gender 

Full or partial SSN:

Business/corporate purpose(s)

Other business/employment/job description(s) 

Professional affiliations 

Business/office address

Intra-business office address (office or workstation) 

Business telephone number(s)

Business cell phone number(s) 

Business fax number(s) 

Business pager number(s) 

Business e-mail address(es)

Bill payee name

Bank routing number(s) 

Income/Assets 

Web navigation habits 
5

Commercially obtained credit history data 

Commercially obtained buying habits 

Credit card number(s) 

Bank account(s) 

Other information:

“Non-personal” information obtained from FCC sources:

Not applicable, Economic

Data, Engineering scientific

Data, Accounting/financial

Data, Legal/regulatory/policy

Data, Other information:

Miscellaneous Business, Technology, or Other Information:

Not applicable

Not publicly available business or technology data, i.e., trade or propriety information

Other information, please specify:

1.8 What are the sources for the information that this information system (or database) is collecting:

Personal information from OSHRC employees: 

Personal information from OSHRC contractors:

Personal information from non-OSHRC individuals and/or households: 

Non-personal information from businesses and other for-profit entities: 

Non-personal information from institutions and other non-profit entities: 

Non-personal information from farms: 

Non-personal information from Federal Government agencies:

Non-personal information from state, local, or tribal governments:

Other sources: 

1.9 Does this information system have any links to other information systems or databases? No.

An information system (or database) may be considered as linked to other information systems (or 

databases) if it has one or more of the following characteristics: 

The information system is a subsystem or other component of another information system or 

database that is operated by another OSHRC bureau/office or non-OSHRC entity (like the FBI, 

DOJ, National Finance Center, etc.);

The information system transfers or receives information, including PII, between itself and 

another OSHRC or non-OSHRC information system or database: 

The information system has other types of links or ties to other OSHRC or non-OSHRC

information systems or databases; 

The information system has other characteristics that make it linked or connected to another 

OSHRC or non-OSHRC information system or database; 

The information system has no links to another information system (or database), i.e., it does 

not share, transfer, and/or obtain data from another system; please skip to Question 1.12. 
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1.10 What PII does the information system obtain, share, and/or use from other information systems? 

Not applicable or none

OSHRC information system and information system name(s):

Non-OSHRC information system and information system name(s):

OSHRC employee’s name: 

(non-OSHRC employee) individual’s name

Other names used, i.e., maiden name, etc.

OSHRC badge number (employee ID)

Other Federal Government employee ID information, i.e., badge number, etc.

SSN:

Race/Ethnicity

Gender

U.S. Citizenship

Non-U.S. Citizenship

Biometric data

Fingerprints

Voiceprints

Retina scan/prints

Photographs 

Other physical information, i.e., hair color, eye color, identifying marks, etc. 

Birth date/Age 

Place of birth 

Medical data 

Marital status 

Spousal information 

Miscellaneous family information: 

Home address 

Home address history 

Home telephone number(s) 

Personal cell phone number(s) 

Personal fax number(s) 

E-mail address(es): 

Emergency contact data 

Credit card number(s) 

Driver’s license 

Bank account(s) 

Non-OSHRC personal employment records 

Non-OSHRC government badge number (employee ID) 

Law enforcement data 

Military records 

National security data 

Communications protected by legal privileges 

Financial history 

Foreign countries visited 

Background investigation history

Digital signature

Other information:

Information about Business Customers and others (usually not considered “personal 

information”):

Not applicable
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Name of business contact/firm representative, customer, and/or others

Race/Ethnicity

Gender

Full or partial SSN:

Business/corporate purpose(s)

Other business/employment/job description(s)

Professional affiliations

Intra-business office address (office or workstation)

Business telephone number(s)

Business cell phone number(s)

Business fax number(s)

Business e-mail address(es)

Bill payee name

Bank routing number(s)

Income/Assets

Web navigation habits

Commercially obtained credit history data

Commercially obtained buying habits

Personal clubs and affiliations

Credit card number(s)

Bank account(s)

Other information:

Miscellaneous Business Information:

Not applicable

Not publicly available business data, i.e., trade or propriety information

Other information:

“Non-personal” information:

Not applicable Economic

Data, Engineering/scientific

Data, Accounting/financial

Data, Legal/regulatory/policy

Data 

Other information data provided 

1.11 What are the sources for the information from the other information system (or database) that you 

are collecting:

Personal information from OSHRC employees: 

Personal information from OSHRC contractors:

Personal information from non-OSHRC individuals and/or households: 

Non-personal information from businesses and other for-profit entities: 

Non-personal information from institutions and other non-profit entities: 

Non-personal information from farms: 

Non-personal information from Federal Government agencies:

Non-personal information from state, local, or tribal governments:

Other sources: 
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1.12 Will the information system derive new information or create previously unavailable information 

through aggregation or consolidation from the information that will now be collected, including 

(where applicable) information that is being shared or transferred from another information system?

Yes 

No 

1.13 Can the information, whether it is: (a) in the information system; (b) in a linked information system;

and/or (c) transferred from another system, be retrieved by a name or a “unique identifier” linked to

an individual, e.g., SSN, name, home telephone number, fingerprint, voice print, etc.?

Yes

No 

1.14 Will the new information include personal information about individuals, e.g., personally 

identifiable information (PII), which is to be included in the individual’s records or to be used to 

make a determination about an individual?

Yes 

No 

If the information system contains information about individuals, please answer Question 1.15; but if the

information system does not contain information about individuals, please skip to Question 1.16.

1.15 What is the potential impact or “security risk” on individuals on whom the information is maintained

in the information system(s) if unauthorized disclosure or misuse of information occurs? 

(Check one)

Results in little or no harm, embarrassment, inconvenience, or unfairness to the individual.

Results in moderate harm, embarrassment, inconvenience, or unfairness to the individual. 

Results in significant harm, embarrassment, inconvenience, or unfairness to the individual.

Please explain your response:

Records cannot be retrieved using the most sensitive PII (i.e., SSNs) as identifiers. Nonetheless, 

sensitive PII and other personal information, as described above, is sometimes included in records 

stored on this cloud-based system. Disclosure of such records could potentially cause 

embarrassment and/or financial harm (in the event information is used for identity theft). Presently, 

only a limited number of case-related documents are stored by Office 365. Going forward, 

however, many of the types of documents stored on the agency’s local server will, instead, be stored 

in the cloud, through Office 365. 

1.16 Is this impact level consistent with the guidelines as determined by the FIPS 199 assessment?

Yes 

No 

1.17 When was the information system last authorized or reauthorized pursuant to OMB Circular 

A-130? The agency reauthorized the information system, Occupational Safety and Health 

Review Commission Network and General Support System, on November 12, 2020.

1.18 Based on the information that you have provided thus far, choose one of the following:

Based on the answers provided above, the information system (IT application or paper files)

does not contain information about individuals nor does it have shared links with other

information systems that may also contain information about individuals that could constitute a
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privacy issue.

A Privacy Impact Assessment (PIA) is not required for this Information System.

Based on the answers provided above, the information system (IT application or paper files)

does contain information about individuals, or it does have shared links with other information

systems that may also contain information about individuals that could constitute a privacy

issue.

A PIA is required for this Information System.