Privacy Impact Assessment

Emergency Alert System

May 23, 2023

Contact

D. Fon Muttamara

Chief Privacy Officer

Merit Systems Protection Board

1615 M Street, NW

Washington, DC 20419

privacy@mspb.gov
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Emergency Alert System

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Abstract

The U.S. Merit Systems Protection Board (MSPB) is implementing a new emergency alert system

utilizing the Everbridge Suite (Everbridge). Everbridge is a global provider of a Software as a 

Service platform for emergency communications. Such communications occur during events that 

affect MSPB’s operations, man-made or natural disasters, and other emergencies affecting the 

workplace or employees. MSPB intends to leverage Everbridge to provide critical 

communications to MSPB employees when there is a need for mass notifications. These 

communications can be tailored to specific events and targeted to specific groups within the 

agency. MSPB is conducting this Privacy Impact Assessment (PIA) because Everbridge requires

personally identifiable information (PII) from MSPB employees to send emergency alerts to them.

Overview

MSPB intends to use Everbridge to help manage emergencies using mass alerts and notifications. 

Everbridge will be managed by MSPB’s Office of Financial and Administrative Management 

(FAM), which is responsible for, among other things, the security of personnel and physical 

locations. FAM will utilize Everbridge for operational response to critical events to ensure the 

safety and security of MSPB personnel and physical locations, as well as to keep MSPB personnel 

up to date on emergencies that may impact MSPB personnel and operations, such as active shooter 

situations, terrorist attacks, or severe weather conditions. FAM will determine, in conjunction 

with other affected MSPB offices, under what circumstances and when to send alerts. Individuals 

within FAM’s management team will serve as the administrator of the system, have access to the 

data, and will draft alerts tailored to specific events or business needs. Additionally, each MSPB 

Regional Director and Chief Administrative Judge will have access to the data and have the ability 

to draft alerts tailored to specific events or business needs for their geographical location.

To utilize Everbridge, MSPB will collect the following employee contact information: MSPBassigned office phone numbers, MSPB-issued mobile device numbers, MSPB email addresses, 

and MSPB duty locations. Employees may voluntarily provide their personal mobile number, 

home phone number, and personal email address. MSPB will not require employees to download 

or install mobile applications to their personal mobile devices, however, if individuals choose to 

voluntarily provide their personal mobile phone numbers, they have the option to download or 

install the Everbridge mobile application to their personal device. At this time, geolocation 

services will not be used to identify an individual’s geographic location. Alerts will be sent in the 

following manner:

• MSPB email addresses: written alerts.

• MSPB-assigned office phones: recorded messages.

• MSPB-issued mobile devices: text alerts and recorded messages.

• MSPB-issued computers: pop-up written alerts.

• Personal email addresses, if provided: written alerts.

• Personal home phones, if provided: recorded messages.

• Personal mobile devices, if provided: text alerts and recorded messages. 
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To begin the initial PII collection, the Office of Information Resources Management (IRM) will 

provide a .csv file to FAM. The .csv file will contain MSPB employee email addresses and MSPBassigned office phone numbers (and extensions if applicable) from MSPB’s Microsoft Active 

Directory, as well as MSPB-issued mobile device numbers. FAM will then provide the file to 

Everbridge through MSPB’s secure file sharing system, Box.com. As new hires onboard at MSPB, 

FAM will manually enter the required PII into the Everbridge system. Additionally, FAM will 

manually delete the PII of departing employees. Employees may voluntarily provide personal 

contact information, which FAM will add to the information maintained in Everbridge for those 

employees.

The privacy risks to the administration of this system have been mitigated through role-based 

access. Access to Everbridge is limited to the system administrators, i.e., specific individuals 

within FAM and IRM (the MSPB office responsible for providing technical support) who require 

access to the system in the performance of their duties. There is no anticipated sharing of the 

information stored in the Everbridge system outside of MSPB.

Section 1.0 Authorities and Other Requirements

1.1 What specific legal authorities and/or agreements permit 

and define the collection of information by the project in

question?

MSPB’s use of Everbridge is consistent with all applicable laws, regulations, and policies. The 

following legal authorities permit MSPB’s use of Everbridge and define the collection of 

information in the system:

• 5 U.S.C. § 1204;

• Federal Continuity Directive (FCD) 1, Federal Executive Branch National Continuity 

Program and Requirements, January 17, 2017;

• FCD 2, Federal Executive Branch Mission Essential Functions and Candidate Primary 

Mission Essential Functions Identification and Submission Process, June 13, 2017; and

• Directive on National Continuity Policy (National Security Presidential Directive 

51/Homeland Security Presidential Directive 20), May 4, 2007.

1.2 What Privacy Act System of Records Notice(s) (SORN(s)) 

apply to the information?

In accordance with the Privacy Act of 1974 (Privacy Act), MSPB proposes to establish a new 

MSPB SORN titled, “MSPB – 4, Emergency Alert System.” This system of records contains 

information that MSPB collects, maintains, and uses for operational response to critical events to 

ensure the safety and security of MSPB personnel and physical locations, as well as to keep MSPB 

personnel up to date on emergencies that may impact MSPB personnel and operations, such as 

active shooter situations, terrorist attacks, or severe weather conditions. This system of records 

will be included in MSPB’s inventory of record systems.
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1.3 Has a system security plan been completed for the 

information system(s) supporting the project?

Everbridge has undergone Certification and Accreditation and was certified by the Federal Risk 

and Authorization Management Program Joint Authorization Board to operate at the Moderate 

impact level on June 7, 2018. IRM is responsible for maintaining the enterprise security 

Authorization to Operate (ATO) for this system and for implementing appropriate security 

controls. The ATO for Everbridge was approved by MSPB on March 9, 2022. A privacy risk

assessment has been conducted on Everbridge through this PIA, which describes the measures that 

MSPB has taken to protect against privacy risks. 

1.4 Does a records retention schedule approved by the 

National Archives and Records Administration (NARA)

exist?

The information collected is subject to General Records Schedule 5.3: Continuity and Emergency 

Planning Records, Item 020 (Employee emergency contact information) – DAA-GRS-2016-

0004-0002. These records are temporary and are destroyed when there is an update or upon 

separation or transfer of the employee.

1.5 If the information is covered by the Paperwork Reduction Act 

(PRA), provide the OMB Control number and the agency

number for the collection. If there are multiple forms, include a 

list in an appendix.

This is not an information collection under the PRA.

Section 2.0 Characterization of the Information

2.1 Identify the information the project collects, uses, disseminates, 

or maintains.

The categories of individuals from which information is collected are MSPB employees. At this 

time, MSPB will collect the following contact information: MSPB-assigned office phone 

numbers, MSPB-issued mobile device numbers, MSPB email addresses, and MSPB duty

locations. MSPB will not require personal contact information. However, if individuals

volunteer to provide their personal contact information, that information will be collected, used, 

disseminated, and maintained by MSPB and Everbridge.

2.2 What are the sources of the information and how is

the information collected for the project?

To begin the initial PII collection, IRM will provide a .csv file to FAM. The .csv file will contain 

MSPB employee email addresses and MSPB-assigned office phone numbers (and extensions if 
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applicable) from MSPB’s Microsoft Active Directory, as well as MSPB-issued mobile device 

numbers. FAM will then provide the file to Everbridge through MSPB’s secure file sharing system, 

Box.com. As new hires onboard at MSPB, FAM will manually enter the required PII into the 

system. Additionally, FAM will manually delete the PII of departing employees. Any collection 

of personal contact information will be voluntary. Employees may provide their personal contact 

information either during onboarding or any time during their tenure at MSPB.

2.3 Does the project use information from commercial sources 

or publicly available data? If so, explain why and how this 

information is used.

No, the project does not use information from commercial sources or publicly available data.

2.4 Discuss how accuracy of the data is ensured.

The accuracy of the data is ensured by collecting the information from MSPB’s Microsoft Active 

Directory, which is the agency’s identity service provider. Additionally, the accuracy of data is 

also ensured by collecting personal information (personal phone number(s) and email) from 

individual employees during onboarding and at any time during an employee’s tenure at MSPB.

2.5 Privacy Impact Analysis: Related to Characterization of 

the Information

Privacy Risk: There is a privacy risk that the system will collect and maintain more information 

than is relevant and necessary to accomplish the agency’s mission.

Mitigation: This risk is partially mitigated. The information is collected from MSPB’s Microsoft 

Active Directory and from the individual employee.

Section 3.0 Uses of the Information

3.1 Describe how and why the project uses the information.

Employees’ MSPB contact information will be used to send emergency alerts to employees for 

their safety and security. The alerts will be sent to employees’ agency-assigned office phone 

numbers, cell phone numbers, and email addresses. Additionally, written alerts will be sent to 

agency-assigned computers via pop-up notifications. Emergency alerts also will be sent to 

employees’ personal phone number(s) and email address if they have been voluntarily provided.

3.2 Does the project use technology to conduct electronic searches, 

queries, or analyses in an electronic database to discover or 

locate a predictive pattern or an anomaly? If so, state how MSPB

plans to use such results.
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The system will not use technology to conduct electronic searches, queries, or analysis in an 

electronic database to discover or locate a predictive pattern or an anomaly.

3.3 Are there other components with assigned roles 

and responsibilities within the system?

No, there are no other MSPB components with assigned roles and responsibilities within the 

system.

3.4 Privacy Impact Analysis: Related to the Uses ofInformation

Privacy Risk: There is a risk that information will be used inappropriately.

Mitigation: This risk is partially mitigated. All system data is managed by FAM. The initial data 

entry of employee work contact information is overseen by Everbridge, but the information is 

provided by FAM in conjunction with IRM. Additionally, the system will have role-based access.

Privacy Risk: There is a risk that MSPB could use the information collected for purposes other 

than that for which the information was collected.

Mitigation: This risk is partially mitigated. MSPB will only utilize the information to the extent 

necessary to provide emergency alerts to MSPB employees. MSPB only collects PII that is directly 

related to the administration of the emergency alert system. All MSPB employees are required to 

take annual privacy training and are subject to discipline for inappropriately using PII. 

Additionally, access to the system and the PII in it will be limited to only the MSPB employees 

with a need-to-know to perform their official duties, specifically, to specific FAM employees, for 

the administration and use of the system, and specific IRM employees, to provide technical 

support.

Section 4.0 Notice

4.1 How does the project provide individuals notice prior to the 

collection of information? If notice is not provided, explain 

why not.

Individuals are provided written notice of the agency’s collection of information through this PIA.

4.2 What opportunities are available for individuals to consent 

to uses, decline to provide information, or opt out of the

project?

The information utilized by the system is information that has been generated and collected by 

MSPB to perform essential agency functions, such as an MSPB-assigned office and mobile 

telephone number and MSPB email address. Any personal contact information is provided 
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voluntarily, and the employee may consent to uses, decline to provide information, or have their 

personal contact information removed at any time.

4.3 Privacy Impact Analysis: Related to Notice

Privacy Risk: There is a risk that MSPB employees will not be given the opportunity to consent 

to the uses of their information.

Mitigation: This risk is partially mitigated. The information being collected is part of the 

employee’s MSPB contact information, provided by MSPB for the employee to perform essential 

functions. Any personal contact information is provided voluntarily, and the employee may 

consent to uses, decline to provide information, or have their personal contact information removed

at any time.

Section 5.0 Data Retention by the project

The following questions are intended to outline how long the project retains the information after 

the initial collection.

5.1 Explain how long and for what reason the information isretained.

Upon separation from MSPB, employee information is removed from the system. The data is 

still maintained in Everbridge’s Amazon Web Services environment until 30 days after the 

expiration of the contract. When MSPB’s contract expires, MSPB’s account will be deactivated 

and listed for deletion. Thirty days from the contract expiration date, MSPB’s data will be flagged 

for purging and all the agency’s data will be removed from the active system. Everbridge 

typically retains an organization’s data for one month in the event the organization wishes to 

extend its subscription.

5.2 Privacy Impact Analysis: Related to Retention

Privacy Risk: There is a risk that information collected by the system may be retained longer 

than is necessary.

Mitigation: This risk is partially mitigated. MSPB will manually remove any employee PII from 

the system upon separation from MSPB. Additionally, the information will be removed from the 

Everbridge servers after 30 days once the contract is completed.

Section 6.0 Information Sharing

6.1 Is information shared outside of MSPB as part of the normal 

agency operations? If so, identify the organization(s) and how 

the information is accessed and how it is to be used.
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No. PII is not shared outside of MSPB as part of normal agency operations. PII is only shared 

with external parties when required by a routine use in MSPB – 4, Emergency Alert System.

6.2 Describe how the external sharing noted in 6.1 is compatible 

with the SORN noted in 1.2.

The external sharing noted in 6.1 denotes that information may be shared in a manner consistent 

with MSPB – 4, Emergency Alert System. External parties who receive access to PII collected 

under the SORN pursuant to a routine use are subject to the same Privacy Act limitations on 

disclosures as MSPB employees.

6.3 Does the project place limitations on re-dissemination?

Yes. MSPB places limitations on re-dissemination of PII. The information shared pursuant to the 

routine uses in MSPB’s SORN is subject to limitations on further dissemination. MSPB outlines 

these limitations and obligations of the receiving party through a transmittal letter. Generally, 

receiving parties may not use the information for a reason not already approved by MSPB or 

further disseminate the information without the prior written consent of MSPB. Records released 

under a Freedom of Information Act (FOIA) request constitute public information, and MSPB has 

no authority to limit their re-dissemination.

6.4 Describe how the project maintains a record of any

disclosures outside of the Department.

MSPB utilizes FOIAonline (https://foiaonline.gov/foiaonline/action/public/home) to track 

requests for information disclosure pursuant to the FOIA, the Privacy Act, routine uses in SORNs, 

or other applicable statutes and regulations. FOIAonline is a web-based application and assists 

MSPB in tracking and recording requests received for the disclosure of information. This includes 

requests subject to the accounting provisions of the Privacy Act. The information retained as part 

of this accounting requirement includes the agency or individual requesting the information, a 

description of the requested information, the reason for the request, the date of the request, the date 

of the release, the authority for the release, and the limitations and obligations on the requesting 

agency or individual with regard to use and further dissemination.

6.5 Privacy Impact Analysis: Related to InformationSharing

Privacy Risk: There is a risk that the information will be shared outside the scope of the 

applicable SORN or without the proper authority or accounting.

Mitigation: This risk is partially mitigated. MSPB only shares information outside the agency as 

documented in this PIA and as permitted by MSPB – 4, Emergency Alert System. An accounting 

of disclosures is documented each time the information is shared outside the agency pursuant to 

the SORN in MSPB’s FOIAonline system. Additionally, annual agency privacy training educates 

MSPB employees on the appropriate way to protect PII and information maintained in an agency 

system of records.
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Privacy Risk: There is a risk associated with whether MSPB may be able to control Everbridge’s 

retention of PII.

Mitigation: This risk is partially mitigated. MSPS’s contract with Everbridge specifies that MSPB 

is the owner of all data collected and maintained. Everbridge is contractually required to destroy 

all information associated with any information collection 30 days after the end of the contract. 

MSPB also contracts for the right to investigate and audit a vendor’s system to ensure they are 

complying with MSPB policies, procedures, and retention schedules. Any egregious or potentially 

illegal conduct could be referred to MSPB’s Office of General Counsel or investigated by the 

MSPB Chief Privacy Officer (CPO).

Section 7.0 Redress

7.1 What are the procedures that allow individuals to access 

their information?

Individuals seeking notification of and access to their records in a system of records may submit a 

request in writing to the Office of the Clerk of the Board, Merit Systems Protection Board, 1615 

M Street, NW, Washington, DC 20419. This request may also be sent to the agency by email at 

privacy@mspb.gov. Individuals requesting access must comply with MSPB’s Privacy Act 

regulations regarding verification of identity and access to records (5 C.F.R. Part 1205).

Individuals will also be able to contact FAM, as the MSPB office responsible for human resources, 

to access the information FAM maintains on employees, including any personal phone numbers 

or email addresses provided by the individual.

7.2 What procedures are in place to allow the subject individual 

to correct inaccurate or erroneousinformation?

Individuals seeking amendment of their records in a system of records may submit a request in 

writing to the Office of the Clerk of the Board, Merit Systems Protection Board, 1615 M Street,

NW, Washington, DC 20419. This request may also be sent to the agency by email at 

privacy@mspb.gov. Individuals requesting amendment must follow MSPB’s Privacy Act 

regulations regarding verification of identity (see Record Access Procedures above) and 

amendment to records (5 C.F.R. Part 1205).

Individuals will also be able to contact FAM, as the MSPB office responsible for human resources, 

to correct inaccurate information FAM maintains on employees, including any personal phone 

numbers or email addresses provided by the individual.

7.3 How does the project notify individuals about the procedures 

for correcting their information?
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This PIA provides notice to individuals on how to correct their information. Additionally, MSPB

– 4, Emergency Alert System provides information to individuals regarding how to correct their 

information.

7.4 Privacy Impact Analysis: Related to Redress

Privacy Risk: There is a risk that individuals will not be able to correct inaccurate information 

that has been collected about them.

Mitigation: The risk is partially mitigated. Individuals may seek amendment of records that they

assert are not accurate, relevant, timely, or complete by submitting an amendment request as 

outlined in MSPB’s Privacy Act regulations at 5 C.F.R. Part 1205.

Privacy Risk: There is a risk that individuals will be unaware of the procedure for requesting 

access to the information that has been collected about them.

Mitigation: The risk is partially mitigated. This PIA provides information for individuals to 

understand how to seek redress, correction, or amendment. Additionally, MSPB’s regulations and 

SORN providing the redress procedures are posted online.

 

Section 8.0 Auditing and Accountability

The following questions are intended to describe technical and policy-based safeguards 

and security measures.

8.1 How does the project ensure that the information is used 

in accordance with stated practices in this PIA?

MSPB ensures that the practices stated in this PIA are followed by implementing training, standard 

operating procedures, policies, rules of behavior, and role-based access. Only employees and 

contractors with a valid need to know may collect and use information obtained from Everbridge. 

Moreover, any MSPB office or program that chooses to collect PII regardless of whether the 

activity requires PRA submission, is required to conduct a Privacy Threshold Analysis or a PIA.

8.2 Describe what privacy training is provided to users 

either generally or specifically relevant to the project.

All MSPB employees and contractors are required to complete privacy awareness training when 

they onboard or begin working on an MSPB contract, respectively, and annually thereafter. 

MSPB’s CPO logs all information governance training completed by agency personnel. This 

ensures that personnel are knowledgeable of their privacy, FOIA, and records management 

responsibilities, which includes their obligation to protect PII.
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8.3 What procedures are in place to determine which users may 

access the information and how does the project determine

who has access?

MSPB employees who have a need to know to perform their official duties will have access to the 

information maintained in Everbridge. MSPB deploys role-based access controls and enforces a 

separation of duties through all MSPB operations to limit access to only those individuals who 

have a need to know in order to perform their official duties. This need to know is determined by 

the respective responsibilities of the employee.

8.4 How does the project review and approve information sharing 

agreements, memoranda of understanding (MOUs), new uses of 

the information, new access tothe system by organizations within 

MSPB and outside?

MSPB’s use of Everbridge does not utilize information sharing agreements or MOUs. New uses 

of the information are not permissible without review and authorization by MSPB’s Chief 

Information Officer and Senior Agency Official for Privacy. If new uses of the information are 

approved, they will only be utilized once appropriate notice has been provided, such as an update 

to this PIA or MSPB’s SORN.

Responsible Officials

D. Fon Muttamara

Chief Privacy Officer

U.S. Merit Systems Protection Board

Approval Signature

William D. Spencer

Senior Agency Official for Privacy

U.S. Merit Systems Protection Board