Privacy Impact Assessment

Qualtrics

December 22, 2020

Contact

D. Fon Muttamara

Chief Privacy Officer

Merit Systems Protection Board

1615 M Street, NW

Washington, D.C. 20419

privacy@mspb.gov
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Abstract

The U.S. Merit Systems Protection Board (MSPB) has purchased licenses for Qualtrics, LLC’s 

Qualtrics XM Platform (Qualtrics). Qualtrics is a Federal Risk and Authorization Management 

Program (FedRAMP) certified, cloud-based Software as a Service (SaaS) experience 

management company owned by SAP SE that provides quantitative statistical analysis

capabilities. MSPB uses Qualtrics to develop and administer surveys as part of MSPB’s general 

authorities to conduct studies and research on matters relevant to the Merit System Principles 

(MSPs) and Prohibited Personnel Practices (PPP). MSPB is conducting this Privacy Impact 

Assessment (PIA) because Qualtrics collects and processes personally identifiable information 

(PII) and other sensitive information when providing the quantitative statistical analysis services

contracted by MSPB, and MSPB collects PII and other sensitive data in order to facilitate the use 

of these surveys.

Overview

The purpose of the Qualtrics SaaS environment is to provide MSPB with a cloud platform to 

develop and administer surveys to (1) prospective, current, or former Federal employees, or (2) 

MSPB employees, customers, and stakeholders. These surveys support (1) special studies of the 

Federal civil service under 5 U.S.C. § 1204(a)(3), (2) review of OPM regulations and significant 

actions under 5 U.S.C. § 1204(e)(3) and § 1206, and (3) evaluation of agency operations, 

programs, and performance under the Government Performance and Results Modernization Act 

and related requirements. The use of Qualtrics supports MSPB’s mission to “conduct, from time 

to time, special studies relating to the civil service and to other merit systems in the executive 

branch” by providing a platform to generate and manage web-based surveys.

The Merit Principles Survey (MPS) and other surveys conducted by MSPB’s Office of Policy 

and Evaluation (OPE) are tools that measure Federal employees’ perceptions of whether, and to 

what extent, MSPs are being protected and PPPs are being prevented in Federal agencies. MSPB 

surveys ask participants to share their attitudes, behaviors, and thoughts on topic areas related to 

the MSPs, PPPs, and other personnel management topics relevant to the merit systems. 

Demographic questions are also included to evaluate differences among subgroups in the way 

responses were distributed. 

Examples of surveys to be conducted using Qualtrics include:

o Large-scale, Government-wide surveys of civilian Federal employees, such as 

MSPB’s periodic MPS;

o Smaller-scale study surveys administered to employees of specific Federal agencies 

or individuals who engage in a specific activity (e.g., applying for a Federal job);

o Internal surveys of MSPB employees; and 

o Surveys of MSPB customers (e.g., individuals and agency representatives who 

participate in an appeal).
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Information that may be collected and stored on Qualtrics falls into three broad categories:

• Sampling information—information used to identify and select employees for a survey. 

Examples of such information include employment status (e.g., permanent full-time), 

employing agency, and supervisory status.

• Administrative information—information used to distribute and administer the survey. 

Examples of such information include email address, name, and demographic 

information (such as occupation or agency). (Demographic information is usually selfreported by the agency, but if available in the sampling information it could be presented 

to the employee in the survey for confirmation or correction.)

• Response information—information comprising the survey respondent’s answers to the 

questions (e.g., work attitudes and work experiences) and survey activity (e.g., metadata 

such as last item completed, date survey was accessed).

In order to administer an MSPB survey, information about Federal employees is routinely 

collected from the Office of Personnel Management’s (OPM) Enterprise Human Resource 

Integration (EHRI) system. The data from EHRI is used to (1) identify current Federal 

employees, (2) determine survey eligibility, (3) collect contact information where necessary and 

available, (4) perform statistical weighting procedures using select demographic information, and 

(5) support research and reporting functions. All survey administrations, data cleaning, and 

statistical weighting procedures are executed by MSPB. At the end of the survey cycle, selected 

summary results and a technical report may be published, and a public version of the data file is 

released.

Records may be retrieved by survey case identifier or other personal identifier but are generally 

only retrieved in this manner leading up to and during the administration of special studies 

surveys. After the survey is administered, personal identifiers are rarely used to retrieve records 

or for any other purpose. Instead, post-administration of the survey, records are typically 

retrieved by a respondent characteristic (such as agency or demographic group) or response 

pattern (such as response to a particular survey item or set of items) in a manner that is not 

intended to identify individual survey respondents. Additionally, post-administration of the 

survey, records may be retrieved by personal identifier for a use consistent with the collection of 

the information and as agreed upon in a Memorandum of Understanding (MOU) between OPM 

and MSPB.

OPE will utilize and adhere to internal agency processes and policies to prevent unauthorized 

use and sharing of information. Only individuals with a “need to know” will be granted access 

to survey responses in Qualtrics, and these individuals will only be able to access specified 

information based on their roles and allocated system permissions. The System Administrator 

from MSPB will be the only authorized user able to create and remove Qualtrics users, and the 

Program Manager is responsible for identifying who will have access to their business unit’s 

surveys and responses. Authorized users will access Qualtrics through the agency’s single signon (SSO) service, which will automatically authenticate the user before granting them access. 

MSPB also plans to set up a regularly scheduled auditing and monitoring program, based on 

recommendations and guidelines from MSPB’s Privacy Officer.
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Records in the system are protected from unauthorized access and misuse through various 

administrative, technical, and physical security measures, such as access controls, mandatory 

security and privacy training, encryption, multi-factor authentication, security guards, and locked 

offices.

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 Qualtrics is consistent with all applicable laws, regulations, and policies, 

including: 5 U.S.C. §§ 1204(a)(3), 1204(e)(3), and 1206.

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

apply to the information?

A System of Records Notice (SORN) is not required for Qualtrics; however, a SORN is required 

for MSPB’s collection of information and use of Qualtrics. In accordance with the Privacy Act 

of 1974, MSPB proposes to establish a new MSPB system of records titled “Surveys for Special 

Studies of the Civil Service.” This system of records contains information that MSPB collects, 

maintains, and uses in order to develop and administer the MPS and other special studies 

surveys, and to evaluate and distribute the results of such surveys. This system of records will be 

included in MSPB’s inventory of record systems.

1.3 Has a system security plan been completed for the 

information system(s) supporting the project?

An Authorization to Operate (ATO) was granted for Qualtrics by FedRAMP on June 29, 2018. 

Assessment and Authorization was completed by Qualtrics as part of the FedRAMP 

authorization package. At the agency level, MSPB has completed a System Security Plan and 

System Privacy Plan for Qualtrics as part of the agency’s internal ATO process.

1.4 Does a records retention schedule approved by the 

National Archives and Records Administration (NARA)

exist?

Data retention is covered in MSPB’s contract with Qualtrics. In addition, MSPB is currently 

working to develop a records schedule to submit to NARA for approval. Until a records 

schedule is in place, the records will be retained as permanent records.
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Records retained by OPM in the EHRI may be retained indefinitely as a basis for longitudinal 

studies. After the disposition date in General Records Schedule-1 (GRS-1) or GRS 20, 

Electronic Records, such records should not be used in making decisions concerning 

employees. Data provided to MSPB from OPM’s EHRI data warehouse under an OPM-MSPB 

MOU is retained until no longer needed or when OPM instructs MSPB to destroy data.

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.

The PRA does not apply to OPE’s survey activities. OPE is currently only collecting 

information from Federal employees in their official capacities.1

 In the event that OPE decides 

to collect information from members of the public, MSPB will initiate an Information Collection

Request to OMB before the collection takes place.

Section 2.0 Characterization of the Information

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

or maintains.

Survey respondents constitute the categories of individuals for whom information is collected. 

This may include Federal employees, other non-MSPB Federal employees, and members of the 

public.

MSPB may collect the following categories of information from individuals.

1. Pay (e.g., Grade, Pay Plan).

2. Work Location (e.g., Agency, Personnel Office Identifier).

3. The Position (e.g., Occupational Series, Supervisory Status).

4. Performance (e.g., Rating Level, Rating Pattern).

5. EHRI Demographics (e.g., Sex, Veteran's Status).

6. Personal Identifiers, whether provided by the individual or as part of the administration of 

the survey (e.g., Employee Name and Email Address, randomly assigned identifier for 

survey administration).

7. Voluntary Survey Question Responses (e.g., Responses to Survey Questions).

8. Personnel Actions History (e.g., Service Computation Date for Retirement Purposes, 

Hiring Authority).

 1 “Agency collections from ‘agencies, instrumentalities, or employees of the United States’ in their official 

capacities are generally not subject to the PRA.” 44 U.S.C. § 3502(3)(A).
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At the end of the survey cycle, selected summary results and a technical report may be published, 

and a public version of the data file is released. The purpose of this information is to provide 

objective, non-partisan studies that assess and evaluate Federal merit systems policies, 

operations, and practices.

In order to administer an MSPB survey, information about Federal employees is routinely 

collected from OPM’s EHRI system. The data from EHRI is used to (1) identify current Federal 

employees, (2) determine survey eligibility, (3) collect contact information where necessary and 

available, (4) perform statistical weighting procedures using select demographic information, and 

(5) support research and reporting functions. All survey administrations, data cleaning, and 

statistical weighting procedures are executed by MSPB. 

2.2 What are the sources of the information and how is

the information collected for the project?

Individual survey participant records are obtained from OPM’s EHRI system, which contains 

general personnel records from the OPM/GOVT-1 General Personnel Records system of 

records, from the individual Federal agencies that participate in MSPB’s surveys, and from the 

individuals who voluntarily complete these surveys.

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. MSPB does not use information from commercial sources or publicly available data.

2.4 Discuss how accuracy of the data is ensured.

Qualtrics does not check for accuracy. It provides the services, and customers use the services as 

they wish. Qualtrics does not know what data is being collected. The survey creator solely 

determines what data is collected. Opinions and experiences are collected directly from 

participants of the surveys; therefore, responses are dependent upon the accuracy of the 

information provided by each participant. MSPB also collects contact information from OPM’s 

EHRI system, which is presumed to be accurate. 

2.5 Privacy Impact Analysis: Related to Characterization of 

the Information

Privacy Risk: There is a risk that Qualtrics or MSPB will collect more information than 

necessary for its reports and analyses.

Mitigation: The risk is partially mitigated. Qualtrics is an enterprise survey software tool, and 

any risks that may arise likely involve the underlying collection of data rather than the software 

that is used to collect the data. 
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The purpose of MSPB special studies surveys is to collect the opinions and experiences of 

participants. Although personal contact information is collected, this information is only entered 

into the Qualtrics tool for the purposes of administering the survey. MSPB does not share 

personal contact information outside of Qualtrics unless required by a routine use in the SORN.

Privacy Risk: There is a privacy risk that Qualtrics or MSPB will fail to protect the anonymity 

of participants.

Mitigation: The risk is partially mitigated. Qualtrics treats all data as highly confidential and 

does not classify or represent the data because only the customer (i.e., MSPB) knows what data it 

is collecting. In other words, Qualtrics provides the services, and customers use the services as 

they wish. All data is safeguarded using industry best security practices that prevent unlawful 

disclosure.

OPE utilizes and adheres to internal MSPB processes to prevent unauthorized use and sharing of 

information. Only individuals with a need to know will be granted access to data associated with 

Qualtrics surveys, and these individuals will only be able to access specified information based 

on their roles and allocated system permissions. This data includes both the survey responses 

themselves as well as any additional data that may be collected from or about the survey 

participant. The MSPB Program Manager is responsible for identifying who has access to the

surveys and responses. Authorized users will access Qualtrics through MSPB’s SSO service that 

will automatically authenticate the user before granting them access. 

Section 3.0 Uses of the Information

3.1 Describe how and why the project uses the information.

The MPS and other special studies surveys are tools that measure Federal employees’ 

perceptions of whether, and to what extent, MSPs are being protected and PPPs are being 

prevented in Federal agencies. MSPB surveys ask participants to share their attitudes, behaviors, 

and thoughts on topic areas related to the MSPs, PPPs, and other topics of personnel 

management relevant to the merit systems. Demographic questions are included to evaluate 

differences among subgroups and the way in which responses are distributed. 

Internally, survey results will be shared with OPE, which develops and administers the surveys. 

Results may also be shared with other MSPB personnel on a need-to-know basis, including

MSPB management, the Office of the General Counsel (OGC) for legal review, the Office of 

Information Resources Management for information technology (IT) support, and the Office of 

the Clerk of the Board for matters pertaining to information governance.

Externally, a de-identified summary of the results of the MPS will be shared with the President

of the United States, Congress, and other Federal decision-makers to be used in developing 

policy that supports both merit and mission accomplishment. Aggregated survey results will also 

be shared with the public, primarily as reports, research briefs, and newsletters on the MSPB 

website. PII is not released outside the agency unless required by a routine use in the SORN. 
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All demographic information released to the public is presented in aggregate form to eliminate 

the potential of re-identifying any individual participant. Additionally, a copy of the deidentified aggregated data is provided to NARA as a permanent Federal record.

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.

Yes. MSPB’s use of Qualtrics will leverage Qualtrics’ ability to conduct electronic searches, 

queries, and analyses to locate predictive patterns or anomalies. In particular, Qualtrics’ 

quantitative statistical analysis capabilities will be used to evaluate differences among 

demographic subgroups when measuring their attitudes, behaviors, and thoughts on topic areas

related to the Civil Service. The ability to quickly synthesize data is particularly valuable for 

interpreting large datasets.

3.3 Are there other components with assigned roles 

and responsibilities within the system?

Not applicable.

3.4 Privacy Impact Analysis: Related to the Uses ofInformation

Privacy Risk: There is a risk that PII collected by Qualtrics or MSPB will be used 

inappropriately prior to it being aggregated into anonymous management reports or analyses.

Mitigation: This risk is partially mitigated. All data is owned and operated by MSPB and not 

Qualtrics. Qualtrics is the data processor. It is a self-service product whereby the Federal 

customer (i.e., MSPB) solely determines what data to collect, from whom, from where, for what

purpose, and when to delete it. 

Any data collected by MSPB is stored on a Federal Information Processing Standards 140-2

encrypted IT system to prevent unauthorized access. Access to participant contact information or 

raw survey data is limited to authorized MSPB employees who have a justifiable business need 

and who have undergone privacy training.

Privacy Risk: There is a risk that Qualtrics or MSPB could use the information collected for 

purposes other than that for which the information was collected, including for operational uses.

Mitigation: This risk is partially mitigated. Qualtrics will only process data to the extent 

necessary to provide services and does not disclose any data to third parties. 

MSPB only collects PII that is directly related to administering a special study. All MSPB

employees are required to take annual privacy training and are subject to discipline for 

inappropriately using PII.
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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.

A Privacy Act Statement is made available to survey participants, informing them of the 

intended purpose and use of their information, and whether or how they may opt out of providing

information. The following Privacy Act Statement is located in the MPS:

Privacy Act Statement

AUTHORITY: Collection of the information is authorized by 5 U.S.C. §§ 1204

and 1206, which requires the Merit Systems Protection Board (MSPB) to conduct 

special studies relating to the civil service and to other merit systems in the 

executive branch. 

PRINCIPAL PURPOSE(S): The purpose of collecting this information is to 

study how well the Federal Government is managing its work force in adherence 

to the merit system principles. Only MSPB staff and our survey support 

contractor staff will have access to individually completed surveys. A deidentified summary of the results will be shared with the President of the United 

States, Congress, and other Federal decision-makers to be used in developing 

policy that supports both merit and mission accomplishment. Any reports issued 

following survey administration will contain only aggregated data and cannot be 

used to identify individual participants.

ROUTINE USE(S): No data will be disclosed that could be used to identify 

individual participants, except as generally permitted under 5 U.S.C. § 552a(b) of 

the Privacy Act of 1974. This includes sharing the information as necessary and 

authorized by routine uses in MSPB’s System of Records Notice, MSPB – 2, 

Surveys for Special Studies of the Civil Service. 

DISCLOSURE: Your responses to this survey are completely voluntary. There 

is no penalty if you choose not to participate. However, we encourage your 

participation to ensure that our data is complete and representative of the Federal 

workforce.
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4.2 What opportunities are available for individuals to consent 

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

project?

Individual participation in MSPB surveys is completely voluntary. There is no penalty if an 

individual chooses not to participate. Each potential survey participant is provided with the 

Privacy Act Statement informing them that participation is voluntary and that there are no 

penalties for refusing to participate.

4.3 Privacy Impact Analysis: Related to Notice

Privacy Risk: There is a risk that Federal employees participating in special studies surveys 

may not be properly protected because this collection of information does not meet the threshold 

for the PRA to apply, and therefore, certain protections of the PRA are not extended to this 

information collection.

Mitigation: This risk is partially mitigated. The Privacy Act requires that an agency supply 

notice to Federal employees any time PII is collected that could later be retrieved. MSPB

requires that potential participants have expressed “informed consent” for any information 

collection regarding their survey participation. Survey activities must be vetted by the MSPB 

Privacy Officer to ensure that there is proper notice given to employees regarding the purpose, 

authority, and voluntariness of the information collection.

Privacy Risk: There is a risk that survey participants may not realize that the information they 

initially provide to MSPB may later be used for other purposes.

Mitigation: This risk is partially mitigated by publishing this PIA and the SORN for MSPB – 2, 

Surveys for Special Studies of the Civil Service, which states that, post-administration of the 

survey, records may be retrieved by personal identifier for another research purpose that 

complies with the MOU between MSPB and OPM. MSPB gives all potential participants the 

opportunity to decline or to discontinue participation at any point, minimizing any potential harm 

resulting from an individual’s lack of notice.

Section 5.0 Data Retention by the Project

5.1 Explain how long and for what reason the information is

retained.

Generally, sampling and administrative information are retained only until the survey closes. PII 

such as employee name and social security number are used only to locate employees and 

administer the survey, and MSPB’s protocol is to purge such data from MSPB systems 

(including the Qualtrics environment) once the need for this information has been met. 

Response data may be retained for a longer period to use the data cleaning and analysis tools 

available in the Qualtrics environment.
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5.2 Privacy Impact Analysis: Related to Retention

Privacy Risk: There is a risk that PII collected may be retained for a longer period than 

necessary.

Mitigation: MSPB mitigates this risk by deleting the data when no longer necessary. PII is 

removed from published datasets, and any demographic data received from participants is 

aggregated and not linked to any particular participant. Information used to initially contact 

prospective participants is typically taken from the OPM EHRI system and is deleted after 

completion of the survey administration or any subsequent follow-up.

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.

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 the SORN for MSPB – 2, Surveys for 

Special Studies of the Civil Service. MSPB may share reports or other materials containing deidentified, aggregated survey results with the President of the United States, Congress, or the 

public. The purpose of this sharing is to provide objective, non-partisan studies that assess and 

evaluate Federal merit systems policies, operations, and practices.

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 the SORN for MSPB – 2, Surveys for Special Studies of the Civil Service. External parties 

provided PII under a routine use are subject to the same Privacy Act limitations on disclosures as 

MSPB employees. Any reports issued following survey administration will contain only 

aggregated data and cannot be used to identify individual participants, so SORN compatibility is 

not needed for such disclosures.

6.3 Does the project place limitations on re-dissemination?

Yes. MSPB places limitations on re-dissemination of PII. With regard to the sharing of 

information with Qualtrics, MSPB’s contract with Qualtrics provides for protections and 

limitations on Qualtrics’ use of this information. Additionally, 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 agency through a transmittal letter. 

Generally, receiving agencies may not use the information for a reason not already approved by 

MSPB or further disseminate the information without prior written consent of MSPB.
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6.4 Describe how the project maintains a record of any

disclosures outside of the Agency.

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

requests for information disclosure pursuant to the Freedom of Information Act (FOIA), the 

Privacy Act, the routine uses in MSPB’s SORNs, and statutes and regulations. FOIAonline is a 

web-based application that 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 is shared outside the scope of MSPB’s SORN 

or without the proper authority or accounting.

Mitigation: This privacy risk is mitigated because MSPB only shares information outside the 

agency as documented in this PIA and as permitted by the SORN for MSPB – 2, Surveys for 

Special Studies of the Civil Service. 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.

Privacy Risk: There are risks associated with the fact that MSPB may not be able to control 

Qualtrics’ retention of PII and survey responses.

Mitigation: This risk is partially mitigated. In MSPB’s contract with Qualtrics, it is specified 

that MSPB is the owner of all data collected. Qualtrics is required contractually to destroy all 

information associated with any information collection at the end of the contract. MSPB also 

contracts for the right to investigate and audit a vendor’s systems to ensure they are complying 

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

conduct could be referred to OGC or investigated by the MSPB Privacy Officer. The Privacy 

Officer consults with MSPB’s Office of Financial and Administrative Management to review

agency contracts and ensure that appropriate language, including Federal Acquisition 

Regulations Privacy Act clauses, is included to protect participant PII.
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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 this 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. 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).

7.2 What procedures are in place to allow the subject individual 

to correct inaccurate or erroneousinformation?

Individuals may request that records about them be amended by writing to the Office of the 

Clerk of the Board, Merit Systems Protection Board, 1615 M Street, NW, Washington, DC 

20419. Individuals requesting amendment must follow MSPB’s Privacy Act regulations 

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

7.3 How does the project notify individuals about the procedures 

for correcting their information?

This PIA provides notice to individuals on how to correct information. Additionally, the SORN 

for MSPB – 2, Surveys for Special Studies of the Civil Service, 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 incorrect information 

that has been collected about them.

Mitigation: The risk is partially mitigated. The purpose of MSPB’s special studies surveys is to 

produce statistical analyses and reports irrespective of the identities of survey respondents. 

MSPB collects a sufficient amount of responses during survey administration to ensure that one 

participant’s erroneous information will not adversely affect the statistics and analyses generated 

from its research, or have any adverse or operational impacts on the participant. Because survey 

responses are collected directly from participants, responses are dependent upon the accuracy of 

the information provided by each participant.

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: This privacy risk is mitigated in several ways. 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.
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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 surveys using Qualtrics. 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 (PTA) or a PIA. MSPB’s Privacy Officer tracks and accounts for all survey 

research efforts by MSPB offices or programs through the PTA and PIA process. Additionally, 

MSPB has entered into an MOU with OPM that provides parameters for MSPB’s use of the 

EHRI data from OPM.

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 training when they onboard or begin working on an MSPB contract, respectively, and annually thereafter. MSPB’s

Privacy Officer logs all information management 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.

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 surveys in Qualtrics. This includes MSPB employees who are involved in the development 

and administering of the surveys.

MSPB deploys role-based access controls and enforces a separation of duties throughout all 

MSPB operations to limit access to only those persons who have a need to know in order to 

perform their duties. This need to know is determined by the respective responsibilities of the 

employee.
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8.4 How does the project review and approve information sharing 

agreements, MOUs, new uses of the information, new access to

the system by organizations within MSPB and outside?

Data provided to MSPB from OPM’s EHRI data warehouse under an MOU is retained until no 

longer needed or when OPM instructs MSPB to destroy data.

Responsible Officials

D. Fon Muttamara

Chief Privacy Officer

Merit Systems Protection Board

Approval Signature

William Spencer

Acting Executive Director

Senior Agency Official for Privacy

Merit Systems Protection Board