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iManage DOCUMENT MANAGEMENT SYSTEM 

PRIVACY IMPACT ASSESSMENT

Background: Rapid advancements in computer technology make it possible to store and retrieve 

vast amounts of data of all kinds quickly and efficiently. These advancements have raised 

concerns about the impact of large computerized information systems on the privacy of data 

subjects. Public concerns about highly integrated information systems operated by the 

government make it imperative to commit to a positive and aggressive approach to protecting 

individual privacy. We have instituted the Privacy Impact Assessment in order to ensure that the 

Federal Labor Relations Authority (FLRA) appropriately considers privacy issues from the 

earliest stages of design.

Purpose: The purpose of this Privacy Impact Assessment is to determine if your collection, 

maintenance, and use of data in this automated system will impact on the privacy rights of 

individuals. Depending on your answers, we may be required to seek additional details from 

you. Please direct questions to Noah Peters, 202- 218-7908 or npeters@fira.gov.

Authorities: 5 U.S.C. 552a, the Privacy Act of 1974, as implemented by OMB Circular A-130. 

PRIVACY IMPACT ASSESSMENT

Provide the commonly used name of the system, spelling out any acronyms. If the system 

will be referred to by acronym, include that in the parentheses after the name.

Document Management System (“DMS”)

Provide a generalized broad description of the system and its purpose (What does this 

system do; what function does it fulfill?)

A Document Management System is the computer system and software used to store, 

manage, and track electronic documents and electronic images of paper based 

information. For the DMS, the FLRA has procured the FileSite Document Management 

System by iManage. The DMS is the primary IT file system used by the FLRA to store 

documents in support of the Agency's mission. It supports the major administrative and 

mission functions of the Agency. The DMS is accessible from all permanent FLRA 

locations and approved remote connections. IRMD is the business owner for the DMS.

Information stored in the DMS is in a centralized off-site “cloud” location. Physical 

security, software and hardware updates of the “cloud” servers containing the DMS data 

is controlled by iManage. Access to the cloud site is limited to a secure VPN connection 

by employees on the FLRA network either locally or through the FLRA VPN. Staff and 

managers are responsible for proper storage, handling, and use of Agency data residing in
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individually assigned DMS storage spaces (“matters” and “folders”), as well as 

compliance with FLRA privacy policies and related records retention, litigation, ediscovery, and information security procedures.

Is the system in the development phase? 

No.

Is this system required by law or Executive Order? 

No.

1. Will/Does this system contain personal data elements? 

No (Go to Section VIII)

Yes X (Continue)

2. List those personal data elements or types of data elements that the system 

will/does contain:

The DMS does not collect data. The system stores and disseminates information 

in support of the Agency's mission. The DMS stores, and transmits a large volume 

of sensitive documents of many types, including both public and nonpublic PII. 

Sensitive PII may relate to specific parties, legal representatives, witnesses, FOIA 

requestors, FLRA employees, FLRA contractors, Personnel matters, HR 

documents, and others.

3. What are the sources of the personal information in the system? (Check all that 

apply):

X FLRA files or databases.

_X_ Non-FLRA files or databases. (List)

Unions and law firms representing an individual or group may provide the 

personal information.

 The record subject himself.

_ Supervisors

Other third party sources (List).

4. Are the personal data elements described in detail and itemized in a record layout 

or other document? If yes, provide the name of the document.

Currently, the FLRA does not maintain this information.

5 . Review the list of personal data elements that you currently collect. Is each data 

element essential to perform some official function? [Note: The questionpertains 

only to data elements that you specifically solicit. It does NOT apply to personal 

data that may be voluntarily provided in a "Remarks," "Comments,"
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"Explanation," or similar type of block where the individual is free to add 

information of his choosing.]

5a. Yes, all data elements solicited are absolutely essential. (Go to 

Section III).

5b. Some of the solicited data elements are nice to have but not essential.

x 5c. None of the personal data elements are necessary. The program could 

function effectively without personal data.

6. If you checked block 5b or 5c above, list the data elements that are not essential.

The DMS does not solicit or collect information. It stores information used by 

FLRA employees.

7. Do the users have an opportunity to decline to provide information or consent to 

particular uses of the information?

No. However they do have the option to remove any personal information before 

submitting, it is not required. Any documents sent to the FLRA by external users 

will be stored in the DMS. Internal users can bypass the DMS and store files 

locally, however, that process is discouraged as it is less secure and local files are 

not backed up.

1. For data collected from sources other than FLRA records and the record subject 

himself, describe how the data will be verified for - -

a. Accuracy:

FLRA personnel are responsible for the accuracy of the information they 

provide.

b. Completeness:

FLRA personnel are responsible for the completeness of the information 

they store in the system.

c. Relevance:

FLRA personnel are responsible for storing relevant data.

2. Describe your procedures for determining if data have been tampered with by 

unauthorized persons. (Note: Do not go into so much detail as to compromise
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system security).

One of the features of the DMS is the addition of more robust auditing details on a 

file. Any time a file is accessed in the DMS the user and time of that access are 

tracked in the systems audit fields. Additionally, the duration that a user checked 

out a file is also contained in the audit fields.

The DMS data resides on the iManage servers. iManage controls prevent nonauthorized users from accessing data.

1. Who will have access to the data in the system (Users, Managers, System 

Administrators, Developers, Others?)

All of the above could have access to the data in DMS. Access is granted on a 

need-to-know basis. Users’ access is managed through Active Directory after the 

users have logged onto the FLRA network.

2. Are criteria, procedures, control s, and responsibilities regarding access 

documented?

No.

3. Do other systems share data or have access to data in this system? 

No X

Yes (Explain).

4. Will other non-FLRA agencies share data or have direct access to data in this 

system (International, Federal, State, Local, Other)?

No _X_(Go to Question IV-9).

Yes (List each agency by name or type (e.g., law enforcement activities; Social 

Security Administration, etc.) and briefly provide the purpose of the 

access.

5. How will the system ensure that agencies get only the information they need to 

fulfill their official function?

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

system is being/was designed?

No x (Explain)
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The DMS stores files that would otherwise be on the agency’s network 

share. The system does not collect personal information. It stores 

documents that may contain personal information.

Yes 

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

individual through a data aggregation process?

No X (Go to Section VI). 

Yes (Continue)

2a. Will the new data be placed in the individual's employment or other type of 

record (whether manual or electronic) that is retrieved by name, SSN, or 

other personal identifier?

No 

Yes (Identify the record, database, or type of record or database). 

Not Applicable X

2b. Can the system make determinations about individuals or employees that 

would not be possible without the new data?

No –

Yes (Explain)

Not Applicable X

2c. Will the data be retrieved by personal identifier (name, SSN, employee 

number, computer ID number, etc.) ?

No (Go to Section VI.) 

Yes (List retrieval fields.) 

Not Applicable X

1. Is the system using technologies in ways that the FLRA has not previously 

employed (e.g., Caller-ID, surveillance, etc.)?

No (Continue)

Yes X (Identify the technology and describe how these technologies affect 

individual privacy.)

The iManage DMS that the FLRA will be using is a “Cloud” based system that 

allows the FLRA to store, retrieve, and search documents more efficiently than 

the previous FLRA file share that the DMS replaces. Additionally, the DMS will 

facilitate the FLRA’s transition to an electronic (paperless) case file.
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The risk to privacy that the DMS creates is that a document stored in the system 

could contain sensitive personal information and the system is located outside of 

the FLRA network on the “Cloud”. That risk is mitigated by restricting access to 

the document to authorized users. Additionally, the iManage DMS system’s 

“Cloud” architecture provides more robust security than the local FLRA file share 

that the DMS is replacing. All users of the system are required to login with a 

user name and password, consistent with NIST guidelines and all electronic traffic 

is encrypted between the user's personal computer and the DMS servers using 

SSL.

2. What controls will be used to prevent unauthorized monitoring? (Note: Do not 

describe your controls and procedures in so much detail as to compromise system 

security.)

Access to the system is based on the rights and privileges established by the 

system owner and operations management. Authentication and access control is 

also supported by the operating system.

1. Does this system currently operate under an existing FLRA or Government- wide 

Privacy Act system of records?

No X (Go to Section VIII.) 

Yes (Continue.)

2. Provide the identifying number and name of each system.

3. If an existing FLRA Privacy Act system of records is being modified, will the 

system notice require amendment or alterati on? (List all proposed changes. 

Consider the following: Will you be collecting new data elements not previously 

approved for collection; using the data for new internal procedures; sharing the 

data with new non-FLRA agencies; keeping the records longer; creating new 

locations of data, etc.?)

No

Yes (Explain your changes.) 

Not Applicable X

4. If the system currently operates under an existing Government-wide Privacy Act 

system of records notice, are your proposed modifications in agreement with the 

existing notice?

No (Explain your changes and continue.)
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Yes (Go to Section VIII.) 

Not Applicable X 

5. If you answered "no" to VII-4 above, have you consulted with the goven1ment

agency that "owns" the government-wide system to determine if they approve of

your modifications and intend to amend or alter the existing notice to

accommodate your needs?

No --

Yes (provide the name and telephone number of the official with responsibility

for the government-wide system.)

Not Applicable _x

Certification: I have read and understand the purpose of this assessment. I have also accurately 

listed the personal data elements collected or accurately answered "no" to Question II-1.

Name: Noah Peters

Title: Solicitor and Senior Agency Official for Privacy

Email address: npeters@flra.gov

Telephone Number: (202) 218-7908

Signature:__________________ Date: 

Name: David Fontaine 

Title: Chief Information Officer 

Email Address: dfontaine@flra.gov

Telephone Number: (202) 218-7778

Signature:___________________ Date: