1

FLRA eFILING 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

Section I. Nature of the System:

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.

Federal Labor Relations eFiling System

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

system do; what function does it fulfill?)

The FLRA eFiling System is a web based software application that allows external 

parties to file cases electronically with the FLRA. In addition to the eFiling application 

the FLRA also accepts cases through other means (ex. Fax, Mail, Personal Delivery, 

etc.). The eFiling application was created to allow users greater flexibility in filing 

cases, streamline the case filing process, and to assist the FLRA in moving away from 

paper files and, ultimately, to an all-electronic case file.

Data is stored in the eFiling application in a Postgres database on a Amazon Web 

Services (AWS) instance.

Using Ruby on Rails and Quick Base APIs, data is transferred from the eFiling 

application to the Case Management application which is currently a Quick Base system
2

with data residing in off-site Quick Base ‘cloud’ servers. The agency is currently 

working to move all of the case management components from Quick Base to a standard 

Ruby on Rails and Postgres solution with all data being stored on Amazon Web Services 

(AWS) servers.

Information stored in the eFiling system is in a centralized off-site “cloud” location. 

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

eFiling data is controlled by Amazon Web Services. FLRA employees are granted 

access to the data on a need to know basis. External parties involved in filing cases with 

the agency have access to their filings and their user profile data.

Is the system in the development phase? 

No.

Is this system required by law or Executive Order? 

No.

Section II. Data in the System:

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 thesystem 

will/does contain:

Users enter personal data to create and profile and additional case specific data 

when filing a case. Data elements include:

• Name

• Address

• Phone Number

• eMail Address

• Agency and/or Union involved in the filing

• Case Type

• Case Details

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

apply):

 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.

 x The record subject himself.
3

 _ Supervisors

Other third party sources (List).

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

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," 

"Explanation," or similar type of block where the individual is free to add 

information of his choosing.]

x 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.

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. 

N/A.

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

particular uses of the information?

N/A.

Section III. Verifying Data.

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:

Parties filing cases are responsible for the accuracy of the information they 

provide. Additionally, the software does make some checks for correct 

formatting of email address, phone number, etc. Users also have the ability to 

enter the email address of a party and, if found, the relevant information for that 

party will auto populate on the form.

b. Completeness:
4

Parties are responsible for submitting complete filings. The software does check 

that required fields are populated and in the correct format. Users are unable to 

continue if they have not entered complete information.

c. Relevance:

Parties select the type of filing they wish to complete and the software controls 

the fields the user must enter. In this manner, only relevant data fields are 

presented to the user for data entry.

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 

system security).

The data resides on the AWS servers. AWS controls prevent non-authorized users 

from accessing data. Additionally, audit fields show additional information on 

when and by whom data was changed.

Section IV. Access to the 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 the FLRA eFiling system. 

Access is granted on a need-to-know basis and requires that users enter their 

account credentials in order to access the system.

2. Are criteria, procedures, controls, and responsibilities regarding access 

documented?

No.

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

No

Yes X (Explain).

After validating a file as correct, it is approved by an FLRA employee and moved 

to the FLRA case management system for further process. Data in the Case 

Management System is stored separately in a Quick Base instance. The FLRA is 

currently working towards moving away from Quick Base and storing all data in a 

Postgres database on AWS.

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

system (International, Federal, State, Local, Other)?
5

No (Go to Question IV-9).

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

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

access.

Potentially, any agency subject to the Federal Service Labor-Management 

Relations Statute, 5 U.S.C. § § 7101 et seq. will share data or have direct accessto 

data in this system. They will need access to the information in order to 

participate in cases brought before the Authority, the Office of the General 

Counsel, and the Federal Service Impasses Panel.

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

fulfill their official function?

The system does not have any automated measures to ensure that the agency is 

sent only the information needed to fulfill its official function. This function is 

performed through policies and staff.

Section V. Attributes of the Personal Data

1. Is the use of the personal data both relevant and necessary to the purposefor 

which the system is being/was designed?

No (Explain) 

Yes x

2. Will the system derive new data or create previouslyunavailable 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
6

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-',

Section VI. Maintenance and Administrative Controls.

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

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

No x (Continue)

Yes (Identify the technology and describe how these technologiesaffect 

individual privacy.)

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.

Section VII. Interface with Privacy Act Systems of Records.

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 alteration? (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
7

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.) Yes X (Go to Section VIII.)

Not Applicable

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

government 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

Section VIII. Certification

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: ___________