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Privacy Impact Assessment

FMCS Conference System

September 20, 2022

Contact

Greg Goldstein

Senior Agency Official for Privacy

Federal Mediation & Conciliation Service

250 E Street SW

Washington, D.C. 20427

Privacy@fmcs.gov
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Abstract

The E-Government Act of 2002, Section 208, and subsequent guidance from the Office of Management 

and Budget (OMB) establishes the requirement for agencies to conduct privacy impact assessments 

(PIAs) for electronic information systems and collections. The Privacy Act of 1974 articulates concepts 

for how the federal government should treat individuals and their information and imposes duties upon 

federal agencies regarding the collection, use, dissemination, and maintenance of personally identifiable 

information (PII).

The assessment is a practical method for evaluating privacy in information systems and collections and 

ensures privacy issues have been identified and adequately addressed. The process is designed to guide 

FMCS system owners and developers in assessing privacy during the early stages of development and 

throughout the System Development Life Cycle (SDLC) to determine how the system will affect the 

privacy of individuals and the extent to which project objectives can be met while also protecting 

privacy. The PIA ensures compliance with laws and regulations governing privacy and demonstrates the 

FMCS’s commitment to protect the privacy of any personal information the Agency collects, stores, 

retrieves, uses, and shares.

Overview

The Chief Learning Officer and the Conflict Management Prevention (CMP)/International Office uses the 

Conference System to collect, develop, and maintain conference attendee and participation information 

in connection with FMCS conferences. The FMCS hosts, co-hosts, sponsors, or co-sponsors conferences 

designed to meet the real-world challenges of labor management relations, conflict resolution, 

mediation, and arbitration. The FMCS uses additional vendors to register attendees and participants 

and to promote conferences. FMCS uses GovDelivery Communications Cloud to promote conference

and Cvent Conference Solutions (Cvent) to register attendees and participants for conferences. 

Section 1. Characterization of the Information

1.1 What information is collected, used, disseminated, created, or maintained in the system? 

Are the types of information collected, used, maintained, and /or shared specified in its 

privacy notices?

The FMCS collects basic information pertaining to individuals requesting to register for conference

or conferences sponsored by the Agency. This information includes:

• List of conference programs, including event location, time, date, conference programs, and

agendas;

• Information pertaining to registration, including names, registration fees, conference

description, and professional affiliation;

• Attendee’s information or participant information, including first name, last name, email

address, title, office, employer/organization, address, room #/ mail code, city, state, zip/postal

code, country, and telephone and fax number; and

• Information concerning the basis for and supporting documentation regarding the conference.

Yes, the information collected, used, maintained and/or shared in the system are specified in its

privacy notices.
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PII Mapping Components

FMCS Conference System consists of FMCS-00012 key components. Each component has been analyzed 

to determine if any elements of that component collect PII. The type of PII collected by FMCS 

Conference system, FMCS-00012, and the functions that collect it are mapped below. 

PII Mapped to Components

Components

Does this 

function 

collect or 

store PII 

(Yes/No)

Type of PII Reason for Collection 

 of PII Safeguards

The mapping of PII to

components assist by

linking of information type

with non-PII or other

specific information to

identify an individual or 

entity. Participant contact 

information is captured by 

the Conference system. 

Yes

• Full names

• Email

addresses

• Title

• Office

• Employer/Orga

nization

• Full addresses

• Telephone and

fax numbers

The purpose of

collecting information 

is to process and

maintain a 

participant's or 

attendee's basic 

contact information for 

FMCS conferences. To 

coordinate delivering 

conference services, 

materials, and updates. 

The basic information 

is used to determine 

the participant’s or 

geographical location 

and to allocate Agency 

resources and have 

adequate preparation 

for the conference. 

On FMCS premises,

there is a NetApp 

Network attached 

Windows File System 

shared folder with 

permissions set to only 

allow those with 

designated access by 

membership thru a 

Windows Azure group 

membership. Group 

access and 

modification is 

controlled by IT which 

uses a privileged 

administrator account. 

Array is physically 

located in a locked 

computer room with 

limited badge access. 

Cvent and GovDelivery 

are remote hosted 

subscription systems 

accessed by 

username/password 

maintained by the host 

company and created 

by the user of the 

systems. FMCS 

administrators 

maintain 

accounts/access and 

content for the hosted 

spaces. Cvent and 
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GovDelivery are both 

FedRAMP authorized 

vendors and use 

government accepted 

procedures for keeping 

data safe.

1.2 What are the sources of the information in the system?

The sources of information generated or collected are from individuals requesting to register for or 

participate in an event sponsored by FMCS. The sources of information include attendees, speakers, 

exhibitors, officials, education professionals, FMCS employees, and guests. 

1.3 How is the information collected?

The information is primarily collected via website from individuals requesting to register for an 

event sponsored by FMCS.

1.4 What is the purpose of the information being collected, used, disseminated, created, or 

maintained?

The purpose of the information is for FMCS to collect, process, and maintain participants’ or 

attendees’ basic contact information for FMCS conferences. The basic information is required to 

determine the participants’ or attendee’s regions or geographical locations and to have adequate 

preparation for the conference. This information is also used to assess the best allocation of FMCS 

resources.

1.5 How will this information be checked for accuracy?

The accuracy is ensured by collecting the information from the source who must attest to the 

truthfulness of the information provided, including any supporting documentation to support the 

registration of the program.

1.6 What specific legal authorities, arrangements, and agreements defined the collection of 

information?

The FMCS is authorized to collect information under the following statutes: 29 U.S.C. 172; 29 U.S.C. 

173 (e); and 29 C.F.R. 1403.

1.7 PRIVACY IMPACT ASSESSMENT: Characterization of the information

Principle of Purpose Specification: The FMCS conference records should mainly address the 

authority which permits the collection of PII and specifically articulate the purpose for which 

records, or data is intended to be used for.

Principle of Minimization: FMCS limits collection of personal information to what is directly relevant

and necessary to accomplish its specified purposes and only retain PII for as long as necessary to 

fulfil its specified purposes. PII should be disposed of in accordance with FMCS disposition schedules 

as approved by the National Archives and Records Administration (NARA).
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Principle of Individual Participation: FMCS protects personal data by adequate and reasonable 

security safeguards against such risks as loss or unauthorized access to data or information. FMCS

also seeks individual consent for the collection, use, dissemination, and maintenance of PII.

Principle of Data Quality and Integrity: FMCS ensures the data or information collected is reliable 

and accurate i.e., the data is complete, consistent, and used for its intended purposes.

Risk Assessment: The main privacy concern is identifying potential activity that may negatively 

impact individual’s contact information presented.

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 mitigated. FMCS will only collect information regarding the Conference 

Records System to process the conference attendee and participants' registration, to manage 

conference programs, and to collect information on FMCS’s operations, which provides for a 

minimal collection of PII. Additionally, FMCS provides the statutory protections afforded under the 

Privacy Act, along with the privacy tenets in the Fair Information Practice Principles and strives to 

only collect personal information that is necessary to accomplish FMCS’s mission.

Section 2. Uses of the Information

2.1 Describe how the information in the system will be used in support of the program’s 

business purpose?

The information shared in the system is used to process conference attendee’s and participant 

registration. The information is used to promote the use of mediation, conflict resolution, and labor 

relations management in accordance with FMCS’s mission through FMCS’s participation in the 

conference. These conferences educate and train members of the public and private sectors. The 

other functions of this system include schedule setting, RSVP/Decline status, and outgoing messages 

from FMCS to attendees.

2.2 What types of tools are used to analyze data and what type of data may be produced?

The GovDelivery is a web-based email subscription application, provided by Granicus, that allows 

members of the public to subscribe to receive information from FMCS via email for various

conferences or educational opportunities. Also, Cvent, an on-line registration system, can handle 

conference registration, speaker information, and allow attendees to register online for any FMCS 

conferences.

2.3 PRIVACY IMPACT ASSESSMENT: Use of the information

How is access to the PII determined? Access is determined by need to know in order to complete 

their required tasks.

Are there procedures, criteria, controls, and responsibilities regarding the access documented? All 

conference records are stored on CVENT registration servers, which are FEDRAMP/FISMA compliant. 

Access to external systems is documented through host provider files and limited to individuals with 

need-to-know.
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Does access require manager’s approval? Yes, all access requires Conference leaderships’ approval 

(usually the Chief Learning Officer or Manager of the Conflict Management Prevention 

(CMP)/International Office but could be other managers).

Is access to the PII being monitored, tracked, or recorded? All access to cloud hosted services is 

monitored and audited and can be accessed on request.

Who is responsible for the assuring of the safeguard for the PII? Cloud providers provide servicelevel agreements (SLAs) for safeguarding data. The owners of the data should be the ones 

responsible for safeguarding it.

Principle of Transparency: FMCS should be transparent in the use of individual data as stated or 

described in the SORN and PIA.

Principle of Use of Limitation: FMCS uses PII collected solely for the purposes specified.

Risk Assessment: It is the identification of threat sources, vulnerability of the system, and 

determination of the likelihood of occurrence of an event or activity amounting to risk.

Privacy Risk: There is a possible risk of misusing or mishandling collected information. 

Mitigation: To mitigate this risk, only authorized users with account logins are allowed to access the 

records.

Section 3. Retention of Information

3.1 What information is being retained?

FMCS retains all information previously listed in section 1.1.

3.2 How long is information retained?

All records are retained and disposed of in accordance with General Records Schedule 6.4, issued by 

NARA and FMCS. Records are destroyed when three years old or when they are no longer needed 

for business use.

3.3 Has the retention schedule been approved by the FMCS Records Office and the National 

Archives and Records Administration (NARA)? If so, please indicate the name of the records 

retention schedule?

The retention schedule has been approved by the FMCS Records Office and NARA. The name of the 

records retention schedule is Public Affairs Records.

3.4 What are the procedures for the elimination of Serial Peripheral Interface (SPI)?

The procedure for the elimination of SPI is adopting a common serial port with TX and RX lines called 

“Asynchronous.” Asynchronous serial connections add extra start and stop bits to each byte which 

help the receiver sync up to data as it arrives.

3.5 Does the system, where feasible, use techniques to minimize the risk to privacy of using 

PII for research, testing, or training?
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The system is well designed to minimize the risk to privacy of using PII for research, testing, or 

training by adopting a protective and preventive mechanism to deprive unauthorized users of using 

PII by deploying Cloud-based services known as GovDelivery and Cvent and on premises there is a 

NetApp network attached Windows file system shared folder with permissions set to only allow 

those with designated access.

3.6 PRIVACY IMPACT ASSESSMENT: Retention of Information

Principle of Minimization: FMCS should only collect PII that is directly relevant and necessary to 

accomplish the specified purposes and only retain PII for as long as necessary to fulfill the specified 

purposes. PII should be disposed of in accordance with FMCS records disposition schedules as 

approved by NARA.

Principle of Data Quality and Integrity: FMCS should, to the extent practical, ensure that PII is 

accurate, relevant, timely, and complete within the context of each use of the PII.

Risk Assessment: The systematic way of evaluating the potential risk that is associated with the 

retention of records for individuals stemming from the processing of their data.

Privacy Risk: There is a possibility of retaining more information than necessary and retaining 

information longer than necessary.

Mitigation: FMCS applies NARA-approved records retention schedules to the information collected. 

Once the records meet the destruction date designated in GRS 6.4, FMCS will destroy the records 

upon three years or when they are no longer needed for business use.

Section 4. Internal Sharing/Receiving/Transmitting and Disclosure.

4.1 Which internal organizations is information shared or received? What information is 

shared or received, and for what purpose? How is the information transmitted or disclosed?

The internal organization which information is shared or received are the Chief Learning Officer and 

CMP/International.

The information FMCS shares or receives is listed in Section 1.1. The purpose for the collection of 

information is for collecting, processing, and maintaining participant's or attendee's basic contact 

information for FMCS conferences. The basic information is required to determine the participant’s 

or attendee’s region or geographical location and to have adequate preparation for the conference. 

This information is used to assess the best allocation of FMCS resources and to perform the task.

4.2 PRIVACY IMPACT ASSESSMENT: Internal sharing and disclosure

There are various risks associated with the sharing of information within FMCS such as information 

security risks, compliance risks, and regulatory risks. The information security risk leads to data 

leakages and unwanted or unauthorized personnel having access to information. The compliance 

risk leads to failure to comply with laws, regulations, and standards. The regulatory risk leads to new 

regulations that threaten FMCS’s business model.

What steps, if any, are currently being taken to mitigate those identified risks? On FMCS premises,

there is a NetApp Network attached Windows File system shared folder with permissions set to only 

allow those with designated access by membership thru a Windows Azure group membership. 
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Group access and modification is controlled by IT which uses a privileged administrator account. 

Array is physically located in a locked computer room with limited badge access. 

The information is transmitted or shared through FMCS’s internal servers with restricted access to 

only authorized personnel and designated officials as determined by agency officials. 

Risk Assessment: This assists FMCS to analyze and assess the privacy risks for individuals arising from 

the processing of their data.

Privacy Risk: There is a risk of sharing information with individuals without a valid need-to-know.

Mitigation: The centralization of data using a NetApp Network has mitigated most of the risks 

associated with the inadvertent release of information. The most viable strategies are by deploying 

data encryption and strong and unique password for assessing of data in the system.

Section 5. External Sharing/Receiving and Disclosure

5.1 With which external organizations (outside FMCS) is information shared/received? What 

information is shared/received, and for what purpose? How is the information transmitted 

and what measures are taken to ensure it is secure?

In addition to those disclosures generally permitted under 5 U.S.C 55a(b) of the Privacy Act, all or a 

portion of the records or information contained in this system may be disclosed to authorized 

entities, as determined to be relevant and necessary, outside the FMCS as a routine use pursuant to 

5 U.S.C552a(b)(3). The information FMCS receives/shares is listed in section 1.1. The Conference 

System is used for collecting, processing, and maintaining participant’s or attendee’s basic contact 

information for FMCS conferences. The basic information is required to determine the participant’s 

or attendee’s region or geographical location and to have adequate preparation for the conference. 

The information is also used to assess the best allocation of FMCS resources. The system gives a 

detailed structure of the conference, including the conference program, keynote sessions, list of 

invited speakers with their background information, timetables for the conference meetings, venues 

of the conference, conference sponsors, and conference fees.

Registration records are held by CVENT on their hosted (FISMA/FedRAMP compliant) servers. FMCS

then collects the information and download it to internal FMCS servers for reporting/conference use 

purposes. At all times, proper authentication via username/password is required for accessing the 

data, both internally and on hosted servers. Conference records are maintained in electronic form 

and only accessible to authorized personnel. 

Is sharing the information outside the agency compatible with the original collection? If so, is it 

covered by an appropriate routine use in a SORN? If not, please describe under what legal mechanism 

the IT system is allowed to share the information in identifiable form or personally identifiable 

information outside of FMCS.

Yes, it is compatible with the original collection. It is also covered by an appropriate routine use in 

the SORN under 5 U.S.C 552a(b)(3) of the Privacy Act.

Describe how information is transmitted to entities external to FMCS and what security measures 

have been taken to protect it during transmission.

GovDelivery is a web-based email subscription management application, powered by Granicus, that 

allow members of the public to subscribe to get information from FMCS via email. Cvent is an on-
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line registration system which can handle conference registration, speaker information, and allow 

attendees to register online for FMCS conferences. Cvent and GovDelivery are remote hosted 

subscription systems accessed by username/password maintained by the host company and created 

by the user of the systems. FMCS administrators maintain accounts/access and content for the 

hosted spaces. Cvent and GovDelivery are both FedRAMP authorized vendors and use government 

accepted procedures for keeping data safe. 

The transmission of information or electronic records to external entities occurs through a web 

browser to the internet or from one of FMCS’s hosted platforms. The information is transmitted 

securely using an encrypted protocol which require strong authentication for access.

External Sharing/Receiving and Disclosure

Program Office or IT 

System information is 

shared/received with

Reason why 

information is 

shared/received 

with the specified 

program or IT 

System

List the specific 

information types 

that are 

shared/received 

with the Program 

or IT System

List all legal authority, 

binding agreement, 

SORN routine use, etc. 

that permit external 

sharing

Method of 

transmission and 

measures in place to 

secure data

Pursuant to the Privacy 

Act, all or a portion of 

the Conference System 

or information may be 

disclosed to authorized 

entities, as is 

determined to be 

relevant and necessary. 

The information 

shared within the IT 

system is used to 

process and 

maintain records of 

individuals who 

participate in FMCS 

programs or 

activities who 

register for 

conferences or 

conferences 

sponsored by FMCS. 

Generally, 

conference 

records or 

information is not 

shared externally 

unless generally 

permitted under 5 

U.S.C. 552a(b) of 

the Privacy Act or 

as a routine use 

pursuant to 5 

U.S.C. 552a(b)(3).

29 U.S.C. 172; 29 U.S.C. 

173 (e); and 29 C.F.R. 

1403

Records are stored 

electronically on 

FMCS’s internal servers

with restricted access

to only authorized 

personnel and 

designated officials as 

determined by agency 

officials. 

5.2 PRIVACY IMPACT ASSESSMENT: External Sharing/ Receiving and Disclosure

Risk Assessment: It is the identification of threat sources, vulnerabilities of the system, and 

determination of the likelihood of occurrence of activities that can impact FMCS.

Privacy Risk: There is a significant risk in sharing information outside the scope of the Conference 

SORN or without the authorized permission for disclosures. It can lead to violation of civil or 

criminal laws or regulations.

Mitigation: The risk is mitigated by ensuring information is only accessible by authorized personnel.

Electronic records are stored on FMCS’s internal servers with restricted access to authorized 

personnel and designated officials as determined by agency policy.

Section 6. Notice
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6.1 Was notice provided to the individual before collection of the information? If yes, please 

provide a copy of the notice as an appendix. (A notice may include a posted privacy policy, a 

Privacy Act notice on forms, or a system of records notice published in the Federal Register.) 

If notice was not provided, why not?

Yes, there are Privacy Act Statements on forms and a system of records notice was published in the 

Federal Register. The system of records notice can be found here. The Privacy Act notice on forms 

can be found here.

6.2 Do individuals have the opportunity and right to decline to provide information? If so, is a 

penalty or denial of service attached?

Yes, individuals do have the opportunity or right to decline to provide information. Failure to 

provide the requested information could result in FMCS’s delay or inability to provide services. To 

receive conference programs or registration confirmations, individuals must provide basic 

information.

6.3 Do individuals have the right to consent to particular uses of the information? If so, how 

does the individual exercise the right?

Yes, as captured in the Privacy Act Statement on the form, individuals consent to the use of the 

information in accordance with the Conference SORN and as needed to receive notifications on the 

programs and conferences from FMCS.

6.4 PRIVACY IMPACT ASSESSMENT: Notice

Principle of Transparency: FMCS provides notice to individuals regarding its collection, use,

dissemination, and maintenance of PII or their conference records. The systems processing 

conference records and PII must be described in the Conference SORN.

Principle of Use Limitation: FMCS should not use or disclose personal information for purposes other 

than those which it has identified.

Risk Assessment: The identification of threat sources, vulnerabilities of the system, and 

determination of the likelihood of occurrence of activities and determining the impact of such risk to 

FMCS.

Privacy Risk: There is the risk that individuals will not be given appropriate notice prior to collection 

of their information.

Mitigation: This risk is mitigated since the system provides notice at the onset of the collection 

process regarding the purpose of the collection, the routine uses of the disclosure of information, 

and the consequences for a failure to provide the information. This risk is also mitigated since the 

notice of the collection of information is provided through the PIA available on the public facing 

website, the Privacy Act Statement on forms, and the systems of records notice in the Federal 

Register for the Conference SORN.

Section 7. Access, Redress, and Correction

7.1 What are the procedures that allow individuals to gain access to their information?
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Attendees and participants may access the GovDelivery system via links placed on client web pages 

or in system-generated emails. GovDelivery subscribers have access to their own personal data in 

the system. Cvent registrants may access their personal data through their registration confirmation 

or by contacting FMCS. Individuals must provide the following information for their records to be 

located and identified: (1) Full name, (2) Address, and (3) A reasonably identifying description of the 

record content requested. Requests can be submitted via fmcs.gov/foia/, via email to 

privacy@fmcs.gov, or via mail to FMCS, Privacy Office, 250 E Street, SW, Washington, DC 20427. 

Also, see 29 CFR 1410.3, Individual access requests, for more information.

7.2 What are the procedures for correcting inaccurate or erroneous information?

See 29 CFR 1410.6, Requests for correction or amendment of records, on how to contest the 

content of any records. Privacy Act requests to amend or correct records may be submitted to the 

Privacy Office at privacy@fmcs.gov or via mail to the Privacy Office at FMCS 250 E Street, SW 

Washington, D.C. 20427. Also, see https://www.fmcs.gov/privacy-policy/.

7.3 How are individuals notified of the procedures for correcting their information?

The PIA for Conference Records and the Conference SORN provides notice to individuals on how to 

correct their information.

7.4 If no formal redress is provided, what alternatives are available to the individual?

There is formal redress provided for the correction of inaccurate information.

7.5 PRIVACY IMPACT ASSESSMENT: Access, Redress, and Correction

Principle of Individual Participation: FMCS involves the individual in the process of using PII. FMCS 

seeks individual consent for the collection, use, dissemination, and maintenance of PII and provide 

mechanisms for appropriate access, correction, and redress regarding its use.

Risk Assessment: The identification of threat sources, vulnerabilities of the system, and 

determination of the likelihood of occurrence of activities and determining the impact of such risk to 

FMCS.

Privacy Risk: An individual may not be aware of the process for accessing and/or correcting 

information.

Mitigation: To mitigate the risk, FMCS has provided a PIA on our public facing website and provided 

a systems of records notice in the Federal Register so individuals are aware of the process for 

accessing and/or correcting information. 

Section 8. Technical Access and Security

8.1 What procedures are in place to determine which users may access the system, and are 

they documented? 

All users are granted access on a need-to-know basis as determined by Senior Leadership and Senior 

Conference Officials. This process is determined and documented by Senior Leadership.

8.2 Will FMCS contractors have access to the system and the PII? If yes, what involvement will 

contactors have with design and maintenance of the system? Has a contractor confidentiality 
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agreement or a Non-Disclosure Agreement (NDA) been developed for contractors who work 

on the system?

Yes, they will. All contractors accessing any of the systems associated with Conference records will 

have Non-Disclosure Agreements in place and will have gone through the security clearance process 

for a Public Trust clearance.

8.3 Describe what privacy training is provided to users either generally or specifically relevant 

to the program or system?

All FMCS users must undergo privacy awareness training and information security and awareness 

training before commencement of their job assignment. These trainings highlight the importance of 

securing FMCS information, PII, and information systems, identifies roles and responsibilities 

employees have when accessing agency systems, defines a privacy breach and how to report a 

breach, provide tips to avoid breaches in information security, provide the basics about the Privacy 

Act and describes Privacy Act resources available at FMCS. 

8.4 Has Authorization and Accreditation (A&A) been completed for the system?

Yes, for Microsoft Office 365 GCC5, Azure and eGovDelivery. Cvent is a FedRamp authorized 

product, so they meet federal security requirements, but we do not have an ATO with them beyond 

our procurement contract.