Audit of USAID’s Implementation of Key Components of a Privacy Program for Its Information Technology Systems

Recommendations

Recommendation 1

USAID's Assistant Administrator for Management send a written request to the Administrator that he designate a senior-level agency official for privacy with Agency-wide responsibility for information privacy issues, as required by Office of Management and Budget M-05-08.

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Recommendation 2

After final action is taken on Recommendation 1, USAID's Director, Human Resources, modify the written position description of the senior agency official for privacy to fully incorporate responsibility for privacy across the Agency.

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Recommendation 3

After final action is taken on Recommendation 1, the supervisor for the senior agency official for privacy modify the written work objectives for the senior agency official for privacy to fully incorporate accountability for privacy across the Agency.

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Recommendation 4

USAID's Chief Privacy Officer perform a written privacy threshold analysis for the Agency's Wellness Staff Care Web site, https://wellnessstaffcare.usaid.gov, and, based on the results of the analysis, prepare a written privacy impact assessment and written system of record notice, if required.

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Recommendation 5

USAID's Chief Information Security Officer prepare the following for the Agency's Wellness Staff Care Web site, https://wellnessstaffcare.usaid.gov:
-A documented review of the security package for the system.
-A documented review of the security risks if the Agency uses the system.
-A written authorization for the system to operate if the system meets security requirements, or if not, take action to discontinue use of the Web site and document its discontinuation.

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Recommendation 6

USAID's Chief Privacy Officer update the Privacy Office's Training Plan for Basic Privacy Training (September 1, 2013) to:
-Explain what action will be taken when individuals do not meet privacy training requirements.
-Require annual privacy refresher training.

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Recommendation 7

USAID's Chief Privacy Officer develop and implement written annual basic privacy training that covers the following privacy topics:
-The definition of personally identifiable information (PII).
-Applicable privacy laws, regulations, and policies.
-Restrictions on data collection, storage, and use of PII.
-Roles and responsibilities for using and protecting PII.
-Appropriate disposal of PII.
-Sanctions of a security or privacy incident involving PII.
-Roles and responsibilities in responding to PII-related incidents and reporting.
-How to respond to an incident, should one occur.
-Rules for teleworking.

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Recommendation 8

USAID's Chief Privacy Officer develop and implement documented role-based privacy training for the following employees: security staff, human resources staff, contracting officers' staff, financial officers' staff, chief information security office staff, and travel staff.

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Recommendation 9

USAID's Chief Privacy Officer update the Privacy Office's Role-Based Personally Identifiable Information (PII) Training Plan (November 1, 2013) to:
-Require role-based privacy training at least annually for employees in the identified roles who handle personally identifiable information.
-List the privacy topics that will be addressed for travel staff.

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Recommendation 10

USAID's Chief Privacy Officer document and implement a process to maintain records of employees who attend role-based privacy training, to include comparing those records to a list of employees that should receive the training.

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Recommendation 11

USAID's Chief Privacy Officer complete written system of record notices for the Web Time and Attendance System and End-to-End Travel System, and publish them in the Federal Register.

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Recommendation 12

USAID's Chief Privacy Officer develop and implement written procedures to review and update system of records notices on at least a biennial basis.

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Recommendation 13

USAID's Chief Privacy Officer finalize the written privacy impact assessments for Facebook (https://www.facebook.com/USAID), Twitter (https://twitter.com/#!/usaid), and Youtube (http://www.youtube.com/usaidvideo).

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Recommendation 14

USAID's Chief Privacy Officer update and finalize the written privacy impact assessment for Making All Voices Count, (http://www.makingallvoicescount.org) to explain the specific purpose of the Agency's use of the third-party Web site or application, whether and how the Agency will maintain personally identifiable information, and for how long, and what other privacy risks exist and how the Agency will mitigate those risks.

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Recommendation 15

USAID's Bureau for Legislative and Public Affairs, Strategic Adviser for Strategic Communications, post final privacy impact assessments on USAID's official external Web site for the following third-party Web sites and document the results:
-Facebook, https://ww.facebook.com/USAID
-GitHub, https://github.com/USAID
-Linkedin, http://www.linkedin.com/groups?gid=118430
-Making All Voices Count, http://www.makingallvoicescount.org/
-Twitter, https://twitter.com/#!/usaid
-Youtube, http://www.youtube.com/usaidvideo

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Recommendation 16

USAID's Chief Privacy Officer review the FLIKR Web site, http://www.flickr.com/people/usaid-indonesia, and make a written determination whether it may provide personally identifiable information to the Agency, and, based on that determination, prepare a privacy impact assessment, as appropriate.

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Recommendation 17

USAID's Bureau for Legislative and Public Affairs, Strategic Adviser for Strategic Communications, implement a written process to maintain an Agency-wide inventory of third-party Web sites that make personally identifiable information available to the Agency.

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Recommendation 18

USAID's Chief Privacy Officer make a written risk-based determination of the frequency that the data loss prevention tool and Pretty Good Privacy should be monitored, and based on that, implement appropriate corrective actions and document the results.

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Recommendation 19

USAID's Chief Privacy Officer revise its written plan to eliminate the unnecessary collection and use of Social Security numbers, to include time frames for reviewing and eliminating the unnecessary collection and use of partial and full Social Security numbers in Agency forms and systems

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Recommendation 20

After taking final action on Recommendation 19, USAID's Chief Privacy Officer implement its plan to eliminate the unnecessary collection and use of Social Security numbers and document the results.

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