EXECUTIVE SUMMARY REPORT
INTRODUCTION TO THE PIA
Purpose
This Privacy Impact Assessment (PIA) seeks to identify the essential
business operational components for the management of the Office of Federal
Contracts and Compliance Programs (OFCCP) enforcement programs (automated and
non-automated) and to ensure that the collection, storage, retrieval and
dissemination of personal identifiable information (PII) is protected and
complies with all privacy act laws. This identification of essential business
operational components and responsibilities primarily cover the Programs'
National Office, but will also have an impact/effect on its' Regional, District
and Area Office facilities.
Scope
This PIA covers the Employment Standards Administration's OFCCP
Information System (OFIS). This information provides mission-critical support
to the OFCCP's mandated mission and function(s), which are described below.
The Office of Federal Contract Compliance Programs (OFCCP) promotes
Federal contractors compliance with equal employment opportunity (EEO) and
affirmative action laws during the performance and subject to Federal contract
provisions. Through the authorities mentioned, OFCCP enforces
non-discrimination and equal opportunity standards for all individuals,
including women, minorities, Vietnam era veterans and persons with
disabilities.
- EXECUTIVE ORDER 11246, as amended, which prohibits discrimination in
employment on the basis of race, color, gender, religion, and national origin,
and requires Federal Government contractors to take affirmative action to
ensure that equal opportunity is provided in all aspects of employment;
- SECTION 503 OF THE REHABILITATION ACT OF 1973, as amended, which
prohibits discrimination in employment on the basis of disability and requires
Federal contractors to take affirmative action to employ and advance in
employment qualified individuals with disabilities; and
- SECTION 4212 OF THE VIETNAM ERA VETERANS' READJUSTMENT ASSISTANCE ACT
OF 1974, as amended, which prohibits employment discrimination and requires
Federal Government contractors to take affirmative action to employ and advance
in employment, qualified covered veterans.
The OFCCP also shares enforcement authority under Title 1 of the
Americans with Disabilities Act and the Immigration Reform and Control Act.
Monitoring Contract Compliance
The OFCCP monitors compliance with these equal employment opportunity
and affirmative action requirements primarily through compliance evaluations,
during which, a compliance officer examines the contractor's affirmative action
program and investigate virtually all aspects of employment. OFCCP also
investigates complaints filed by individuals alleging discrimination on the
basis of race, color, sex, religion, national origin, disability or cover
veteran's status.
Compliance Assistance
To help contractors understand their contractual obligations for EEO and
affirmative action, OFCCP provides technical assistance. Staff from district
offices offers guidance to contractors on how to develop affirmative action
programs and what to expect during a compliance evaluation. Compliance
assistance is provided through company seminars, training programs held in
conjunction with industry liaison groups, and one-on-one consultations.
Approach
The "Privacy Impact Assessment Questionnaire" defined in section 2 of
this document was used to evaluate the OFCCP's guidelines for the collection
and protection of personal and identifiable electronic data, and its'
compliance with current Privacy Act Laws. The OFCCP performed the analysis
according to policies and guidelines defined in the Department of Labor's PIA
Impact Methodology and Assessment.
Results
Based on the Privacy Impact Assessment Questionnaire, OFCCP states that
OFIS does collect personal identifiable information. The OFCCP has also
implemented the necessary business, audit and security controls to ensure that
PII is protected.
Summary
Information that is collected from individuals is used to conduct
investigations of alleged violations of the Order or Acts enforced by OFCCP.
The OFCCP protects an individual's right to privacy and supports the Privacy
Act, 5 U.S.C. 552a, and OMB Circular No. A-130, "Management of Federal
Information Resources," 61 Fed. Reg. 6428 (Feb. 20, 1996).
There are no adverse impacts on OFCCP's Federal Information System due
to PIA results. The detailed Privacy Impact Assessment Questionnaire in Section
2 provides details to substantiate OFCCP findings.
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