EXECUTIVE SUMMARY REPORT
INTRODUCTION TO THE PIA
Purpose
The assessment was performed to ensure Veterans' Employment and Training
Services' compliance with the Privacy Act of 1974 and other legislation
requirements. The guidelines include E-Government Act of 2002, Office of
Management and Budget (OMB) Circular A-130, the Management of Federal
Information Resources and Circular A-11. As mandated by the Department each
agency must assess their policies and systems against the Privacy Impact
Methodology developed by the Department.
Scope
System Name: USERRA IMS (DOL-VETS-OAMB-M-001)
System Title: Uniformed Services' Employment and Reemployment Rights Act
(USERRA) Information Management System (IMS).
System Owner: Veterans Employment and Training Services
The USERRA IMS is operational and has held production status since
October 1, 1996. The system recently under went a software change and is now
using Cold Fusion. The system is routinely evaluated to determine what upgrades
or service pak (s) may be needed.
General Description
The purpose of the USERRA IMS is to establish an effective automated
process of collecting, consolidating, and reporting USERRA data submitted by
Veterans' Employment and Training Service (VETS) staff. The system provides the
capability to interactively accept and manipulate data, then perform a roll up
of information through Regional Offices to the Regional Lead Center (RLC). The
USERRA IMS replaces existing software applications used to support the USERRA
program and includes enhanced output capabilities, new administrative services,
and additional functionality not previously available through existing VETS
information management systems.
The USERRA module supports interactive input and update of current
USERRA case data. Data is maintained in such a way that the baseline data
entered can be manipulated to provide both standard reports and flexible
spreadsheet data exports for use in assisting in the analysis of USERRA
operations and outcomes. The system is accessible through the Department of
Labor (DOL) Employees' Communications Network (ECN); however, it resides and is
hosted at the National Veterans' Training Institute (NVTI). It provides
information for use at several organizational and administrative levels,
including: VETS field staff doing investigations, VETS supervisors and
managers, VETS executive staff, and Congress. Data collected does not only
include information on cases opened by investigators, but also provides output
to support specified information requirements on other activities essential to
the USERRA program, such as outreach actions, employer contacts and technical
assistance responses.
System Interconnection/Information Sharing
The USERRA IMS is a standalone application connected via a dedicated
connection to the Internet and using the TCP/IP protocol stack.
The USERRA system is an independent/standalone system and does not
depend on sharing data with any other systems.
The USERRA IMS is operational and has held production status since
October 1, 1996. The system is routinely evaluated to determine what upgrades
or service pak(s) may be needed.
General Description of Sensitivity
The USERRA IMS sensitivity is primarily focused on the confidentiality
of the case data, which has a high sensitivity. Certain categories of personal
information reflected in the USERRA IMS regarding individual claimants,
employers, and others involved in particular USERRA cases must remain
confidential under the Privacy Act.
Approach
VETS approached the PIA by first reviewing in detail the Privacy Act of
1974, E-Government Act of 2002, the Office of Management and Budget Circular
A-130 and the Management of Federal Information Resources and Circular A-11.
VETS then reviewed its current security documents and procedures and compared
them to the guidance provided in the above mentioned documents. VETS then went
through the PIA questionnaire answering the questions and determining risk.
Results
The results of the PIA are favorable. VETS has met the requirements
outlined in the above mentioned documents. VETS has in place the following
requirements:The Workload Management Systems contain personally identifying
information. Based on this assessment SOL has determined that the WMS have
adequate controls in place to meet minimal compliance with federal privacy
requirements and that all risks have been minimized.
- PARN posting
- Does not share PII with other sources
- VETS users are the only users of the data
Summary
VETS is compliant with the Privacy Impact Methodology Guidance provided
by the OCIO. VETS' USERRA Information System security and policies satisfy the
requirements outlined in the following documents:
- Privacy Act of 1974 and other legislation requirements.
- The guidelines include E-Government Act of 2002,
- Office of Management and Budget (OMB) Circular A-130
- Management of Federal Information Resources
- and Circular A-11
Because VETS has satisfied these requirements no mitigating actions are
required. Attached is the PIA Questionnaire that was used to determine if there
were any risks to public information associated with the data captured by
USERRA IMS.
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