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Privacy Impact Assessment Questionnaire

DOL — National Contact Center (DOL-NCC) — FY 2014

Overview

  • System Name: Department of Labor National Contact Center (DOL-NCC) system
  • Owner Agency: Office of Public Affairs Division of Enterprise Communications (OPA DEC)
  • The DOL-NCC System supports one Major Application (Siebel Customer Relationship Management) and all DOL-NCC operational applications associated with the three specific contact center sites in Chantilly, Virginia (VA), Barbourville, Kentucky, (KY), and Fort Worth, Texas (TX).
  • The DOL-NCC System supports the DOL objective to provide nationwide toll-free telephone, email assistance, and publication fulfillment to the public with questions about job loss, business closures, pay and leave, workplace safety and health, pension and health benefits, workplace injuries, and more. The DOL-NCC System provides workflow, data capture, telecommunication functionality, and reporting to the DOL.
  • Modules in the system support call, email, fulfillment, and text message handling - in addition to the recording of such transactions for quality control purposes.
  • The Information Owner (DOL) is responsible for direction and approval of all program specific operations and has provided the vendor with applicable information regarding information sensitivity, operational risks, and required security controls. The DOL-NCC System supports contracted services not associated with any DOL Network. The DOL-NCC System supports contracted employees at vendor operated facilities.
  • The PIA ensures the confidentiality, integrity, and availability of the information contained within the system. This assessment aims to determine what types of data are collected, stored, or shared and by its nature, whether that data will cause an invocation of the Privacy Act of 1974.

Introduction

The DOL-NCC System supports one Major Application (and multiple support application components) with operations based out of three specific contact center sites in Virginia (VA), Kentucky (KY), and Texas (TX).

The DOL-NCC System supports one Major Application (Siebel Customer Relationship Management) and all DOL-NCC operational applications associated with the three specific contact center sites in Chantilly, Virginia (VA), Barbourville, Kentucky, (KY), and Fort Worth, Texas (TX). The DOL-NCC System supports the DOL objective to provide nationwide toll-free telephone email assistance, and publication fulfillment to the public with questions about job loss, business closures, pay and leave, workplace safety and health, pension and health benefits, workplace injuries, and more. The DOL-NCC System provides workflow, data capture, telecommunication functionality, and reporting to the DOL.

Characterization of the Information

The following questions are intended to define the scope of the information requested and/or collected as well as reasons for its collection as part of the program, system, or technology being developed.

Specify whether the system collects personally identifiable information (PII) on DOL employees, other federal employees, contractors, members of the public (U.S. citizens), foreign citizens, or minor children. The system contains PII from Federal employees, Contractor staff, and members of the public, who contact the DOL-NCC with inquiries regarding labor and workplace related topics.

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

A customer's contact information (name, e-mail address and phone number) may be collected in the event that DOL-NCC operations personnel are unable to readily address a customer's inquiry or is directed to do so by program processes and procedures. DOL-NCC operations personnel will perform additional research and contact the customer back to fulfill the original inquiry or the customer's contact information is forwarded to the appropriate DOL Subject Matter Expert.

Mailing address data may be collected by the NCC System in order to send customers (per their request) additional information (i.e. forms, publications, referrals etc.).

What is the PII being collected, used, disseminated, or maintained?

  • First and/or Last Name
  • Business and/or Personal Phone Number
  • Business, Mailing, and/or Residential Address
  • Business and/or Personal E-mail Address

How is the PII collected?

PII is collected both over the phone and via email by DOL-NCC personnel and saved within the CRM application. Customers are also able to submit requests to the NCC via the DOL (DOL.gov) website.

In addition, all inbound calls to the DOL-NCC are recorded for quality monitoring and customer satisfaction assurance. The recorded content contains PII elements (based upon the nature of the conversation). The recordings are stored and available for 30 days (within a centralized/internal-only application with access granted to only authorized QA and management personnel).

How will the information be checked for accuracy?

PII is collected both over the phone and via email by DOL-NCC personnel and saved within the CRM application. When PII-related information is collected from a customer over the phone, the information is verbally repeated back to the customer, for verification that the collected information is considered to be accurate.

Customers are also able to email requests to the NCC via the DOL (DOL.gov) website. The only validation for accuracy in regards to an incoming email message is the source email address. There is an inherent risk that customers could provide inaccurate contact information within the context of an email message.

What specific legal authorities, arrangements, and/or agreements defined the collection of information?

Information requested is the minimum information necessary to provide resolution to the customer at their request, and was agreed upon with the DOL.

Privacy Impact Analysis

All PII captured as part of the DOL-NCC operating environment (i.e. CRM application, recorded calls) is saved for 30 days and purged thereafter. Exceptions to this requirement include captured OSHA and MSHA related information (requiring supporting documentation of fatalities and injuries, which is retained indefinitely.

Unauthorized Data Access (Confidentiality):

The data repository, which houses the collected information, is secured and access is tightly controlled. Only authorized system administrators and engineers have access to the data repository. The system housing the data repository is neither able to establish nor respond to any connections to/from external entities. All access attempts to the data repository are logged and monitored.

In addition, all inbound calls to the DOL-NCC are recorded for quality monitoring and customer satisfaction assurance. The recorded content contains PII elements (based upon the nature of the conversation). The recordings are stored and available for 30 days (within a centralized/internal-only application with access granted to only authorized QA and management personnel).

Data Integrity:

Restrictive account permissions control access to the data repository. DOL-NCC operations personnel accounts are not granted administrative access to the systems and software components which comprise the data repository. In addition, all data-entry actions are tracked. To ensure the integrity of data, security controls (within the CRM application components) are utilized to track and monitor all changes for data entered and modified within the repository.

Uses of the PII

The following questions are intended to clearly delineate the use of information and the accuracy of the data being used.

Describe all the uses of the PII

PII is collected to allow designated DOL-NCC personnel and DOL Subject Matter Experts follow-up with customers contacting the DOL-NCC.

PII is collected to provide an initial point of contact for notices to OSHA and MSHA for regulatory requirements.

PII is collected to allow requested materials (brochures, posters, etc.) to be sent to individuals / businesses requesting the materials.

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

A commercial off the-shelf (COTS) reporting application is used to generate automated reports, which are analyzed by DOL-NCC personnel. These reports do not contain PII elements and are used for metrics reporting and analytics.

Queries can be performed within the CRM software component.

Queries can be performed within the call recording application component.

Will the system derive new data, or create previously unavailable data, about an individual through aggregation of the collected information?

No. PII is purged from the CRM repository every 30 days. Exceptions to this requirement include captured OSHA and MSHA related information (requiring supporting documentation of fatalities and injuries, which is retained indefinitely). Each contact is treated as a new contact. New records are created for each contact.

If the system uses commercial or publicly available data, please explain why and how it is used.

The information provided to the customers is also available on DOL's website. It is approved by the DOL Subject Matter Experts according to the content lifecycle and then added into the CRM software component (knowledge base). This information is managed by DOL-NCC content personnel and follows the content lifecycle process.

Privacy Impact Analysis

As part of the DOL-NCC training curriculum, all DOL-NCC operations personnel receive instructions on how to handle PII data. CRM access restrictions limit access to PII data elements based upon job function.

Retention

The following questions are intended to outline how long information will be retained after the initial collection.

How long is information retained in the system?

All PII captured as part of the DOL-NCC operating environment (i.e. CRM application, recorded calls) is saved for 30 days and purged thereafter. Exceptions to this requirement include captured OSHA and MSHA related information (requiring supporting documentation of fatalities and injuries, which is retained indefinitely).

Has the retention schedule been approved by the DOL agency records officer and the National Archives and Records Administration (NARA)?

N/A

How is it determined that PII is no longer required?

DOL-NCC purges PII every 30 days with the exception of OSHA and MSHA related information (retained indefinitely due to regulations). This retention period was defined based on best business processes and practices. PII is required for fulfilling requests from customers until requests are resolved.

What efforts are being made to eliminate or reduce PII that is collected, stored or maintained by the system if it is no longer required?

Information requested is the minimum information necessary to provide a complete resolution to the customer at their request, and was agreed upon with DOL.

Members of the public may provide pertinent contact information (name, phone number, address, or email address), if they wish to order a publication or have someone contact them with additional information. No personally identifiable information is collected without the individual's consent.

In addition, email messages delivered to the DOL-NCC may contain PII based upon the context of the email message which is sourced from the general public.

Privacy Impact Analysis

All PII captured as part of the DOL-NCC operating environment (i.e. CRM application, recorded calls) is saved for 30 days and purged thereafter. Exceptions to this requirement include captured OSHA and MSHA related information (requiring supporting documentation of fatalities and injuries, which is retained indefinitely). The data is of a low sensitivity. Risk is mitigated by minimizing, controlling, and auditing access to the repository.

Internal Sharing and Disclosure

The following questions are intended to define the scope of sharing within the Department of Labor.

With which internal organization(s) is the PII shared, what information is shared, and for what purpose?

PII is shared within DOL agencies for the purpose of resolving a customer inquiry.

How is the PII transmitted or disclosed?

PII is transmitted and disclosed electronically via email or telephone to authorized DOL agency personnel. In addition, two designated DOL SMEs have read-only access to the CRM Major Application (communication channel is protected via IPSEC AES-256 VPN tunnel).

Audio recording extracts may be provided to authorized DOL agency personnel via a secure file-transfer portal (operated by the vendor). Access to the portal is restricted to specific DOL-assigned public IP addresses and personnel (authentication). Content remains for a 30-day period within the portal and is then subject to an automated purge process.

All audio recording extracts are encrypted using WinZip (AES-256 bit encryption technology). The private key utilized to encrypt the file is required to be provided verbally or within a separate communication channel that was utilized for the encrypted file transport.

Privacy Impact Analysis

PII is only shared within DOL agencies for the purpose of resolving a customer inquiry, validating quality assurance, or when there is an identified threat call which must be escalated. .

PII that is shared is limited to the minimum information needed to allow the DOL-NCC or DOL SME to contact the customer to resolve their issue. This would typically include the customer's name, phone number and the nature of their inquiry.

Transfer of PII over the telephone is verified by the phone number dialed and the relationships developed between the vendor personnel and the DOL SMEs. Information shared via email requires a user to enter their user name and password to obtain the information. Although misdirected email is a possibility, this is reduced by the use of predefined distribution lists. Two DOL SMEs who have access to our CRM knowledgebase must connect via a secure VPN.

All vendor and DOL personnel who have access to PII information are required to complete an annual DOL training curriculum and sign a DOL non-disclosure statement "Rules of Conduct and the Consequences for Failure to Follow Rules Concerning the Safeguarding of Personal Identifiable Information".

External Sharing and Disclosure

The following questions are intended to define the content, scope, and authority for information sharing external to DOL which includes federal, state and local government, and the private sector.

With which external organization(s) is the PII shared, what information is shared, and for what purpose?

None.

Is the sharing of PII outside the Department compatible with the original collection? If so, is it covered by an appropriate routine use in a SORN? If so, please describe. If not, please describe under what legal mechanism the program or system is allowed to share the PII outside of DOL.

Not Applicable.

How is the information shared outside the Department and what security measures safeguard its transmission?

Not Applicable.

Privacy Impact Analysis

Not Applicable.

Notice

The following questions are directed at notice to the individual of the scope of PII collected, the right to consent to uses of said information, and the right to decline to provide information.

Was notice provided to the individual prior to collection of PII?

PII is only collected when the customer chooses to share PII for further resolution of their issue.

Notice is provided by the DOL-NCC operations personnel when the information is collected from the customer.

Do individuals have the opportunity and/or right to decline to provide information?

Yes.

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

A customer's contact information (name, e-mail address and phone number) may be collected in the event that DOL-NCC operations personnel are unable to readily address a customer's inquiry or is directed to do so by program processes and procedures. DOL-NCC operations personnel will perform additional research and contact the customer back to fulfill the original inquiry or the customer's contact information is forwarded to the appropriate DOL Subject Matter Expert.

Mailing address data is collected by the NCC System in order to send customers (per their request) additional information (i.e. forms, publications, referrals etc.).

Privacy Impact Analysis

The DOL-NCC operations personnel informs the customer that their information will be forwarded to the appropriate Department of Labor personnel for resolution. If the individual refuses, information is not collected. No PII is collected without the individual's consent.

Access, Redress, and Correction

The following questions are directed at an individual's ability to ensure the accuracy of the information collected about them.

What are the procedures that allow individuals to gain access to their information?

At the customer's discretion, a service request number would be provided. This number permits a customer the ability to reference their original inquiry (upon contacting the DOL-NCC).

What are the procedures for correcting inaccurate or erroneous information?

An escalation to a supervisor or DOL-NCC content personnel would be required. These personnel can create a contact record within the CRM application, which will contain the updated information.

Original (captured) information is not typically modified since it would likely have been acted upon (i.e. referenced/sourced for providing literature or knowledge base content).

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

Not Applicable.

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

Not Applicable.

Privacy Impact Analysis

Very limited (non-sensitive) PII is collected and no information is collected without the individual's knowledge and consent.

All PII is verified with the individual before it is entered into the CRM Major Application.

Technical Access and Security

The following questions are intended to describe technical safeguards and security measures.

What procedures are in place to determine which users may access the system and are they documented?

DOL-NCC personnel are granted access to the CRM software and data repository based on least privilege and separation of duties. Permissions (application-specific) are assigned based upon job function and requirements as specified in the DOL-NCC CRM Responsibility Definitions policy document.

Will Department contractors have access to the system?

Yes, only via IPSEC VPN (using AES-256 bit encryption). Access is granted based on least privilege and separation of duties to support DOL-NCC operations.

Describe what privacy training is provided to users, either generally or specifically relevant to the program or system?

  • All new DOL-NCC personnel receive an initial eight day training program that includes instruction on the proper usage and operations of the CRM application. Included in this initial training is DOL's Annual Department of Labor Information System Security Awareness (ISSA) Training and Annual DOL PII Training.
  • All DOL-NCC personnel are required to complete annual DOL ISSA and PII training.
  • All vendor employees are required to complete a separate, corporate-mandated, annual Computer Security training.

What auditing measures and technical safeguards are in place to prevent misuse of data?

To ensure the integrity of data, various logging and tracking mechanisms are enforced both at the network, system layer, and within the CRM Major Application and Audio Recording components.

In addition, network and system security controls are enforced to strengthen the confidentiality and integrity of the backend components which comprise the DOL-NCC support environment.

Privacy Impact Analysis

No PII is collected without the individual's knowledge and consent. The collected information (Name, Address, Telephone Number and/or Email Address) is housed in a secured data repository and purged according to Section 3.6 Retention. Technical access and security controls are enforced to strengthen the confidentiality and integrity of the components which comprise the DOL-NCC support environment.

Technology

The following questions are directed at critically analyzing the selection process for any technologies utilized by the system, including system hardware, RFID, biometrics, and other technology.

What stage of development is the system in, and what project development life cycle was used?

DOL-NCC is in the Operations and Maintenance stage of the DOL System Development and Lifecycle Management (SDLCM).

Does the project employ technology which may raise privacy concerns? If so please discuss their implementation?

Not Applicable.

Determination

As a result of performing the PIA, what choices has the agency made regarding the information technology system and collection of information?

  • OPA has completed the PIA for DOL-NCC system, which is currently in operation.
  • OPA has determined that the safeguards and controls for this moderate system adequately protect the information.