PIA for GSA IT Hire1).pdfResume / CV Optional links to social networking profiles 1a. What stage of the life cycle is the system currently in? Development 2a. What are the sources

1 U.S. General Services Administration

PIA for GSA IT Hire

Part 1.

System Title: GSA IT Hire

FIPS-199 Categorization: Moderate

Office of Responsibility: OCIO Office Correspondence Code: IO

Program/System Manager or System Owner Name and Title: Erika Dinnie

Phone: 202-494-2144

E-mail: [email protected]

Organization Title and Correspondence Code: IM

System/Project Manager Name and Title: Megan Schmith

Phone: 571-388-6566

E-mail: [email protected]

Organization Title and Correspondence Code: IAS 3/1/2016

X Mark Vogelgesang on bela...

S/PM or SO

Signed by: MARK VOGELGESANG


AO Name and Title: David Shive Phone: (202) 501-1000 E-mail: [email protected] Organization Title and Correspondence Code: I

Information System Security Officer Name and Title: Daniel Stanfield Phone: (817) 850-5595 E-mail: [email protected] Organization Title and Correspondence Code: IST

3/1/2016

X Daniel Stanfield

ISSO

Signed by: DANIEL STANFIELD (Affiliate)

GSA Privacy Officer Name: Lauren Pierce Phone: (571) 388-6570 E-Mail: [email protected] Organization Title: Acting Privacy Officer Correspondence Code: ISP

3/1/2016

X Lauren Pierce

Privacy Officer

Signed by: LAUREN PIERCE

Date of Last PIA: N/A Date of PIA Update: 2/22/2016

Previously Associated System/Application Name: N/A

Associated SORN/Number: OPM/GOVT-5

Date Current ATO Expires: 14-SEP-2016

ATO Status: Current


Note on template responses: Read field comments for assistance and then overwrite with

your response.

Qualifying Questions

Question Explanation / Instructions

1. Does your system collect any information in identifiable form (personal data) on the general public? (YES or NO) If YES, a full PIA is required, starting FY 2004

Yes

2. Does your system collect any information in identifiable form (personal data/information) on the government employees? (YES or NO) If YES, a full PIA is required, starting FY 2005

Yes

3. Describe how and why the system uses this personal information to fit an agency mission.

GSA IT Hire Application will collect data of potential IT professionals interested in job opportunities at GSA.

(Please Note: If you answered “No” to Question #1 and Question #2, Part 2 is not required.

Part 2 is for systems that answered “Yes” to either question. A PIA for an existing system must

be conducted annually and submitted to the GSA Privacy Officer in conjunction with

Assessment & Accreditation Packages and/or Continuous Monitoring Schedules. The PIA Part

1 questions MUST appear on ALL PIAs, to include Third Party and/or Contractor System

Owned System PIAs.


Part 2. SYSTEM ASSESSMENT

A. Data in the System

Question Explanation/Instructions

1. Identify all information to be included and collected in the system, including personal data.

Full name

Personal physical home address

Personal home or mobile phone

Personal email addresses

Citizenship

US Armed Forces Veteran status

Current employer

Resume / CV

Optional links to social networking profiles

1a. What stage of the life cycle is the system currently in?

Development

2a. What are the sources of the information in the system and how is it collected?

Public users of the system provide their information on the application form. Self-entry is the only methodology of data entry into this system.

2b. What GSA files and databases are used?

Data is to be stored in the GSA Salesforce.com implementation within the GSA Enterprise Engagement Organization (EEO). Salesforce EEO Org Objects: GSA IT Applications and Applicants Information

2c. What Federal agencies are providing data for use in the system?

None.

2d. What State and local agencies are providing data for use in the system?

None.


2e. From what other third party sources will the data be collected?

None.

2f. What information will be collected from the individual whose record is in the system?

Full name

Personal physical home address

Personal home or mobile phone

Personal email addresses

Citizenship

US Armed Forces Veteran status

Current employer

Resume / CV

Optional links to social networking profiles

3a. How will the data collected from sources other than Federal agency records or the individual be verified for accuracy?

There is no data collected other than directly from the individual entering their applications.

3b. How will data be checked for completeness?

Applicants are responsible for ensuring the data they enter is correct and complete. Data entry forms use format constraints.

3c. Is the data current? How is data accuracy ensured?

Applicant entries are one time entries of contact information and resumes. There is not a direct means for an individual to update their information. In the event that someone moves to a new address or would like to update the content of their resume, there are two options available. 1) The submitter creates a new submission via the form. Upon receipt, the program office will consider the new submission and no longer use the old submission. 2) The submitter can contact the GSA IT Hire team via e-mail and request an update to their information. Individuals who are interested in potential job offerings in GSA IT will not have the ability to log into the system.


4. Are the data elements described in detail and documented? If yes, what is the name of the document?

Data elements listed in the GSA IT Hire Technical Design Document. Please see question Part 2 A, question 2f in this document.

5. How does the individual whose data is used in the system receive notification prior to the collection of information?

An individual is notified by a Privacy Notice displayed on the first page of the application and prior to the applicant “Submit” button for sharing their data. The Privacy Notice displayed is as follows:

Privacy Act Statement. Federal agencies rate applicants for Federal jobs under the authority of sections 1104, 1302, 3301, 3304, 3320, 3361, 3393, and 3394 of title 5 of the United States Code. We need the information requested and in any associated vacancy announcements to evaluate your qualifications. Other laws require us to ask about citizenship, military service, etc. Failure to furnish the requested information may delay or prevent action on your application. Incomplete addresses and ZIP Codes, personal email addresses, social networking profiles, or other information may slow processing. We may confirm information from your records with prospective nonfederal employers concerning tenure of employment, civil service status, length of service, and date and nature of action for separation as shown on personnel action forms of specifically identified individuals. For routine uses and other relevant information, please see OPM/GOVT-5 for the system of records notice (71 F.R. 35351).

B. Access to the Data


1a. Who will have access to the data in the system?

Users with the GSA IT Hire Manager - CRE (create, read, edit) permission set and the GSA System Administrator profile will have access to the data. All user access requests will be approved by the application owner.


1b. Is any of the data subject to exclusion from disclosure under the Freedom of Information Act (FOIA)? If yes, explain the policy and rationale supporting this decision.

Personally Identifiable Information (PII) data contained within GSA IT Hire is exempt from FOIA Policy #6. Documents which are "personnel and medical and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy." 5 U.S.C. § 552(b)(6). This exemption protects the privacy interests of individuals by allowing an agency to withhold personal data kept in government files.

2. How is access to the data by a user determined? Are criteria, procedures, controls, and responsibilities regarding access documented?

The access to data is controlled by Permission sets “GSA IT Hire - Hiring Managers - CRE (create, read, edit)” and access shall not be granted until it’s authorized by Application Owner. The Application Owner shall only be granting access to individuals who are in the position to contact potential applicants on behalf of GSA.

3. Will users have access to all data in the system or will the users’ access be restricted? Explain.

Individual Access: Once data is submitted, the original submitter of the data

will not have access to the data. In the event that the submitter would like

to change or correct information that was submitted, they can contact the

GSA IT Hire team via e-mail. The e-mail address is shared on the form, the

post-submission thank you page, and in a confirmation e-mail. Additionally,

the submitter may submit the form again and create a new record.

System Administrators Access: System administrators will have access to

the data provided by the submitter. All system administrators hold an MBI

clearance and are required to login using an SNA token.

Managers and Supervisors Access: Managers and supervisors with hiring

authority will have access to the application and data. Per GSA Salesforce

security guidelines, all hiring managers and supervisors must be approved

by the application owner.


4. What controls are in place to prevent the misuse (e.g. browsing) of data by those having access?

The access to applicant data would require approval of Application owners.

Access to the data will be granted via assignment of the “GSA IT Hire -

Manager - CRE (create, read, edit)” permission set.

Data also protected as defined by NIST 800-53 controls provided in the

embedded document below.

NIST 800-53 Controls

5a. Do other systems share data or have access to data in this system? If yes, explain.

No.

5b. Who will be responsible for protecting the privacy rights of the clients and employees affected by the interface?

Application Owner (see top of document), Office of the Chief Information

Officer, Management Services Division (IM).

6a. Will other agencies share data or have access to data in this system (International, Federal, State, Local, and Other)?

No.


6b. How will the data be used by the agency?

The submitter’s data (consisting of e-mail address, phone number, resume,

etc) will be used to evaluate whether or not an individual should be put

forth for consideration for a job within GSA IT. Contact information will be

used to reach out to the individual.

6c. Who is responsible for assuring proper use of the data?

Application Owner (see top of document), Office of the Chief Information

Officer, Management Services Division (IM).

6d. How will the system ensure that agencies only get the information to which they are entitled?

N/A

7. What is the life expectancy of the data and for what reason?

Data is not aged or removed as a matter of normal procedure. App Owner

may request that records are deleted by a Salesforce administrator as

applicable.

8. How will the data be disposed of when it is no longer needed?

App Owner may request that records are deleted by a Salesforce administrator as applicable. Otherwise, data to be removed from Salesforce.com processes will follow industry standard approaches to cleansing and aging out of archives. GSA policies that govern sanitation are followed where applicable: GSA IT Security Procedural Guides, Media Sanitization, CIO-IT Security-06-32 and NIST SP 800-88.


C. Attributes of the Data


1. Is the use of the data both relevant and necessary to the purpose for which the system is being designed?

Yes, the PII data requested is the minimal amount

needed for the GSA IT managers to contact an individual.

A listing of all fields and descriptions can be found below:

Applicant Email Address

Applicant Name

Best Contact Number

- phone number of the applicant

City and State, or Zip Code

Current Employer (optional)

Link #1 (optional)

- Links 1-3 are optionally required fields where a

submitter may share links to GitHub, LinkedIn, or

other professional social media platforms.

Link #2 (optional)

Link #3 (optional)

Resume

- Plain text resume for the applicant

U.S. Citizen

- Simple yes/no asking if the individual is a US

Citizen. Some federal jobs require US Citizenship

as a pre-requisite.

Veterans’ Preference Claim (optional)

- Allows an applicant to designate the veterans’

preference claim that is applicable to them

Veteran Status (US Armed Forces) (optional)

- Simple yes/no asking if the individual is a veteran

of the US Armed Forces


2a. Will the system derive new data or create previously unavailable data about an individual through aggregation from the information collected?

No, we are not collecting or aggregating any new data

outside of what is requested on the form. If an individual

submits the form multiple times, the data would be

stored as separate records in the system. Multiple

submissions of the form would not enhance an

individual’s standing or competitiveness within the

organization.

2b. Will the new data be placed in the individual's record (client or employee)?

N/A

2c. Can the system make determinations about individuals that would not be possible without the new data?

N/A

2d. How will the new data be verified for relevance and accuracy?

N/A

3a. If the data is being consolidated, what controls are in place to protect the data and prevent unauthorized access? Explain.

N/A

3b. If processes are being consolidated, are the proper controls remaining in place to protect the data and prevent unauthorized access? Explain.

N/A


4. How will the data be retrieved? Can it be retrieved by personal identifier? If yes, explain.

Data retrieved by name, or by unique resume ID

numbers. Resumes can be browsed by skills and other

qualified content.

5. What are the potential effects on the privacy rights of individuals of: a. Consolidation and linkage of files and systems; b. Derivation of data; c. Accelerated information processing and decision-making; and d. Use of new technologies. How are the effects to be mitigated?

There are no known effects on the privacy rights of

individuals who avail themselves of the tool.

This system is not linked to other files and systems.

There is no derivation of data.

There is no use of accelerated information processing

and decision-making, and no use of new technologies.

D. Maintenance of Administrative Controls


1a. Explain how the system and its use will ensure equitable treatment of individuals.

We do not collect any information that would

distinguish a submitter by race, sexual orientation,

gender, or nationality. We do request that individuals

denote whether or not they are US citizens because

many jobs within GSA IT contain a US citizenship

provision.

1b. If the system is operated in more than one site, how will consistent use of the system be maintained at all sites?

The system is operated in the salesforce.com cloud

based environment.


1c. Explain any possibility of disparate treatment of individuals or groups.

Not applicable, we do not capture that type of

information.

2.a. What are the retention periods of data in this system?

Data is not aged or removed as a matter of normal

procedure. App Owner may request that records are

deleted by a Salesforce administrator if the record is

no longer relevant.

2.b. What are the procedures for eliminating the data at the end of the retention period? Where are the procedures documented?

App Owner may request that records are deleted by a Salesforce administrator if the record is no longer relevant. Otherwise, data to be removed from Salesforce.com processes will follow industry standard approaches to cleansing and aging out of archives. GSA policies that govern sanitation are followed where applicable: GSA IT Security Procedural Guides, Media Sanitization, CIO-IT Security-06-32 and NIST SP 800-88.

2c. While the data is retained in the system, what are the requirements for determining if the data is still sufficiently accurate, relevant, timely, and complete to ensure fairness in making determinations?

In the event that someone moves to a new address or

would like to update the content of their resume,

there are two options available. 1) The submitter

creates a new submission via the form. This will

create a new record in the application. It will not

merge the new submission into a previous record. 2)

The submitter can contact the GSA IT Hire team via e-

mail and request an update to their information.

3a. Is the system using technologies in ways that Federal agencies have not previously employed (e.g. Caller-ID)?

No.

3b. How does the use of this technology affect individuals’ privacy?

Use of this technology does not affect individuals'

privacy. This is information individuals already supply

when applying for jobs and this technology does not

have an additional effect on privacy. All information is

voluntarily provided to the Agency for employment


consideration.

4a. Will this system provide the capability to identify, locate, and monitor individuals? If yes, explain.

The system will provide the capability to identify

individuals and locate them within a city and state or

zip code. This is to allow a means for hiring managers

to identify potential applicants within a given

geographic region. The application will not be used to

monitor individuals.

4b. Will this system provide the capability to identify, locate, and monitor groups of people? If yes, explain.

No.

4c. What controls will be used to prevent unauthorized monitoring?

The information is voluntarily provided and is not of a nature that relates to monitoring. All GSA employees are required to complete IT Security Awareness and Privacy 101 Training.

5a. Under which Privacy Act System of Records Notice (SORN) does the system operate? Provide number and name.

OPM/GOVT-5

5b. If the system is being modified, will the SORN require amendment or revision? Explain.

N/A