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Privacy Impact Assessment for the Request and Appeal Files for the Freedom of Information Act

On this page:


I. Data in the System

  1. Generally describe what data/information will be collected in the system.

    A copy of each Freedom of Information Act request received and a copy of all correspondence related to the request, including name, affiliation address, telephone numbers, and other information about a requester. A computerized index includes the name and affiliation of each requester, the request identification number, and the subject.

  2. What are the sources and types of the information in the system?

    Incoming Freedom of Information Act requests and related correspondence from the record subject; EPA offices.

  3. How will the data be used by the Agency?

    To respond to FOIA requests and to prepare reports on FOIA activities.

  4. Why is the information being collected? (Purpose)

    Freedom of Information Act, 5 U.S.C. 552.

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II. Access to the Data

  1. Who will have access to the data/information in the system (internal and external parties)? If contractors, are the Federal Acquisition Regulations (FAR) clauses included in the contract (24.104 Contract clauses; 52.224-1 Privacy Act Notification; and 52.224-2 Privacy Act)?

    EPA employees and contactors. Yes.

  2. What controls are in place to prevent the misuse of data by those having authorized access?

    New authorized users are provided training on proper use of the data.

  3. Do other systems share data or have access to data/information in this system? If yes, explain who will be responsible for protecting the privacy rights of the individuals affected by the interface? (i.e., System Administrators, System Developers, System Managers)

    No.

  4. Will other agencies, state or local governments share data/information or have access to data in this system? (Includes any entity external to EPA.)

    No.

  5. Do individuals have the opportunity to decline to provide information or to consent to particular uses of the information? If yes, how is notice given to the individual? (Privacy policies must clearly explain where the collection or sharing of certain information may be optional and provide users a mechanism to assert any preference to withhold information or prohibit secondary use.)

    In order for EPA to process a FOIA request or appeal certain data, name and address are required to be enterted in the database.

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III. Attributes of the Data

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

    The data is used to track and respond to FOIA requests and appeals and is consistent with E.O. 13392.

  2. If data are being consolidated, what controls are in place to protect the data from unauthorized access or use? Explain.

    n/a

  3. 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 data be retrieved? Can it be retrieved by personal identifier? If yes, explain. (A personal identifier is a name, Social Security Number, or other identifying symbol assigned to an individual, i.e. any identifier unique to an individual.)

    Name of requester or tracking number.

  5. Is the Web privacy policy machine readable? Where is the policy stated? (Machine readable technology enables visitors to easily identify privacy policies and make an informed choice about whether to conduct business with that site.)

    This is an internal system accordingly, it does not require a privacy policy attached to the Webpage.

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IV. Maintenance of Administrative Controls

  1. Has a record control schedule been issued for the records in the system? If so, provide the schedule number. What are the retention periods for records in this system? What are the procedures for eliminating the records at the end of the retention period? (You may check with the record liaison officer (RLO) for your AA-ship, Tammy Boulware (Headquarters Records Officer) or Judy Hutt, Agency Privacy Act Officer, to determine if there is a retention schedule for the subject records.)

    Yes, EPA Record Schedule 263. See attached.

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

    The data that is being maintained is case specific and we maintain the database pursuant to an approved EPA records schedule.

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

    Yes. The system can search on a requesters name or request identification number.

  4. Does the system use any persistent tracking technologies?

    No.

  5. Under which System of Records (SOR) notice does the system operate? Provide the name of the system and its SOR number if applicable. For reference, please view this list of Agency SORs. (A SOR is any collection of records under the control of the Agency in which the data is retrieved by a personal identifier. The Privacy Act Officer will determine if a SOR is necessary for your system.)

    EPA-9

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