DHS office describes how it assesses privacy

The Homeland Security Department’s privacy office has released a policy guidance document that explains the principles the office uses to assess the privacy effects of DHS programs.

ΔDHS’ privacy office released a memorandum Dec. 29 that laid out eight fair information practice principles (FIPPs) that it said constitute the foundation for the department's privacy policy development and implementation. That office said it has already been using FIPPs in its privacy notices and assessments.

"They are the things that we use when evaluate the privacy impact of any information system, any program of any activity,” said Hugo Teufel, DHS’ chief privacy officer.

FIPPs, used to assess the effects of systems, processes and programs on individual privacy, are central to the 1974 Privacy Act, and variations of the principles are reflected in international privacy protection frameworks, as well as state-level and national legislation, the memo said.

The memo describes how the privacy office applies the principles specifically to DHS programs. The incoming Obama administration will appoint a new chief privacy officer there.

The FIPPS said in the memo that DHS should:

• Be transparent and provide notice to the individuals regarding collection and use of personally identifiable information (PII).

• When possible, seek consent from individuals to use their PII and provide access, correction and redress regarding DHS’ use of PII.

• Explain the authority that permits DHS to collect PII and the ways it will be used.

• Only collect PII that is necessary to accomplish the specific purpose and keep it only as long as necessary.

• Use PII only for the purpose specified in the notice. Limit sharing of PII outside the department to purposes that are compatible with the reasons that PII was collected.

• Ensure,  as much as possible, that data is accurate, relevant, timely and complete.

• Protect PII with appropriate security.

• Be held accountable for complying with the principles and provide training for all employees and contractors who use PII and perform audits.

About the Author

Ben Bain is a reporter for Federal Computer Week.

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