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Privacy Impact Assessment for the External Compliance Program Discrimination Complaint Files

On this page:


I. Data in the System

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

    Information on administrative complaints filed with EPA alleging discrimination by a recipient of EPA financial assistance.

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

    The source of all information in the chart is administrative complaints filed with EPA alleging discrimination by a recipient of EPA financial assistance. The types of information in the chart are; EPA identification number assigned to each complaint, the status of each complaint, the state the alleged discrimination occurred, whether the complainant is an individual or an organization, the alleged recipient, the date (month/year) the complaint was received by EPA, the date (month/year) the complaint was accepted or closed, and the type of program or activity described in the complaint.

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

    The data is provided to keep a chronological listing of all discrimination complaints received and processed by EPA. It also provides a snapshot of potential problem areas to help OCR determine where some of our external compliance reviews should be conducted.

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

    This system (complaint chart) is kept to provide the general public with a chronological listing of all discrimination complaints received and processed by EPA. Complainants, as well as recipients, can access the site and check the status of all complaints. Other members of the public can survey the information to understand the type of discrimination complaints received by EPA at any given time, the geographic location of alleged discrimination, as well as the variety of alleged violators.

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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)?

    This data/information is kept in an Adobe file on the website. Only internal staff involved in uploading the data/information on OCR's website have direct access to the data. External parties can view the data/information once it is posted on the website.

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

    Only the Assistant Director of OCR's External Compliance Team and a Team member have access to the non-protected version of the Chart. OCR's web liaison (the person resides on another OCR Team) sends the Adobe file to the Contractor to be placed on OCR's website.

  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.)

    Yes, complainants are contacted via letter, after a complaint is received and sent a Consent Form. The Consent Form authorizes EPA to disclose the Complainant's identity to persons to the alleged Recipient. The Consent Form states that the material and information disclosed will be used only for authorized civil rights compliance and enforcement activities. Complainants are also told that they are not required to give this release.

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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.

    This system (complaint chart) is kept to provide the general public with a chronological listing of all discrimination complaints received and processed by EPA. Complainants, as well as recipients, can access the site and check the status of all complaints. Other members of the public can survey the information to understand the type of discrimination complaints received by EPA at any given time, the geographic location of alleged discrimination, as well as the variety of alleged violators.

  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.)

    Data is retrieved via the Complaint ID number assigned by OCR. Data is not stored based on personal identifiers, although personal information may exist.

  5. What achievements of goals for machine readability have been incorporated into this system? 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.)

    A link to EPA's Privacy and Security Notice appears on every page of OCR's website, including the Chart listing all Title VI Complaints Filed with EPA.

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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.)

    OCR maintains a records management schedule for all administrative complaints alleging discrimination by EPA recipients.

  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 Complaint Chart is reviewed and updated monthly.

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

    No.

  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.)

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