Establish standard processes to ensure consistent work flow and communications between program office and Privacy Office personnel

Ensure role-based privacy training is provided to all personnel with privacy responsibilities

Ensure privacy awareness training is provided to all contractor and third party personnel

Provide personnel tasked with handling Privacy Act requests with recurring training on Privacy Act exceptions

Establish documentation procedures for accounting of disclosures made under the Privacy Act, as required by 5 USC 552a(c)

Establish an annual computer matching activity reporting process to meet the requirements of OMB Circular A-108

Determine if general support system privacy threshold assessments or privacy impact assessments should be completed; if not, document the rationale

Develop the technical capability to identify, inventory, and monitor the existence of PII within the HUD environment

Develop and implement a process to inventory all agency PII holdings not less than annually.

Renew the PII minimization effort, to include a prioritization by the SAOP of specific minimization initiatives

Require all system owners to review the records retention practices for each information system and take any corrective actions necessary to ensure adherence to the applicable records retention schedule

A. Issue a clean desk policy prohibiting unattended and unsecured sensitive data in workplaces. B. Implement procedures to enforce the clean desk policy.

Require the 12 grantees to correct their action plans to ensure that they comply with program requirements and submit the corrected plans to HUD for review or require the grantees to repay HUD from non-Federal funds for any amount of the $7,779,450 they received that they cannot support.

Require the Housing Authority of Brevard County to repay $1,520 in ineligible escrow funds to HUD from non-Federal funds for the program participant that exceeded allowable contract terms of the FSS program.

Monitor the grantees’ efforts to improve the accuracy and completeness of the PIC program data to ensure that program outcomes reported to Congress are accurately supported.

Develop and implement a plan to monitor grantee FSS programs, including to ensure that escrow accounts are calculated correctly.

Develop and implement policies and procedures to ensure that documentation is maintained by grantees to support program participants’ contractual agreements.

Put all project bank accounts in the name of the project.

Separate all owner bank accounts from the project’s bank accounts.

Develop and implement controls over the distinction between project funds and owner funds. These controls should include policies related to when the owner is allowed to take project funds owed to the owner.