Renew the PII minimization effort, to include a prioritization by the SAOP of specific minimization initiatives
Publication Report
2018-OE-0001 | September 13, 2018
HUD Privacy Program Evaluation Report
We conducted this evaluation to determine the effectiveness of the U.S. Department of Housing and Urban Development’s (HUD) privacy program We assessed the adequacy of agency strategies, plans, controls and practices at the enterprise and… moreRelated Recommendations
Office of Administration
Ensure the privacy program is staffed with experienced personnel (such as a Chief Privacy Officer) to manage the operational aspects of the program.
Issue a notice at the Secretary level delegating and clarifying the authority and responsibilities of the SAOP and Privacy Office
A. Document the roles and specific responsibilities of all positions assigned privacy responsibilities. B. Communicate these responsibilities on a recurring basis, at least annually, to individuals holding these positions.
Implement thorough human capital processes to ensure execution of the HUD privacy program and all its requirements
Finalize and approve the draft privacy program strategic plan
Ensure the privacy program is integrated with the enterprise risk program and that privacy risks are incorporated into the agency risk management process
Establish an executive leadership dashboard to communicate continuous monitoring of key program risks and issues
A. Develop an internal privacy program communication plan to describe how privacy issues will be disseminated and best practices will be shared. B. Implement the communication plan
Develop a dedicated budget to address Privacy Office training needs and initiatives
Update all privacy guidance to reflect current Federal requirements and processes.
Implement a formal process for the Privacy Office to issue and communicate privacy guidance, requirements, and deadlines.
Update and continue to maintain a central collaboration area to include all current privacy program policies, procedures, and guidance
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
- Status2018-OE-0001-20OpenClosed
Develop the technical capability to identify, inventory, and monitor the existence of PII within the HUD environment
- Status2018-OE-0001-21OpenClosed
Develop and implement a process to inventory all agency PII holdings not less than annually.
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.