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 program levels. We also examined the level of progress achieved since we last evaluated the program in 2014.
We found that HUD had updated its privacy impact assessment processes, and took a more active role to ensure privacy is properly addressed in the agency’s technology and business operations. HUD had also improved its incident response and reporting capabilities, strengthened the physical security and protection of its sensitive records, and continued to upgrade the privacy awareness training provided to all employees. However, HUD had not established a strategic plan for privacy, and key initiatives were put on hold pending the staffing of key privacy program management positions. HUD had not integrated privacy risks into its enterprise risk management (ERM) process, had not formalized many oversight practices, and lacked a structured compliance program. Critically, HUD continued to lack the capability to fully identify and inventory its extensive holdings of personally identifiable information (PII).
We recommend HUD address the 14 remaining open recommendations from our 2014 privacy program evaluation, and address all 24 additional recommendations provided in this report. In particular, we recommend that HUD establish a strategic plan for its privacy program, ensure the availability of adequate resources and privacy expertise, implement a formal compliance program, clarify privacy roles across the agency, develop the capability to identify and inventory all of its PII, and fully integrate the privacy program with its enterprise risk management process and with other enterprise programs.
Recommendations
Office of Administration
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Status2018-OE-0001-01OpenClosedClosed on September 25, 2020
Ensure the privacy program is staffed with experienced personnel (such as a Chief Privacy Officer) to manage the operational aspects of the program.
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Status2018-OE-0001-02OpenClosedClosed on August 13, 2020
Issue a notice at the Secretary level delegating and clarifying the authority and responsibilities of the SAOP and Privacy Office
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Status2018-OE-0001-03OpenClosedClosed on January 10, 2023
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.
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Status2018-OE-0001-04OpenClosedClosed on July 10, 2024
Implement thorough human capital processes to ensure execution of the HUD privacy program and all its requirements
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Status2018-OE-0001-05OpenClosedClosed on June 25, 2020
Finalize and approve the draft privacy program strategic plan
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Status2018-OE-0001-06OpenClosedClosed on November 18, 2021
Ensure the privacy program is integrated with the enterprise risk program and that privacy risks are incorporated into the agency risk management process
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Status2018-OE-0001-07OpenClosedClosed on May 22, 2020
Establish an executive leadership dashboard to communicate continuous monitoring of key program risks and issues
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Status2018-OE-0001-08OpenClosedClosed on May 22, 2020
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
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Status2018-OE-0001-09OpenClosedClosed on October 01, 2021
Develop a dedicated budget to address Privacy Office training needs and initiatives
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Status2018-OE-0001-10OpenClosedClosed on December 09, 2021
Update all privacy guidance to reflect current Federal requirements and processes.
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Status2018-OE-0001-11OpenClosedClosed on May 22, 2020
Implement a formal process for the Privacy Office to issue and communicate privacy guidance, requirements, and deadlines.
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Status2018-OE-0001-12OpenClosedClosed on September 17, 2020
Update and continue to maintain a central collaboration area to include all current privacy program policies, procedures, and guidance
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Status2018-OE-0001-13OpenClosedClosed on May 22, 2020
Establish standard processes to ensure consistent work flow and communications between program office and Privacy Office personnel
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Status2018-OE-0001-14OpenClosedClosed on July 10, 2024
Ensure role-based privacy training is provided to all personnel with privacy responsibilities
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Status2018-OE-0001-15OpenClosedClosed on July 10, 2024
Ensure privacy awareness training is provided to all contractor and third party personnel
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Status2018-OE-0001-16OpenClosedClosed on August 13, 2020
Provide personnel tasked with handling Privacy Act requests with recurring training on Privacy Act exceptions
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Status2018-OE-0001-17OpenClosedClosed on September 17, 2020
Establish documentation procedures for accounting of disclosures made under the Privacy Act, as required by 5 USC 552a(c)
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Status2018-OE-0001-18OpenClosedClosed on September 17, 2020
Establish an annual computer matching activity reporting process to meet the requirements of OMB Circular A-108
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Status2018-OE-0001-19OpenClosedClosed on April 08, 2021
Determine if general support system privacy threshold assessments or privacy impact assessments should be completed; if not, document the rationale
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Status2018-OE-0001-20OpenClosed
Develop the technical capability to identify, inventory, and monitor the existence of PII within the HUD environment
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Status2018-OE-0001-21OpenClosed
Develop and implement a process to inventory all agency PII holdings not less than annually.
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Status2018-OE-0001-22OpenClosedClosed on November 19, 2020
Renew the PII minimization effort, to include a prioritization by the SAOP of specific minimization initiatives
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Status2018-OE-0001-23OpenClosedClosed on July 01, 2021
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
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Status2018-OE-0001-24OpenClosedClosed on December 31, 2020
A. Issue a clean desk policy prohibiting unattended and unsecured sensitive data in workplaces. B. Implement procedures to enforce the clean desk policy.