Justice Management Division
`
`Privacy Impact Assessment
`for the
`Personal Identity Verification (PIV) Card System
`
`Issued by:
`Stuart Frisch, Senior Component Official for Privacy
`
`Reviewed by: Vance E. Hitch, Chief Information Officer, Department of Justice
`
`Approved by: Nancy C. Libin, Chief Privacy and Civil Liberties Officer,
`Department of Justice
`
`Date originally approved:
`Date revision approved:
`
`September 19, 2007
`March 24, 2011
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`Introduction
`
`Program Overview
`
`Homeland Security Presidential Directive 12 (HSPD-12), issued on August 27,
`2004, required the establishment of a standard for identification of Federal Government
`employees and contractors. HSPD-12 directs the use of a common identification
`credential for both logical and physical access to federally controlled facilities and
`information systems. This policy is intended to enhance security, increase efficiency,
`reduce identity fraud, and protect personal privacy.
`
`HSPD-12 requires that the Federal credential be secure and reliable. The National
`Institute of Standards and Technology (NIST) published a standard for secure and
`reliable forms of identification, Federal Information Processing Standard Publication 201
`(FIPS 201), Personal Identity Verification (PIV) of Federal Employees and Contractors.
`The credential is for physical and logical access.
`
`FIPS 201 has two parts: PIV I and PIV II. The requirements in PIV I support the control
`objectives and security requirements described in FIPS 201, including the standard
`background investigation required for all Federal employees and long-term contractors.
`The standards in PIV II support the technical interoperability requirements described in
`HSPD-12. PIV II specifies standards for implementing identity credentials on integrated
`circuit cards (i.e., smart cards) for use in a Federal system. Simply stated, FIPS 201
`requires agencies to:
`• Establish roles to facilitate identity proofing, information capture and storage,
`and card issuance and maintenance.
`• Develop and implement a physical security and information security
`infrastructure to support these new credentials.
`• Establish processes to support the implementation of a PIV program.
`
`DOJ Implementation
`
`In response to HSPD-12 and to meet the requirements summarized above, the
`General Services Administration (GSA) established the HSPD-12 Managed Service
`Office (MSO) to provide common, shared infrastructure and services to assist federal
`agencies in the implementation of HSPD-12. DOJ has signed up to use the GSA MSO’s
`shared infrastructure and services. Approximately 25 other federal agencies are also
`using the GSA managed service. The scope of the GSA managed services consists of
`enrollment stations, system infrastructure through a centralized PIV Identity Management
`System (IDMS), card production facility, and card activation, finalization, and issuance.
`DOJ will use GSA enrollment and issuance stations hosted in DOJ space and staffed by
`DOJ personnel, which link to the GSA MSO IDMS, card production facility, and other
`services. DOJ Justice Management Division, Security and Emergency Planning Staff,
`and Enterprise Solutions Staff are jointly responsible for the identity management and all
`aspects of the DOJ HSPD-12 implementation including serving as the main internal and
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`external point of contact with respect to program planning, operations, business
`management, communications and technical strategy.
`
`The revision to the September 2007 PIA adds language to describe a tool being used to
`assist DOJ components to structure data in the correct format as they import data from
`existing personnel data sources to GSA’s USAccess HSPD-12 card system. Use of this
`tool is temporary and will be phased out when it is no longer needed.
`
`Section 1.0 The System and the Information Collected and Stored
`within the System.
`
`The following questions are intended to define the scope of the information in the
`system, specifically the nature of the information and the sources from which it is
`obtained.
`
`1.1 What information is to be collected?
`
`The biographic and biometric information collected includes: full name, Social
`Security number, Applicant ID number, date of birth, current address, digital color
`photograph, fingerprints (10), biometric template (two fingerprints), organization,
`employee affiliation, work e-mail address, work telephone number, office address, copies
`of identity source document, employee status, military status, foreign national status,
`federal emergency response official status, law enforcement official status, results of
`background check, Government agency code, and PIV card issuance location.
`Additionally, the PIV Identity Management System (IDMS) and PIV cards contain other
`data not collected from the PIV Applicant that are either (i) electronically stored on the
`card; (ii) electronically stored in the IDMS; and/or (iii) physically displayed on the card.
`This information and the purpose of its use is described in Figure 1.
`
`Figure 1: Other PIV Information Stored, Collected or Used
`
`IDMS
`(Electronically
`Stored)
`X
`
`PIV Card
`(Physically
`Displayed)
`X
`
`PIV Card
`(Electronically
`Stored)
`X
`
`Card expiration date
`
`Personal Identification Number
`(PIN)
`
`Agency card serial number
`
`X
`
`Issuer identification number
`Contact Integrated Circuit Chip
`(ICC)
`
`X
`
`X
`
`X
`
`X
`
`Purpose
`
`To verify card is valid and allow access to
`facilities and computer systems
`For optional/ selected use either for
`physical access to highly secured
`buildings/ space or to log-on to sensitive
`computer systems (“level 3”) that require
`multi-factor authentication, beyond the
`typical user ID/ password.
`For identifying
`and maintaining agency
`cards
`Verify issuers authority
`Used to authenticate a PIV cardholder’s
`identity with card readers that require card
`to be inserted into the reader. Can be
`used for physical access to
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`IDMS
`(Electronically
`Stored)
`
`PIV Card
`(Physically
`Displayed)
`
`PIV Card
`(Electronically
`Stored)
`
`Contactless ICC
`
`PIV authentication key
`
`Cardholder Unique Identifier
`[Federal Agency Smart Card
`Credential Number (FASC-N)
`
`PIV Registrar
`signature)
`
`Approval (digital
`
`X
`
`X
`
`X
`
`X
`
`Purpose
`
`buildings/office space and logical access
`to computer systems.
`Used to authenticate a PIV cardholder’s
`identity with low-frequency radio signal
`“proximity loop” card readers that allow
`card to pass by the card reader. Primary
`use is for physical access to buildings and
`office space.
`Used to authenticate the PIV card to the
`host computer system in relation to
`validating a PIV cardholder’s identity.
`Used to authenticate the cardholder to the
`host computer system and is comprised of
`the agency code plus a sequential number
`for the employee, creating a unique
`number for all Federal employees. This
`allows interoperability of the PIV card
`throughout the Federal Government.
`Used to verify the authenticity of the
`individual sending the message, and
`verifies the content has not been altered.
`
`1.2 From whom is the information collected?
`
`The information is collected from PIV Applicants, the individuals to whom a PIV
`card is issued. The PIV Applicant may be a current or prospective Federal employee, or
`a contractor. Some information is pre-populated in the IDMS based on DOJ human
`resources data by the applicant’s Sponsor.
`
`Section 2.0 The Purpose of the System and the Information Collected
`and Stored within the System.
`
`The following questions are intended to delineate clearly the purpose for which
`information is collected in the system.
`
`2.1 Why is the information being collected?
`
`As required by FIPS 201, DOJ will collect biographic and biometric information
`from the PIV Applicant in order to: (i) conduct the background investigation or other
`national security investigation for federal employees and contractors; (ii) complete the
`identity proofing and registration process; (iii) create a data record in the PIV Identity
`Management System (IDMS); and (iv) issue a PIV card, as mandated by HSPD-12. The
`PIV card issuance process, including background check requirements, and physical and
`electronic contents of the PIV card are defined by FIPS 201.
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`2.2 What specific legal authorities, arrangements, and/or
`agreements authorize the collection of information?
`
`The information is required to meet the requirements of HSPD-12 and FIPS 201.
`
`2.3 Privacy Impact Analysis: Given the amount and type of information
`collected, as well as the purpose, discuss what privacy risks were
`identified and how they were mitigated.
`
`The privacy risks identified were compromise of privacy data at the GSA
`managed service core system, external to DOJ; compromise of privacy data at the DOJ
`operated enrollment stations; and compromise of data on an individual PIV card. Risks
`are from both internal (trusted personnel) and external actors.
`The risk of data compromise is mitigated by physical, administrative, and
`technical security measures. All access to data is restricted on a “need-to-know” basis.
`All access has role based restrictions. Role based access controls are enforced via the use
`of PIV cards. Individuals with access privileges have undergone vetting and suitability
`screening and are trained in their responsibilities to protect privacy data. Data is secured
`physically by locks on doors and locking storage containers. The hosting facility
`buildings have security guards and secured doors. All entrances are monitored through
`electronic surveillance equipment. Picture identification badges are required for access to
`the facility. All data is encrypted in transit between the GSA MSO and DOJ. Secure
`(encrypted) virtual private networks (VPN) are used from the enrollment stations at DOJ
`to the GSA servers. GSA maintains an audit trail and performs random periodic reviews
`to identify unauthorized access. DOJ receives periodic reports which detail card
`issuances, revocations, and other information on card statistics. These reports are
`reviewed by Security and Emergency Planning Staff.
`
`Section 3.0 Uses of the System and the Information.
`
`The following questions are intended to clearly delineate the intended uses of the
`information in the system.
`
`3.1 Describe all uses of the information.
`
` The information identified above is used in each step of the PIV process as described
`below:
`
`• Conduct a background investigation. The PIV background investigation as
`required by FIPS 201 is a condition of Federal employment (now extended to
`contractors) and matches PIV Applicants information against FBI databases to
`prevent the hiring of applicants with a criminal record or possible ties to
`terrorism. If persons decline providing this information, they cannot be hired as a
`permanent employee, nor work at the agency as a contractor long-term (over 6
`months). Two forms are used to initiate the background investigation,
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`Questionnaire for Non-Sensitive Positions Standard Form 85 (SF-85) or the
`Questionnaire for National Security Positions Standard Form 86 (SF-86). Note:
`The background information collected as part of this process and its results are
`kept in the background investigation files; however, not stored on the PIV card.
`• Complete the identity proofing and registration process. The biographic
`information collected as part of this process is used to establish the PIV
`applicant’s identity. Biometrics are used to ensure PIV Applicants have not been
`previously enrolled in the PIV system. As part of this process, FIPS 201 requires
`that Applicants provide two forms of identity source documents in original form.
`The identity source documents must come from the list of acceptable documents
`included in Form I-9, OMB No. 115-0316, Employment Eligibility Verification.1
`PIV Applicants will also participate in an electronic signature process conforming
`to the Electronic Signature (ESIGN) Act. This confirms presentation of and
`agreement with the privacy notice, confirms the intent to participate in the PIV
`process, and submit to a name-based threat background check as required
`depending on job requirements.
`• Create a data record in the PIV Identity Management System (IDMS). The
`IDMS is used during the registration process to create the PIV Applicant’s pre-
`enrollment and enrollment record, manage and maintain this information
`throughout the PIV card lifecycle, and, verify, authenticate and revoke PIV
`cardholder access to federal resources. A unique identifier is assigned during
`registration and used to represent the individual’s identity and associated
`attributes stored in the system.
`• Issue a PIV card. A PIV card is issued upon successful completion of the
`background investigation and identity proofing and registration process, and,
`successful completion of the enrollment process. Biometrics are used during PIV
`card issuance to verify PIV Applicant identity and complete activation of the card.
`This provides much stronger security assurances than typical card activation
`protections such as Personal Identification Numbers (PINs) or passwords. Once
`the individual has been issued a PIV Card, the IDMS is updated to reflect that the
`card has been issued. The issued PIV card cannot be used for access to DOJ
`facilities and networks until activated at the participating location, by the local
`facility operator or system owner.
`• Usage of PIV Card for physical and logical access: The biometrics collected
`can be used to verify that the rightful cardholder is presenting the card in relation
`to physical and logical access to federal facilities and information (i.e.,
`computers). The biographic and other information displayed on the PIV card is
`used by physical security guards for identity verification purposes.
`
`3.2 Does the system analyze data to assist users in identifying
`previously unknown areas of note, concern, or pattern? (Sometimes
`referred to as data mining.)
`
`
`1 Form I-9 can be downloaded at: http://uscis.gov/graphics/formsfee/forms/i-9.htm
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`No. Biometrics collected from PIV applicants are used to perform a check to
`
`ensure that a PIV card has not been previously issued to the same individual.
`
`3.3 How will the information collected from individuals or derived
`from the system, including the system itself be checked for
`accuracy?
`
`PIV card applicant data is checked against existing human resources and
`
`personnel security data by the sponsor of the applicant. Data is checked against I-9
`identity source documents during enrollment. Applicant data is also verified during the
`background investigation process. Upon submittal from the enrollment station, data is
`digitally signed to prevent tampering or modification.
`
`3.4 What is the retention period for the data in the system? Has the
`applicable retention schedule been approved by the National
`Archives and Records Administration (NARA)?
`
`Disposition of records will be according to NARA disposition authority N1-269-
`
`06-1 (pending).
`
`3.5 Privacy Impact Analysis: Describe any types of controls that may
`be in place to ensure that information is handled in accordance with
`the above described uses.
`
`Only authorized personnel with a “need-to-know” are allowed access to the
`information. These individuals are trained in their roles on the system to carry out the
`process described in FIPS 201. The personnel are trained in their responsibilities to
`protect privacy information. The system records transactions in audit logs which are
`reviewed for inappropriate activity. No data is stored on the DOJ enrollment
`workstations. Once an enrollment package is transmitted to the GSA core system, all
`applicant information is deleted from the enrollment workstations.
`
`Section 4.0 Internal Sharing and Disclosure of Information within the
`System.
`
`The following questions are intended to define the scope of sharing both within
`the Department of Justice and with other recipients.
`
`4.1 With which internal components of the Department is the
`information shared?
`
`The information is entered at enrollment stations staffed by DOJ
`
`personnel, and is only shared internally by those filling the roles in the GSA managed
`service, listed below. DOJ internally fills 1, 2, 6, and 7. During the up-front background
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`investigation process and identity proofing, relevant personal data will also be matched
`against databases at the Federal Bureau of Investigations (FBI) to prevent the hiring of
`applicants with a criminal record or possible ties to terrorism.
`
` The roles are described below.
`
`1. PIV Sponsor: The individual who substantiates the need for a PIV credential to
`be issued to the Applicant and provides sponsorship to the Applicant. The PIV
`Sponsor requests the issuance of a PIV credential to the Applicant. PIV Sponsors
`shall meet the following minimum standards: (i) is a Federal Government
`employee and be authorized in writing by DOJ to request a PIV credential; (ii)
`have valid justification for requesting a PIV credential for an Applicant; (iii) be in
`a position of responsibility for DOJ; and (iv) have already been issued a valid PIV
`credential.
`
`
`
`• Using the GSA managed service, the PIV Sponsor completes a PIV Request
`for an applicant and submits it to the PIV Registrar and the PIV Issuer
`• For the initial effort of sponsoring large numbers of existing employees and
`contractors for PIV cards, a file containing sponsorship information on
`multiple individuals can be uploaded to the GSA managed service by the
`Security Officer, as described below. The individuals’ information in the file
`must first be reviewed and approved by a DOJ Sponsor and Adjudicator
`before upload. This process is referred to as “bulk upload.” Bulk upload files
`are sent from DOJ to the GSA managed service system over an encrypted
`interface. The bulk upload process is temporary and will be phased out over
`time.
`
`2. PIV Registrar: This role may be filled by DOJ or GSA personnel. The entity
`responsible for identity proofing of the Applicant and ensuring the successful
`completion of the background checks. The PIV Registrar provides the final
`approval for the issuance of a PIV credential to the Applicant. PIV Registrars
`shall meet the following minimum standards: (i) is a Federal Government official
`and is designated in writing as a PIV Registrar; (ii) is capable of assessing the
`integrity of the Applicant’s identity source documents; i.e., is trained to detect any
`improprieties in the applicant’s identity-proofing documents; and (iv) is capable
`of evaluating whether a PIV application is satisfactory and apply organization-
`specific processes to an unsatisfactory PIV application. Thus, the PIV Registrar
`needs training on organization processes and procedures for evaluating an
`unsatisfactory PIV application.
`
`The PIV Registrar has access to the following information:
`• Applicant’s SF 85, or equivalent
`• Two forms of identity source documents
`
`The PIV Registrar logs into an enrollment station and:
`
`
`
`
`
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`• Compares the applicant’s PIV request information (name, date of birth,
`contact information) with the corresponding information provided by the
`sponsor.
`• Captures a facial image of applicant.
`• Fingerprints the applicant, obtaining all fingerprints.
`•
`Initiates a NACI, unless NACI has already been completed.
`• Notifies the sponsor and designated PIV Issuer that applicant had been
`approved or not.
`
`
`
`3. PIV Issuer (GSA Managed Service): This role is described in Section 5,
`External Sharing and Disclosure.
`
`
`4. PIV Digital Signatory (GSA Managed Service): This role is described in
`Section 5, External Sharing and Disclosure
`
`
`5. PIV Authentication Certification Authority (CA): This role is described in
`Section 5, External Sharing and Disclosure
`
`6. PIV Adjudicator (DOJ): The entity responsible for determining whether the
`Applicant is suitable to receive a credential, based on results obtained from the
`OPM background investigation. Adjudicator responsibilities include: (i)
`confirming fingerprint results from OPM/FBI; (ii) adjudicating NACI (or higher
`level OPM investigation) and resolving issues if necessary; (iii) providing final
`results to the PIV Registrar; and (iv) updating the Official Personnel File (OPF) or
`Contract file with “Certificate of Investigation.”
`
`7. Security Officer (DOJ): The security officer is a DOJ individual authorized to
`physically collect revoked cards, and is the daily contact for agency employees to
`report lost, missing, or stolen PIV cards. The security officer is responsible for
`revoking or suspending PIV cards, if required. The Security Officer can also
`perform bulk uploads. All information on DOJ personnel in the IDMS can be
`viewed by the security officer.
`
`
`4.2 For each recipient component or office, what information is shared
`and for what purpose?
`
`As described in the section above, each of the roles logs into the GSA Managed
`
`Service system to execute their portion of the FIPS 201 card issuance process. The
`information involved and the purpose of the role is described in the section above. A
`“least privilege” role-based access system restricts access to data on a need-to-know
`basis; access to the data is limited to those with an operational need to access the
`information.
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`4.3 How is the information transmitted or disclosed?
`
`The information is transmitted from the enrollment station to the GSA IDMS using an
`encrypted virtual private network. No information is stored on the enrollment stations.
`The resulting PIV cards are mailed to DOJ. DOJ Sponsors, Adjudicators, and Security
`Officers access the GSA system using a web browser and an encrypted web session.
`Sponsorship data for bulk uploads may be prepared using desktop office automation
`software, such as spreadsheets, or a custom software tool developed to format
`sponsorship data and produce a bulk upload file. The bulk upload file is sent to the GSA
`managed service by a Security Officer over an encrypted connection. DOJ Registrars
`collect fingerprints and a digital photograph of the applicant and transmit an enrollment
`package to the IDMS using the enrollment workstations.
`
`4.4 Privacy Impact Analysis: Given the internal sharing, discuss
`what privacy risks were identified and how they were mitigated.
`
`The privacy risk is that private information could be compromised by any of the
`
`roles filled by DOJ personnel. The risk is mitigated by having trained, vetted personnel
`fill these roles. All access for DOJ personnel to the GSA Managed Service system is role
`based, and requires a PIV card to log in. Personnel must be appointed and undergo
`training, including their responsibilities to protect privacy information. DOJ receives
`periodic reports which detail card issuances, revocations, and other information on card
`statistics. These reports are reviewed by Security and Emergency Planning Staff.
`
`Section 5.0 External Sharing and Disclosure
`
`The following questions are intended to define the content, scope, and authority
`for information sharing external to DOJ which includes foreign, Federal, state and local
`government, and the private sector.
`
`5.1 With which external (non-DOJ) recipient(s) is the information
`shared?
`
`The information is shared with GSA as the outsourced provider of PIV cards.
`
`Specifically, GSA will fill the following roles:
`PIV Issuer (GSA Managed Service): The entity that performs credential
`personalization operations and issues the identity credential to the Applicant after all
`background checks, identity proofing, and related approvals have been completed.
`The PIV Issuer is also responsible for maintaining records and controls for PIV
`credential stock to ensure that stock is only used to issue valid credentials.
`
`
`
`The PIV Sponsor completes a PIV request for an applicant and submits it to the
`PIV Registrar and PIV Issuer. The PIV Registrar makes available following
`information to the PIV Issuer using the enrollment workstation:
`• Facial image
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`• Copy of result of background investigation
`• Other data associated with applicant (e.g. employee affiliation)
`
`
`PIV Digital Signatory (GSA Managed Service): The entity that digitally signs the
`PIV biometrics and CHUID. This role applies for PIV-II. The PIV Registrar makes
`available to the PIV Digital Signatory:
`• Electronic biometric data for card personalization
`• Other data associated with the applicant that is required for generating signed
`objects for card personalization.
`
`PIV Authentication Certification Authority (CA): The CA that signs and issues
`the PIV Authentication Certificate. This role applies to PIV-II
`
`
`
`
`During the up-front background investigation process and identity proofing,
`relevant personal data will also be shared with the Office of Personnel Management
`(OPM), which is responsible for conducting the NACI and other higher-level
`investigations for DOJ.
`
`Additionally, information about individuals that is stored for purposes of issuing a PIV
`card may be given without individual’s consent as permitted by the Privacy Act of 1974
`(5 U.S.C. § 552a(b)), including to:
`• an appropriate government law enforcement entity if records show a violation or
`potential violation of law;
`• a court or other adjudicative body when the records are relevant and necessary to a
`law suit;
`• a federal, state, local, tribal, or foreign agency whose records could facilitate a
`decision whether to retain an employee, continue a security clearance, or agree to a
`contract;
`• a Member of Congress or to Congressional staff at a constituent’s written request; to
`the Office of Management and Budget to evaluate private relief legislation;
`• agency contractors, grantees, or volunteers, who need access to the records to do
`agency work and who have agreed to comply with the Privacy Act;
`the National Archives and Records Administration for records management
`inspections; and
`• other federal agencies to notify them when a PIV card is no longer valid.
`
`The full system of records notice with complete description of routine uses was published
`in the Federal Register: GSA GOVT-7, Federal Personal Identity Verification Identity
`Management System (PIV IDMS), 71 FR 56983 (September 28, 2006).
`
`
`5.2 What information is shared and for what purpose?
`
`•
`
`As described in 5.1 above.
`
`5.3 How is the information transmitted or disclosed?
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`The information is transmitted electronically over encrypted VPNs from the
`enrollment station to the IDMS. Sponsorship information is sent by DOJ Sponsors using
`an encrypted web session. Sponsorship data for bulk uploads may be prepared using
`desktop office automation software, such as spreadsheets, or a custom software tool
`developed to format sponsorship data and produce a bulk upload file. The sponsorship
`software tool helps ensure the data is in the correct format prior to sending it to the GSA
`managed service system, reducing the risk of sending erroneous data. The bulk upload
`file is sent to the GSA managed service by a Security Officer over an encrypted
`connection. The completed PIV cards are mailed to DOJ.
`
`5.4 Are there any agreements concerning the security and privacy
`of the data once it is shared?
`
`Yes, the DOJ and GSA have signed a Memorandum of Understanding for DOJ to obtain
`PIV card services from GSA. There is an Interconnection Security Agreement describing
`data security and the responsibilities of GSA and DOJ for protecting the data.
`
`5.5 What type of training is required for users from agencies outside
`DOJ prior to receiving access to the information?
`
`All outside personnel undergo background investigations and must complete
`training to ensure they are knowledgeable about how to protect personally identifiable
`information. The training is accomplished by self-paced, web based learning modules
`which include an audio track, video clips, and screen shots.
`
`5.6 Are there any provisions in place for auditing the
`recipients’ use of the information?
`
`Yes. GSA maintains an audit trail and performs random periodic reviews to
`detect unauthorized access or suspicious behavior. The periodic reports on card issuance
`activity are reviewed by DOJ. DOJ Sponsors and the Security Officer can view
`information on DOJ personnel in the GSA system.
`
`5.7 Privacy Impact Analysis: Given the external sharing, what privacy
`risks were identified and describe how they were mitigated.
`
`The risks to privacy data from sending DOJ data to an external agency were
`
`considered in the decision to outsource PIV card services to GSA. There is the risk that
`data could be compromised by either an internal or external actor. The risk is mitigated
`by multiple technical, physical, and administrative controls. The GSA system must meet
`all Federal Information Security Management Act requirements, as well as OMB and
`NIST policies and standards. DOJ will conduct a careful review of the certification and
`accreditation activities performed by GSA prior to using the system for any DOJ data.
`
`
`Access to data is restricted by agency. Only DOJ appointed roles have access to
`DOJ data, with the exception of GSA database administrators and system administrators
`
`CARDWARE EXHIBIT 2032
`SAMSUNG V. CARDWARE
`PGR2023-00012
` Page 12 of 18
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`who have access to data from all agencies using the GSA managed service. All outside
`personnel undergo background investigations and must complete training to ensure they
`are knowledgeable about how to protect personally identifiable information. An
`Interagency Agreement and Interconnection Security Agreement define DOJ and GSA
`responsibilities to protect data.
`
`
`Section 6.0 Notice
`
`
`The following questions are directed at notice to the individual of the scope of
`information collected, the opportunity to consent to uses of said information, and the
`opportunity to decline to provide information.
`
`6.1 Was any form of notice provided to the individual prior to collection
`of information? If yes, please provide a copy of the notice as an
`appendix. (A notice may include a posted privacy policy, a Privacy Act
`notice on forms, or a system of records notice published in the Federal
`Register Notice.) If notice was not provided, why not?
`
`The System of Records Notice is attached as an appendix. The PIV Card Usage
`
`Privacy Act Notice is attached as an appendix.
`
`6.2 Do individuals have an opportunity and/or right to decline to
`provide information?
`
` While there is no legal requirement to use a PIV Card, employees who do not use a
`PIV Card will be treated as visitors when entering a federal building and will be barred
`from access to certain federal resources. If using a PIV card is a condition of the job,
`withholding requested information will affect job placement or employment prospects.
`
` 6.3 Do individuals have an opportunity to consent to particular uses of
`the information, and if so, what is the procedure by which an individual
`would provide such consent?
`
`PIV applicants using an electronic signature process conforming to the Electronic
`
`Signature (ESIGN) Act confirm presentation of and agreement with the Privacy Act
`statement, agree to participate in the PIV process and submit to a background check
`appropriate to job requirements.
`
`6.4 Privacy Impact Analysis: Given the notice provided to
`individuals above, describe what privacy risks were identified and
`how you mitigated them.
`
`CARDWARE EXHIBIT 2032
`SAMSUNG V. CARDWARE
`PGR2023-00012
` Page 13 of 18
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