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United States Government Accountability Office:
GAO:
Testimony:
Before the Subcommittee on Information Policy, Census, and National
Archives, Committee on Oversight and Government Reform:
For Release on Delivery:
Expected at 2 p.m. EDT:
Tuesday, March 11, 2008:
Privacy:
Government Use of Data from Information Resellers Could Include Better
Protections:
Statement of Linda D. Koontz, Director:
Information Management Issues:
GAO-08-543T:
GAO Highlights:
Highlights of GAO-08-543T, a testimony before Subcommittee on
Information Policy, Census, and National Archives, Committee on
Oversight and Government Reform.
Why GAO Did This Study:
Federal agencies collect and use personal information for various
purposes from information resellers—companies that amass and sell data
from many sources. GAO was asked to testify on its April 2006 report on
agency use of reseller data. For that report, GAO was asked to
determine how the Departments of Justice, Homeland Security, and State
and the Social Security Administration used personal data from
resellers and to review the extent to which agencies’ policies and
practices for handling this information reflected the Fair Information
Practices, a set of widely accepted principles for protecting the
privacy and security of personal data. GAO was also asked to provide an
update on the implementation status of its recommendations and to
comment on provisions of the proposed Federal Agency Data Protection
Act. In preparing this testimony, GAO relied primarily on its April
2006 report.
What GAO Found:
In fiscal year 2005, the Departments of Justice, Homeland Security, and
State and the Social Security Administration reported that they used
personal information obtained from resellers for a variety of purposes,
including performing criminal investigations, locating witnesses and
fugitives, researching assets held by individuals of interest, and
detecting prescription drug fraud. The agencies planned spending
approximately $30 million on contractual arrangements with resellers
that enabled the acquisition and use of such information. About 91
percent of the planned fiscal year 2005 spending was for law
enforcement (69 percent) or counterterrorism (22 percent).
Agency practices for handling personal information acquired from
information resellers did not always fully reflect the Fair Information
Practices. That is, for some of these principles, agency practices were
uneven. For example, although agencies issued public notices when they
systematically collected personal information, these notices did not
always notify the public that information resellers were among the
sources to be used. This practice is not consistent with the principle
that individuals should be informed about privacy policies and the
collection of information. Contributing to the uneven application of
the Fair Information Practices are ambiguities in guidance from the
Office of Management and Budget (OMB) regarding the applicability of
privacy requirements to federal agency uses of reseller information. In
addition, agencies generally lacked policies that specifically address
these uses.
GAO made recommendations to OMB to revise privacy guidance and to the
four agencies to develop specific policies for the use of personal
information from resellers. The five agencies generally agreed with the
report and described actions initiated to address the recommendations.
Since GAO issued its report, agencies have taken steps to address the
recommendations. For example, the Department of Homeland Security
Privacy Office incorporated specific questions in its May 2007 Privacy
Impact Assessment guidance concerning use of commercial data. In
addition, the Department of Justice took steps to update its public
notices to specify their use of data from information resellers. OMB,
however, has not implemented GAO’s recommendation to clarify guidance
on use of commercial data.
The Federal Agency Data Protection Act was introduced on December 18,
2007. The legislation, among other things would require that agencies
(1) conduct privacy impact assessments for their uses of commercial
data, and (2) promulgate regulations concerning the use of commercial
data brokers. GAO considers these requirements to be consistent with
the results and the recommendations made to the agencies in its 2006
report.
What GAO Recommends:
GAO is not making additional recommendations at this time. However, in
its 2006 report, GAO made recommendations to the Office of Management
and Budget and the four agencies to address agency use of personal
information from commercial sources. Agency officials generally agreed
with the content of the report. Since then, 2 of the 4 agencies have
taken steps to address its recommendations; however, OMB has not issued
clarified guidance.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.GAO-08-543T]. For more information, contact
Linda Koontz at (202) 512-6240 or KoontzL@gao.gov.
[End of section]
Abbreviations:
DEA: Drug Enforcement Administration:
DHS: Department of Homeland Security:
DOJ: Department of Justice:
FBI: Federal Bureau of Investigation:
OECD: Organization for Economic Cooperation and Development:
OIG: Office of the Inspector General:
OMB: Office of Management and Budget:
PIA: privacy impact assessments:
SSA: Social Security Administration:
State: Department of State:
TSA: Transportation Security Administration:
[End of section]
Mr. Chairman and Members of the Subcommittee:
I appreciate the opportunity to discuss critical issues surrounding the
federal government's purchase of personal information[Footnote 1] from
businesses known as information resellers. As you are aware, the ease
and speed with which people's personal information can be collected by
information resellers from a wide variety of sources and made available
to government and other customers has accelerated with technological
advances. In recent years, security breaches at large information
resellers such as ChoicePoint and LexisNexis have raised questions
about how resellers and their federal customers handle people's
personal information--and especially whether their practices are fully
consistent with widely accepted practices for protecting the privacy
and security of personal information.
Federal agency use of personal information is governed primarily by the
E-Government Act of 2002 and the Privacy Act of 1974. The E-Government
Act of 2002 strives to enhance protection for personal information in
government information systems by requiring that agencies conduct
privacy impact assessments (PIA). A PIA is an analysis of how personal
information is collected, stored, shared, and managed in a federal
system. The Privacy Act of 1974[Footnote 2] requires that the use of
personal information be limited to predefined purposes and involve only
information germane to those purposes. The provisions of the Privacy
Act, in turn, are largely based on a set of principles for protecting
the privacy and security of personal information, known as the Fair
Information Practices, which were first proposed in 1973 by a U.S.
government advisory committee.[Footnote 3] These principles, now widely
accepted, include:
1. collection limitation,
2. data quality,
3. purpose specification,
4. use limitation,
5. security safeguards,
6. openness,
7. individual participation, and:
8. accountability.[Footnote 4]
These principles, with some variation, are used by organizations to
address privacy considerations in their business practices and are also
the basis of privacy laws and related policies in many countries,
including the United States, Germany, Sweden, Australia, and New
Zealand, as well as the European Union.
As agreed, my testimony today will be based primarily on the agency
information contained in a report we issued in April 2006.[Footnote 5]
For that report, we analyzed fiscal year 2005 contracts and other
vehicles for the acquisition of personal information from information
resellers by the Departments of Justice (DOJ), Homeland Security (DHS),
and State (State) and the Social Security Administration (SSA). We
compared relevant agency guidelines and management policies and
procedures to the Fair Information Practices. We also updated the
implementation status of recommendations contained in our 2006 report
and analyzed provisions of the proposed Federal Agency Data Protection
Act.[Footnote 6] Our work was performed in accordance with generally
accepted government auditing standards. Those standards require that we
plan and perform the audit to obtain sufficient, appropriate evidence
to provide a reasonable basis for our findings and conclusions based on
our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit
objectives.
Today, after a brief summary of the laws that govern agency use of
personal information, I will summarize the information contained in our
2006 report on how the selected agencies used the personal information
that they purchased from resellers and the extent to which the agencies
had policies and practices that reflected the Fair Information
Practices. I will also provide an update on steps taken by the agencies
to address the recommendations contained in our 2006 report. Finally, I
will comment on specific privacy related provisions of the proposed
Federal Agency Data Protection Act.
Results in Brief:
In fiscal year 2005, DOJ, DHS, State, and SSA reported that they
planned to spend a combined total of approximately $30 million[Footnote
7] to purchase personal information from resellers. The vast majority-
-approximately 91 percent--of the planned spending was for purposes of
law enforcement (69 percent) or counterterrorism (22 percent). For
example, components of DOJ (the largest user of resellers) used the
information for criminal investigations, locating witnesses and
fugitives, researching assets held by individuals of interest, and
detecting fraud in prescription drug transactions. DHS acquired
personal information to aid its immigration fraud detection and border
screening programs. SSA and State purchased personal information from
information resellers to detect and investigate fraud, verify
identities, and determine benefits eligibility.
Agency practices for handling personal information acquired from
information resellers reflected four of eight principles established by
the Fair Information Practices. Agency practices generally reflected
the collection limitation, data quality, use limitation, and security
safeguards principles. For example, law enforcement agencies (including
the Federal Bureau of Investigation and the U.S. Secret Service)
generally reported that they corroborate information obtained from
resellers to ensure that it is accurate when it is used as part of an
investigation, reflecting the data quality principle that data should
be accurate, current, and complete, as needed for the defined purpose.
However, agencies did not always have practices for handling reseller
information to fully address the purpose specification, individual
participation, openness, and accountability principles. For example:
* Although agencies notified the public through Federal Register
notices and published PIAs that they collected personal information
from various sources, they did not always indicate specifically that
information resellers were among those sources.
* Some agencies lacked robust audit mechanisms to ensure that use of
personal information from information resellers was for permissible
purposes, reflecting an uneven application of the accountability
principle.
Contributing to agencies' uneven application of the Fair Information
Practices were ambiguities in guidance from the Office of Management
and Budget (OMB) on how privacy requirements apply to federal agency
uses of reseller information. In addition, agencies generally lacked
policies that specifically address these uses.
We made recommendations to OMB to revise privacy guidance and to the
four agencies to develop specific policies for the use of personal
information from resellers. The agencies generally agreed with the
report and described actions initiated to address our recommendations.
Since we issued our report, two of the four agencies have taken steps
to address our recommendations. For example, the DHS Privacy Office
incorporated specific questions in its May 2007 PIA guidance concerning
use of commercial data. In addition, DOJ took steps to ensure that
their system-of-records notices specifically reference their use of
data from information resellers. OMB, however, has not implemented our
recommendation to clarify guidance on use of commercial data.
On December 18, 2007, the Federal Agency Data Protection Act was
introduced. This legislation, among other things would require that
agencies (1) conduct PIAs for their uses of commercial data and (2)
promulgate regulations concerning the use of commercial data brokers.
We believe that these requirements are consistent with the results of
our 2006 report and the recommendations we made to the agencies.
Background:
Before advanced computerized techniques, obtaining people's personal
information usually required visiting courthouses or other government
facilities to inspect paper-based public records, and information
contained in product registrations and other business records was not
generally available at all. Automation of the collection and
aggregation of multiple-source data, combined with the ease and speed
of its retrieval, have dramatically reduced the time and effort needed
to obtain such information. Information resellers provide services
based on these technological advances.
We use the term "information resellers" to refer to businesses that
vary in many ways but have in common collecting and aggregating
personal information from multiple sources and making it available to
their customers. These businesses do not all focus exclusively on
aggregating and reselling personal information. For example, Dun &
Bradstreet primarily provides information on commercial enterprises for
the purpose of contributing to decision making regarding those
enterprises. In doing so, it may supply personal information about
individuals associated with those commercial enterprises. To a certain
extent, the activities of information resellers may also overlap with
the functions of consumer reporting agencies, also known as credit
bureaus--entities that collect and sell information about individuals'
creditworthiness, among other things. To the extent that information
resellers perform the functions of consumer reporting agencies, they
are subject to legislation specifically addressing that industry,
particularly the Fair Credit Reporting Act.
Information resellers have now amassed extensive amounts of personal
information about large numbers of Americans. They supply it to
customers in both government and the private sector, typically via a
centralized online resource. Generally, three types of information are
collected:
* Public records such as birth and death records, property records,
motor vehicle and voter registrations, criminal records, and civil case
files.
* Publicly available information not found in public records but
nevertheless publicly available through other sources, such as
telephone directories, business directories, classified ads or
magazines, Internet sites, and other sources accessible by the general
public.
* Nonpublic information derived from proprietary or nonpublic sources,
such as credit header data,[Footnote 8] product warranty registrations,
and other application information provided to private businesses
directly by consumers.
* Figure 1 illustrates how these types of information are collected and
aggregated into reports that are ultimately accessed by customers,
including government agencies.
Figure 1: Typical Information Flow through Resellers to Government
Customers:
[See PDF for image]
This figure is an illustration of the typical information flow through
resellers to government customers. The following information is
depicted:
Sources:
Public records;
Publicly available information;
Nonpublic information.
Information resellers:
Collected information from sources stored in databases;
Information from databases is aggregated into a report;
Queries are received from users through the internet;
Reports are generated to users via the internet.
Users:
Agency makes a query via the internet to information resellers;
Agency received reports via the internet from information resellers.
Source: GAO analysis of information reseller and agency-provided data.
[End of figure]
Federal Laws and Guidance Govern Use of Personal Information in Federal
Agencies:
No single federal law governs all use or disclosure of personal
information. The major requirements for the protection of personal
privacy by federal agencies come from the Privacy Act of 1974 and the
privacy provisions of the E-Government Act of 2002.
Federal use of personal information is governed primarily by the
Privacy Act of 1974,[Footnote 9] which places limitations on agencies'
collection, disclosure, and use of personal information maintained in
systems of records. The act describes a "record" as any item,
collection, or grouping of information about an individual that is
maintained by an agency and contains his or her name or another
personal identifier. It also defines "system of records" as a group of
records under the control of any agency from which information is
retrieved by the name of the individual or by an individual identifier.
The Privacy Act requires that when agencies establish or make changes
to a system of records, they must notify the public by placing a notice
in the Federal Register identifying, among other things, the type of
data collected, the types of individuals about whom the information is
collected, the routine uses[Footnote 10] of the data, and procedures
that individuals can use to review and correct their personal
information. Additional provisions of the Privacy Act are discussed in
the 2006 report.
The E-Government Act of 2002 requires that agencies conduct PIAs. A PIA
is an analysis of how personal information is collected, stored,
shared, and managed in a federal system. Under the E-Government Act and
related OMB guidance, agencies must conduct PIAs (1) before developing
or procuring information technology that collects, maintains, or
disseminates information that is in a personally identifiable form; (2)
before initiating any new data collections involving personal
information that will be collected, maintained, or disseminated using
information technology if the same questions are asked of 10 or more
people; or (3) when a system change creates new privacy risks, for
example, by changing the way in which personal information is being
used.
OMB is tasked with providing guidance to agencies on how to implement
the provisions of the Privacy Act and the E-Government Act and has done
so, beginning with guidance on the Privacy Act, issued in
1975.[Footnote 11] OMB's guidance on implementing the privacy
provisions of the E-Government Act of 2002 identifies circumstances
under which agencies must conduct PIAs and explains how to conduct
them.
The PIA mandate in the E-Government Act of 2002 provided a mechanism by
which agencies can consider privacy in the earliest stages of system
development. PIAs can be an important tool to help agencies to address
openness and purpose specification principles early in the process of
developing new information systems. To the extent that PIAs are made
publicly available,[Footnote 12] they provide explanations to the
public about such things as the information that will be collected, why
it is being collected, how it is to be used, and how the system and
data will be maintained and protected.
The Fair Information Practices Are Widely Agreed to Be Key Principles
for Privacy Protection:
The Privacy Act of 1974 is largely based on a set of internationally
recognized principles for protecting the privacy and security of
personal information known as the Fair Information Practices. A U.S.
government advisory committee first proposed the practices in 1973 to
address what it termed a poor level of protection afforded to privacy
under contemporary law.[Footnote 13] The Organization for Economic
Cooperation and Development (OECD)[Footnote 14] developed a revised
version of the Fair Information Practices in 1980. This version of the
principles was reaffirmed by OECD ministers in a 1998 declaration and
further endorsed in a 2006 OECD report.[Footnote 15] The Fair
Information Practices, have, with some variation, formed the basis of
privacy laws and related policies in many countries, including the
United States, Germany, Sweden, Australia, and New Zealand, as well as
the European Union.[Footnote 16]
In addition, in its 2007 report, Engaging Privacy and Information
Technology in a Digital Age, the National Research Council[Footnote 17]
found that the principles of fair information practice for the
protection of personal information are as relevant today as they were
in 1973. Accordingly, the committee recommended that the Fair
Information Practices should be extended as far as reasonably feasible
to apply to private sector organizations that collect and use personal
information. The eight principles of the OECD Fair Information
Practices are shown in table 1.
Table 1: The OECD Fair Information Practices:
Principle: Collection limitation;
Description: The collection of personal information should be limited,
should be obtained by lawful and fair means, and, where appropriate,
with the knowledge or consent of the individual.
Principle: Data quality;
Description: Personal information should be relevant to the purpose for
which it is collected, and should be accurate, complete, and current as
needed for that purpose.
Principle: Purpose specification;
Description: The purposes for the collection of personal information
should be disclosed before collection and upon any change to that
purpose, and its use should be limited to those purposes and compatible
purposes.
Principle: Use limitation;
Description: Personal information should not be disclosed or otherwise
used for other than a specified purpose without consent of the
individual or legal authority.
Principle: Security safeguards;
Description: Personal information should be protected with reasonable
security safeguards against risks such as loss or unauthorized access,
destruction, use, modification, or disclosure.
Principle: Openness;
Description: The public should be informed about privacy policies and
practices, and individuals should have ready means of learning about
the use of personal information.
Principle: Individual participation;
Description: Individuals should have the following rights: to know
about the collection of personal information, to access that
information, to request correction, and to challenge the denial of
those rights.
Principle: Accountability;
Description: Individuals controlling the collection or use of personal
information should be accountable for taking steps to ensure the
implementation of these principles.
Source: OECD.
[End of table]
The Fair Information Practices are not precise legal requirements.
Rather, they provide a framework of principles for balancing the need
for privacy with other public policy interests, such as national
security, law enforcement, and administrative efficiency. Ways to
strike that balance vary among countries and according to the type of
information under consideration.
Agencies Used Governmentwide Contracts to Obtain Personal Information
from Information Resellers for a Variety of Purposes:
DOJ, DHS, State, and SSA reported approximately $30 million through
contracts with information resellers in fiscal year 2005.[Footnote 18]
The agencies reported using personal information obtained from
resellers for a variety of purposes including law enforcement,
counterterrorism, fraud detection/prevention, and debt collection. In
all, approximately 91 percent of agency uses of reseller data were in
the categories of law enforcement (69 percent) or counterterrorism (22
percent). Figure 2 details contract values categorized by their
reported use.
Figure 2: Fiscal Year 2005 Contractual Vehicles Enabling the Use of
Personal Information from Information Resellers, Categorized by
Reported Use:
[See PDF for image]
This figure is a pie-chart depicting Fiscal Year 2005 Contractual
Vehicles Enabling the Use of Personal Information from Information
Resellers, Categorized by Reported Use. The following data is depicted:
Law enforcement: 69%;
Counterterrorism: 22%;
Fraud detection/prevention: 4%;
Debt collection: 3%;
Other: 2%.
Source: GAO analysis of agency-provided data.
[End of figure]
DOJ, which accounted for about 63 percent of the funding, mostly used
the data for law enforcement and counterterrorism. DHS also used
reseller information primarily for law enforcement and
counterterrorism. State and SSA reported acquiring personal information
from information resellers for fraud prevention and detection, identity
verification, and benefits eligibility determination.
DOJ and DHS Used Information Resellers Primarily for Law Enforcement
and Counterterrorism:
In fiscal year 2005, DOJ and its components reported approximately $19
million through contracts with a wide variety of information resellers,
primarily for purposes related to law enforcement (75 percent) and
counterterrorism (18 percent). The Federal Bureau of Investigation
(FBI), which is DOJ's largest user of information resellers, used
reseller information to, among other things, analyze intelligence and
detect terrorist activities in support of ongoing investigations by law
enforcement agencies and the intelligence community. In this capacity,
resellers provided the FBI's Foreign Terrorist Tracking Task Force with
names, addresses, telephone numbers, and other biographical and
demographical information as well as legal briefs, vehicle and boat
registrations, and business ownership records.[Footnote 19]
The Drug Enforcement Administration (DEA), the second largest DOJ user
of information resellers in fiscal year 2005, obtained reseller data
primarily to detect fraud in prescription drug transactions.[Footnote
20] Agents used reseller data to detect irregular prescription patterns
for specific drugs and trace this information to the pharmacy and
prescribing doctor.[Footnote 21]
DHS and its components reported that they used information reseller
data in fiscal year 2005 primarily for law enforcement purposes, such
as developing leads on subjects in criminal investigations and
detecting fraud in immigration benefit applications (part of enforcing
immigration laws). DHS's largest investigative component, the U.S.
Immigration and Customs Enforcement, is also its largest user of
personal information from resellers. It collected data such as address
and vehicle information for criminal investigations and background
security checks. Another DHS component, U.S. Customs and Border
Protection, conducts queries on people, businesses, property. The
Federal Emergency Management Agency, an additional component, used an
information reseller to detect fraud in disaster assistance
applications.
DHS also reported using information resellers in its counterterrorism
efforts. For example, the Transportation Security Administration (TSA),
a DHS component, used data obtained from information resellers as part
of a test associated with the development of its domestic passenger
prescreening program, called Secure Flight.[Footnote 22] TSA planned
for Secure Flight to compare domestic flight reservation information
submitted to TSA by aircraft operators with federal watch lists of
individuals known or suspected of activities related to
terrorism.[Footnote 23]
SSA and State Used Information Resellers Primarily for Fraud Prevention
and Detection:
In an effort to ensure the accuracy of Social Security benefit
payments, the SSA and its components reported approximately $1.3
million in contracts with information resellers in fiscal year 2005 for
purposes relating to fraud prevention (such as skiptracing),[Footnote
24] confirming suspected fraud related to workers' compensation
payments, obtaining information on criminal suspects for follow-up
investigations, and collecting debts. For example, the Office of the
Inspector General (OIG), the largest user of information reseller data
at SSA, used several information resellers to assist investigative
agents in detecting benefits abuse by Social Security claimants and to
assist agents in locating claimants. Regional office agents may also
use reseller data in investigating persons suspected of claiming
disability fraudulently.
State and its components reported approximately $569,000 in contracts
with information resellers for fiscal year 2005, mainly to support
investigations of passport-related activities. For example, several
components accessed personal information to validate familial
relationships, birth and identity data, and other information submitted
on immigrant and nonimmigrant visa petitions. State also used reseller
data to investigate passport and visa fraud cases.
Agencies Lacked Policies on Use of Reseller Data, and Practices Do Not
Consistently Reflect the Fair Information Practices:
Agencies generally lacked policies that specifically addressed their
use of personal information from commercial sources (although DHS
Privacy Office officials reported in 2006 that they were drafting such
a policy[Footnote 25]), and agency practices for handling personal
information acquired from information resellers did not always fully
reflect the Fair Information Practices. Specifically, agency practices
generally reflected four of the eight Fair Information Practices.
As table 2 shows, the collection limitation, data quality, use
limitation, and security safeguards principles were generally reflected
in agency practices. For example, several agency components
(specifically, law enforcement agencies such as the FBI and the U.S.
Secret Service) reported that in practice, they generally corroborate
information obtained from resellers when it is used as part of an
investigation. This practice is consistent with the principle of data
quality.
Agency policies and practices with regard to the other four principles
were uneven. Specifically, agencies did not always have policies or
practices in place to address the purpose specification, openness, and
individual participation principles with respect to reseller data. The
inconsistencies in applying these principles as well as the lack of
specific agency policies can be attributed in part to ambiguities in
OMB guidance regarding the applicability of the Privacy Act to
information obtained from resellers. Further, privacy impact
assessments, a valuable tool that could address important aspects of
the Fair Information Practices, were often not conducted. Finally,
components within each of the four agencies did not consistently hold
staff accountable by monitoring usage of personal information from
information resellers and ensuring that it was appropriate; thus, their
application of the fourth principle, accountability, was uneven.
Table 2: Application of Fair Information Practices to the Reported
Handling of Personal Information from Data Resellers at Four Agencies:
Principle: Collection limitation. The collection of personal
information should be limited, should be obtained by lawful and fair
means, and, where appropriate, with the knowledge or consent of the
individual;
Agency application of principle: General;
Agency practices: Agencies limited personal data collection to
individuals under investigation or their associates.
Principle: Data quality. Personal information should be relevant to the
purpose for which it is collected, and should be accurate, complete,
and current as needed for that purpose;
Agency application of principle: General;
Agency practices: Agencies corroborated information from resellers and
did not take actions based exclusively on such information.
Principle: Purpose specification. The purpose for the collection of
personal information should be disclosed before collection and upon any
change to that purpose, and its use should be limited to that purpose
and compatible purposes;
Agency application of principle: Uneven;
Agency practices: Agency system-of-records notices did not generally
reveal that agency systems could incorporate information from data
resellers. Agencies also generally did not conduct privacy impact
assessments for their systems or programs that involve use of reseller
data.
Principle: Use limitation. Personal information should not be disclosed
or otherwise used for other than a specified purpose without consent of
the individual or legal authority;
Agency application of principle: General;
Agency practices: Agencies generally limited their use of personal
information to specific investigations (including law enforcement,
counterterrorism, fraud detection, and debt collection).
Principle: Security safeguards. Personal information should be
protected with reasonable security safeguards against risks such as
loss or unauthorized access, destruction, use, modification, or
disclosure;
Agency application of principle: General;
Agency practices: Agencies had security safeguards such as requiring
passwords to access databases, basing access rights on need to know,
and logging search activities (including "cloaked logging," which
prevents the vendor from monitoring search content).
Principle: Openness. The public should be informed about privacy
policies and practices, and individuals should have ready means of
learning about the use of personal information;
Agency application of principle: Uneven;
Agency practices: See Purpose specification above. Agencies did not
have established policies specifically addressing the use of personal
information obtained from resellers.
Principle: Individual participation. Individuals should have the
following rights: to know about the collection of personal information,
to access that information, to request correction, and to challenge the
denial of those rights;
Agency application of principle: Uneven;
Agency practices: See Purpose specification above. Because agencies
generally did not disclose their collections of personal information
from resellers, individuals were often unable to exercise these rights.
Principle: Accountability. Individuals controlling the collection or
use of personal information should be accountable for taking steps to
ensure the implementation of these principles;
Agency application of principle: Uneven;
Agency practices: Agencies did not generally monitor usage of personal
information from information resellers to hold users accountable for
appropriate use; instead, they relied on users to be responsible for
their behavior. For example, agencies may instruct users in their
responsibilities to use personal information appropriately, have them
sign statements of responsibility, and have them indicate what
permissible purpose a given search fulfills.
Source: GAO analysis of agency-supplied data.
Legend:
General = policies or procedures to address all major aspects of a
particular principle.
Uneven = policies or procedures addressed some, but not all, aspects of
a particular principle or some but not all agencies and components had
policies or practices in place addressing the principle.
Note: We did not independently assess the effectiveness of agency
information security programs. Our assessment of overall agency
application of the Fair Information Practices was based on the policies
and management practices described by the Department of State and SSA
as a whole and by major components of DOJ and DHS. We did not obtain
information on smaller components of DOJ and DHS.
[End of table]
Agency procedures generally reflected the collection limitation, data
quality, use limitation, and security safeguards principles. Regarding
collection limitation, for most law-enforcement and counterterrorism
purposes (which accounted for 90 percent of usage in fiscal year 2005),
agencies generally limited their personal data collection in that they
reported obtaining information only on specific individuals under
investigation or associates of those individuals. Regarding data
quality, agencies reported taking steps to mitigate the risk of
inaccurate information reseller data by corroborating information
obtained from resellers. Agency officials described the practice of
corroborating information as a standard element of conducting
investigations. Likewise, for non-law-enforcement use, such as debt
collection and fraud detection and prevention, agency components
reported that they mitigated potential problems with the accuracy of
data provided by resellers by obtaining additional information from
other sources when necessary. As for use limitation, agency officials
said their use of reseller information was limited to distinct purposes
that were generally related to law enforcement or counterterrorism.
Finally, while we did not assess the effectiveness of information
security at any of these agencies, we found that all four had measures
in place intended to safeguard the security of personal information
obtained from resellers.[Footnote 26]
Limitations in the Applicability of the Privacy Act and Ambiguities in
OMB Guidance Contributed to an Uneven Adherence to the Purpose
Specification, Openness, and Individual Participation Principles:
The purpose specification, openness, and individual participation
principles stipulate that individuals should be made aware of the
purpose and intended uses of the personal information being collected
about them, and, if necessary, have the ability to access and correct
their information. These principles are reflected in the Privacy Act
requirement for agencies to publish in the Federal Register, "upon
establishment or revision, a notice of the existence and character of a
system of records." This notice is to include, among other things, the
categories of records in the system as well as the categories of
sources of records.[Footnote 27]
In a number of cases, agencies using reseller information did not
adhere to the purpose specification or openness principles in that they
did not notify the public that they were using such information and did
not specify the purpose for their data collections. Agency officials
said that they generally did not prepare system-of-records notices that
would address these principles because they were not required to do so
by the Privacy Act. The act's vehicle for public notification--the
system-of-records notice--is required of an agency only when the agency
collects, maintains, and retrieves personal data in the way defined by
the act or when a contractor does the same thing explicitly on behalf
of the government. Agencies generally did not issue system-of-records
notices specifically for their use of information resellers largely
because information reseller databases were not considered "systems of
records operated by or on behalf of a government agency" and thus were
not considered subject to the provisions of the Privacy Act.[Footnote
28] OMB guidance on implementing the Privacy Act does not specifically
refer to the use of reseller data or how it should be treated.
According to OMB and other agency officials, information resellers
operate their databases for multiple customers, and federal agency use
of these databases does not amount to the operation of a system of
records on behalf of the government. Further, agency officials stated
that merely querying information reseller databases did not amount to
agency "maintenance" of the personal information being queried and thus
also did not trigger the provisions of the Privacy Act. In many cases,
agency officials considered their use of resellers to be of this type-
-essentially "ad hoc" querying or "pinging" of reseller databases for
personal information about specific individuals, which they believed
they were not doing in connection with a formal system of records.
In other cases, however, agencies maintained information reseller data
in systems for which system-of-records notices had been previously
published. For example, law enforcement agency officials stated that,
to the extent they retain the results of reseller data queries, this
collection and use is covered by the system-of-records notices for
their case file systems. However, in preparing such notices, agencies
generally did not specify that they were obtaining information from
resellers. Among system-of-records notices that were identified by
agency officials as applying to the use of reseller data, only one--
TSA's system-of-records notice for the test phase of its Secure Flight
program--specifically identified the use of information reseller
data.[Footnote 29]
In several of these cases, agency sources for personal information were
described only in vague terms, such as "private organizations," "other
public sources," or "public source material," when information was
being obtained from information resellers.
The inconsistency with which agencies specify resellers as a source of
information in system-of-records notices is due in part to ambiguity in
OMB guidance, which states that "for systems of records which contain
information obtained from sources other than the individual to whom the
records pertain, the notice should list the types of sources
used."[Footnote 30] Although the guidance is unclear as to what would
constitute adequate disclosure of "types of sources," OMB and DHS
Privacy Office officials agreed that to the extent that reseller data
is subject to the Privacy Act, agencies should specifically identify
information resellers as a source and that merely citing public records
information does not sufficiently describe the source.
Aside from certain law enforcement exemptions[Footnote 31] to the
Privacy Act, adherence to the purpose specification and openness
principles is critical to preserving a measure of individual control
over the use of personal information. Without clear guidance from OMB
or specific policies in place, agencies have not consistently reflected
these principles in their collection and use of reseller information.
As a result, without being notified of the existence of an agency's
information collection activities, individuals have no ability to know
that their personal information could be obtained from commercial
sources and potentially used as a basis, or partial basis, for taking
action that could have consequences for their welfare.
Privacy Impact Assessments Could Address Openness and Purpose
Specification Principles but Often Were Not Conducted:
PIAs can be an important tool to help agencies to address openness and
purpose specification principles early in the process of developing new
information systems. To the extent that PIAs are made publicly
available,[Footnote 32] they provide explanations to the public about
things such as the information that will be collected, why it is being
collected, how it is to be used, and how the system and data will be
maintained and protected.
However, few agency components reported developing PIAs for their
systems or programs that make use of information reseller data. As with
system-of-records notices, agencies often did not conduct PIAs because
officials did not believe they were required. Current OMB guidance on
conducting PIAs is not always clear about when they should be
conducted. According to guidance from OMB, a PIA is required by the E-
Government Act when agencies "systematically incorporate into existing
information systems databases of information in identifiable form
purchased or obtained from commercial or public sources."[Footnote 33]
However, the same guidance also instructs agencies that "merely
querying a database on an ad hoc basis does not trigger the PIA
requirement." Reported uses of reseller data were generally not
described as a "systematic" incorporation of data into existing
information systems; rather, most involved querying a database and, in
some cases, retaining the results of these queries. OMB officials
stated that agencies would need to make their own judgments on whether
retaining the results of searches of information reseller databases
constituted a "systematic incorporation" of information.
Until PIAs are conducted more thoroughly and consistently, the public
is likely to remain incompletely informed about agency purposes and
uses for obtaining reseller information.
Agencies Often Did Not Have Practices in Place to Ensure Accountability
for Proper Handling of Information Reseller Data:
According to the accountability principle, individuals controlling the
collection or use of personal information should be accountable for
ensuring the implementation of the Fair Information Practices. This
means that agencies should take steps to ensure that they use personal
information from information resellers appropriately.
Agencies described using activities to oversee their use of reseller
information that were largely based on trust in the individual user to
use the information appropriately, rather than on management oversight
of usage details. For example, in describing controls placed on the use
of commercial data, officials from component agencies identified
measures such as instructing users that reseller data are for official
use only and requiring users to sign statements attesting 1) to their
need to access information reseller databases and 2) that their use
will be limited to official business. Additionally, agency officials
reported that their users are required to select from a list of vendor-
defined "permissible purposes" (for example, law enforcement,
transactions authorized by the consumer) before conducting a search on
reseller databases.
While these practices appear consistent with the accountability
principle, they are focused on individual user responsibility instead
of monitoring and oversight. Agencies did not have practices in place
to obtain reports from resellers that would allow them to monitor usage
of reseller databases at a detailed level. Although agencies generally
receive usage reports from the information resellers, these reports are
designed primarily for monitoring costs. Further, these reports
generally contained only high-level statistics on the number of
searches and databases accessed, not the contents of what was actually
searched, thus limiting their utility in monitoring usage.
To the extent that federal agencies do not implement methods such as
user monitoring or auditing of usage records, they provide limited
accountability for their usage of information reseller data and have
limited assurance that the information is being used appropriately.
Not All Agencies Have Taken Steps to Address our Recommendations:
In our report, we recommended that the agencies develop specific
policies for the collection, maintenance, and use of personal
information obtained from resellers. We also recommended that OMB
revise its privacy guidance to clarify the applicability of
requirements for public notices and privacy impact assessments to
agency use of personal information from resellers and direct agencies
to review their uses of such information to ensure it is explicitly
referenced in privacy notices and assessments. The agencies generally
agreed with our findings and described actions initiated to address our
recommendations.
Since the issuance of our 2006 report, two of the four agencies have
taken action to address our recommendation. For example, the DHS
Privacy Office incorporated specific questions in its May 2007 PIA
guidance concerning use of commercial data. The guidance requires
programs that use commercial or publicly available data to explain why
and how such data are used. Further, the guidance for systems that use
or rely on commercial data requires an explanation of how data accuracy
and integrity are preserved and the reliability of the data assessed
with regard to its value to the purpose of the system. According to DHS
Privacy Office officials, after identifying use of commercial data
through the PIA process, the Privacy Office works with the relevant DHS
component to review uses of commercial data to ensure appropriate
controls are in place and that the planned uses are appropriately
disclosed in privacy notices. In addition, officials at DOJ informed us
that the Privacy and Civil Liberties Office has in place a verbal
agreement with agency components that there are to be no bulk
acquisitions of commercial data and that when the agency takes in data
from commercial sources, there should be a valid system-of-records
notice that specifically identifies commercial data as a source.
Further, DOJ has updated several of its system-of-records notices to
reflect their use of data from information resellers. SSA and State
have not yet addressed our recommendation.
However, OMB has not addressed our recommendations. In an August 2006
letter to congressional committees in response to the recommendations
contained in our April 2006 report, OMB noted that work on the
protection of personal information through the Identity Theft Task
Force was ongoing and that following the completion of this work, they
would consider issuing appropriate clarifying guidance concerning
reseller data. Since then, OMB's efforts on the Identity Theft Task
Force have been completed and on May 22, 2007 OMB issued M-07-16,
"Safeguarding Against the Breach of Personally Identifiable
Information." To date, OMB has not issued additional clarifying
guidance concerning reseller data.
Privacy Provisions of the Proposed Federal Agency Data Protection Act
are Consistent with Our Recommendations:
The Federal Agency Data Protection Act was introduced on December 18,
2007. Among other things, the legislation contains privacy provisions
that would require agencies to conduct PIAs when "purchasing or
subscribing for a fee to information in identifiable form from a data
broker." We believe that such a requirement is consistent with the
recommendations contained in our report, particularly given the debate
concerning whether or not agencies "systematically incorporate"
information or are "merely pinging or querying the information." Our
report found that PIAs could serve to address certain Fair Information
Practice principles such as purpose specification and openness, but
often were not conducted. Such a requirement could more readily ensure
agencies perform these assessments. Further, since OMB has not
clarified its guidance on this issue, a requirement in law could
provide needed direction to agencies.
The proposed Federal Agency Data Protection Act would also require each
agency to prescribe regulations that specify, among other things, the
personnel permitted to access, analyze, or otherwise use commercial
reseller databases. This legislation is consistent with our
recommendation that agencies develop policies concerning their use of
personal information from information resellers.
In summary, services provided by information resellers are important to
federal agency functions such as law enforcement and fraud protection
and identification. While agencies have taken steps to adhere to some
Fair Information Practices such as the collection limitation, data
quality, use limitation, and security safeguards principles, they have
not taken all the steps they could to reflect others--or to use the
specific processes of the Privacy Act and E-Government Act
requirements--in their handling of reseller data. Because OMB privacy
guidance does not clearly address information reseller data, agencies
are left largely on their own to determine how to satisfy legal
requirements and protect privacy when acquiring and using reseller
data. Since we issued our report in 2006, two of the four agencies have
taken steps to address our recommendations. However, OMB has not
modified its guidance. Without current and specific guidance, the
government risks continued uneven adherence to important, well-
established privacy principles and lacks assurance that the privacy
rights of individuals are being adequately protected. Absent action
from OMB to revise guidance, privacy provisions contained in the
proposed Federal Agency Data Protection Act could clarify the need to
conduct privacy impact assessments wherever reseller data are involved
and promote the development of agency policies and procedures
concerning the use of such data. We believe these provisions are
consistent with the results and recommendations contained in our 2006
report.
Mr. Chairman, this concludes my testimony today. I would be happy to
answer any questions you or other members of the subcommittee may have.
Contacts and Acknowledgements:
If you have any questions concerning this testimony, please contact
Linda Koontz, Director, Information Management, at (202) 512-6240, or
koontzl@gao.gov. Other individuals who made key contributions to this
testimony were Susan Czachor, John de Ferrari, Nancy Glover, Rebecca
LaPaze, David Plocher, and Jamie Pressman.
[End of section]
Footnotes:
[1] For purposes of this report, the term personal information is
defined as any information about an individual maintained by an agency,
including (1) any information that can be used to distinguish or trace
an individual's identity, such as name, Social Security number, date
and place of birth, mother's maiden name, or biometric records, and (2)
any other information that is linked or linkable to an individual, such
as medical, educational, financial, and employment information.
[2] The Privacy Act of 1974, Pub. L. No. 93-579, 88 Stat. 1896
(codified as amended at 5 U.S.C. § 552a) provides safeguards against an
invasion of privacy through the misuse of records by federal agencies
and allows citizens to learn how their personal information is
collected, maintained, used, and disseminated by the federal
government.
[3] Congress used the committee's final report as a basis for crafting
the Privacy Act of 1974. See U.S. Department of Health, Education, and
Welfare, Records, Computers, and the Rights of Citizens: Report of the
Secretary's Advisory Committee on Automated Personal Data Systems
(Washington, D.C.; July 1973).
[4] Descriptions of these principles are shown in table 1.
[5] GAO, Personal Information: Agency and Reseller Adherence to Key
Privacy Principles, GAO-06-421 (Washington, D.C.: Apr. 4, 2006).
[6] H.R. 4791, Federal Agency Data Protection Act, 110TH Cong.,
introduced by Representative Wm. Lacy Clay, December 18, 2007.
[7] This figure may include uses that do not involve personal
information. Except for instances where the reported use was primarily
for legal research, agency officials were unable to separate the dollar
values associated with use of personal information from uses for other
purposes (for example, LexisNexis and West provide news and legal
research in addition to public records). The four agencies obtained
personal information from resellers primarily through two general-
purpose governmentwide contract vehicles--the Federal Supply Schedule
of the General Services Administration and the Library of Congress's
Federal Library and Information Network.
[8] Credit header data are the nonfinancial identifying information
located at the top of a credit report, such as name, current and prior
addresses, telephone number, and Social Security number.
[9] The Privacy Act of 1974, Pub. L. No. 93-579, 88 Stat. 1896
(codified as amended at 5 U.S.C. § 552a) provides safeguards against an
invasion of privacy through the misuse of records by federal agencies
and allows citizens to learn how their personal information is
collected, maintained, used, and disseminated by the federal
government.
[10] Under the Privacy Act of 1974, the term "routine use" means (with
respect to the disclosure of a record) the use of such a record for a
purpose that is compatible with the purpose for which it was collected.
5 U.S.C. § 552a (a(7)).
[11] OMB, "Privacy Act Implementation: Guidelines and
Responsibilities," Federal Register, Volume 40, Number 132, Part III,
pages 28948-28978 (Washington, D.C.; July 9, 1975). Since the initial
Privacy Act guidance of 1975, OMB has periodically published additional
guidance. Further information regarding OMB Privacy Act guidance can be
found on the OMB Web site at [hyperlink,
http://www.whitehouse.gov/omb/inforeg/infopoltech.html].
[12] The E-Government Act requires agencies, if practicable, to make
PIAs publicly available through agency Web sites, publication in the
Federal Register or by other means. Pub. L. No. 107-347, § 208
(b)(1)(B)(iii).
[13] U.S. Department of Health, Education, and Welfare, Records,
Computers and the Rights of Citizens.
[14] OECD, Guidelines on the Protection of Privacy and Transborder Flow
of Personal Data (Sept. 23, 1980). The OECD plays a prominent role in
fostering good governance in the public service and in corporate
activity among its 30 member countries. It produces internationally
agreed-upon instruments, decisions, and recommendations to promote
rules in areas where multilateral agreement is necessary for individual
countries to make progress in the global economy.
[15] OECD, Making Privacy Notices Simple: An OECD Report and
Recommendations (July 24, 2006).
[16] European Union Data Protection Directive ("Directive 95/46/EC of
the European Parliament and of the Council of 24 October 1995 on the
Protection of Individuals with Regard to the Processing of Personal
Data and the Free Movement of Such Data") (1995).
[17] National Research Council of the National Academies, Engaging
Privacy and Information Technology in a Digital Age (Washington, D.C.;
2007).
[18] This figure comprises contracts and task orders with information
resellers that included the acquisition and use of personal
information. However, some of these funds may have been for uses that
do not involve personal information; we could not omit all such uses
because agency officials were not always able to separate the amounts
associated with the use of personal information from those for other
uses (for example, LexisNexis and West provide news and legal research
in addition to public records). In some instances, where the reported
use was primarily for legal research, we omitted these funds from the
total.
[19] GAO, Data Mining: Agencies Have Taken Key Steps to Protect Privacy
in Selected Efforts, but Significant Compliance Issues Remain, GAO-05-
866 (Washington, D.C.: Aug. 15, 2005).
[20] DEA's mission includes enforcing laws pertaining to the
manufacture, distribution, and dispensing of legally produced
controlled substances.
[21] The personal information contained in this information reseller
database is limited to the prescribing doctor and does not contain
personal patient information.
[22] For an assessment of privacy issues associated with the Secure
Flight commercial data test, see GAO, Aviation Security: Transportation
Security Administration Did Not Fully Disclose Uses of Personal
Information during Secure Flight Program Testing in Initial Privacy
Notices, but Has Recently Taken Steps to More Fully Inform the Public,
GAO-05-864R (Washington, D.C.: July 22, 2005).
[23] TSA's current plans for Secure Flight do not include the use of
reseller information.
[24] Skiptracing is the process of locating people who have fled in
order to avoid paying debts.
[25] Subsequent to the 2006 report, the DHS Privacy Office took steps
to develop guidance on the use of personal information from information
resellers in its PIA guidance.
[26] Although we did not assess the effectiveness of information
security at any agency as part of this review, we have previously
reported on weaknesses in almost all areas of information security
controls at 24 major agencies, including DOJ, DHS, State, and SSA. For
additional information see GAO, Information Security: Weaknesses
Persist at Federal Agencies Despite Progress Made in Implementing
Related Statutory Requirements, GAO-05-552 (Washington, D.C.: July 15,
2005) and Information Security: Department of Homeland Security Needs
to Fully Implement Its Security Program, GAO-05-700 (Washington, D.C.:
June 17, 2005).
[27] 5 U.S.C. § 552a(e)(4)(C) & (I). The Privacy Act allows agencies to
claim an exemption from identifying the categories of sources of
records for records compiled for criminal law enforcement purposes, as
well as for a broader category of uses, including investigative records
compiled for criminal or civil law enforcement purposes.
[28] The act provides for its requirements to apply to government
contractors when agencies contract for the operation by or on behalf of
the agency, a system of records to accomplish an agency function. 5
U.S.C. § 552a(m).
[29] As we have previously reported, this notice did not fully disclose
the scope of the use of reseller data during the test phase. See GAO,
Aviation Security: Transportation Security Administration Did Not Fully
Disclose Uses of Personal Information during Secure Flight Program
Testing in Initial Privacy Notices, but Has Recently Taken Steps to
More Fully Inform the Public, GAO-05-864R (Washington, D.C.: July 22,
2005).
[30] OMB, "Privacy Act Implementation: Guidelines and
Responsibilities," Federal Register, Volume 40, Number 132, Part III,
p. 28964 (Washington, D.C.: July 9, 1975).
[31] The Privacy Act allows agencies to claim exemptions if the records
are used for certain purposes. 5 U.S.C. § 552a (j) and (k). For
example, records compiled for criminal law enforcement purposes can be
exempt from the access and correction provisions. In general, the
exemptions for law enforcement purposes are intended to prevent the
disclosure of information collected as part of an ongoing investigation
that could impair the investigation or allow those under investigation
to change their behavior or take other actions to escape prosecution.
In most cases where officials identified system-of-record notices
associated with reseller data collection for law enforcement purposes,
agencies claimed this exemption.
[32] The E-Government Act requires agencies, if practicable, to make
privacy impact assessments publicly available through agency Web sites,
publication in the Federal Register, or by other means. Pub. L. No. 107-
347, § 208 (b)(1)(B)(iii).
[33] OMB, Guidance for Implementing the Privacy Provisions of the E-
Government Act of 2002, Memorandum M-03-22 (Washington, D.C.: Sept. 26,
2003).
[End of section]
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