Diff of GWES PIA text

gwes_pia_diff_20250205_vs_20250228

4c4
< February 5, 2025
---
> February 28, 2025
41,43c41,43
< disseminates only the information of federal government employees.
< Therefore, no PIA is required. OPM has nevertheless chosen to conduct this
< PIA in its discretion.
---
> disseminates information about federal government employees. Therefore,
> no PIA is required. OPM has nevertheless chosen to conduct this PIA in its
> discretion.
48c48
< these duties, OPM internally developed the GWES to enable widespread and
---
> these duties, OPM internally developed the GWES to enable widespread,
56,58c56,59
< simultaneous communication with federal government employees. The
< GWES maintains only the names and government email addresses of federal
< government employees, as well as voluntary responses to mass emails.
---
> rapid email communication with federal government employees. The GWES
> is designed to maintain the names and government email addresses of
> federal government employees, as well as emails sent from the system and
> responses to those emails.
63,66c64,67
< government-wide emails to federal government employees. This system
< increases efficiency and transparency by allowing simultaneous
< communication with the federal workforce OPM has been tasked with
< overseeing.
---
> government-wide emails to federal government employees and receive
> responses. This system increases efficiency and transparency by allowing
> fast and widespread communication with the federal workforce OPM has
> been tasked with overseeing.
68,80c69,84
< Microsoft mailboxes. OPM uses this system to communicate with federal
< employees, a capacity which is within its statutory authority. The only
< information collected, maintained, or used by the GWES are (1) names of
< federal employees, (2) their government email addresses, and (3) short,
< voluntary email responses.
< The information in the GWES is accessible by a handful of individuals within
< OPM, overseen by the Chief Information Officer.
< The GWES is built upon employee contact information found in the
< Enterprise Human Resources Integration (EHRI) and Official Personnel Folder
< (OPF) record systems. Additional contact data is collected from the
< employing agencies of federal workers, which is received through email. The
< GWES is subject to existing OPM security plans and the data is stored in
< secure mailboxes or on government computers requiring PIV access.
---
> Microsoft applications procured in the normal course. OPM uses this system
> to communicate with federal employees, in a capacity within its statutory
> authority. The GWES is designed to collect, maintain, and use the (1) names
> of federal employees, (2) their government email addresses, and (3) email
> messages and responses, which may include additional information about
> the employee provided by that employee. The GWES blocks responses from
> emails that do not have government domains.
> The information in the GWES is accessible by a limited number of individuals
> within OPM who have a need for the information in the performance of their
> duties, overseen by the Chief Information Officer.
> The GWES is built largely upon employee email contact information found in
> the Enterprise Human Resources Integration (EHRI) and Official Personnel
> Folder (OPF) record systems. Additional email contact data is collected from
> the employing agencies of federal workers. OPM applies filters to these
> various sources to remove erroneous domains before emails are sent. The
> GWES is subject to existing and approved OPM security plans and the data is
87a92,94
> stored in secure Microsoft applications and on government computers
> requiring PIV access.
> 
98,99c105,108
< §§ 301, 2951, 3301, 6504, 8347, and 8461. These authorities permit OPM to
< maintain and request information regarding federal employees.
---
> §§ 301, 2951, 3301, 4302, 6504, 8347, and 8461. These authorities permit
> OPM to maintain and request information regarding federal employees. The
> President may also, from time to time, direct OPM to collect information or
> communicate with the federal workforce on particular subject matters.
102,105c111,115
< Email systems are not generally subject to the Privacy Act of 1974, but to
< the extent that records pertaining to individuals are retrieved for purposes of
< making decisions about individuals, the records relevant to this project are
< covered by the OPM GOVT-1 and OPM/Central-21 SORNs.
---
> Email systems are not generally subject to the Privacy Act of 1974.
> However, to the extent the GWES contain records subject to the Privacy Act,
> or information stored on secure government computers, the information in
> this system is covered by various OPM SORNs, including but not limited to
> OPM GOVT-1, GOVT-2, Central-21, and Internal-21 SORNs.
108,117c118,120
< The Office 365 mailbox has been granted an Authorization to Operate (ATO)
< that includes a system security plan. The government computer storing the
< data is subject to standard security requirements, including limited PIV
< access.
< 1.4. Does a records retention schedule approved by the National
< Archives and Records Administration (NARA) exist?
< To the extent that email records in the system are used for personnel
< decisions, records in the system are governed by GRS 6.1 Capstone E-mail
< Retention. Item 040 (DAA-GRS-2017-0007-0004) covers any eOPF records
< and requires that they be destroyed when survivor or retirement claims are
---
> The GWES is located within Microsoft applications and on secure government
> computers. These Microsoft Applications have been granted an Authorization
> to Operate (ATO) that includes an approved system security plan. The
125,128c128,134
< adjudicated or when records are 129 years old, whichever is sooner, but
< longer retention is authorized if required for business use. Item 080 (DAAGRS2017-0007-0012) covers other personnel contact information and
< requires destroying remaining documents 1 year after employee separation
< or transfer.
---
> government computers storing the data are subject to standard security
> requirements, including limited PIV access.
> 1.4. Does a records retention schedule approved by the National
> Archives and Records Administration (NARA) exist?
> Depending on the nature and type of record within the GWES, various NARAapproved records schedules may apply. Item 040 (DAA-GRS-2017-00070004) covers any eOPF records and item 080 (DAA-GRS2017-0007-0012)
> covers other personnel contact information. Email records are governed by
> GRS 6.1, Capstone E-mail Retention.
133,134c139,140
< Information contained in GWES is not subject to the PRA because it is not
< collected from the public.
---
> Information contained in the GWES is not subject to the PRA because it is
> not collected from the public.
139,143c145,148
< GWES collects, maintains, and uses the names and government email
< addresses of federal government employees. GWES also collects and
< redistributes responses to emails sent to those addresses, which are limited
< to short, voluntary, non-identifying information. Specifically, GWES contains
< the following:
---
> The GWES is designed to collect, maintain, and use the names and
> government email addresses of federal government employees. The GWES
> also maintains emails sent to those addresses, and collects and maintains
> responses to those emails. Specifically, the GWES contains the following:
146,148c151,153
< Employee Contact Data: GWES collects, maintains, and uses the
< names and government email addresses of federal government
< employees. Other identifying information is not used.
---
> Employee Contact Data: The GWES is designed to collect, maintain,
> and use the names and government email addresses of federal
> government employees. Other identifying information is not used.
153,155c158,159
< Contact Data, GWES collects, maintains, and redistributes short,
< voluntary responses.
< 
---
> Contact Data, the GWES stores that email and may collect and
> maintain responses. In some circumstances, responses may also be
161a166,168
> sent directly to or redistributed to employing agencies or other
> agencies consistent with applicable restrictions on the particular data
> at issue and using authorized means of transmission.
165,167c172,176
< systems. Additionally, some data is collected from the employing agencies of
< federal workers, which is received through email.
< The Employee Response Data is sent to OPM by email.
---
> systems. Additionally, some email contact data is collected from the
> employing agencies of federal workers. The system applies filters to remove
> erroneous domains before emails are sent.
> The Employee Response Data is sent by federal government employees to
> OPM by email.
171,172c180,181
< Many of the names and email addresses of federal government employees
< are publicly available.
---
> No, although many names and email addresses of federal government
> employees are publicly available.
174,180c183,189
< OPM has a high degree of confidence in the accuracy of the Employee
< Contact Data because it comes from the EHRI and OPF systems, which are
< subject to their own accuracy measures as outlined in their respective PIAs,
< as well as directly from the employing agencies.
< OPM has a high degree of confidence in the accuracy of the Employee
< Response Data because OPM receives the information directly from
< employees through their secure government email addresses.
---
> The Employee Contact Data comes from the EHRI and OPF systems, which
> are subject to their own accuracy measures as outlined in their respective
> PIAs, as well as directly from the employing agencies.
> The Employee Response Data comes directly from employees through their
> secure government email addresses. OPM anticipates that the responses will
> cover information within employees’ personal knowledge or information
> provided to them in the course of their official duties.
185,188d193
< Mitigation: This risk has been mitigated by compiling the Employee Contact
< Data only through the EHRI and OPF systems, and directly from the
< employing agencies. GWES only uses email addresses with government
< domains.
195a201,205
> Mitigation: This risk has been mitigated by compiling the Employee Contact
> Data through the EHRI and OPF systems, and directly from the employing
> agencies. The GWES uses email addresses with government domains and
> uses a filtering mechanism to remove contact data erroneously captured
> before emails are sent.
198c208
< Mitigation: Because OPM uses GWES to send emails only to employees’
---
> Mitigation: Because OPM uses the GWES to send emails to employees’
201,205c211,213
< Additionally, GWES has implemented procedures for employees to correct
< any erroneous responses by working with the human capital officer in their
< employing agency. If an erroneous response is sent, it can easily be
< corrected in GWES when the human capital officer notifies OPM. GWES
< blocks all responses from emails that do not have government domains.
---
> Additionally, employees have the ability to correct any erroneous responses
> by working with the human capital officer or manager in their employing
> agency.
209,210c217,218
< GWES enables OPM to communicate directly with federal government
< employees simultaneously and help OPM fulfill its statutory and delegated
---
> The GWES enables OPM to communicate directly and quickly with federal
> government employees and help OPM fulfill its statutory and delegated
212,213c220,223
< workforce. OPM further communicates employee responses to employing
< agencies to facilitate those agencies’ own personnel management.
---
> workforce. OPM may also further communicate employee responses to
> employing agencies to facilitate those agencies’ own personnel management,
> or other agencies as appropriate to facilitate government-wide workforce
> initiatives.
218,222c228,229
< GWES programmatically evaluates responses to verify the quality of the
< system and the substance of the Employee Response Data.
< 3.3. Are there other programs or offices with assigned roles and
< responsibilities within the system?
< No.
---
> OPM employees programmatically evaluate responses to verify the quality of
> the system and analyze the substance of the Employee Response Data. OPM
229a237,243
> anticipates enhancing and refining its response analyses over time. OPM
> may also query specific responses or emails to evaluate them as needed.
> Responses may be used to assist in making personnel decisions and to
> inform broader workplace initiatives.
> 3.3. Are there other programs or offices with assigned roles and
> responsibilities within the system?
> No.
233,236c247,250
< Mitigation: This risk is mitigated by restricting access to a limited number
< of individuals assigned to access the GWES information and blocking others
< from access. The data is stored only in secure Microsoft mailboxes, and on
< secure government computers requiring a PIV card to access.
---
> Mitigation: This risk is mitigated by restricting disclosure to a limited
> number of individuals who have a need to know the GWES information. The
> data is stored in secure Microsoft applications, and on secure government
> computers requiring a PIV card to access.
245,257c259,263
< collection of Employee Contact Data. All individuals are provided advance
< notice of the Employee Response Data, as it is voluntarily provided by the
< individuals themselves in response to an email.
< 4.2. What opportunities are available for individuals to consent to
< uses, decline to provide information, or opt out of the project?
< The Employee Response Data is explicitly voluntary. The individual federal
< government employees can opt out simply by not responding to the email.
< 4.3. Privacy Impact Analysis: Related to Notice
< Privacy Risk: There is a risk that individuals will not realize their response
< is voluntary.
< Mitigation: This risk is mitigated by ensuring that any email sent using
< GWES is clear, by explicitly stating that the response is voluntary, and by
< including specific instructions for a response.
---
> collection of Employee Contact Data. Employees are provided notice of
> collection of the Employee Response Data in the emails disseminated using
> the GWES. Employees provide the data themselves in response to the email.
> This PIA also serves as a public resource explaining the purpose of the
> GWES, applicable SORNs, and other privacy-related information.
264a271,282
> 4.2. What opportunities are available for individuals to consent to
> uses, decline to provide information, or opt out of the project?
> Individual federal government employees can decline to provide information
> by not responding to the email. The consequences for failure to provide the
> requested information will vary depending on the particular email at issue.
> 4.3. Privacy Impact Analysis: Related to Notice
> Privacy Risk: There is a risk that individuals will not know their information
> is being collected, maintained, and distributed through the GWES.
> Mitigation: This risk is mitigated by the publication of this PIA and through
> various statements provided to government employees explaining the
> information collection at issue.
> 
268,272c286,287
< The Employee Contact Data will be retained indefinitely so that OPM can use
< GWES to contact federal government employees. The Employee Response
< Data will be retained consistent with GRS 6.1 Capstone E-mail Retention,
< which establishes retention at 7 years for most users and 15 years, followed
< by permanent retention with NARA, for Capstone officials.
---
> The records in the GWES are maintained according to the retention
> schedules identified in Section 1.4.
274c289
< Privacy Risk: There is a risk that GWES information will be retained for
---
> Privacy Risk: There is a risk that the GWES information will be retained for
276c291
< Mitigation: The risk is mitigated because OPM can delete all GWES
---
> Mitigation: The risk is mitigated because OPM can delete all the GWES
278a294,299
> OPM Form 5003
> 
> 
  Privacy Impact Assessment
> Government-Wide Email System (GWES)
> Page 9
> 
283,286c304,309
< The GWES information of any particular individual may be shared outside of
< OPM with that employee’s employing agency, consistent with applicable laws
< and policies. Emails sent using GWES inform the employee that he consents
< to OPM’s sharing of his response in this way by replying to the email.
---
> OPM anticipates regularly sharing GWES information relating to particular
> employees with their employing agency. In certain situations, data may also
> be shared with other agencies. Any data sharing will be undertaken
> consistent with applicable laws and policies, including pursuant to routine
> uses of applicable SORNs or employee consent. Data will be shared via
> authorized systems hosted either by OPM or the receiving agency.
290,291c313,327
< consistently with applicable provisions of the Privacy Act, including through
< employee consent.
---
> consistent with applicable provisions of the Privacy Act, including through
> the routine uses of pertinent SORNs. The principal personnel SORN, GOVT-1,
> is owned by OPM but information may be accessed by employing agencies as
> needed.
> 6.3. Does the project place limitations on re-dissemination?
> Government agencies that receive GWES information are generally subject
> to both the government-wide SORNs referenced in Section 1.2 as well as
> their own SORNs. Their use or disclosure of the information may occur only
> as consistent with applicable legal limitations.
> 6.4. Describe how the project maintains a record of any disclosures
> outside of OPM.
> OPM keeps a record of distributions to the employing agencies in Microsoft
> applications. All actions taken by a user in Microsoft systems are logged,
> monitored, and accessed by those with a need to know for the performance
> of their official duties.
297c333
< Page 9
---
> Page 10
299,308d334
< 6.3. Does the project place limitations on re-dissemination?
< Government agencies that receive GWES information are generally subject
< to the government-wide SORN referenced in Section 1.2 and their use or
< disclosure of the information may occur only as consistent with the Privacy
< Act, applicable SORNs, and any inter-agency agreements.
< 6.4. Describe how the project maintains a record of any disclosures
< outside of OPM.
< The GWES keeps a record of all email distributions to the employing
< agencies in mailbox. All actions taken by a user in the mailbox system are
< logged, monitored, and accessed by those with a need to know.
312,315c338,340
< Mitigation: This risk is mitigated by disseminating GWES information only
< as consistent with relevant SORNs or as otherwise permitted by the Privacy
< Act, and by requiring receiving agencies to adhere to relevant legal
< requirements and inter-agency agreements.
---
> Mitigation: This risk is mitigated by limiting access to the GWES and
> disseminating GWES information only as consistent with relevant SORNs or
> as otherwise permitted by applicable law.
320,321c345,348
< The federal government employees in GWES have access to their own
< individual information.
---
> The federal government employees in the GWES have access to their own
> individual information. Employees will have a copy of any email that is sent,
> as well as their response. In addition, access procedures are outlined in each
> relevant SORN referenced in 1.2.
325,326c352,362
< employee in GWES is directed to inform the human capital officer in their
< employing agency. The employing agency will correct the inaccurate or
---
> employee covered by the GWES may inform the human capital officer or a
> manager in their employing agency, who can work with the employee and
> OPM as necessary to correct the problem.
> 7.3. How does the project notify individuals about the procedures for
> correcting their information?
> Emails sent through the GWES, or related guidance disseminated through
> agency human capital officers or managers, may inform individual federal
> employees of the procedures for correcting erroneous information through
> their employing agency. Also, employees may follow the publicly accessible
> access and amendment procedures outlined in the relevant SORNs
> referenced in 1.2.
332c368
< Page 10
---
> Page 11
334,341d369
< erroneous information. The erroneous information can also be corrected in
< GWES when the human capital officer notifies OPM.
< 7.3. How does the project notify individuals about the procedures for
< correcting their information?
< Any email sent through GWES, or related guidance disseminated through
< agency human capital officers, will inform individual federal employees of the
< procedures for correcting erroneous information through their employing
< agency.
345,347c373,376
< Mitigation: Lodging the corrective mechanism in the human capital officer
< at the employing agency gives each employee intuitive and easy access to
< the corrective mechanism.
---
> Mitigation: Lodging the primary corrective mechanism in the human capital
> officer or manager at the employing agency gives each employee intuitive
> and easy access to the corrective mechanism. Also, each SORN has clear
> access and amendment procedures that employees may follow.
352,354c381,383
< GWES information is captured by OPM’s auditing tools and retained in the
< tools archive. The Office of the Chief Information Security Officer reviews for
< suspicious or unusual activity and suspected violations, and appropriate
---
> GWES information is captured by OPM’s auditing tools and retained in an
> auditing archive. The Office of the Chief Information Security Officer reviews
> for suspicious or unusual activity and suspected violations, and appropriate
358,359c387,397
< All OPM employees are required to take IT Security and Privacy Awareness
< training on an annual basis, and sign OPM’s Rules of Behavior.
---
> OPM employees are required to take IT Security and Privacy Awareness
> training on an annual basis, and agree to OPM’s Rules of Behavior before
> accessing the system.
> 8.3. What procedures are in place to determine which users may
> access the information and how does the project determine who has
> access?
> Only a limited number of OPM employees with a need to know will have
> access to the full extent of the GWES data. No employee has access unless
> specifically authorized by the system owner and the authorizing official. Data
> sharing outside OPM is permitted only insofar as consistent with applicable
> law and as described above.
365c403
< Page 11
---
> Page 12
367,373d404
< 8.3. What procedures are in place to determine which users may
< access the information and how does the project determine who has
< access?
< Only a limited number of employees with a need to know will have access to
< the full extent of GWES data. As necessary, and with consent of the
< individual federal employee, GWES information will be shared with those
< who need to know at that individual’s employing agency.
378,379c409,411
< Understanding (MOUs) would need to be reviewed and approved by all
< appropriate OPM stakeholders consistent with applicable law.
---
> Understanding (MOUs) would need to be reviewed and approved by the
> system owner in coordination with the Office of the Chief Information
> Officer, as consistent with applicable law.