FEDERAL BUREAU OF INVESTIGATION
PRIVACY IMPACT ASSESSMENT
Contract Linguist Automated Support System
March 31, 2006
I. BACKGROUND
This PIA is conducted pursuant to the E-Government Act of 2002, P.L. 107-347, the accompanying guidelines issued by the Office of Management and Budget (OMB) on September 26, 2003, and the FBI's PIA guidelines.
The Contract Linguist Program is administered by the Contract Linguist Unit (CLU). One of the CLU's major programs is the Contract Linguist Applicant Processing and Suitability Program (Contract Linguist Program) which screens and selects qualified contract linguist applicants, coordinates all phases of pre-contract vetting and ensures the completion of background investigations and suitability determinations. In administering the program, CLU contracts with linguists, language monitors, testers/raters, trainers, interpreters and tutors. All applicants to the Contract Linguist Program must pass a language proficiency exam, a polygraph examination focused on candidates' involvement with foreign counterintelligence matters, and must successfully complete a comprehensive personnel security interview. CLU currently processes applications to the program via several Access databases, spread sheets and paper forms. CLU advises that its current processes are inefficient. Accordingly, CLU is developing the Contract Linguist Automated Support System (CLASS) in order to automate its ability to hire contract linguists, language monitors, testes/raters, trainers, interpreters, and tutors and to more effectively manage and evaluate the contract Linguist Program. CLASS will be a web-based system which will reside on a server located at FBIHQ or at a remote location. The location has not yet been determined.
CLASS will consist of a hiring component and a management component. The hiring program is similar to fbijobs.gov or Quickhire. CLU will post vacancy announcements on its internet website and contract linguists, translators, monitors, testers/raters will submit employment applications via the web. Applicants will initially enter personal identifying information; then answer a series of registration questions. Applicants will also enter resume information covering periods of current and past employment; and answer a series of questions that are specifically keyed to the position for which the individual is applying. The sources of applicant information are the general public (including all Federal employees and U. S. citizens). The information collected includes the following personal identifying information: name, social security number, date of birth, citizenship information, military service information, place of birth, home address, home and cellular telephone numbers, fax number, e-mail address, and case id number. Applicants must create a password and user ID to submit applications via CLASS. During this process, applicants will be advised of the FBI's website privacy and security policies. A Privacy Act Statement will also be included on the website.
CLASS will screen applicants based upon criteria established by CLU and will forward the information to CLU for review. CLU will review applicant materials and select applicants for referral to the Language Testing and Assessment Unit (LTAU). LTAU will forward the name and identifying information of the applicant to the Department of Defense, Defense Manpower Data Center (DMDC) which will transmit an appropriate language test to a third-party testing center via encrypted channels. The Applicant will schedule the test in CLASS. Applicants will report to the third-party testing center and take the test on-line. After completion, the test will be graded and the results will be sent back to the FBI (LTAU) via encrypted channel. CLU will input the results into CLASS. CLASS will generate a pass/fail letter which is accessible to the applicant.
If the applicant passes the written examination, CLU will schedule the applicant for an oral examination (also administered at a third-party testing center) via CLASS. The oral examination consists of FBI personnel/contractors conversing with applicants via telephone. The examination will be recorded and uploaded into CLASS. If the applicant passes the oral examination, the applicant will be referred to the Security Division (SecD) for a background suitability determination. Upon receipt of information from SecD during the various stages of the background investigation process, CLU personnel will enter information into CLASS. Accordingly, CLASS will contain background/suitability information such as polygraph dates/results, background investigatory information such as drug usage history, credit/financial issues, criminal violations (i.e., arrests), derogatory employment/military information, medical information such as sexual abuse, and employment misconduct information such as security violations, etc. Once hired, contractors will submit invoices for work performed via CLASS.
In addition to the applicant component, CLASS will be used as a workflow management tool which will assist CLU with identifying hiring and workload bottlenecks and trends important to managing an effective and efficient contract linguist program. To that end, CLASS will have a report generation function which will give CLU an overview of its contract linguist personnel resources (i.e., the number of linguists who speak Arabic assigned to a particular division and the translation needs of that particular division). Furthermore, CLASS will also include a function which will permit CLU to process invoices electronically. Ultimately, CLASS will improve contract linguist hiring efficiency during the preliminary screening process, testing and assessment phase, the background investigation and suitability phase, and the contract initiation and payment cycles.
II. ASSESSMENT
A. What information is to be collected?
CLASS will contain personal identifying information such as name, social security number, address, telephone number, e-mail address, etc.; background security/suitability information such as drug usage history, medical/psychological information, criminal violation information, military records, credit/financial information, polygraph examination results and language testing and hiring information. CLASS will also contain workflow and management information which will assist CLU with identifying workload bottlenecks, and general trends important to managing an effective and efficient linguist program. CLASS Application Data Sets are attached as Addendum A.
B. Why is the information being collected?
The information is being collected so that CLU can manage and administer the Contract Linguist Program in a more efficient and effective manner.
C. What is the intended use of the information?
The information will be used to screen applicants, schedule foreign language tests, test and assess applicants, and track background investigation/suitability determinations. Information will also be used by management to evaluate contract linguist hiring processing times and potential processing problems.
D. With whom will the information be shared?
Information will be shared within CLU to administer the Contract Linguist Program. Information from CLASS will also be shared with other FBI divisions on a need to know basis (i.e., field offices who have requested translation services). Information from CLASS will also be shared with federal government agencies and third-party testing centers involved with the administration of foreign language testing for the federal government. Information from CLASS may also be shared with the National Virtual Translation Center (NVTC) which acts as a clearinghouse for facilitating interagency use of translators and identifies translator resources. Lastly, information may be shared with authorized law enforcement and intelligence community members for legitimate investigative and intelligence purposes in accordance with applicable laws and regulations.
E. What notice or opportunities for consent would be provided to individuals regarding what information is collected and how that information is shared?
Individuals will be advised via CLASS that the submission of an employment application and foreign language testing is voluntary. Applicants will be further advised that the refusal to provide information or to submit to foreign language testing may have adverse consequences (i.e., if an applicant refuses to take a foreign language proficiency examination, the applicant will not be hired). Applicants will be provided with an opportunity to consent to the uses of the information via the online employment application. Further, applicants will be advised of how the collected information will be used via the privacy policy and Privacy Act statements which will be posted on the website.
F. How will the information be secured?
Users of CLASS will be limited to applicants and FBI personnel. Access to the system will be restricted by password. The database will use a role-based model for controlling access to the system. User accounts and role assignments will be controlled by the system administrator. CLU staff members will conduct quarterly audits to ensure that employees possess the appropriate level of access to CLASS data, as well as to ensure that access is terminated for employees who leave CLASS or no longer require access to particular data sets.
G. Is a system of records being created under Section 552a of Title 5, United States Code, (commonly referred to as the "Privacy Act")?
CLASS will contain personally identifiable information regarding individuals and information will be retrieved by name or personal identifier. CLASS will be part of the FBI's Central Records System. Thus, a new Privacy Act systems notice is not required.
H. What choices did the FBI make regarding an IT system or collection of information as a result of performing the PIA?
Prior to procuring CLASS, CLU examined the possibility of using Quickhire to process applicants to the contract linguist program, but determined that because Quickhire does not maintain a workflow management platform which would permit CLU to generate reports and process invoices, there was no reasonable alternative to proceeding with the development of CLASS. Accordingly, CLU has decided to proceed with the development of the system.
III. APPROVAL
The FBI's Senior Privacy Official has reviewed this system for privacy policy issues, perceives no unusual privacy concerns at stake here, and approves the FBI's implementation of the system. Based on the foregoing, the FBI Senior Privacy Official has determined that CLASS presents no noteworthy privacy concerns. A new Privacy Act systems notice is not required. Completion of a full PIA and referral to the Privacy Council also is not required.
ADDENDUM A
CLASS - DATA FIELDS
BACKGROUND TABLE
FIELDS DESCRIPTION SOURCE
FIELDOFFICE Processing Field Office Applicant
RECFIELDOFFICE Receiving Field Office
SSN Social Security Number Applicant
LASTNAME Applicant's Last Name Applicant
FIRSTNAME Applicant's First Name Applicant
MI Applicant's Middle Initial Applicant
DOCLU Date Case Opened
TYPE Contract Linguist (CL) or Language Specialist (LS) Applicant
CLTOLSCONVERSION Is the Candidate an On-Board CL Now Being Considered for an LS Position?
LANGUAGE1 CL or LS Applicant
LANGUAGE2 CL or LS Applicant
CASEID Case ID Number ACS-CLU
STATUS Current Status of Case CLU
DINACTIVE Date Applicant's Processing Was Discontinued CLU
RINACTIVE Reason Applicant's Processing Was Terminated CLU, FO, or Sec.
DATEEOD Date LS Applicant EOD CLU
HOME Applicant's Home Phone Number Applicant
WORK Applicant's Work Phone Number Applicant
CELL NUMBER Applicant's Cell Number Applicant
EMAIL Applicant's E-mail Address Applicant
ADDRESS Applicant's Street Address, including Apartment Number Applicant
CITY City of Applicant's residence Applicant
STATE State of Applicant's residence Applicant
ZIPCODE Zip Code of Applicant's Residence Applicant
ADVINIT Advertisement Initiative Which Secured the Applicant's Interest Applicant
ECTESTING Date of EC to the Field Requesting Test Results CLU
DATETESTREQ Date Test Materials Were Requested from LTAU
DATERESULTS Date Received Report of Test Results Applicant
GRADE Grade Candidate Qualified Conversion
STEP Step Candidate Qualified Conversion
RECRUITBONUS Recruitment Bonus, if applicable Conversion
STUDENTLOAN Conversion
DATEREQFD140 Date of EC Requesting FD-140 (LS Only) Conversion
DATERECFD140 Date Received FD-140 (LS Only) Conversion
DATETOPASSU Date FD-140 is forwarded to PASSU for a Grade Determination (LS-only) Conversion
DATERECEIVEDGD Date Grade Determination is Received from PASSU Conversion
DATETOSECDIV Date Package is Forwarded to BAEU, ASD *(
DATEREQPOLY CL Only CLU
DATEPOLY1 CL Only CLU - FO
POLYRES1 (P)ass/(F)ail/(I)nconclusive Poly - CLU
DATEPOLY2 CL Only CLU - FO
POLYRES2 (P)ass/(F)ail/(I)nconclusive Poly - CLU
DATETOCOGPU CL Only CLU
CLUANL LAAU Analyst Assigned to BI CLU
DATEBIINIT CL or LS Sec - CLU
ACCREQ CL Only CLU
CLRREQ CL Only CLU
DATEOFPSI CL Only CLU - FO
DATEOFSF86 CL Only Applicant
DATEAUD CL Only
SACAPP CL Only
DATERECHQCHECKS Date HQ Checks are received from ISU
DATEREQHQ Date HQ Checks are requested from ISU
DATETOCCU CL Only
DATERETBYCCU CL Only
DATERETTOCCU CL Only
DATEAPPBYCCU CL Only
DATEDENIEDBYCCU CL Only
DATEOFSF-312 Date SF-312 Received from Field Office FO
REASONDISC CL Only
DATEAPPBYASD LS Only
LOGSHEET LS Only
FBILINGUIST Yes/No Response Applicant
NVTCLINGUIST Yes/No Response Applicant
POB Place of Birth Applicant
INTERNET_EMAIL Applicant
CLASS - DATA FIELDS
TABLES: BI DISCONTINUATION AND LINGUIST TYPE
DESCRIPTION - BI DISCONTINUATION SOURCE
Approved for Contract CLU
Credit/Financial Issue CLU - FO
Criminal Violations CLU - FO
Declined Employment Offer - (LS Only) Applicant
Derog. Education CLU - FO
Derog. Employment CLU - FO
Derog. Military Record CLU - FO
Drug Usage Outside Guidance CLU - FO
Failed Audiometer CLU - FO
Failed Language Battery CLU - FO
Failed Polygraph - FCI CLU - FO
Failed Polygraph - Series II CLU - FO
Federal Employee - No Far Except. CLU - FO
Hired (LS Only) CLU - FO
ISU - Denied Access CLU - FO
Lack of Candor CLU - FO
Medical/Psychological CLU - FO
No Current Need - Monitor CLU - FO
No Longer Interested Applicant
No Need in Any FO CLU - FO
No Show for Language Testing CLU - FO
Not a U.S. Citizen CLU - FO
Not Currently Available CLU - FO
Other CLU - FO
Reconciliation Adjustment - No Record CLU - FO
Referred to Tiger Team CLU - FO
Removed from Contract - Performance CLU - FO
Unresponsive to Field CLU - FO
Upgrade Approved - Previous Approval CLU - FO
DESCRIPTION - LINGUIST TYPE SOURCE
Contract Admin (CSC) CLU
Contract Language Monitor CLU
Contract Linguist CLU
Language Monitor CLU
Language Specialist CLU
TACL CLU
CLASS - DATA FIELDS
TABLES: ACCESS, AGENCY, CLEARANCE TYPE, and AD CAMPAIGN DESCRIPTION - ACCESS SOURCE
1 - Escorted CLU
2 - Unescorted CLU
3 - Restricted Unescorted CLU
DESCRIPTION - AGENCY SOURCE
DLS
ABSI
METRO
LCE
FBI
SOS
PARA
FSI
DoD
CIA
NSA
Termseek
DESCRIPTION - CLEARANCE TYPE SOURCE
Secret CLU
Top Secret CLU
DESCRIPTION - AD CAMPAIGN SOURCE
Employee Referrals
Homepage
Monster Board
National Security Education Program
US Copts
CLASS - DATA FIELDS
TABLES: MISCONDUCT MATTERS AND MISCONDUCT TYPE
FIELDS - MISCONDUCT MATTERS SOURCE
Status
Date Opened and Assigned
LAAU Analyst
Field Office
Final Adjudication
Last Name
First Name
260F Case ID
Allegation 1
Allegation 2
Allegation 3
Date Letter Uploaded to Appropriate ALS File
Task Description
LAAU Primary
SecDiv Primary
Notes
DESCRIPTION - MISCONDUCT TYPE SOURCE
Arrest - DWI
Assault and Battery
Disruptive Behavior
Divided Loyalty - Unavailable for Assignment
Failure to Abide by Office Rules
Lack of Candor
PARM - DI Polygraph - Access Not Suspended
PARM - DI Polygraph - Access Suspended
Security Violation - General
Sexual Abuse - Other Employment
Sexual Harassment
T&A Fraud
Theft
Unauthorized Disclosure - Sensitive/Classified
Unauthorized Use of FBI Telephones
