May 11, 2004
At the June 26, 2003 meeting of the Department’s Investment Review Board (IRB) a decision was made to begin the process of consolidating the Department’s IT infrastructure in advance of the move to the new headquarters facility. A consolidated IT infrastructure has the benefit of delivering to the end users improved, more consistent and more highly secured IT services at a total cost of ownership (TCO) that is equal-to or less than the current cost of provisioning such services. This double benefit of improved services at a reduced cost is only possible with a commitment to a standardized, well structured IT infrastructure delivered by a world-class service organization. Thus, the IT Consolidation project if properly executed will contribute to implementing the President’s Management Agenda vision of eliminating redundant services while improving overall IT service and security levels. In addition, because there is an increasingly critical need for real time communications among the Operating Administrations and the Department, the need for a single consolidated e-mail and directory capability across the Department (excluding the FAA) is strongly supported. Thus, this program will support the strategic goals of improved service to citizens, increased security of operations, at a reduced cost, while also providing improved, internal communications across the agencies and within the entire Department. The Office of the Chief Information Officer has the responsibility to effect this consolidation and will do so by creating a DOT Common Operating Environment (COE). The DOT Information Technology Services (DOT-ITS), a division of the Chief Information Officer’s Office, will be responsible for the establishment and maintenance of the COE. That office will administer desktop and network operations for the Department.
Since privacy management is an integral and important part of the COE, the department has retained the services of privacy experts to help assess its privacy management program by utilizing proven technology, sound policies and procedures, and proven methodologies.
The privacy management process is built upon a methodology that has been developed and implemented in leading companies around the country and globally. The methodology is designed to help ensure that DOT will have the information, tools and technology necessary to effectively manage privacy and employ the highest level of fair information practices while allowing DOT to achieve its mission of protecting and enhancing a most important U.S. transportation system. The methodology is based upon the following:
There are numerous information systems within the department that collect and retain PII for a myriad of purposes such as Human Resources management, email and phone directories, contingency contact databases, financial records, etc. The COE is a standard infrastructure which is comprised of numerous systems and networks.
IT COE stores PII and non-PII and makes these data available to appropriate personnel involved in desktop and network operations. These staff members use the network to conduct daily operations.
Network systems within the COE provide no reports without PII to the public and individuals requesting such information.
Designated, approved federal employees and contractors have access to IT Systems and the COE according to job roles and responsibilities for use in their respective jobs.
DOT does not share information from its network or IT systems in any other way.
The DOTnet Web site provides a link to a privacy policy at the point of PII collection.
DOT provides Web site access to a privacy officer who addresses privacy concerns and questions.
IT staff and contractors with access to COE data receive basic security training with some privacy components. These users also annually read and sign a Non-Disclosure Agreement containing privacy provisions and penalties for unauthorized disclosure of data. In addition to physical access, electronic access to PII is limited according to job function. DOT controls access privileges according to a documented roles matrix, with each individual receiving the minimum necessary access to PII and permissions. Many IT users receive read-only access to all or some of the data.
In addition, access to PII requires access to a secure LAN with complex passwords and regular change intervals. Much of the data requires second passwords when accessing a particular system which houses the PII. Password and account procedures comply with the following basic guidelines: