August 12, 2004
Table of Contents
Overview of OST (OST) privacy management process for CASTLE
Personally identifiable information and CASTLE
Why CASTLE collects information
How CASTLE uses information
How CASTLE shares information
How CASTLE provides notice and consent
How CASTLE ensures data accuracy
How CASTLE provides redress
How CASTLE secures information
System of records
The Office of the Secretary (OST), within the Department of Transportation (DOT), has been given the responsibility of formulating national transportation policy and promoting intermodal transportation. Other responsibilities include negotiation and implementation of international transportation agreements, assuring the fitness of US airlines, enforcing airline consumer protection regulations, issuing regulations to prevent alcohol and illegal drug misuse in transportation systems, improving the security of the national transportation system, and preparing transportation legislation.[1]
As part of its support function for DOT, OST is moving its current time and attendance system, Integrated Personnel and Payroll System (IPPS), to a new Web-enabled and more efficient system, CASTLE. CASTLE will manage a full range of Human Resource (HR) time and attendance collections for DOT employees. To accomplish this, CASTLE stores and maintains HR-related personnel data on current employees, and maintains data on former employees for 52 weeks after their separation before destroying those data. The CASTLE system is currently in product development and testing. When deployed, CASTLE will be accessed by DOT employees through a password-protected intranet Website.
Privacy management is an integral part of the CASTLE project. DOT/OST has retained the services of privacy experts to help assess its privacy management program, utilizing proven technology, methodologies, and sound policies and procedures.
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 and OST will have the information, tools, and technology necessary to manage privacy effectively and employ the highest level of fair information practices while allowing OST to achieve its mission of protecting and enhancing all U.S. civil transportation systems. The methodology is based upon the following:
The CASTLE system uses both PII and non-PII - data to manage time and attendance functions throughout DOT. In addition to current employee PII, CASTLE may also contain PII of former employees for 52 weeks, helping to ensure that former employee’s rights are protected. CASTLE PII may include name, social security number, and employment status.
In addition, CASTLE uses logon names and passwords to control access. Therefore, CASTLE also contains the name and password of each DOT user and associates the data with that individual.
An individual’s PII enters the CASTLE system when that person is hired by DOT. CASTLE receives employee data from other DOT systems; including Consolidated Personnel Management Information System (CPMIS), Consolidated Uniform Payroll System (CUPS), and IPPS.
CASTLE collects information in order to fulfill basic time and attendance functions, such as recording and tracking vacation taken, personal time taken, and work project time. CASTLE interfaces with other DOT HR systems to send information necessary to record employee pay and HR actions appropriately. The CASTLE system collects PII only when an individual becomes an employee of DOT.
Information in CASTLE is used to monitor and manage time and attendance functions. CASTLE uses PII to identify an individual and ensure that the time and attendance information is accounted to the correct individual.
CASTLE shares PII with other HR systems, such as payroll and other similar systems. CASTLE shares name and social security number with other systems to ensure the time and attendance information logs to the correct individual’s record.
Entry of PII into CASTLE is a necessary condition of any employment relationship with DOT, and individuals provide PII for that purpose. DOT does not use CASTLE PII for secondary purposes; therefore, consent for secondary uses is not needed.
CASTLE receives PII primarily from other HR-related systems, each with data quality procedures and processes. At any time, an individual can request information on his or her PII and may request some changes as appropriate.
The CASTLE system is housed in Oklahoma City, Oklahoma. Personnel with physical access have all undergone and passed DOT background checks.
In addition to physical access, electronic access to PII in CASTLE is limited according to a matrix of job function and accounting activities. Different users are provided different levels of access.
OST controls access privileges through the following roles:
The following matrix describes the privileges and safeguards around each of these roles as they pertain to PII.
ROLE |
ACCESS |
SAFEGUARDS |
---|---|---|
Employee User |
View, enter, and change time and attendance information pertaining only to his or her own record. |
The following safeguards apply:
|
Technical Administrator |
Variable, depending on job responsibilities. Permissions may include combination of:
|
The following safeguards apply:
|
Headquarter TEAM Administrator |
Variable, depending on job responsibilities:
|
The following safeguards apply:
|
Access for all CASTLE users, regardless of permissions, is protected through a user ID and password combination with the following safeguards:
In addition, CASTLE maintains an audit trail of all CASTLE transactions, when those transactions are processed, and the individual(s) who initiated them. OST regularly monitors this audit trail.
OST trains users on CASTLE and privacy responsibilities through instructor-led training. In addition, OST staff complete annual specialized security training.
CASTLE replaces IPPS, which was the prior system of records subject to the Privacy Act. For that purpose, its Privacy Act System of Records notice is listed under DOT/ALL 11. DOT is currently working to amend the system of records accordingly. OST has certified and accredited CASTLE in accordance with DOT Information Technology security requirements.