Electronic Newsletter Subscription Database Privacy Impact Assessment

Name of System:

Electronic Newsletter Subscription Database

Purpose of the System:

The United States Mint is planning to create a new opt-in-only electronic newsletter covering the Presidential 1$ Coin Act. When someone asks to receive this newsletter by clicking the appropriate button at the electronic newsletter subscription page on the United States Mint’s Web site, or by emailing or calling the Mint’s customer care center and requesting a subscription, we will collect and retain only the requester’s email address for our electronic newsletter subscriber database. Once confirmed, subscribers’ email addresses will be added to this database, which contains only email addresses and no other personally-identifying information. A field in the existing database will be added to indicate whether subscribers have opted-in to receive the new newsletter, in the same manner as current database entries indicate existing subscribers and the newsletters they receive.

System of Record Number(s), if applicable at this time: Not applicable at this time

  1. Contact Information: (Provide name, title, and organization.)1. Who is the person(s) completing this document?April Stafford, Program Manager, Office of Sales and Marketing
    Mike Welther, Project Manager, Office of Sales and Marketing

    2. Who is the system developer/analyst?

    Mike Welther, Project Manager, Office of Sales and Marketing

    3. Who is the system owner/manager?

    Mary Lhotsky, Communications Specialist, Office of Sales and Marketing

    4. Who is the Information Systems Security Manager who reviewed this document?

    Rene Smeraglia, Assistant Director, OCIO, Office of Information Security

    5. Who is the Bureau Privacy Act Officer who reviewed this document?

    Kathleen Saunders-Mitchell, Disclosure Officer, Office of Information Security/Records Management Division

  2. System Application/General Information:1. Does this system contain any personal information about individuals?No. The system contains only email addresses and an indication of the requested newsletters, with no names or other personal information. It does not identify whether or not the subscriber is an individual, business or other entity.

    2. What legal authority authorizes the purchase or development of this system/application? (List statutory provisions or Executive Orders that authorize the maintenance of this information to meet an official program mission/goal.)

    31 U.S.C. § 5112(p).

    3. For new systems, how is privacy addressed in documentation related to system development; including statement of need, functional requirements analysis, alternatives analysis, feasibility analysis, benefits/cost analysis, and especially the initial risk assessment?

    This is not a new system. It is the addition of a subscription option for an existing system.

  3. Data in the System:1. What categories of individuals are covered in the system? (e.g., employees, contractors, the public, etc.)General public, as well as employees and contractors who subscribe to one of the electronic newsletter(s) offered through the system.

    2. What are the sources of the information in the system?

    Those wishing to subscribe voluntarily submit their email addresses and indicate which of our electronic newsletters they choose to receive. There are no current plans to obtain information from other sources for this system.

    2a. Is the source of the information collected directly from the individual or is it taken from another source? If not directly from the individual, then what other sources?

    The information collected is the email address provided by a submitter or submitter representing a company or organization opting in for receipt of electronic newsletter(s).

    2b. What Federal agencies are providing data for use in the system?

    None, except to the extent an agency elects to subscribe to one of our newsletters, in which case it provides its email address and preferences like any other subscriber.

    2c. What State and/or local agencies are providing data for use in the system?

    None, except to the extent an agency elects to subscribe to one of our newsletters in which case it provides its email address and preferences like any other subscriber.

    2d. From what other third party sources will data be collected?

    None.

    2e. What information will be collected from the employee and the public? (e.g., social security numbers, addresses, telephone numbers, badge numbers, user identifiers, credit card numbers, etc.)

    If a subscriber requests a subscription using the United States Mint’s online subscription page for these newsletters, the interface collects only the subscriber’s email address and newsletter selections to be uploaded; no other information can be submitted. If a potential subscriber requests a subscription by email, telephone or other means and the subscriber submits additional information, this system nevertheless stores only the subscriber’s email address and requested newsletter preferences.

    3. Accuracy, Timeliness, and Reliability

    3a. How will data collected from sources other than from bureau records be verified for accuracy?

    A confirmation email is sent to the address supplied by the submitter to verify that it is correct and validly entered by the submitter. The confirmation email is a response to the submitter to validate the email address and online subscription selection(s).

    3b. How will data be checked for completeness?

    A confirmation email is sent to the address supplied by the submitter to verify that it is correct and validly entered by the submitter. The confirmation email is a response to the submitter to validate the email address and on-line subscription selection(s).

    3c. Is the data current? How will this be ensured?

    Data is as current as the email address supplied by the subscriber. The newsletter subscription page on the main section of United States Mint’s Web site provides instructions and a means of updating email address information for existing subscribers.

    3d. Are the data elements described in detail and documented? If yes, what is the name of the document?

    Protocols for verifying the email addresses are addressed in the original system Functional Requirement Document.

    4. What opportunities do individuals have to decline to provide information (i.e., where providing information is voluntary) or to consent to particular uses of information (other than required or authorized uses)?

    Subscription is entirely voluntary, but subscribers must provide email addresses in order to receive electronic newsletters. Subscribers can unsubscribe from one or more United States Mint electronic newsletters they have requested to receive at any time through the newsletter subscription page on the main section of United States Mint’s Web site. Individuals are not given the opportunity to consent to particular uses of information other than required or authorized uses because there are no particular uses of information for which the United States Mint will use the information other than to send the email to the email address submitted by the requester.

  4. Attributes of the Data:1. Is the use of the data both relevant and necessary to the purpose for which the system is being designed?Yes. The purpose of the system is to collect email addresses so that electronic newsletters can be sent by email to requesting subscribers.

    2. Will the system derive new data or create previously unavailable data about an individual through segregation from the information collected, and how will this be maintained and filed?

    No, not at this time.

    3. Will the new data be place in the individual’s record?

    This system does not contain Privacy Act records. The system only collects and stores email addresses and newsletter selections for persons or entities that request electronic newsletter subscriptions through the newsletter subscription page on the main section of United States Mint’s Web site or by otherwise contacting the United States Mint. No names or other information are stored in this system.

    4. Can the system make determinations about employees/public that would not be possible without the new data?

    No. The system does not identify subscribers or note their status as employees or members of the public.

    5. How will the new data be verified for relevance and accuracy?

    There are no current plans to derive or create new data.

    6. Do the records in this system share the same purpose, routine use, and security requirements?

    The contents of the system share the same purpose: to store email addresses and subscription preferences for subscribers who request on-line subscription to United States Mint electronic newsletters.

    The database does not contain Privacy Act records. Because it is not deemed a Privacy Act system of records, “routine use” as described by the Privacy Act of 1974 does not apply at this time.

    Data in this system is maintained in a secured environment with access by authorized personnel; see item 7 below for more detailed information regarding security requirements.

    7. If the data is being consolidated, what controls are in place to protect the data from unauthorized access or use?

    Data will not be consolidated or commingled. Authorized access will be granted through administrative screen passwords only accessible from the United States Mint end of the system. All access is by authorized users only. Mint Directive MD 9C-2 (Mint Computer Use) prohibits personnel from accessing or browsing system information except in performance of their assigned job functions. Mint computer users are instructed on, acknowledge and agree to abide by the IT System User Rules of Behavior that prohibit unauthorized access to and use of data.

    8. How will the data be retrieved? Does a personal identifier retrieve the data? If yes, explain and list the identifiers that will be used to retrieve information on the individual.

    Data is retrieved by querying the “opt-in” field for that particular subscription option. Access to the data is limited to authorized persons working on the electronic newsletter program and only for the purpose of sending electronic newsletter(s) to subscribers.

    9. What kinds of reports can be produced on individuals? What will be the use of these reports? Who will have access to these reports?

    A report that lists one or more email addresses and the subscription options chosen can be generated. Only authorized United States Mint employees and contractors will have access to these reports.

  5. Maintenance and Administrative Controls:1. If the system is operated in more than one site, how will consistent use of the system and data be maintained in all sites?The system is operated in one geographical location.

    2. What are the retention periods of the data in this system?

    Electronic information in the system will be maintained in a secured environment for a period in accordance with National Archives and Records Administration requirements for the system.

    3. What are the procedures for disposition of the data at the end of the retention period?

    The disposition of data contained in the system or reports generated from the system will be maintained and disposed of in accordance with records retention schedules approved by the National Archives and Records Administration.

    4. Is the system using technologies in ways not previously employed (e.g., monitoring software, Smart Cards, Caller ID)?

    No.

    5. How does the use of this technology affect public/employee privacy?

    The system is not using technologies in ways not previously employed.

    6. Will this system provide the capability to identify, locate, and monitor individuals? If yes, explain.

    No.

    7. What kinds of information are collected as a function of the monitoring of individuals?

    This system only allows the transmission of electronic newsletters via email. No information is collected as a function of monitoring individuals.

    8. What controls will be used to prevent unauthorized monitoring?

    System controls are implemented in a role based least access manner. Authorized personnel and authorized contractors will have the least amount of access to the system required to perform their job function. Transactions are logged and subject to monitoring for inappropriate activity.

    9. If the system is web-based, does it use persistent cookies or other tracking devices to identify web visitors?

    The system is web-based to the extent that individuals can subscribe via the newsletter subscription page on the main section of United States Mint’s Web site by submitting their email addresses and noting their newsletter preferences. The United States Mint main Web site (www.usmint.gov) does not currently use cookies to store individually-identifiable information, or to track actions of visitors (including newsletter subscribers) to its Web site over time or across Web sites.

    10. Under which Privacy Act system of records notice does the system operate?

    The system does not contain Privacy Act records, and is therefore not a system of records under the Privacy Act.

    11. If the system is being modified, will the Privacy Act system of records notice require amendment or revision? Explain.

    The system does not contain Privacy Act records, and is therefore not a system of records under the Privacy Act.

  6. Access to Data:1. Who will have access to the data in the system? (e.g., users, managers, contractors, others) Will those with access to the data have appropriate training and security clearances to handle the sensitivity of the information?Only authorized Mint personnel and authorized contractors will have access to the data in this system. All authorized personnel and authorized contractors having system access are required to have appropriate security clearances. All Mint personnel and authorized contractors are informed of and must acknowledge United States Mint directives, MD 9C-2 (Mint Computer Use) MD 9C-3 (Information Systems Access Policy), IT System User Rules of Behavior and Information Security Awareness Program.

    2. How is access to the data by a user determined? Are criteria, procedures, controls, and responsibilities regarding access documented?

    Subscribers are able to unsubscribe or modify their subscription preferences and email addresses through the newsletter subscription page on the main section of United States Mint’s Web site. This is the only access provided to subscribers. Internal Mint administrative access to this database must be authorized by the system owner and/or program official. Administrative access is granted only to authorized Mint personnel or authorized contractors for the purpose of maintaining the database. All Mint personnel and authorized contractors are informed of and must acknowledge United States Mint directives, MD 9C-2 (Mint Computer Use) MD 9C-3 (Information Systems Access Policy), IT System User Rules of Behavior and Information Security Awareness Program.

    3. Will users have access to all data on the system or will the user’s access be restricted? Explain.

    Subscribers are able to unsubscribe or modify their subscription preferences and email addresses through the newsletter subscription page on the main section of United States Mint’s Web site. This is the only access provided to subscribers. All internal Mint access is granted the necessary privileges to perform the job function. Access controls are in place to prevent users who do not have a business need to access data from doing so.

    4. What controls are in place to prevent the misuse (e.g., unauthorized browsing) of data by those having access?

    System controls are implemented in a role based least access manner. Authorized Mint personnel or authorized contractors will have the least amount of access to the system required to perform their job function. Transactions are logged and subject to monitoring for inappropriate activity. All Mint personnel and authorized contractors are informed of and must acknowledge United States Mint directives, MD 9C-2 (Mint Computer Use) MD 9C-3 (Information Systems Access Policy), IT System User Rules of Behavior and Information Security Awareness Program.

    5. Are contractors involved in the design and development of the system and will they be involved with the maintenance of the system? If yes, were Privacy Act contract clauses inserted in their contracts and other regulatory measures addressed?

    Yes, authorized contractors are involved with the development and maintenance of the system. Their contracts include non-disclosure agreements.

    6. Do other systems share data or have access to the data in this system? If yes, explain.

    No, this system does not share data with any other system.

    7. Who will be responsible for protecting the privacy rights of the public and employees affected by the interface?

    All Mint users have a responsibility to safeguard information and data under their control. United States Mint program and information security personnel and contractors work in tandem to accomplish this for this system.

    8. Will other agencies share data or have access to the data in this system (Federal, State, Local, Other)?

    Except to the extent disclosure is required by law, no sharing of system data with other agencies is currently contemplated.

    9. How will data be used by the other agency(s)?

    Except to the extent disclosure is required by law, no sharing of system data with other agencies is currently contemplated.

    10. Who is responsible for assuring proper use of the data?

    United States Mint program office staff, the staff of the United States Mint Office of the Chief Information Officer, and their respective contractors work together to assure proper use of the system and the data in the system.

The Following Officials Have Approved this Document:

  1. System Owner______________________________(Signature and Date)

    Name:

    Title:

  2. Program Manager______________________________(Signature and Date)Name:

    Title:

  3. Information Systems Security Manager______________________________(Signature and Date)Name:

    Title:

  4. IT Reviewing Official______________________________(Signature and Date)Name:

    Title:

  5. Records Management Officer______________________________(Signature and Date)Name:

    Title:

  6. Privacy Act Officer______________________________(Signature and Date)Name:

    Title:

     

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