Update regarding USPS Retail Survey Lacks Privacy Act Safeguards?
The POS Identification Number “was only used at the aggregated level. The survey has now been discontinued.” Meaning? Yet two days later, it is still online and working. If you leave your POS ID # blank, it states: “Text Response is Required.” There is still no ‘Privacy Act Notice.’ Typical postal double-speak?
From: USPSEmployees @ usps.gov
To: doncheney @ xxxx.com
Date: Thu, 20 May 2010 05:36:47 -0500
Subject: FW: USPS Retail Employee Survey Lacks Privacy Act Safeguards
Good morning Mr. Cheney,
We appreciate your patience while your inquiry was being investigated. The Retail Employee Survey was never reviewed or approved by the Privacy office. The POS Identification Number was not pulled into the survey results and was only used at the aggregated level. The survey has now been discontinued.
Thank you for bringing this matter to our attention.
USPS Privacy Office
From: Don Cheney [mailto:doncheney @ xxxx.com]
Sent: Friday, April 16, 2010 4:18 PM
To: PRIVACY OFFICE
Subject: USPS Retail Employee Survey Lacks Privacy Act Safeguards
Some USPS managers are requiring all window clerks to answer an online survey regardless of how many hours they work the window. I clicked on the link, https://USPSLSSA.questionpro.com, and didn’t see a valid ‘Privacy Act Notice.’ Specifically, content items b, c, d, and e listed in section 3-2.2.b.1 for a ‘Privacy Act Notice’ are missing. Since the retail clerks have to enter their POS ID, they are personally identifiable and should receive a ‘Privacy Act Notice.’ Did your office approve this online survey?
Handbook AS-353 Guide to Privacy, the Freedom of Information Act, and Records Management
3-2.2 Privacy Notice
The following describes privacy notice requirements.
a. General. When the Postal Service asks customers, employees, or other individuals to provide information about themselves and that information is maintained in a system of records, the Postal Service must provide an appropriate privacy notice. The Privacy Office must approve all new forms (hard copy and electronic) that collect customer, employee, or other individuals’ information. This includes hard copy and electronic forms, new forms, and forms scheduled for revision and reprinting.
b. Content. The privacy notice must contain the following information:
1. For individual consumers, employees, or other individuals, the privacy notice must explain:
a. The reason the information is being collected.
b. Whether providing it is mandatory or voluntary, and the effects of not providing it.
c. The disclosures (known as routine uses) that may be made of the information.
d. Which statute or executive order authorizes the collection.
Exhibit 3-2.2 Procedures to Provide a Privacy Notice
For employees, a privacy notice that meets the content requirement of section 3-2.2b must be available on the screen near where data is collected.