This is the accessible text file for GAO report number GAO-02-1058 
entitled 'Information Management: Selected Agencies' Handling of 
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Report to the Chairman, Committee on Governmental Affairs, U.S. Senate:

September 2002:


Selected Agencies’ Handling of Personal Information:


Highlights: Information Management: Selected Agencies’ Handling of 

Personal Information:

Highlights of GAO-02-1058, a report to the Chairman, Committee on 

Governmental Affairs, U.S. Senate:

Why GAO Did This Study:

To obtain government services, members of the public must often 

provide agencies with personal information, which includes both 

identifying information (such as a name or Social Security number, 

which can be used to locate or identify someone) and nonidentifying 

information (such as age or gender). GAO was asked to review agencies’ 

handling of the personal information they collect and whether this 

handling conforms with federal law, regulation, and agency guidance.

What GAO Found:

GAO reviewed the processes used in handling personal information 

collected from the public on forms at four different agencies—

Education, Labor, and State. These four agencies were chosen because 

forms represent a range of characteristics, including the time needed 

fill them out (the total paperwork burden hours) and the purpose of the 

information they collect. In reviewing these forms, GAO concentrated on 

four areas (information collection, privacy, security, and records 


Handling of personal information varied among the agencies studied. 

Overall, agencies collected a substantial amount of personal 

of a wide variety of types, including personal identifying information 

(names and Social Security numbers) and demographic, financial, and 

legal data (see display below). Agency procedures for handling personal 

information collected were complex, involving numerous processes and a 

wide range of personnel with access to the information. The personal 

information collected was shared extensively with other federal 

agencies, other government entities (state, local, tribal, and 

and private individuals and organizations through authorized 

The agencies generally complied with the key requirements and guidance 

pertaining to information collection, privacy, security, and records 

management. However, GAO identified isolated instances of forms that 

were not accurate or current; other forms did not contain the proper 

privacy notices.

Figure: Agencies Collect Many Types of Personal Information:

[See PDF for image]

Source: GAO analysis.

[End of figure]

What GAO Recommends:

To strengthen agency compliance with requirements for handling personal 

information, GAO recommends that the Secretary of Labor ensure that 

collection forms are up to date and include appropriate Privacy Act and 

other notices. GAO also recommends that the Secretary of Agriculture 

ensure that the notices of how the department shares forms data be 

assessed and forms updated as appropriate.

Labor, Agriculture, Education, and State officials generally agreed 

GAO’s report. In addition, Labor officials posted a valid, up-to-date 

form as recommended.

This is a test for developing highlights for a GAO report. The full 

including GAO’s objectives, scope, methodology, and analysis is 

at For additional information 

about the report, contact  Linda Koontz (202-512-6240). To provide 

on this test highlights, contact Keith Fultz (202-512-3200) or 





Agency Comments:


Appendix I: Selected Agencies’ Handling of Personal Information:

Appendix II: Objectives, Scope and Methodology:

Selected Bibliography:

Related GAO Products:


Table 1: Forms Analyzed:

Letter September 30, 2002:

The Honorable Joseph I. Lieberman

Chairman, Committee on Governmental Affairs

United States Senate:

Dear Mr. Chairman:

The security and protection of personal information[Footnote 1] is a 

topic of growing national concern. Personal information is provided to 

the government by the public for a specific purpose--to receive a 

government benefit, obtain a service or loan, or participate in a 

program. However, this information in the hands of unauthorized persons 

can present a risk to those who provide it--such as misuse of personal 

information or loss of personal privacy.

This report addresses the flow and management of personal information 

at four agencies: the Departments of Agriculture, Education, Labor, and 

State. At your request, we selected one information collection[Footnote 

2] form requesting personal information at each of these agencies, to 

review its life cycle from collection, use, dissemination, and storage, 

through archiving and/or disposal. As agreed with your office, our 

objectives were to (1) document the flow of and practices associated 

with the handling of personal information within these agencies and (2) 

evaluate these information flows and practices against agency and 

federal guidance.

To fulfill our objectives, we modeled the data flows for each of these 

forms. We conducted structured interviews with top agency officials and 

program managers to understand the data flow and agency practices. We 

also reviewed applicable laws and regulations and analyzed agency 

documentation on policies and procedures for using, protecting, making 

available, and disposing of this information. We conducted our review 

from March 2001 to July 2002, in accordance with generally accepted 

government auditing standards.

On August 19, 2002, we provided a detailed briefing[Footnote 3] to your 

office on the results of our work. The briefing slides are included as 

appendix I, and a detailed discussion of objectives, scope, and 

methodology is included as appendix II. The purpose of this report is 

to provide the published briefing slides and appendixes to you and to 

officially transmit our recommendations to the Secretaries of Labor and 


In brief, we reported that these four agencies’ handling of personal 

information varied greatly--including the types and amount collected--

and a wide range of personnel had access to the information. Further, 

these agencies generally followed the applicable laws and regulations 

in the collections we reviewed, and the agency officials recognized the 

need to protect this information. We did, however, note isolated 

instances of forms that were not accurate or current, and other forms 

that did not contain the proper privacy notices.


In order to meet the requirements of the Privacy Act and other relevant 

laws and guidance protecting personally identifiable information, we 

recommend that the Secretary of Labor ensure that the appropriate 

agency officials review their data collection forms to ensure that the 

electronic forms (1) include the Paperwork Reduction Act and Privacy 

Act statements and all notices, as appropriate; and (2) are valid and 

up to date. We also recommend that the Secretary of Agriculture ensure 

that Agriculture officials periodically determine that notices of how 

they share personal information from their data collections are still 

valid (updating their forms as appropriate).

Agency Comments:

In providing oral comments on a draft of this report, officials at 

Labor, State, Agriculture, and Education--including the Assistant 

Secretary for Employment Standards at Labor, the Director of 

Information Management and Liaison at State, and representatives from 

the offices of the Chief Information Officers at Agriculture and 

Education--generally agreed with our results. Officials also provided 

technical comments that we incorporated as appropriate. In addition, 

Labor noted that, as we recommended, they have now posted a valid, up-

to-date electronic employee compensation form on their Web site, which 

includes the required Paperwork Reduction Act and Privacy Act 


As agreed with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days 

from the date of this letter. At that time, we will send copies to the 

Secretaries of the Departments of Agriculture, Education, Labor, and 

State; the Director of the Office of Management and Budget; and other 

interested congressional committees. Copies will also be available at 

no charge on our Web site at

Should you have any questions on matters contained in this report, 

please contact me at (202) 512-6240, or by E-mail at 

Other key contributors to this report included Elizabeth Bernard, Tonia 

Brown, Barbara Collier, Patricia Fletcher, Michael Jarvis, Colleen 

Phillips, David Plocher, and Warren Smith.

Sincerely yours,

Linda D. Koontz

Director, Information Management Issues:

Signed by Linda D. Koontz:

[End of section]


Appendix I: Selected Agencies’ Handling of Personal Information:

[See PDF for Image]

[End of figure]

[End of section]

Appendix II Objectives, Scope, and Methodology:

Our objectives were to:

* determine how agencies are handling personal information collected on 

selected information collection forms; and:

* evaluate the adequacy of agencies’ handling of personal information 

against federal law, regulation, and agency guidance.

We chose one form per information collection from a system of records 

in each of four agencies: Department of Agriculture, Department of 

Education, Department of Labor, and Department of State. We chose these 

four agencies to reflect a broad range in the level of the paperwork 

burden that their information collection imposed on the public; the 

total paperwork burden ranged from a low of about 16.56 million hours 

to a high of about 186.11 million hours annually.

From these agencies, we selected four information collections that 

offered a range of the following variables:

* the type of information collected, e.g., demographic, financial, 

medical, or criminal activity;

* the collection and submission media, e.g., paper, facsimile, and/or 

electronic transactions;

* the type of collection, e.g., application for a direct or guaranteed 

loan, grant or subsidy, medical benefits and/or workplace compensation, 

or receipt of a service;

* the scope of the system, including computer matching agreements;

* the size of the collection burden in hours; and:

* the population groups or audience using the collection, e.g., 

farmers, students, federal workers, and the general public.

Table 1 shows the forms that we analyzed and their owners.

Table 1: Forms Analyzed:

Department; Component; Form.

Agriculture; Farm Service Agency; “Request for Direct Loan Assistance,” 

form FSA-410-1; OMB No.: 0560-0167.

Education; Office of Federal Student Aid; “Free Application for Federal 

Student Aid,” 

form FAFSA; OMB No.: 1845-0001.

Labor; Office of Workers’ Compensation Programs, Division of Federal 

Employees’ Compensation; “Claim for Compensation,” 

form CA-7; OMB No.: 1215-0103.

State; Bureau of Consular Affairs; “Application for U.S. Passport or 


form DS-11; OMB No.: 1405-0004.

Source: Agency data.

[End of table]

To document the flow and practices associated with the handling of 

personal information, we developed detailed data flows of each of these 

forms[Footnote 4] in cooperation with agency personnel involved in the 

direct use of the data. First, we conducted structured interviews with 

top agency officials, including Chief Information Officers and staff, 

to understand the policy framework in place at the agency level. 

Second, we analyzed agency documentation on policies and procedures for 

using, protecting, and making available this information and mapped the 

procedures to the data flows. Third, we interviewed program managers 

responsible for the collection and use of the data collected on the 

forms to better understand the chosen information collection. Fourth, 

using data modeling software, we held in-depth data flow modeling 

meetings with agency staff who received, processed, maintained, and 

disposed of the data, as well as with the program managers responsible 

for the systems. Fifth, we submitted the model of the flow of personal 

information to the system users for their feedback to ensure the 

model’s validity. Finally, we reviewed past GAO reports for relevant 

information on information collection, privacy, security, and records 


In order to evaluate the information flows and practices against agency 

and federal guidance, we reviewed applicable laws and regulations and 

met with and obtained documentation from appropriate agency officials. 

We identified the key requirements of the laws and then compared these 

with agency practices. Our review of laws covered the Privacy Act of 

1974, the Computer Matching and Privacy Protection Act of 1988, the 

Paperwork Reduction Act of 1995, the Government Paperwork Elimination 

Act of 1998, the Computer Security Act of 1987, the Government 

Information Security Reform Act of 2000, the Federal Records Act, and 

the Code of Federal Regulations. We also reviewed pertinent OMB 


We conducted our review from March 2001 to July 2002, in accordance 

with generally accepted government auditing standards.

[End of section]

Selected Bibliography:

[End of section]


Internal Revenue Service Technical Manual, Office of Privacy Advocate. 

Privacy Impact Assessment. Version 1.3. Washington, D.C.: December 17, 


Office of Management and Budget. FY 2001 Report to Congress on Federal 

Government Information Security Reform. Washington, D.C.: February 13, 


Office of Management and Budget, OIRA. Managing Information Collection 

and Dissemination: Fiscal Year 2002. Washington, D.C.: n.d.

Privacy Working Group, Information Policy Committee, Information 

Infrastructure Task Force. Privacy and the National Information 

Infrastructure: Principles for Providing and Using Personal 

Information. Washington, D.C.: June 6, 1995.

SRA International, Inc. Report on Current Recordkeeping Practices 

within the Federal Government. Prepared for the National Archives and 

Records Administration. Arlington, VA: December 10, 2001.


Department of Agriculture, Office of Inspector General, Great Plains 

Region. Farm Service Agency/Commodity Credit Corporation: Security Over 

Information Technology Resources. 03099-47-KC. Washington, D.C.: 

October 31, 2001.


Department of Education, Office of Inspector General, Final Audit 

Report on Audit of the Department’s Records Management Program. ED-OIG/

A11-A0011. Washington, D.C.: September 2001.

[End of section]

Related GAO Products:

[End of section]


Paperwork Reduction Act: Changes Needed to Annual Report. GAO-02-651R. 

Washington, D.C.: April 29, 2002.

Social Security Numbers: SSNs Are Widely Used by Government and Could 

Be Better Protected. GAO-02-691T. Washington, D.C.: April 29, 2002.

Paperwork Reduction Act: Burden Increases and Violations Persist. GAO-

02-598T. Washington, D.C.: April 11, 2002.

Information Resources Management: Comprehensive Strategic Plan Needed 

to Address Mounting Challenges. GAO-02-292. Washington, D.C.: February 

22, 2002.

U.S. Postal Service: Update on E-Commerce Activities and Privacy 

Protections. GAO-02-79. Washington, D.C.: December 21, 2001.

Computer Security: Improvements Needed to Reduce Risk to Critical 

Federal Operations and Assets. GAO-02-231T. Washington, D.C.: November 

9, 2001.

Electronic Government: Challenges Must Be Addressed With Effective 

Leadership and Management. GAO-01-959T. Washington, D.C.: July 11, 


Record Linkage and Privacy: Issues in Creating New Federal Research and 

Statistical Information. GAO-01-126SP. Washington, D.C.: April 1, 2001.

Information Management: Progress in Implementing the 1996 Electronic 

Freedom of Information Act Amendments. GAO-01-378. Washington, D.C.: 

March 16, 2001.

Information Security: Advances and Remaining Challenges to Adoption of 

Public Key Infrastructure Technology. GAO-01-277. Washington, D.C.: 

February 26, 2001.

High-Risk Series: An Update. GAO-01-263. Washington, D.C.: January 1, 


Electronic Government: Government Paperwork Elimination Act Presents 

Challenges for Agencies. GAO/AIMD-00-282. Washington, D.C.: September 

15, 2000.

Internet Privacy: Comparison of Federal Agency Practices with FTC’s 

Fair Information Principles. GAO/AIMD-00-296R. Washington, D.C.: 

September 11, 2000.

Internet Privacy: Agencies’ Efforts to Implement OMB’s Privacy Policy. 

GAO/GGD-00-191. Washington, D.C.: September 5, 2000.

Electronic Government: Federal Initiatives Are Evolving Rapidly But 

They Face Significant Challenges. GAO/T-AIMD/GGD-00-179. Washington, 

D.C.: May 22, 2000.

Information Technology: Comments on Proposed OMB Guidance for 

Implementing the Government Paperwork Elimination Act. GAO/AIMD-99-

228R. Washington, D.C.: July 2, 1999.

Corps of Engineers Electronic Signature System. GAO/AIMD-97-18R. 

Washington, D.C.: November 19, 1996.


Farm Loan Programs: Improvements in the Loan Portfolio but Continued 

Monitoring Needed. GAO-01-732T. Washington, D.C.: May 16, 2001.

USDA Electronic Filing: Progress Made, But Central Leadership and 

Comprehensive Implementation Plan Needed. GAO-01-324. Washington, 

D.C.: February 28, 2001.

Information Security: USDA Needs to Implement Its Departmentwide 

Information Security Plan. GAO/AIMD-00-217. Washington, D.C.: August 

10, 2000.

Information Security: Software Change Controls at the Department of 

Agriculture. GAO/AIMD-00-186R. Washington, D.C.: June 30, 2000.

USDA Information Security: Weaknesses at National Finance Center 

Increase Risk of Fraud, Misuse, and Improper Disclosure. GAO/AIMD-99-

227. Washington, D.C.: July 30, 1999.


Student Financial Aid: Use of Middleware for Systems Integration Holds 

Promise. GAO-02-7. Washington, D.C.: November 30, 2001.

Education Information Security: Improvements Made But Control 

Weaknesses Remain. GAO-01-1067. Washington, D.C.: September 12, 2001.

Financial Management: Internal Control Weaknesses Leave Department of 

Education Vulnerable to Improper Payments. GAO-01-585T. Washington, 

D.C.: April 3, 2001.

Major Management Challenges and Program Risks: Department of Education. 

GAO-01-245. Washington, D.C.: January 1, 2001.

Student Loans: Improvements in the Direct Loan Consolidation Process. 

GAO/HEHS-99-19R. Washington, D.C.: November 10, 1998.


Office of Workers’ Compensation Programs: Further Actions Are Needed to 

Improve Claims Review. GAO-02-637. Washington, D.C.: May 9, 2002.

Office of Workers’ Compensation Programs: Further Actions Are Needed to 

Improve Claims Review. GAO-02-725T. Washington, D.C.: May 9, 2002.

Department of Labor: Status of Achieving Key Outcomes and Addressing 

Major Management Challenges. GAO-01-779. Washington, D.C.: June 15, 


Workers’ Compensation: Action Needed to Reduce Payment Errors in SSA 

Disability and Other Programs. GAO-01-367. Washington, D.C.: May 4, 


Office of Workers’ Compensation Programs: Goals and Monitoring Are 

Needed to Further Improve Customer Communications. GAO-01-72T. 

Washington, D.C.: October 3, 2000.

Information Security: Software Change Controls at the Department of 

Labor. GAO/AIMD-00-192R. Washington, D.C.: June 30, 2000.

Major Management Challenges and Program Risks: Department of Labor. 

GAO/OCG-99-11 Washington, D.C.: January 1, 1999.

Federal Employees’ Compensation Act: Percentages of Take-Home Pay 

Replaced by Compensation Benefits. GAO/GGD-98-174. Washington, D.C.: 

August 17, 1998.


Electronic Signature: Sanction of the Department of State’s System. 

GAO/AIMD-00-227R. Washington, D.C.: July 10, 2000.

Information Security: Software Change Controls at the Department of 

State. GAO/AIMD-00-199R. Washington, D.C.: June 30, 2000.


[1] Personal information is defined as all information associated with 

an individual and includes both identifying information (e.g., name, 

Social Security number, E-mail address, and agency-assigned case 

number) and nonidentifying information (e.g., age, finances, and 


[2] Collections of information include (1) requests for information for 

transmission to the government, such as application forms and written 

report forms; (2) record keeping requirements; and (3) third party or 

public disclosure requirements.

[3] We have amended the briefing as of September 12, 2002, to include 

technical corrections and suggestions provided by the agencies.

[4] We used a data flow modeling tool called Workflow Analyzer from 

Meta Software to map the flow of personal information on each form.

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