PRIVACY IMPACT ASSESSMENT

Transcription

1 PRIVACY IMPACT ASSESSMENT Microsoft Office SharePoint Collaboration & Communication Solution June 2013 FDIC Internal System Table of Contents System Overview Personally Identifiable Information (PII) in SharePoint Purpose & Use of Information in SharePoint Sources of Information in SharePoint Notice & Consent Access to Data in SharePoint Data Sharing Data Accuracy in SharePoint Data Security for SharePoint System of Records Notice (SORN) Contact Us

2 Microsoft Office SharePoint Collaboration System Overview SharePoint is a Microsoft-based product that provides an integrated enterprise environment, allowing users to collaborate, share, and manage electronic information within workgroups and project teams. The Microsoft SharePoint program utilized by the FDIC provides a growing selection of functionalities to improve business collaboration and communications. This includes browser-based process management modules, a document/records management platform, enterprise search modules, personalization, blogs and wikis 1, and advanced indexing and searching capabilities. FDIC mainly uses SharePoint to host Division/Office websites, shared workspaces, information repository and document storage. Authorized users can manipulate certain controls or interact with pieces of content, such as lists and document libraries. SharePoint allows site owners to manage content and security for sites under their responsibility. Acting in coordination with Division/Office SharePoint points of contact, site owners/administrators are responsible for monitoring and maintaining the content of their respective sites. The site owners/administrators ensure that information collected or placed into the FDIC SharePoint sites are appropriate and in line with FDIC data protection and retention policies. FDIC SharePoint sites are the Corporation s secure workspace for collaboration on active documents and other content for business purposes. Data stored on FDIC SharePoint sites may potentially include agency-sensitive information (SI) and personally identifiable information (PII) as necessary to accomplish authorized FDIC business needs. Users are prohibited from storing personal, non-business documents within any FDIC SharePoint site. They must also identify documents containing SI or PII, in accordance with the Corporation s SharePoint Governance Plan and associated policies and procedures. SharePoint also provides a secure work area, known as My Site, where users have the capability to post a professional picture and enter business-related and personal information, such as their professional biography and skills and interests, for others within the FDIC to view. The public profile information is managed by the individual user, and the user may choose privacy levels that help ensure that data stored in their profiles is visible only to intended parties within the Corporation. Personally Identifiable Information (PII) in SharePoint FDIC SharePoint sites will host a variety of data. In general, all electronically stored information found on FDICshare and FDICbcs SharePoint sites must be related to official FDIC business and, as such, may include SI and PII about internal (FDIC) and external (non-fdic) entities as necessary for authorized FDIC business needs. The specific types of PII maintained within FDICshare and FDICbcs SharePoint sites vary depending on the particular business purpose(s) for which the site was designed. FDICmysite ( My Site ) provides a secure workspace for individual users to store business-related and personal information about themselves for others within the Corporation to view. 1 The use of wikis and blogs functionality within FDIC SharePoint is prohibited without prior authorization from Division and Office Directors. 1

3 Microsoft Office SharePoint Collaboration The Document Library section of all SharePoint sites must use the FDIC Document Library template, which requires users to specify a sensitivity level (sensitive, sensitive PII, or non-sensitive) for all documents stored in FDICshare and FDICbcs SharePoint sites. Although users are allowed to store business related SI/PII in SharePoint, users are strongly encouraged to store such records in the official System of Records (SOR) or other appropriate document repositories prescribed in the official business processes and file plans. Moreover, the FDIC SharePoint Governance Plan and associated FDIC policies prohibit users from storing personal (non-business) data in FDICshare and FDICbcs SharePoint sites. Purpose & Use of Information in SharePoint The collection and use of SharePoint data is relevant and necessary to accomplish authorized FDIC business needs. The specific types of PII maintained within SharePoint vary based on the business need(s) for which each SharePoint site was designed (i.e., examination and enforcement, resolution and receivership, legal, vendor/contract management, Human Resources/personnel, etc.). Sources of Information in SharePoint Data maintained in FDICshares and FDICbcs SharePoint sites is obtained and uploaded by authorized FDIC staff and contractors in connection with their various Corporate and Receivership job responsibilities. For example, many documents and items maintained in FDICbcs SharePoint repositories are obtained from failed financial institutions as part of the Division of Resolutions and Receiverships (DRR) bank closing activities performed by FDIC staff and contractors. With regard to FDICmysite, the following types of business and organizational tree information are pulled from Microsoft Active Director (AD) to populate individual users My Site public profile pages: FDIC user name, work address, work telephone number, title, division, supervisors, work groups, etc. Additionally, individual FDIC users can choose to post a professional picture and enter additional business-related and personal data about themselves on their respective My Site profile pages, including a professional biography, skills and interests, languages spoken, schools attended, personal telephone numbers, and birthday. All content posted by users to My Site must be business appropriate and professional in nature. With the exception of a professional photograph, users are not able to upload any other documents to their public profile sites; information may only be entered into predefined text box fields on their respective page. The FDIC SharePoint environment is only accessible to internal FDIC network users. However, FDIC staff or contractors may obtain or receive business data from federal, state, and local agencies as part of their official business functions. They may also receive business data from third-party sources, such as commercial databases (i.e., Lexis-Nexis), nonpublic investigatory databases, credit bureaus, etc. They may store this data in designated SharePoint repositories. In addition, FDIC network users may include federal, state, or local agencies who require access to FDIC SharePoint sites in order to review or post data for official business purposes. All network users are authenticated in order to access or post documents to SharePoint. 2

4 Microsoft Office SharePoint Collaboration Notice & Consent Individual FDIC users have the right to opt out of providing their information for inclusion in SharePoint. FDIC users must affirmatively choose to add personal information to their public profile page within FDICmysite. Business and organizational information (non-pii) is included in FDICmysite. For documents posted on FDICbcs and FDICshare sites, the individuals whose PII is contained in these documents may or may not have the opportunity to opt out of providing their personal information. For example, information posted to FDICbcs sites may be obtained from failed financial institutions, not directly from individuals; this information may be necessary to support the Corporation s resolution and receivership activities. Therefore, the individual is not provided with an opt-out notice. In general, the specific circumstances under which individuals are offered a choice to opt out is dependent on the source of the data. Access to Data in SharePoint In general, only authorized users who require access to SharePoint information in order to perform their official job responsibilities will be granted access to their respective SharePoint sites. Farm Administrator Responsible for all servers in the SharePoint server farm and able to perform all administrative tasks in the SharePoint Central Administration Website for the server or server farm; responsible for global SharePoint configuration, shared services, policies, procedures, and SharePoint vision. Site Collection Administrator Responsible for SharePoint area content. Site Administrator Responsible for site provisioning; maintains and administers site. Site Administrator Assistant Backup to Site Administrators; assists Site Administrator with all tasks but does not manage security, provision new sites, or apply any customizations. Division/Office SharePoint Coordinator Responsible for overall management of Division/Office SharePoint site. Contributor Responsible for adding, editing, and collaborating with other contributors. Reader Adhere to internal Division/Office procedures for approval information on SharePoint and ensure organizational compliance with FDIC policies, procedures, standards, and guidelines governing information resources. In addition, authorized staff and contractors in the Division of Information Technology (DIT) have global access to all FDIC SharePoint sites for information technology purposes. With regard to FDICmysite, the public profile information is edited and managed by the individual user. Users can choose privacy levels that help ensure their data is visible only to intended individuals within the Corporation. 3

5 Data Sharing Other Systems that Share of Have Access to Data in the System: Microsoft Office SharePoint Collaboration There are no direct interconnections between FDIC SharePoint sites and other systems at this time, aside from the business-related data provided by Microsoft Active Director (AD) to FDICmysite. System Name Microsoft Active Directory (AD) System Description Active Directory is a Microsoft program that serves as a database for information about users such as phone numbers, address, user names, etc. Type of Information Processed FDIC user name, work address, work telephone number, title, division, supervisor, work groups, etc. Data Accuracy in SharePoint Each individual user is responsible for ensuring the completeness and accuracy of the data they post to SharePoint sites. Users are required to specify a sensitive level (sensitive, sensitive PII, or non-sensitive) for all documents stored in SharePoint. Additionally, each Division/Office is responsible for conducting annual access and content reviews of their site collections, along with periodic site reviews, in accordance with FDIC SharePoint rules and regulations. Data Security for SharePoint Access to data within the FDIC SharePoint environment is based on business need and a user s need to know. Additionally, access is determined according to the principle of least privilege whereby user accounts are provided the minimal, most restrictive set of permissions required to perform their work. Data contained in the SharePoint environment is secured through controlled access and passwords, and is only accessible to authenticated network users. An audit trail process captures activities on SharePoint sites and monitors usage of the SharePoint servers to prevent unauthorized and suspicious activities. Only the DIT Administrator and his/her designee have access to run the SharePoint audit reporting tool and generate reports. System of Records Notice (SORN) The FDIC SharePoint sites do not currently operate as a Privacy Act System of Records (SORs), nor do they require changes to any existing system of records. FDICshare and FDICbcs may be used to process and store Privacy Act Records from existing FDIC Privacy Act SORs by authorized FDIC staff and contractors in connection with their various Corporate and Receivership job responsibilities. 4

6 Contact Us To learn more about the FDIC s Privacy Program, please visit: Microsoft Office SharePoint Collaboration If you have a privacy-related question or request, Privacy@fdic.gov or one of the FDIC Privacy Program Contacts. You may also mail your privacy question or request to the FDIC Privacy Program at the following address: 3501 Fairfax Drive, Arlington, VA