8.6 Agency Specific Privacy Compliance
All changes in this version
Title changed
Before · SP 800-63A
Agency Specific Privacy Compliance
After · SP 800-63A-4
Agency Specific Privacy Compliance
Control changed
Before · SP 800-63A
Section 4.2 requirement 12 covers specific compliance obligations for federal CSPs. It is critical to involve your agency’s SAOP in the earliest stages of digital authentication system development to assess and mitigate privacy risks and advise the agency on compliance requirements, such as whether or not the PII collection to conduct identity proofing triggers the Privacy Act of 1974 [ Privacy Act ] or the E-Government Act of 2002 [ E-Gov ] requirement to conduct a Privacy Impact Assessment. For example, with respect to identity proofing, it is likely that the Privacy Act requirements will be triggered and require coverage by either a new or existing Privacy Act system of records due to the collection and maintenance of PII or other attributes necessary to conduct identity proofing. The SAOP can similarly assist the agency in determining whether a PIA is required. These considerations should not be read as a requirement to develop a Privacy Act SORN or PIA for identity proofing alone; in many cases it will make the most sense to draft a PIA and SORN that encompasses the entire digital authentication process or include the digital authentication process as part of a larger programmatic PIA that discusses the program or benefit the agency is establishing online access to.
Due to the many components of digital authentication, it is important for the SAOP to have an awareness and understanding of each individual component. For example, other privacy artifacts may be applicable to an agency offering or using proofing services such as Data Use Agreements, Computer Matching Agreements, etc. The SAOP can assist the agency in determining what additional requirements apply. Moreover, a thorough understanding of the individual components of digital authentication will enable the SAOP to thoroughly assess and mitigate privacy risks either through compliance processes or by other means.
After · SP 800-63A-4
Section 4.2 requirement 12 covers specific compliance obligations for federal CSPs. It is critical to involve your agency’s SAOP in the earliest stages of digital authentication system development to assess and mitigate privacy risks and advise the agency on compliance requirements, such as whether or not the PII collection to conduct identity proofing triggers the Privacy Act of 1974 [ Privacy Act ] or the E-Government Act of 2002 [ E-Gov ] requirement to conduct a Privacy Impact Assessment. For example, with respect to identity proofing, it is likely that the Privacy Act requirements will be triggered and require coverage by either a new or existing Privacy Act system of records due to the collection and maintenance of PII or other attributes necessary to conduct identity proofing. The SAOP can similarly assist the agency in determining whether a PIA is required. These considerations should not be read as a requirement to develop a Privacy Act SORN or PIA for identity proofing alone; in many cases it will make the most sense to draft a PIA and SORN that encompasses the entire digital authentication process or include the digital authentication process as part of a larger programmatic PIA that discusses the program or benefit the agency is establishing online access to.
Due to the many components of digital authentication, it is important for the SAOP to have an awareness and understanding of each individual component. For example, other privacy artifacts may be applicable to an agency offering or using proofing services such as Data Use Agreements, Computer Matching Agreements, etc. The SAOP can assist the agency in determining what additional requirements apply. Moreover, a thorough understanding of the individual components of digital authentication will enable the SAOP to thoroughly assess and mitigate privacy risks either through compliance processes or by other means.