1. Washington Headquarters Services Executive Services Directorate Directives Division DoD Information Collection Program
Public Collections Training: SORNs, Systems, and Surveys Tuesday July 12th,

2. Agenda System of Record Notices (SORNs) How PRA and Privacy interact
Timeline and Process
Reviewing SORNs for PRA requirements
Correct documentation on the SORN to avoid unnecessary delays
IT Systems
How to clear Mega Systems and Feeder Systems
Surveys
How surveys differ from other Collection Instruments
Generic Options
Normal
Fast Track
Questions, Comments, Concerns

3. System Of Record Notices SORNs

4. SORN: PRA & PRIVCY
How does the PRA and Privacy Act relate to one another?
The Paperwork Reduction Act grants the Department the approval to COLLECT the information. The Privacy Act SAFEGUARDS the information once we have it.
For this reason, PRA approval needs to be granted before any information enters our possession.
In what way are our processes similar?
Both programs report to OMB. OMB has final review of our documents before it is finalized. The same individual reviewing SORNs and Privacy Exemption Rules are the same individual that reviews Public Collection Packages.
Both programs and processes include 30 day comment periods, which are intended to run simultaneously when being processed together.
How do we interact?
A few ways. Requirements for the PRA can be identified by looking at a SORN, but a requirement for a SORN or other privacy protection can be identified during the PRA process. Both have goals of complete compliance.
We also must communicate issues/comments from OMB or other Federal Agencies with one another to ensure consistency.

5. SORN PROCESS WITH PRA REQUIREMENT

6. SORN: REVIEW & DOCUMENTATION
CATEGORIES OF INDIVIDUALS
Both the Privacy Officer and IMCO should be looking at this. We are looking for impact on a public population (e.g., Contractors, Spouses, Veterans, Retirees, Applicants, Foreign Nationals).
“Government Employees” should be questioned as to if this includes Contractors.
CATEGORIES OF RECORDS
This is particularly a job for the IMCO.
They will be looking for possible exemptions, exceptions, or already approved collections.
RECORD SOURCE
While this section in the specific SORN may not helpful, the reviewer should be asking the appropriate questions to narrow down the SOURCE of information. Where does it reach our public respondent?
Action Officers who are clearing this System of Records should know where this information stems from. CIO offices also can sometimes provide insight on this.

7. EXAMPLES

8. 15 Minute Break
UP NEXT:
Clearing IT Systems

9. IT SYSTEMS

10. IT SYSTEMS & PRA “Paperwork” Reduction Act
The concept and intent of the law is the approval of “collections of information, regardless of form or format.”
In 1943, IT Systems were not a consideration.
New to Everyone
ALL Federal Agencies are going through the same growing pains.
Testing the waters = No clear guidance yet from OMB on how to proceed.
General guidelines have been provided on previous packages.
MEGA Systems are not our Friends
Mega Systems are Good and Bad for PRA.
Makes the tracking and clearance process extremely difficult.
At what level do you clear a system?

11. ________________________ Clearance follows the information.
DOD MEGA SYSTEM
________________________
A, B, C, D, E, F
A, B F
THREE PRA APPROVALS:
Clearance follows the information.
Mega System is cleared!
C, D, E
FEEDER 1
_________________
FEEDER 2
_________________
FEEDER 3
_________________
A, B, G, H
C, D, E
F, I, J

12. ________________________ Clearance follows the information.
DOD MEGA SYSTEM
________________________
A, B, C, D, E, F
A, B F
THREE PRA APPROVALS:
Clearance follows the information.
Mega System is cleared!
C, D, E
FEEDER 1
_________________
FEEDER 2
_________________
FEEDER 3
_________________
A, B, G, H
C, D, E
F, I, J
Sub-Feeder
_________
F, I, J, K

13. ________________________
DOD MEGA SYSTEM
________________________
A, B, C, D, E, F
K, L
A, B F
C, D, E
FEEDER 1
_________________
FEEDER 2
_________________
FEEDER 3
_________________
A, B, G, H
C, D, E
F, I, J

14. IT SYSTEMS & PRA: TAKE-AWAYS
We should always know where the information is coming from.
The point where the Respondent is involved is the clearance point.
Clearances follow the information.
Systems can be partially covered, and multiple clearances can cover the same system.
Additional information always creates an additional requirement.
Building an Inventory!

15. 15 Minute Break
UP NEXT:
Surveys

16. SURVEYS

17. SURVEYS AS INSTRUMENTS OF COLLECTION
OMB’S CONCERN: THE PUBLIC IS OVERBURDENED BY SURVEYS
DOD’S CONCERN: LOTS OF MONEY SPENT ON DUPLICATIVE WORK & LOW RESPONSE RATES
RESULT:
OMB reviews all surveys separately ( Surveys cannot be combined with any other type of instrument).
OMB requires a Supporting Statement Part B for additional information.
OMB’s statistician will look at Supporting Statement Part B while the submitted collection is under review.
OMB requires that DoD conduct a statistical review of the package prior to it leaving the Department.
Mandatory DMDC review for all Surveys (or survey-like) collections.
Ensures best practices are being used in design and measurement.

18. SURVEYS AS INSTRUMENTS OF COLLECTION
Federal Agency Social Media Pages intended to disseminate information OUT to the public; not to collect information.
PRA is still applicable “regardless of form or format.”
PRA applies to collections of facts or OPINIONS.
Common Sense always applies (Privacy implications as well)
Generic might be a good option.
OMB provided Guidance on Social Media – Ask your IMCO.

19. SURVEYS AS INSTRUMENTS OF COLLECTION
Survey Monkey is NOT the best option.
Retains a copy of respondent information.
Has the option to SELL respondent information at their discretion.
When is Survey Monkey OK?
Entered an agreement with Survey Monkey (beyond their standard subscriptions), and has cleared CIO for information security.
DoD Guidance & Alternatives
DoD Guidance: DoD Instruction : DoD Internet Services and Internet-Based Capabilities
ALWAYS Check with your CIO if there is any doubt.
ICE & MAX.GOV

20. KNOWLEDGE CHECK
A Social Media Post asked individuals whether or not new equipment was needed at the fitness facility on base. Does this need clearance?
If a common response is expected from many, this is a standardized collection of information from the public. Not to mention, this may or may not influence policy and government funding decisions.

21. KNOWLEDGE CHECK
A Social Media Post advertises that the Department of the Navy will be surveying Veterans for ways to improve communication. The Post provides a link to the DON website. Does this require PRA?
The Social Media Post itself does not require PRA, but the survey on the DON website does. OMB will want to see a screenshot of this post because it shows how the public is reached and invited to participate.

22. GENERIC SURVEYS
OMB’s effort to streamline the paperwork clearance process.
Involves an initial approval.
Each instrument developed over the three year approval period goes in for an expedited review.

23. GENERIC SURVEYS: WHAT WOULD APPLY?
Collections where the intent and process is fully developed, but the specific questions or surveys may not be.
Generic Clearances cannot be used for complex survey research projects.
MUST BE:
LOW BURDEN
LOW COST
VOLUNTARY
NON-CONTROVERSIAL
NOT PERMITTED WHEN POLICY OR FUNDING DECISIONS WILL BE MADE
GENERIC

24. GENERIC SURVEYS: NORMAL & FAST TRACK OPTIONS
NORMAL GENERIC: Must fit the constraints on the previous slide. 10 day turn around for one-pager submissions.
FAST TRACK GENERIC: Even more constraints are placed on a fast track. This is a 5 day turn around for one-pager submissions.
Data must be qualitative.
Surveys must be simple in design (such as comment cards).
PROCESS: Two Stages to the approval process:
STANDARD APPROVAL: The overall concept must go through the normal 4-6 month review process, complete with public comment period. OMB approves the collection’s concept and scope and grants a three year approval.
ONE-PAGER SUBMISSION: As survey instruments are developed over the three year period, the surveys, correspondence, and the ONE-PAGER are submitted to OMB for review. Based on the type of Generic you chose, they will return a determination within 5-10 days.

25. GENERIC SURVEYS Interactive Customer Evaluation (ICE)
Cleared as
Understanding what is covered – NOT EVERYTHING IS COVERED
One-Pager process still applies
DoD Fast Track Generic
Cleared as
How to “Bundle”
FUTURE DoD-Wide Generics for Internal Collections as well

26. Office of Information Management (OIM)
Paperwork Reduction Act (PRA): Contact Information
Office of Information Management (OIM)
Frederick C. Licari, DoD Public Collections Clearance Officer
(571)
DoD Information Collections Team
DoD Information Collections Organizational Inbox
DoD Directives Organizational Inbox
DoD Information Collections Website
(PRA Package Information and Templates are available at this link)
OMB Website for Currently Active DoD Collections
(Searchable Public Collection Link)

27. Questions, Comments, Concerns?