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Overview of FRTIB Privacy Program

FRTIB’s program is led by FRTIB’s Senior Agency Official for Privacy (SAOP), and is run by the Privacy Division within FRTIB’s Office of General Counsel (OGC). The mission of the Privacy Division is to preserve and enhance privacy protections for all individuals who entrust their personal information to the FRTIB by embedding and enforcing privacy protections throughout all of FRTIB’s activities. The Privacy Division implements requirements in the Privacy Act of 1974, as amended; the E-Government Act of 2002; and the Federal Information Security Modernization Act (FISMA), as well as policy directives and best practices issued in furtherance of those Acts.

The Privacy Division adheres to the policy framework embodied in the Fair Information Practice Principle (FIPPs) to ensure that individual privacy is protected throughout the collection, maintenance, use, and dissemination of all personally identifiable information (PII) maintained by the FRTIB. The FIPPs consist of the following five core principles: (1) Notice/Awareness; (2) Choice/Consent; (3) Access/Participation; (4) Integrity/Security; and (5) Enforcement/Redress. The Privacy Division carries out the following core functions:

FRTIB Privacy Office Organization

Pursuant to the Federal Employees’ Retirement System Act of 1986 (FERSA), FRTIB is required to administer the Thrift Savings Plan (TSP) prudently, solely in the interest of TSP participants and their beneficiaries, and for the exclusive purpose of providing benefits to participants and their beneficiaries. FRTIB’s Privacy Program is housed within the Office of General Counsel (OGC). The Privacy Division within OGC develops and executes strategies to ensure that privacy is protected for all employees who entrust their personal information to the FRTIB, including (1) TSP participants and beneficiaries; and (2) FRTIB employees and contractors, while promoting the integrity and usability of FRTIB’s data—one of FRTIB’s most valuable strategic assets. The Privacy Division is led by FRTIB’s General Counsel, who has also been formally designated as FRTIB’s Senior Agency Official for Privacy (SAOP) pursuant to OMB Memorandum 16-24, Role and Designation of Senior Agency Officials for Privacy.

The SAOP is FRTIB’s key policy advisor on implementing the Privacy Act of 1974; the privacy provisions of the Federal Information Security Modernization Act (FISMA); the privacy provisions contained in the E-Government Act of 2002; Office of Management and Budget (OMB) requirements; and National Institute of Standards and Technology (NIST) guidance. In accordance with OMB Circular A-130, Managing Information as a Strategic Resource, the SAOP is responsible for:

In accordance with OMB Memorandum 16-24, FRTIB’s SAOP has delegated the daily operations of FRTIB’s privacy program to a senior attorney within OGC, who functions as FRTIB’s Chief Privacy Officer. With the oversight of FRTIB’s SAOP, the CPO handles all of the substantive components of FRTIB’s Privacy Division. Additionally, FRTIB’s Privacy Division is staffed by a team of attorneys who have no non-privacy duties.

Strategic Goals and Objectives for Privacy

Goal 1

Maintain compliance with federal privacy laws, regulations, and best practices.

The Privacy Division serves two primary functions with respect to compliance. First, the Privacy Division represents the interest of TSP participants and beneficiaries in compliance with federal privacy laws, regulations, and best practices. Second, the attorneys in the Privacy Division provide legal advice to the Executive Director, Board Members, and staff of the FRTIB. Adhering to privacy laws and implementing best practices is critical to the success of both the Privacy Division as well as the Agency.

Goal 2

Foster a culture of privacy and demonstrate leadership through policy and strategic partnership

The Privacy Division’s core mission is to preserve and enhance privacy protections for all individuals who entrust their personal information to the Agency, and fostering a culture of privacy at the Agency is a necessary component for achieving this mission. In accordance with the FIPPs, FRTIB is authorized to only collect information necessary to carry out its mission and must use that information in accordance with the stated purpose for which it was originally collected. FRTIB is also authorized to collect, maintain, use, and disseminate personal information from TSP participants, beneficiaries, and individuals who work and seek to work for the Agency.

Goal 3

Provide outreach, training, and education to promote and enhance privacy Agency wide

FRTIB’s Privacy Division ensures that all FRTIB personnel have a baseline understanding of federal privacy requirements by providing training for new hires and annually thereafter. FRTIB’s Privacy Division also develops and provides targeted, role-based training to employees with specialized roles on a periodic basis.

Goal 4

Develop and maintain top privacy professionals in the federal government

FRTIB’s Privacy Division has grown considerably over the past few years and continues to mature. Attracting and retaining specialized talent is critical to the Privacy Division’s continued success. Providing support, opportunities for professional growth and development, and maintaining a workplace environment in which they are valued are all crucial to recruiting and maintaining a high-performing workforce.