cityofaustin / atd-data-tech

Austin Transportation Data & Technology Services
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Identify what TPW data requires privacy notifications #17885

Open maccallump opened 3 months ago

maccallump commented 3 months ago

Received email from Privacy Office. Requires to review TPW data for possible PII that require privacy notifications.

The City of Austin’s Privacy Office assists departments to evaluate privacy risks to individuals arising from the processing of their personal information and helps ensure that privacy considerations and protections are incorporated into City processes and projects prior to purchase or deployment. These assessments are called Privacy Threshold Analyses (PTAs) and Privacy Impact Assessments (PIAs).

PRIVACY THRESHOLD ANALYSIS (PTA) A PTA is a questionnaire used to determine if an information technology system contains personal or restricted information, whether a Privacy Impact Assessment (PIA) is required, and if any other privacy and/or security requirements apply to the system. It should be completed when proposing a new information technology system that will collect, store, or process identifiable information or when starting to develop or significantly modify such a system, or when a new electronic collection of identifiable information is being proposed. The Department conducts a Privacy Threshold Analysis when: ☐ an activity involves personal information or otherwise affects an individual’s privacy. ☐ a Privacy Impact Assessment (PIA) is required. ☐ an existing PIA needs updated due to a new or modified collection of personal information. ☐ The department does not currently conduct or participate in PTA’s ☐ The department will conduct or participate in PTA’s. ☐ Click here to enter other processes for conducting Privacy Threshold Analyses

maccallump commented 3 months ago

DEPARTMENT INFORMATION PRIVACY PROGRAM PLAN (PLAN) (For Integrating the Fair Information Practice Principles and Privacy by Design) Privacy Threshold Analysis and Privacy Impact Assessments Please download this document and once complete, email it to privacy@austintexas.gov. Click here to enter Department Name Click here to enter business unit, office, program, system, or subdepartment, if applicable The City of Austin’s Privacy Office assists departments to evaluate privacy risks to individuals arising from the processing of their personal information and helps ensure that privacy considerations and protections are incorporated into City processes and projects prior to purchase or deployment. These assessments are called Privacy Threshold Analyses (PTAs) and Privacy Impact Assessments (PIAs).

PRIVACY THRESHOLD ANALYSIS (PTA) A PTA is a questionnaire used to determine if an information technology system contains personal or restricted information, whether a Privacy Impact Assessment (PIA) is required, and if any other privacy and/or security requirements apply to the system. It should be completed when proposing a new information technology system that will collect, store, or process identifiable information or when starting to develop or significantly modify such a system, or when a new electronic collection of identifiable information is being proposed. The Department conducts a Privacy Threshold Analysis when: ☐ an activity involves personal information or otherwise affects an individual’s privacy. ☐ a Privacy Impact Assessment (PIA) is required. ☐ an existing PIA needs updated due to a new or modified collection of personal information. ☐ The department does not currently conduct or participate in PTA’s ☐ The department will conduct or participate in PTA’s. ☐ Click here to enter other processes for conducting Privacy Threshold Analyses

PRIVACY IMPACT ASSESSMENT (PIA) A PIA is an analysis of how information is collected, maintained, stored, and disseminated. In addition, its purpose is to ensure compliance with applicable legal, regulatory, and policy requirements for privacy; determine and examine the privacy risks and effects of collecting personal information; and evaluate the protections and processes for handling information to mitigate those privacy risks. The PIA uses the Fair Information Practice Principles (FIPPs) and the Information Lifecycle to assess and mitigate any impact to an individual’s privacy. The Department conducts a Privacy Impact Assessment when: ☐ Developing or procuring any new technologies or systems that handle or collect personal or restricted information. ☐ Creating a new program, system, technology, or information collection that may have privacy implications. ☐ Updating an existing system that results in new privacy risks. ☐ Issuing a new or updated rulemaking that involves the collection of personal or restricted information. ☐ The department does not currently conduct or participate in PIA’s. ☐ The department will conduct or participate in PTA’s. ☐ Click here to enter other processes for conducting Privacy Impact Assessments

maccallump commented 3 months ago

Privacy office documents have been submitted. The document discussing privacy notices included the following: TPW does not have the tools to identify PII information in current TPW Datasets. Also, TPW doesn’t own many of the functions that gather this information. I am unable to agree to this without additional tools and clarification from the Privacy Office

maccallump commented 2 months ago

07/18/2024: Privacy Office meeting to talk about plans for rolling out privacy policies and procedures. Asked Privacy Office to come to TPW and present. Maybe the August Managers meeting.