Pia

U.S. Department of Housing and
Urban Development
Office of Policy Development & Research
Housing Counseling Research Data Files
Privacy Impact Assessment
August 26, 2008

DOCUMENT ENDORSEMENT
I have carefully assessed the Privacy Impact Assessment (PIA) for Housing Counseling Data
Research Files. This document has been completed in accordance with the requirement set forth
by the E-Government Act of 2002 and OMB Memorandum 03-22 which requires that "Privacy
Impact Assessments" (PIAs) be conducted for all new and/ or significantly altered IT Systems,
and Information Collection Requests.
ENDORSEMENT SECTION
Please check the appropriate statement.
X

The document is accepted.
The document is accepted pending the changes noted.
The document is not accepted.

Based on our authority and judgment, the data captured in this document is current and accurate.

/S/ Marina Myhre
SYSTEM OWNER, MARINA MYHRE
THE PROGRAM EVALUATION DIVISION
OFFICE OF POLICY DEVELOPMENT AND RESEARCH

08/28/08
Date

/S/ Mark Shroder
PROGRAM AREA MANAGER, MARK SHRODER, ACTING DIRECTOR OF
THE PROGRAM EVALUATION DIVISION
OFFICE OF POLICY DEVELOPMENT AND RESEARCH

08/28/08
Date

N/A
DEPARTMENTAL PRIVACY ADVOCATE
OFFICE OF THE CHIEF INFORMATION OFFICER
U. S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

/S/ Donna Robinson-Staton
DONNA ROBINSON-STATON, DEPARTMENTAL PRIVACY ACT
OFFICER
OFFICE OF THE CHIEF INFORMATION OFFICER
U. S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

Date

09/09/08
Date

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TABLE OF CONTENTS
DOCUMENT ENDORSEMENT ................................................................................................ 2
ENDORSEMENT SECTION ...................................................................................................... 2
TABLE OF CONTENTS ............................................................................................................. 3
SECTION 1: BACKGROUND................................................................................................... 4
Importance of Privacy Protection – Legislative Mandates:........................................................ 4
What is the Privacy Impact Assessment (PIA) Process? ............................................................ 5
Who Completes the PIA?............................................................................................................ 5
When is a Privacy Impact Assessment (PIA) Required?............................................................ 5
What are the Privacy Act Requirements? ................................................................................... 6
Why is the PIA Summary Made Publicly Available? ................................................................ 6
SECTION 2 – COMPLETING A PRIVACY IMPACT ASSESSMENT................................ 7
Question 1: Provide a brief description of what personal information is collected................... 7
Question 2: Will any of the personally identifiable information be accessed remotely or
physically removed? ................................................................................................................... 9
Question 3: Type of electronic system or information collection............................................ 10
Question 4: Why is the personally identifiable information being collected? How will it be
used? ......................................................................................................................................... 11
Question 5: Will you share the information with others? (e.g., another agency for a
programmatic purpose or outside the government)? ................................................................ 13
Question 6: Can individuals “opt-out” by declining to provide personal information or by
consenting only to particular use (e.g., allowing their financial information to be used for basic
rent eligibility determination, but for not for sharing with other government agencies)?........ 13
Question 6: How will the privacy of the information be protected/ secured? What are the
administrative and technological controls?............................................................................... 14
Question 7: If privacy information is involved, by what data element(s) is it retrieved from the
system?...................................................................................................................................... 15
SECTION 3: DETERMINATION BY HUD PRIVACY ADVOCATE ............................... 16

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FINAL/APPROVED
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
PRIVACY IMPACT ASSESSMENT (PIA) FOR:
HOUSING COUNSELING RESEARCH DATA FILES
OMB Unique Identifier for IT System(s): N/A and Insert PCAS #: N/A
AUGUST 26, 2008
NOTE: See Section 2 for PIA answers, and Section 3 for Privacy Act Officer’s determination.

SECTION 1: BACKGROUND
Importance of Privacy Protection – Legislative Mandates:
HUD is responsible for ensuring the privacy and confidentiality of the information it collects on
members of the public, beneficiaries of HUD programs, business partners, and its own
employees. These people have a right to expect that HUD will collect, maintain, use, and
disseminate identifiable personal information only as authorized by law and as necessary to carry
out agency responsibilities.
The information HUD collects is protected by the following legislation and regulations:
• Privacy Act of 1974, as amended affords individuals the right to privacy in records that
are maintained and used by Federal agencies. (See
http://www.usdoj.gov/foia/privstat.htm; see also HUD Handbook1325.1 at
www.hudclips.org);
• Computer Matching and Privacy Protection Act of 1988 is an amendment to the Privacy
Act that specifies the conditions under which private information may (or may not) be
shared among government agencies. (See http://www.usdoj.gov/foia/privstat.htm);
• Freedom of Information Act of 1966, as amended
(http://www.usdoj.gov/oip/foia_updates/Vol_XVII_4/page2.htm) provides for the
disclosure of information maintained by Federal agencies to the public, while allowing
limited protections for privacy. See also HUD’s Freedom of Information Act Handbook
(HUD Handbook 1327.1 at www.hudclips.org);
• E-Government Act of 2002 requires Federal agencies to conduct Privacy Impact
Assessments (PIAs) on its electronic systems. (See http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=107_cong_public_laws&docid=f:publ347.107.pdf; see also the
summary of the E-Government Act at
http://www.whitehouse.gov/omb/egov/pres_state2.htm);
• Federal Information Security Management Act of 2002 (which superceded the Computer
Security Act of 1987) provides a comprehensive framework for ensuring the
effectiveness of information security controls over information resources that support
Federal operations and assets, etc. See also the codified version of Information Security

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•

regulations at Title 44 U.S. Code chapter 35 subchapter II
(http://uscode.house.gov/search/criteria.php); and
OMB Circular A-130, Management of Federal Information Resources, Appendix I
(http://www.whitehouse.gov/omb/circulars/a130/appendix_i.pdf) defines Federal Agency
responsibilities for maintaining records about individuals.

Access to personally identifiable information will be restricted to those staff that has a need to
access the data to carry out their duties; and they will be held accountable for ensuring privacy
and confidentiality of the data.
What is the Privacy Impact Assessment (PIA) Process?
The Privacy Impact Assessment (PIA) is a process that evaluates issues related to the privacy of
personally identifiable information in electronic systems. See background on PIAs and the 7
questions that need to be answered, at: http://www.hud.gov/offices/cio/privacy/pia/pia.cfm.
Personally identifiable information is defined as information that actually identifies an
individual, e.g., name, address, social security number (SSN), or identifying number or code; or
other personal/ sensitive information such as race, marital status, financial information, home
telephone number, personal e-mail address, etc. Of particular concern is the combination of
multiple identifying elements. For example, knowing name + SSN + birth date + financial
information would pose more risk to privacy than just name + SSN alone.
The PIA:
• Identifies the type of personally identifiable information in the system (including any
ability to combine multiple identifying elements on an individual);
• Identifies who has access to that information (whether full access or limited access
rights); and
• Describes the administrative controls that ensure that only information that is necessary
and relevant to HUD’s mission is included.
Who Completes the PIA?
Both the program area System Owner and IT Project Leader work together to complete the PIA.
The System Owner describes what personal data types are collected, how the data is used, and
who has access to the personal data. The IT Project Leader describes whether technical
implementation of the System Owner’s requirements presents any risks to privacy, and what
controls are in place to restrict access of personally identifiable information.
When is a Privacy Impact Assessment (PIA) Required?
1. New Systems: Any new system that will contain personal information on members of the
public requires a PIA, per OMB requirements (this covers both major and non-major
systems).

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2. Existing Systems: Where there are significant modifications involving personal
information on members of the public, or where significant changes been made to the system
that may create a new privacy risk, a PIA is required.
3. Information Collection Requests, per the Paperwork Reduction Act (PRA):
Agencies must obtain OMB approval for new information collections from ten or more
members of the public. If the information collection is both a new collection and automated,
then a PIA is required.
What are the Privacy Act Requirements?
Privacy Act. The Privacy Act of 1974, as amended (http://www.usdoj.gov/foia/privstat.htm)
requires that agencies publish a Federal Register Notice for public comment on any intended
information collection. Privacy Act Systems of Records are created when information pertaining
to an individual is collected and maintained by the Department, and is retrieved by the name of
the individual or by some other identifying number, symbol, or other identifying particular
assigned to an individual. The E-Government Act of 2002 requires PIAs for electronic systems
as well as information collection requests that are automated. So, there is a relationship between
the new PIA requirement (when automation is involved) and the long-standing Privacy Act
System of Records Notices (for both paper-based and automated records that are of a private
nature). For additional information, contact the Departmental Privacy Act Officer in the Office
of the Chief Information Officer.
Why is the PIA Summary Made Publicly Available?
The E-Government Act of 2002 requires that the analysis and determinations resulting from the
PIA be made publicly available. The Privacy Advocate in HUD’s Office of the Chief
Information Officer (OCIO) is responsible for publishing the PIA summary on HUD’s web site.
See: http://www.hud.gov/offices/cio/privacy/pia/pia.cfm.

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SECTION 2 – COMPLETING A PRIVACY IMPACT ASSESSMENT
Please submit answers to the Departmental Privacy Act Officer in the Office of the Chief
Information Officer (OCIO). If any question does not apply, state Not Applicable (N/A) for that
question, and briefly explain why it is not applicable.
Program Area: Program Evaluation Division, RRE, Office of Policy Development & Research
Subject matter expert in the program area: Marina L. Myhre, Office of Policy Development
and Research, Program Evaluation Division, Program Evaluation Division, (202) 402-5705.
Program Area Manager: Todd M. Richardson, Office of Policy Development and Research,
Program Evaluation Division, (202) 402-5706.
IT Project Leader: N/A, not an internal HUD system so no IT Project Leader
For IT Systems:
• Name of system: Housing Counseling Research Data Files
• PCAS #: N/A
• OMB Unique Project Identifier #: N/A
• System Code:
For Information Collection Requests:
• Name of Information Collection Request (ICR): Data Collection for the Housing
Counseling Outcome Evaluation is the information collection request that is in process of
being approved by OMB with the expectation that all responses/data collected will be
automated. Expected implementation date of the off-site (on contractors’ computers)
automated system is October 1, 2008.
•

OMB Control #: Will be provided when OMB approves the ICR

Question 1: Provide a brief description of what personal information is collected.
The Housing Counseling Research Data Files are necessary for the execution of HUD’s
Housing Counseling Program. HUD’s Office of Policy Development and Research (PD&R) is
conducting an outcome evaluation of the components of it Housing Counseling Program related
to clients seeking assistance to either purchase a home (pre-purchase clients) to resolve or
prevent mortgage delinquency (foreclosure mitigation clients).
The study is designed to gather statistically accurate information on outcomes realized by
the clients of the participating housing counseling agencies. The study focuses on two groups of
clients: (1) clients seeking assistance to purchase a home (pre-purchase clients) and (2) clients
seeking to resolve or prevent a mortgage delinquency (foreclosure mitigation clients). Up to
thirty housing counseling agencies at random will be recruited to participate in this study. The
selected agencies will provide samples of data from each of the two groups, selected. The data
collected through the study will support analysis of not just the frequency of different client

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outcomes, but also the association between these outcomes and client characteristics, client
circumstances, and the extent of services received.
Additionally, the proposed study will fulfill two important needs for HUD and the
counseling field. First, it will provide systematic information on the outcomes realized by
counseling clients and how these outcomes vary with the characteristics or clients and the
services they receive. The study will also lay the groundwork for a subsequent pre-purchase
impact evaluation by testing data collection procedures to be used to enroll clients, gather
information on the characteristics of the services they receive, and track them over time.
If this automated system (or Information Collection Request) involves personally identifiable
information on members of the public, then mark any of the categories that apply below:
Personal Identifiers:
X Name
X Social Security Number (SSN)
X Other identification number (specify type): Counseling Agency ID number
X Birth date
X Home address
X Home telephone
X Personal e-mail address
Fingerprint/ other “biometric”
Other (specify):
None
Comment:

Personal/ Sensitive Information:
X Race/ ethnicity
X Gender/ sex
X Marital status
X Spouse name
X # of children
X Income/ financial data (specify type of data, such as salary, Federal taxes paid, bank
account number, etc.): Gross monthly income, amount in savings, amount in
retirement accounts, monthly rent paid, monthly utilities paid, mortgage payment
status
X Employment history: Current work status, employment history
X Education level:
Medical history/ information
Disability
Criminal record
X Other (specify): Born in U.S.; English as primary language; homeownership status;
foreclosure status; name, address, and telephone numbers of two relatives or friends
for future follow-up
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None
Comment:
Question 2: Will any of the personally identifiable information be accessed remotely or
physically removed?
Yes
No
If yes, Proceed to answering the following questions.
Have the security controls been reviewed and approved by the
Information Security Officer?
What security controls are in place to protect the information (e.g., encryptions)?
Counseling agencies will be instructed to collect all consent forms and baseline
questionnaires from study participants once they are completed and place them in a sealed
envelop and store them in a locked cabinet in a locked office.
Once a week the sealed envelopes containing the consent forms and baseline
questionnaires will be sent via overnight mail service with package tracking to our
subcontractor IMPAQ International at their offices in Columbia, MD. The consent forms
will then scanned into electronic files that will be encrypted and then provided to Abt
Associates via a secure, password protected HTTPS site. When the consent forms are
used to obtain credit reports for the study, a copy of the consent form will be provided
using the same secure HTTPS site and encrypted files to the agency that obtains the credit
reports. The baseline questionnaires will be entered into a secure electronic database that
is encrypted at the database level. Both the consent forms and baseline questionnaires will
then be stored at a secure off-site facility for the duration of the project. Once the study
is completed, and in keeping with any provisions of the contract governing the retention of
records related to the project, the paper files will be shredded.
All desktop and laptop computers at IMPAQ as well as the database developed for this
project will be protected by IMPAQ's security infrastructure. All PII in the database will
be encrypted at the database level. All other data will be entered into the database by
counselors via a secure website so that all data transmitted over the Internet are encrypted.
The only PII that counselors will have access to read will be the name, address, phone
number, and email address of the study participants at their agencies.
Once the project is over, a copy of the data without any Social Security numbers or dates
of birth will be provided to HUD by the contractor. The contractor will then destroy the
data in their possession in accordance with the specifications in the contract.
What HUD approved application is used to grant remote access (e.g., VPN, Citrix)?
N/A. Counselors would access the system through the Internet via Internet Explorer web
browser. The system requires a username and password to gain access, and only
authorized counselors or staff at each agency would be provided with a username and
password.

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Is there a policy in place restricting remote access from certain locations outside the
Department (For example: Policy may permit remote access, but prohibits access from a
particular place; such as, Kinko’s/Starbuck) or is remote access permitted from all areas
outside the Department?
Yes, no remote access is allowed. Any person from a given counseling agency would be
able to see only data entered into the system by counselors from that same agency. A
counselor from a given agency would not be able to see any data entered by counselors at
other agencies.
Is there a policy that identifies “if” or “if not” downloading and remote storage of this
information is allowed (For example: Policy may permit remote access, but prohibit
downloading and local storage)?
Yes, counseling agencies will not be able to download data from the database. They will
be able to access the database remotely, but the only personally identifiable information
they can access will be the names, addresses, phone numbers, and emails of the study
participants from their agency. Refer to security controls.
Comment:

Question 3: Type of electronic system or information collection.
A. If a new electronic system (or one in development): Is this a new electronic system
(implemented after April 2003, the effective date of the E-Government Act of 2002)?
Yes

No

If yes, please proceed to answering the following questions.
Does the system require authentication?
Is the system browser-based?
Is the system external-facing (with external users that require
authentication)?
B If an existing electronic system: Mark any of the following conditions for your existing
system that OMB defines as a “trigger” for requiring a PIA (if not applicable, mark N/A):
X

Conversion: When paper-based records that contain personal information are
converted to an electronic system Abt Associates has created a baseline
questionnaire for counseling clients to fill out. Current plans are for the counseling
clients to fill this in by hand, counseling agency staff will store it in a locked file
cabinet in a locked office, and then mail all collected forms weekly by FedEx or
other secure and trackable carrier to Abt or IMPAQ for entry into the CSDS
database. This paper form is simply referred to as the "Baseline Questionnaire".
N/A From Anonymous (Non-Identifiable) to “Non-Anonymous” (Personally
Identifiable): When any systems application transforms an existing database or
data collection so that previously anonymous data becomes personally identifiable
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N/A Significant System Management Changes: When new uses of an existing
electronic system significantly change how personal information is managed in the
system. (Example #1: when new “relational” databases could combine multiple
identifying data elements to more easily identify an individual. Example #2:
when a web portal extracts data elements from separate databases, and thereby
creates a more open environment for exposure of personal data)
N/A Merging Databases: When government databases are merged, centralized,
matched, or otherwise significantly manipulated so that personal information
becomes more accessible (with special concern for the ability to combine multiple
identifying elements)
N/A New Public Access: When new public access is given to members of the public or
to business partners (even if the system is protected by password, digital
certificate, or other user-authentication technology)
N/A Commercial Sources: When agencies systematically incorporate into databases
any personal data from commercial or public sources (ad hoc queries of such
sources using existing technology does not trigger the need for a PIA)
N/A New Inter-agency Uses: When agencies work together (such as the federal EGov initiatives), the lead agency should prepare the PIA
N/A Business Process Re-engineering: When altering a business process results in
significant new uses, disclosures, or additions of personal data
N/A Alteration in Character of Data: When adding new personal data raises the risks
to personal privacy (for example, adding financial information to an existing
database that contains name and address)

C. If an Information Collection Request (ICR): Is this a new Request that will collect
data that will be in an automated system? Agencies must obtain OMB approval for
information collections from 10 or more members of the public. The E-Government Act of
2002 requires a PIA for ICRs only if the collection of information is a new request and the
collected data will be in an automated system.
X Yes, this is a new ICR and the data will be automated
No, the ICR does not require a PIA because it is not new or automated)
Comment:
Question 4: Why is the personally identifiable information being collected? How will it be
used?
Mark any that apply:
Homeownership:
Credit checks (eligibility for loans)
Loan applications and case-binder files (via lenders) – including borrower SSNs,
salary, employment, race, and other information
Loan servicing (MIP collections/refunds and debt servicing for defaulted loans
assigned to HUD)
X Loan default tracking: Only for the purpose of tracking the outcomes of the housing
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X

counseling administered to the counseling clients participating in the study.
Issuing mortgage and loan insurance
Other (specify): Soft credit checks for the purpose of evaluating client outcomes of
pre-purchase and foreclosure mitigation counseling.
Comment:

Rental Housing Assistance:
Eligibility for rental assistance or other HUD program benefits
Characteristics on those receiving rental assistance (for example, race/ethnicity, # of
children, age)
Property inspections
Other (specify):
Comment:
Grants:
Grant application scoring and selection – if any personal information on the grantee
is included
Disbursement of funds to grantees – if any personal information is included
Other (specify):
Comment:
Fair Housing:
Housing discrimination complaints and resulting case files
Other (specify):
Comment:
Internal operations:
Employee payroll or personnel records
Payment for employee travel expenses
Payment for services or products (to contractors) – if any personal information on
the payee is included
Computer security files – with personal information in the database, collected in
order to grant user IDs
Other (specify):
Comment:
Other lines of business (specify uses):

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Question 5: Will you share the information with others? (e.g., another agency for a
programmatic purpose or outside the government)?
Mark any that apply:
Federal agencies?
State, local, or tribal governments?
Public Housing Agencies (PHAs) or Section 8 property owners/agents?
FHA-approved lenders?
X Credit bureaus? To conduct soft hits on counseling clients’ credit reports.
Local and national organizations?
Non-profits?
Faith-based organizations?
Builders/ developers?
X

Comment: To individuals under contract to HUD or under contract to another
agency with funds provide by HUD—for the preparation of studies and statistical
reports directly related to the management of HUD’s Housing Counseling Programs.
A. To future researchers selected by HUD to carry out the objectives of HUD’s
Housing Counseling Program in aggregate form without individual
identifiers--name, address, social security number--for the performance of
research and statistical activities of the Housing Counseling Programs.
B. To authorized social science researchers participating in HUD’s Housing
Counseling Program in aggregate form without individual identifiers--name,
address, social security number--for the performance of research and
statistical activities of the Housing Counseling Programs.
C. To participating counseling agencies for only part of the database to gather
data identifying information that they gather from their own clients
participating in the study and not the part of the database that contains social
security numbers, birth dates, or data on the housing counseling clients of
other agencies.
D. To credit bureaus to draw credit reports on the individuals selected to
participate in the Housing Counseling Outcome Evaluation.
E. To HUD’s Housing Counseling System, including the Client Activity
Reporting System (CARS) to match sample clients’ baseline, service
tracking, and outcome data gathered during the course of this research to data
reported on those clients in CARS.

Question 6: Can individuals “opt-out” by declining to provide personal information or by
consenting only to particular use (e.g., allowing their financial information to be used for
basic rent eligibility determination, but for not for sharing with other government
agencies)?
X

Yes, they can “opt-out” by declining to provide private information or by consenting
only to particular use
No, they can’t “opt-out” – all personal information is required
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Comment:
If Yes, please explain the issues and circumstances of being able to opt-out (either for specific
data elements or specific uses of the data):
Clients of the participating counseling agencies will not be required to participate in the study
and so can opt out entirely. If clients decline to participate, it will not affect their ability to
receive services from the agencies. Clients can also agree to participate in the study but decline
to provide any specific information items requested. None of the information items will be
mandatory to participate in the study.

Question 6: How will the privacy of the information be protected/ secured? What are the
administrative and technological controls?
Mark any that apply and give details if requested:
X
X

X

X

System users must log-in with a password
When an employee leaves:
• How soon is the user ID terminated? (1 day, 1 week, 1 month, unknown)?
• How do you know that the former employee no longer has access to your
system? (explain your procedures or describe your plan to improve):
Each employee at IMPAQ has a unique identifier. There is no general company ID
that can be used by multiple employees to login to the system.
It is a violation of IMPAQ security policy to share usernames and logins with
anyone else. When an employee leaves IMPAQ, part of the exit checklist is to
disable the employee's account, so that the employee can no longer login. Remote
access privileges are also disabled.
Are access rights selectively granted, depending on duties and need-to-know? If
Yes, specify the approximate # of authorized users who have either:
• Full access rights to all data in the system:
Limited/restricted access rights to only selected data:
Yes, access rights will be selectively granted, depending on duties and need-toknow. Full access rights to all data in the system will be granted to fewer than 5
users, primarily project managers at IMPAQ and Abt Associates. Limited access
rights will be granted to all participating counseling agencies. Counselors will only
have the ability to review records pertaining to clients of their agency.
Are disks, tapes, and printouts that contain personal information locked in cabinets
when not in use? (explain your procedures, or describe your plan to improve):
No, no disks or tapes are involved in the system. Backup is performed through an
online vendor who backs up data on a frequent, regular basis in a manner such that
the data are encrypted while in transmission over the Internet. No hard-copy
printouts containing personal information are anticipated to be generated on a

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X

X

regular basis. If any are generated as a result of ad hoc report requests, they will be
carefully handled and shredded as soon as they are no longer needed. If these
reports are needed for more than 1 day, they will be kept locked in a locked filing
cabinet or in other storage rooms at IMPAQ or at off-site storage vendors which are
heavily secured.
If data from your system is shared with another system or data warehouse, who is
responsible for protecting the privacy of data that came from your system but now
resides in another? Explain the existing privacy protections, or your plans to
improve:
No, data from our system will not be shared with another system or data warehouse.
Counselors will only be able to view limited data on their own agency clients online.
That data will only be viewed on the counselor’s computer monitor. Our system
will not be designed to download data into a computer at the counselor’s agency.
Other methods of protecting privacy (specify):
Besides physical security of data, IMPAQ has in place procedures for handling
datasets with personal identifiers that is similar to FedEx tracking system in that
personal signatures by members of the IT department or the research team on the
project are required at all stages of data handling until the personal identifiers are
stripped and replaced with unique identifiers that are of no use to a potential identity
thief. All IMPAQ staff are trained in security procedures and policies. Multiple
layers of security are built into the IMPAQ computing infrastructure to maximize
security.
Comment:

Question 7: If privacy information is involved, by what data element(s) is it retrieved from
the system?
Mark any that apply
X

X

Name:
Social Security Number (SSN)
Identification number (specify type):
Birth date
Race/ ethnicity
Marital status
Spouse name
Home address
Home telephone
Personal e-mail address
Other (specify):
None
Comment:

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Other Comments (or details on any Question above):

SECTION 3: DETERMINATION BY HUD PRIVACY ACT OFFICER
The system offers equitable risk assessment using a secure encrypted network for system
access; however, it is the policies and procedures and laws that govern the protection of the data
that ultimately protect individual privacy rights. The security safeguards, administrative
controls, and professionalism applied by Housing Counseling Data Research user officials serves
to further protect individual privacy rights. Please refer to questions 2 and 6 for a detailed
description of the processes in place to ensure data protection.
This system is also classified as a Privacy Act System of Records which is expected to be
published in the Federal Register September 2008. Please visit this site →
http://www.hud.gov/offices/cio/privacy/pia/fednotice.cfm to access the official notice.

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