DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
Office of Human Resource Management Programs and Policies (AHP)
Information Systems Division (AHP-100)
PRIVACY IMPACT ASSESSMENT
For The
August 2010
The Federal Aviation Act of 1958 gives the Federal Aviation Administration (FAA) the responsibility to carry out safety programs to ensure the safest, most efficient aerospace system in the world. The FAA is responsible for:
This system only processes electronic FAA-to-FAA leave balance transfers. Paper-based transfers and transfers to or from non-FAA personnel are not processed through this system.
The OVLTP/ELTP system contains both personally identifiable information (PII) and non-PII of FAA employees who have been approved to accept leave donations under the Voluntary Leave Transfer Program (leave recipients), and FAA employees who have volunteered to transfer available leave to FAA employees who are eligible for such donations (leave donors).
Information collected in the OVLTP/ELTP system about leave recipients includes:
The OVLTP/ELTP is an FAA-internal system used to administer the FAA’s electronic Leave Transfer Program. The FAA’s participation in the program is mandated by 5 U.S.C. 6331-6340; 5 CFR part 630, subpart I, but participation by leave recipients and donors is voluntary.
OVLTP was established to help ease the financial burdens of FAA employees who have exhausted their available paid leave and have a personal or family member with a medical emergency that will require that FAA employee to take a length of leave outside of their available leave balance. The leave recipients are employees absent from duty for prolonged periods due to a certified medical condition that causes a substantial loss of income. This program allows FAA employees to voluntarily donate annual leave or sick leave to approved leave recipients.
The Emergency Leave Transfer Program (ELTP) was established to help current FAA employees who were adversely affected under: (a) Operation Enduring Freedom, (b) Operation Noble Eagle, or (c) an emerging disaster affecting a family member that was a result of the September 11, 2001 terrorist actions. This program allows employees to voluntarily donate accrued annual or sick leave to ELTP leave recipients.
Input into the OVLTP/ELTP system is a voluntary alternative to paper-based processes that are used under the pre-existing Voluntary Leave Transfer Program (VLTP) and Emergency Leave Transfer Program (ELTP).
Note: An MOU is in place for the personnel data (names, leave balance etc.) that serves as the basis for the OVLTP/ELTP system between the AWALAN and the DOT=>IR.
49 U.S.C. 322. 5 U.S.C. 5101, et seq.; 31 U.S.C. 3512. Executive Orders 12107, 12196, and 12564 and 5 U.S.C. chapters 11, 31, 33, 43, 61, 63, and 83.
The OVLTP/ELTP system receives feeds from the DOT IR system, which contains the total available leave time associated with each FAA employee.
A prospective leave donor is able to look up his or her own Annual and/or Sick leave balances within the OVLTP/ELTP system as this data is present in the system due to the feed from the DOT IR system. This information assists the employee in validating his or her own up-to-date leave balances in preparation to make a donation to any FAA employee that is an approved recipient.
For a person to be included in the system as a leave recipient, the individual must first submit their request-related data into the system. After that data has been entered, the system generates an email to the manager of the potential leave recipient requesting review and approval. If the manager approves the request, the request is then passed onto HR staff for review and approval. If HR approves the request, the leave recipient will be added into the system as a formal leave recipient.
When a leave donor completes an online transaction, he or she is able to see the full list of eligible FAA leave recipients, broken down by FAA regional offices. The leave donor is able to see the individual’s full name and the requested leave time. The leave donor is then able to select who he or she would like to donate to. When the leave donor submits their donor request, the request must then be approved by the donor’s supervisor and HR. If the donor’s request is approved by the donor’s manager and HR, the payroll liaisons will receive notification that a pending donation request is outstanding. At that time, the payroll liaisons are able to view the details of the request and the request can be processed. The amount of donated leave, as well as identifying information for the donor and recipient, is displayed electronically to payroll liaisons who accomplish the transfer within the external payroll system, FPPS.
The use of a SSN for both donors and recipients is currently necessary for the proper payroll action of increasing and decreasing employees leave balances within the DOI/FPPS system, resulting in an accurate Leave and Earnings Statements posting to Employee Express by the DOI/FPPS system. Due to the fact that the system encrypts SSNs, using the system to process leave donations reduces the risk of unauthorized disclosures of SSNs by eliminating the need for personnel to manually deliver paper forms containing SSNs.
The PII and the medical information contained in OVLTP/ELTP is shared with the supervisor of the leave recipients, the pertinent leave coordinators in HR, and with the payroll liaisons. Donors do not systematically receive an overview of the circumstances behind the requests.
Payroll liaisons receive notice when leave request are approved, and can view the details of the request. For the leave recipient, these details include the person’s full name, SSN, and their available leave time. For the leave donor, this data includes the person’s full name, SSN, their available leave time, and the amount of time he or she is donating. Payroll liaisons then use the SSNs and full names of both parties to manually transfer the donation within FPPS, the external payroll system.
Other than the manual adjustments made to leave time by the payroll liaison, no other data is shared downstream from OVLTP/ELTP.
Note: An MOU is in place for the personnel data (names, leave balance etc.) that serves as the basis for the OVLTP/ELTP system between the AWALAN and the DOT IR.
Prior to an employee entering a request to either receive or donate leave, the individual passes through screens that explain the system’s purpose and the fact that the program is voluntary. To receive a user ID and password to use the OVLTP/ELTP system, either to request or donate leave, the employee must first conscientiously apply for and receive a user ID and password, and then negotiate through the initial logon screen that included the application’s rules of behavior.
By requesting a user ID, the employee consents to the use of his or her data for the primary purpose of participating in the FAA’s electronic leave donation program. There is no secondary use for the data collected through this system.
The user is also told that the OVLTP/ELTP system is voluntary, but if he/she does not want to use the online system, there is a paper-based process available that may be used to accomplish donations. If the individual is also not comfortable with that process, they can simply not participate in the program.
The OVLTP/ELTP downloads the pertinent name and leave balance information for leave recipients and donors directly from the FPPS-based personnel and payroll tables located on the DOT IR system. If that data is incorrect, it must be adjusted upstream in DOT IR.
The OVLTP/ELTP program makes internal calculations to ensure that donor applicants cannot donate more leave than they have, or than they can legally donate, given their own leave balances. Requests for assistance in cases of medical need are accompanied by medical contact information that supervisors may use to verify circumstances. Additionally, HR must actively review each request and donation before approval can be granted.
Under the provisions of the Privacy Act, individuals may request searches of the OVLTP/ELTP file to determine if any records have been added that may pertain to them.
Under the provisions of the Privacy Act, individuals may request searches of the OVLTP/ELTP system to determine if any records have been added that may pertain to them.
Notification procedure: Individuals wishing to know if their records appear in this system may inquire in person or in writing to the appropriate system manager. Included in the request must be the following:
For questions relating to privacy go to the FAA Privacy Policy: http://www.faa.gov/privacy/.
OVLTP/ELTP takes appropriate security measures to safeguard PII and other sensitive data. Medical information fields and SSN fields are encrypted in the database, and an FAA Order 1370.92 compliant password is required to access the system.
In addition, OVLTP/ELTP limits access to PII according to job function.
Data in OVLTP/ELTP is currently maintained under GRS 1, Item 37. All donation-related data is purged one year after the case closes.
OVLTP/ELTP is a system of records subject to the Privacy Act as it is searched by Name and SSN. You can find OVLTP/ELTP applicable SORNs at the following location:
http://www.dot.gov/privacy/privacyactnotices/
The SORNs applicable to OVLTP/ELTP are as follows:
DOT 11, Integrated Personnel and Payroll Systems, IPPS
DOT 19, Federal Personnel and Payroll Systems (FPPS)
OPM GOVT 10, Employee Medical File System Records