Federal Trade Commission Privacy Impact Assessment Sentinel

Federal Trade Commission

Privacy Impact Assessment

Sentinel Network Services

(SNS)

January 2021

Table of Contents

System Overview ........................................................................................................................ 3

Data Type, Sources, and Use ...................................................................................................... 9

Data Access and Sharing .......................................................................................................... 17

Notice and Consent ................................................................................................................... 20

Data Accuracy and Security ...................................................................................................... 22

Data Retention and Disposal ..................................................................................................... 24

Website Privacy Evaluation ...................................................................................................... 25

Privacy Risks and Evaluation ................................................................................................... 26

System Overview

1.1 Describe the project/system and its purpose.

The Federal Trade Commission’s (FTC) Bureau of Consumer Protection (BCP) protects

consumers from a variety of fraudulent, deceptive, and unfair practices in the marketplace,

including identity theft, telemarketing fraud, internet fraud, and consumer credit issues. To

further its consumer protection mission, the FTC brings civil and administrative law

enforcement actions to enforce its laws and provides consumer and business education to

enable the public to avoid common harms. The FTC works to ensure that consumers have

accurate information for purchasing decisions and confidence in the traditional and electronic

marketplaces.

BCP’s consumer protection-related activities include consumer complaint collection and

analysis, individual company and industry-wide investigations, administrative and federal court

litigation, rulemaking proceedings, consumer and business education, and the operation of

consumer protection programs. One focus of these activities is the enforcement of the

Telemarketing Sales Rule (TSR) and Do Not Call regulations (16 C.F.R. Part 310). BCP uses

the National Do Not Call Registry

(DNC) to protect consumers from unwanted telemarketing

sales calls; to collect complaints about calls that consumers receive; to assist telemarketers in

complying with regulations; and to assist law enforcement investigations of violations. In

addition, BCP uses the Consumer Response Center (CRC) to allow consumers to report

instances of identity theft and other consumer protection complaints, to guide and educate

consumers, and to assist law enforcement investigations of alleged violations. The CRC acts as

both an information collection and dissemination point to assist the FTC in achieving its

consumer protection mission.

Consumer complaint information received by the FTC is available to thousands of civil and

criminal law enforcement personnel in the United States and abroad through a secure internet

website called the Consumer Sentinel Network (CSN). CSN thus makes the complaint filing

and collection process more efficient for both consumers and law enforcement. Consumers file

one complaint that can be accessed by numerous agencies, each of which may have jurisdiction

and the ability to assist the consumer or prosecute the alleged violation. Likewise, civil and

criminal law enforcement members are able to access, analyze and extract data from CSN,

which also provides a host of other investigatory tools.

In response to the White House Executive Order entitled “Improving the Security of Consumer

Financial Transactions,” released on October 17, 2014, BCP provides the website

IdentityTheft.gov, which lets consumers who have experienced identity theft create a

customized recovery plan based on their specific situation. The website allows consumers to

enter identity theft complaint information, create an identity theft report, and then provides

consumers with a personalized checklist of steps and tools to remediate the identity theft.

BCP’s DNC, CRC, CSN, and IDT programs are collectively referred to as Sentinel Network

Services (SNS). The FTC has contracted with Leidos (formerly Lockheed Martin Information

Systems & Global Services) to implement, maintain, and operate SNS. SNS is a powerful

consumer protection data source, much of which is available to the federal, state, local, and

international law enforcement community. SNS data is also used to identify and track trends

and potential problems affecting the marketplace. SNS contains data collected by the FTC as

well as data collected by other entities and forwarded to the FTC. External contributors include

a broad array of public and private domestic and foreign organizations.

SNS uses several applications or components to collect and share consumer data as described

below. SNS-related data is owned by BCP’s Division of Consumer Response and Operations

(DCRO).

Consumer Response Center (CRC)

The CRC gathers, processes, and updates consumer information via telephone-based services

and Internet-based complaint forms. Consumers may contact the CRC by using two toll- free

telephone numbers, 1-877-FTC-HELP or 1-877-ID-THEFT. Toll-free services include:

• Interactive Voice Response

• Teletypewriter (TTY) for hearing impaired persons

• Live telephone conversations with customer service representatives

Users access a multi-channel bilingual (English and Spanish) contact center to file complaints,

report instances of identity theft, receive and print an identity theft report, and request or receive

consumer education materials.

Consumers may also file complaints directly from their computers and mobile devices using the

online ReportFraud portal, which asks consumers to answer a series of questions organized into

a few simple steps. The portal can be accessed from the URLs Reportfraud.ftc.gov and

www.ftc.gov/complaint. Based on the consumer’s submission the portal will auto-fill

recommended dispute letters, provide steps for reversing fraudulent transactions, and allow

users to see how scams are impacting their specific community. Additionally, the self-service

complaint capability allows ReportFraud.ftc.gov users to provide updated information for their

complaint via ReportFraud.ftc.gov. Consumers who file complaints online in Spanish using

their computers also have access to a web chat feature if they need technical assistance. This

web chat feature is not currently available to consumers using mobile devices. The

ReportFraud.ftc.gov website also use an automated 24x7 Chatbot service to simulate human

interaction with users and assist them to quickly connect with the answers they need when filing

a complaint.

Consumers with cross-border e-commerce complaints

may file an online complaint at

www.econsumer.gov, which offers cross-border consumer protection information and an

additional separate online cross-border complaint form. All information on econsumer.gov,

including the complaint form, is available in English, Spanish, French, German, Polish,

Japanese, Korean, and Turkish. Cross-border e-commerce complaints received from consumers

through the econsumer.gov complaint form are automatically entered into CSN.

Finally, consumers may contact the CRC through postal mail.

The CRC currently handles about 2 million consumer interactions per year. As of May 2020,

consumers have filed 2,187,517 identity theft, fraud, and other complaints with the FTC.

Approximately 64% of those complaints (1,403,824) were submitted online.

National Do Not Call Registry

(DNC)

The DNC consists of four major functions: consumer registration, telemarketer access, law

enforcement access, and consumer complaints. The consumer registration function allows

Cross-border complaints are those where the consumer’s reported country of residence is different from the country

where the consumer reports the company is located.

consumers to register their telephone numbers in the DNC system and to verify whether their

phone numbers are on the registry. Consumers carry out these activities through the secure

Internet site at www.donotcall.gov or via nationwide toll-free telephone numbers (1-888-382-

1222 or TTY 1-866-290-4236). Consumers may also delete their telephone numbers from the

registry by using the toll-free system, if they are calling from the phone that is registered. Users

of the consumer internet site or toll-free telephone number may interact with DNC in English or

Spanish. In addition, the telephone system supports hearing-impaired persons through a toll-free

number for TTY access.

Telemarketers may access DNC through the Internet site www.telemarketing.donotcall.gov.

New telemarketers create a profile and receive an organization ID and password. They then

subscribe to area codes their telemarketing campaign will call and, if required, pay for their

DNC subscription. Upon successful completion of that step, they download registered consumer

telephone numbers within the selected area codes to ensure that they do not call those numbers.

Telemarketers originally were required to download and scrub their lists every 90 days; in 2005,

this was shortened to 31 days. Each time telemarketers access DNC, they must certify that their

organization will comply with the DNC requirements. In addition, telemarketers may access an

online helpdesk system to obtain assistance with technical questions and issues.

CSN law enforcement members in the United States, Canada, and Australia may access the

DNC system to support investigations of violations of the Telemarketing Sales Rule. These

Sentinel members can access information about the registration, verification, and deletion

transactions for individual consumer telephone numbers. They may also gather information

about telemarketer enrollment profiles, clients, subscriptions, and downloads.

Consumers may file complaints about alleged violations of the Do Not Call rules through

Donotcall.gov or by calling 1-888-382-1222. Consumer complaint data received through DNC

is made available to law enforcement on the CSN. In addition, alleged violations are reported

every weekday on the Do Not Call Reported Calls Data webpage. This data contains the

telephone number that made the unwanted call, date and time the call was made, the subject

matter of the call, whether the call was reported to be a robocall, and the complainant’s city and

state.

Consumer Sentinel Network (CSN)

CSN, accessed at www.consumersentinel.gov, is the website through which local, state, federal,

and international law enforcement agencies access complaints collected by the CRC directly

from consumers or complaints collected by other entities and forwarded to the FTC. Included

within CSN is the IDT Data Clearinghouse, which is the nation’s repository of identity theft

complaints, gathered through the Identity Theft Portal. Identity theft complaints are only

available to those law enforcement agencies that request, and are approved for, access to that

data.

Law enforcement authorities that are members of www.econsumer.gov also can access a subset

of the complaints housed in CSN. The www.econsumer.gov site is an initiative of the

International Consumer Protection and Enforcement Network (ICPEN). ICPEN is a network of

governmental organizations in the enforcement of fair trade practice laws and other consumer

protection activities. Through the www.econsumer.gov website, consumers can file complaints

focusing on e-commerce and fraud. Those complaints are housed in CSN, and members of

econsumer.gov are able to access the complaints received through econsumer.gov. Members of

econsumer.gov also can access cross-border complaints in CSN filed through the FTC’s CRC

(either online via ReportFraud.ftc.gov or over the phone) or obtained from external data

contributors that have agreed to share complaints with econsumer members. The econsumer

members will receive these complaints with all consumer PII redacted, except for the

consumers’ country of residence (if it is reported). If an econsumer member requires the

consumers’ PII to support an ongoing investigation or enforcement action, they can apply

directly to the FTC to obtain the complaints containing that information.

Authorized users access the CSN through a secure, password-protected internet site that uses

two-factor authentication. CSN users’ access to the various subsets of data in the system is

based on the access requested by and approvals granted to the organization to which they

belong. For example, certain Canadian law enforcement organizations have access to general

fraud complaints but not identity theft complaints.

Authorized CSN users may search the complaint database by company or suspect name,

address, telephone number, consumer location, type of scam or identity theft, etc. As of 2020,

CSN served over 3,000 law enforcement users around the world that have signed appropriate

confidentiality agreements restricting their use and disclosure of CSN data to law enforcement

purposes.

Information from the CSN system may be compared to existing matter information within the

FTC Redress Enforcement Database (RED) to determine whether any relationships may exist

involving likely recidivists. An automated search between the two systems is performed to

determine if relevant matter-related words or concepts appear in CSN that may overlap with

data in CSN; if a match appears, a notice is emailed to the FTC staff person working on that

particular matter. There is no direct connection between CSN and the RED; for more

information about the RED, refer to the Redress Enforcement Database PIA.

CSN is an effective tool for immediate and secure access to consumer complaints about fraud,

identity theft, Internet fraud, telemarketing, and consumer credit issues, among others.

Authorized law enforcement users can utilize CSN to:

• Find complaints

• Store search results in 100 MB of online storage space

• Search within searches

• Gather related complaints using keywords in the search results

• Extract a limited number of complaints from the system for use in special investigations

Identity Theft Portal (IDT)

IDT, accessed at www.IdentityTheft.gov, allows consumers to file their identity theft

complaints, receive identity theft educational information, and use advanced functionality to

assist with their recovery and remediation. IDT offers secure, self-service capabilities that

provide consumers with a personalized identity theft recovery plan and the opportunity to notify

the Internal Revenue Service (IRS) directly of tax-related ID theft. The portal provides

consumers with customized recovery steps and tools to track their actions in remediating

identity theft.

The FTC will employ the existing procedures under the Commission’s delegation of authority effective March 14,

1997, 62 Fed. Reg. 15185, and the re-delegation by the Director of the Bureau of Consumer Protection dated May 22,

1997, to make determines about releasing the requested information.

All FTC Privacy Impact Assessments are available online.

After filing an identity theft complaint, consumers are provided with the option to create an

account on IDT. Consumers who set up an account on IDT access it through the secure,

password- protected website with two-factor authentication. To create an account, consumers

are sent a temporary password (which is active for 24 hours) to their previously entered email

address. Consumers log in using their email address and the temporary password, at which time

they are prompted to create a permanent password for future use. At that point, a one-time

passcode is delivered to consumers’ phones. Consumers must use this temporary passcode,

which is active for five minutes, to gain access to their IDT account. Moreover, each time

consumers access their IDT account, a one-time passcode is delivered to their phone that must

be entered along with their email address and password.

Consumers can use IDT to:

• File an identity theft complaint and receive an IDT report

• Obtain a personalized checklist of steps they should take to review

• Utilize a personalized dashboard to track their progress and suggest additional action

steps based on an updated complaint information

• Access and update their IDT report as often as necessary

• Automatically generate prefilled letters and forms, based on their complaint information,

that consumers can send to CRAs, government agencies, and businesses to resolve their

incidents of identity theft

• Electronically submit an Identity Theft Affidavit (IRS Form 14039) to the IRS

For some SNS websites, including www.donotcall.gov, www.consumersentinel.gov,

andReportfraud.ftc.gov, , the FTC participates in the General Service Administration’s (GSA’s)

Federal Digital Analytics Program, which uses a Federal government-specific version of Google

Analytics Premium. More information on that program is accessible at

https://digital.gov/services/dap/common-questions-about-dap-faq/.

The Identity Theft Report Verification Portal allows the three national credit reporting agencies

(CRAs)—Experian, Equifax, and TransUnion—to verify the validity of potentially fraudulent

identity theft reports purportedly generated from IdentityTheft.gov. This secure online portal

permits a limited number of CRA employees to check whether a questionable report was filed

on IdentityTheft.gov, based on information contained in SNS. Following a two-factor

authentication protocol, the portal requires the CRA employee to enter the consumer’s first

name, last name, and the identity theft (IDT) report number, as they appear on the IDT report

provided by the consumer to the CRA. After it searches SNS for this information, the portal

informs the CRA user whether there is a full match, partial match, or no match. The portal does

not display nor verify the content of the IDT report, and it does not provide any other consumer

data. The verification portal is limited to individual searches.

1.2 What specific legal authority allows for the collection, maintenance, or

dissemination of information for this project/system?

Several statutes authorize the FTC to collect and maintain consumer complaints. Section 6(a) of

the FTC Act, 15 U.S.C. § 46(a), authorizes the Commission to compile information concerning

and to investigate business practices in or affecting commerce, with certain exceptions.

Information relating to unsolicited commercial email is collected pursuant to the FTC’s law

enforcement and investigatory authority under the CAN-SPAM Act of 2003, 15 U.S.C. § 7704.

In addition, the Identity Theft and Assumption Deterrence Act of 1998, 18 U.S.C. § 1028 note,

mandates the Commission’s collection of IDT complaints, and Executive Order 13681,

Improving the Security of Consumer Financial Transactions, requires various government

agencies to consolidate identity theft resources onto IdentityTheft.gov wherever possible, and to

enhance the functionality of IdentityTheft.gov, including by coordinating with the credit

bureaus to streamline the reporting and remediation process with the credit bureau’s systems to

the extent feasible.

Amendments to the Telemarketing Sales Rule (TSR), 16 C.F.R. Part 310, required the

implementation of the National Do Not Call Registry

and collection of consumer telephone

numbers and DNC-related complaints. The TSR also requires telemarketers to access the

National Do Not Call Registry.

Telemarketer SSN/EIN collection is mandatory under 31

U.S.C. § 7701.

User names, password, and other system user data that is collected from CSN users accessing

the secure system is collected pursuant to the Federal Information Security Modernization Act

of 2014 (FISMA), 44 U.S.C. § 3551 et seq.

Data Type, Sources, and Use

2.1 Specify in the table below what types of personally identifiable information (PII)

may

be collected or maintained in the system/project. Check all that apply.

The various SNS components collect and maintain personal information that consumers

voluntarily submit when they contact the FTC to file a complaint or to request information. The

CRC and IDT collect such information directly from consumers or from their guardians or

others acting on their behalf. The information may be submitted by using the CRC’s online

ReportFraud portal found at ReportFraud.ftc.gov or www.ftc.gov/complaint, developing a

personalized identity theft recovery plan at www.IdentityTheft.gov, or by calling or writing to

the CRC. Consumers may also submit similar information through the separate complaint form

found at econsumer.gov. The personal information provided to and collected by SNS may

include:

PII Elements: This is not intended to be an exhaustive list. Specify other categories of PII as

needed.

Full Name

Date of Birth

Home Address

Phone Number(s)

Place of Birth

Age (range)

Race/ethnicity

Alias

Sex

Email Address

Work Address

Taxpayer ID

Credit Card Number

Facsimile Number

Medical Information

Education Records

Social Security Number

Mother’s Maiden Name

Biometric Identifiers (e.g.,

fingerprint, voiceprint)

Audio Recordings

Photographic Identifiers

(e.g., image, x-ray, video)

Certificates (e.g., birth,

death, marriage, etc.)

Legal Documents, Records,

Notes (e.g., divorce decree,

criminal records, etc.)

Vehicle Identifiers (e.g.,

license plates)

Financial Information (e.g.,

account number, PINs,

passwords, credit report,

etc.)

Geolocation Information

Passport Number

User ID

Internet Cookie Containing

PII

Employment Status,

History, or Information

Employee Identification

Number (EIN)

Salary

Military Status/Records/ ID

Number

IP/MAC Address

Investigation Report or

Database

Driver’s License/State ID

Number (or foreign country

equivalent)

Other (Please Specify): See

description below

Additional PII elements may include: address of victim at time of identity theft (if different than

current address), relationship to suspect (only for identity theft complaints), free-form

description of consumer’s issue(s), and steps taken in remediating their identity theft problem,

and complaint reference number may also be included.

Consumers submitting complaints about the accuracy of their credit reports are encouraged to

submit their complaints to the Consumer Financial Protection Bureau (CFPB), and those filing

their complaints online are directed to the appropriate form at that agency. SNS collects and

maintains the subject matter of consumers’ complaints and information regarding the

companies, entities, or individuals about which the consumer is complaining. If the complaint is

Per OMB Circular A-130, personally identifiable information (PII) means information that can be used to distinguish or

trace an individual’s identity, either alone or when combined with other information that is linked or linkable to a

specific individual.

As the consumer begins to type in his/her address, an address auto-completion application verifies and validates the

consumer’s address, listing possible responses. In performing this function, this application does not collect or have

access to consumer information in the SNS database.

reported by someone else on behalf of the consumer, then the name, address, and contact

information of the person reporting the complaint is also captured along with the affected

consumer’s information, and both are stored in CSN.

If consumers submit their entire identity theft complaint by phone, but would like to print a

copy of a report of their complaint to provide to law enforcement, the CRC customer service

representative will start the IDT account creation process by generating a temporary password

that will be sent to the consumers’ email address. Consumers will access their IDT account

online using a two-factor authentication process and will be prompted to create a permanent

password. They then will be able to print their report from the secure dashboard.

When consumers’ complaints contain information about an individual, the CRC and IDT may

collect the following personal information about the individual about whom the consumers are

complaining:

• First and last name

• Middle name and suffix (only for identity theft complaints)

• Street address, city, state, country, and postal code

• Email address

• Telephone number(s)

• Individual’s relationship to consumer (only for identity theft complaints)

• Method individual used to obtain the complainant’s personal information without

authorization (only for identity theft complaints)

In addition to the standard information collected on the CRC’s complaint form, consumers who

identify themselves as associated with the military may provide their service branch, posting,

status, and pay grade.

To help victims of scams reverse high dollar, fraudulent banking transactions,

ReportFraud.ftc.gov may also collect complaint data with useful banking data fields and

facilitate data transfer to the FBI Recovery Asset Team (RAT) for investigation.

If consumers opt to submit an Identity Theft Affidavit (IRS Form 14039) electronically to the

IRS when visiting IDT, the following additional information may be requested to complete the

affidavit:

• Taxpayer Identification Number (Social Security Number)

• Tax year(s) where identity theft occurred

• Last year a tax return was filed

• Preferred contact language

• Preferred contact time

• Mailing address and name used on last filed tax return (if changed)

• Copy of IRS notice or letter number (if received)

• If affidavit is being filed out by representative on behalf on consumer, their

relationship to the consumer

For system auditing purposes, SNS also collects and stores the following user responses and

computer system- and network-related information along with the consumer complaints:

Consumers have the option to submit an Identity Theft Affidavit (Form 14039) electronically to the IRS when they visit

www.IdentityTheft.gov.

If consumers opt to fill out the affidavit, they will need to provide their SSN. SSNs collected for

the purpose of filing an affidavit with the IRS will be deleted from SNS within two business days after the IRS confirms

receipt of the affidavit, and in any event, no later than 15 days after the consumer submits it to the FTC.

• Internet protocol (IP) address of the computer the consumer was using when

submitting a complaint online or participating in a web chat session

• Name of the domain and host from which the consumer gained access to the online

complaint forms

• Answers or responses provided by consumers to the questions presented by the online

ReportFraud portal or the IVR while gathering their complaints

• Date and time when the consumer’s complaint or questions are submitted or updated

• Duration of any web chat session

• Transcripts of any web chat sessions

• User’s Internet browser software information

• Time and date of login to IDT account

The source IP address for Identity Theft is collected to identify services and entities, such as

public libraries, community-based organizations, legal assistance services, and other

organizations that consumers use to access IdentityTheft.gov.

Consumers with technical and navigation questions on IdentityTheft.gov can click on a web

chat icon labeled: “Having trouble categorizing your complaint? Click here to chat with tech

support [hours are listed].” Consumers then receive a dialogue box that prompts them to put

their first name and up to 250 characters of alphanumeric text to describe their technical issue.

The consumer’s first name and description of their technical issue is collected to facilitate a

professional interaction with the customer service representative and to aid in resolving the

consumer’s issue. This information, along with a transcript of the chat, date, and duration of the

chat, are maintained for 60 days, for auditing, QA, and billing purposes only.

SNS also includes consumer complaint data collected and forwarded to the FTC by external

data contributors. External data contributors include a broad array of public and private

domestic and foreign law enforcement, consumer protection, and other organizations. The

consumer complaint data collected from external data contributors includes the same type of

data collected by the CRC.

DNC collects and maintains information that consumers voluntarily submit either via the

internet site or by calling the DNC’s toll-free telephone numbers. For registrations,

verifications, and deletions completed over the telephone, the only information provided by

consumers is their telephone number. Consumers registering via the DNC website must also

provide an email address, which is used as part of an online confirmation process that includes

the delivery of an email message containing a single-use, limited duration link to confirm the

DNC registration information. Importantly, the DNC registry uses a secure hash algorithm to

maintain the security of consumers’ email address information. For consumers who call the

DNC toll-free telephone numbers, access control is limited by requiring them to call from the

telephone that they wish to register, delete, or verify. The DNC only collects telephone

numbers, and the numbers are not associated with any other information, including email

addresses.

For DNC complaints, consumers must provide the telephone number that the telemarketer

called and when the telemarketer called. Optionally, consumers may also provide the name

Only the first two bullets on this list – answers provided by consumers and date and time when a consumer submits or

updates his/her complaint or questions – are directly linked to the complaint information stored in SNS.

The content of log chat sessions are collected and retained for 60 days for auditing, accounting, and quality assurance

purposes. The web chats prompt users not to share personal information and automatically redacts SSN.

and/or the telephone number of the telemarketing company, their name and address, and

additional comments. Consumers are cautioned not to provide sensitive PII such as their SSNs.

Any such information is redacted and not retained. Consumers are also asked to answer the

following four questions:

• Have you done any business with this company in the last 18 months or contacted

them in the last 3 months?

• Was this a pre-recorded message?

• Have you asked this company to stop calling you?

• Did you receive a phone call or mobile text message?

When telemarketers enroll and create their profiles, they must provide the following

information: their organization name and address; Employer Identification Number (EIN) or

SSN in the case of a sole proprietorship; organization contact person; and the contact person’s

telephone number and email address. If an entity is accessing the registry on behalf of a seller-

client, the entity also will need to identify that client. Telemarketer payment information,

including account numbers, is collected and handled by Pay.Gov, the federal government

payment processor operated by the US Department of the Treasury, and is not shared with the

FTC.

Telemarketers who submit requests to DNC’s online Help Desk are explicitly cautioned, with a

notice at the top of the request form, not to provide their EIN or SSN when making a Help Desk

request. If an EIN or SSN is provided, it is redacted.

When telemarketers download the list of telephone numbers from the DNC, the system keeps

track of the area codes of the telephone numbers that are downloaded. For system auditing and

security purposes, DNC also collects and stores certain computer system and network related

information. This information, which typically is collected for any website that maintains logs,

is needed to protect the security of the site and monitor traffic patterns, including threat

indicators of attacks on the site. It includes the following:

• Date and time when the user gained access to DNC

• Name of the domain and host from which the user gained access to the DNC site

• Internet address of the site from which the user linked directly to the DNC site

• Internet protocol (IP) address of the computer the user was using

• User’s Internet browser software information

• User’s computer Operating System information

Law enforcement users requesting access to the CSN must go through a comprehensive and

secure registration process and become approved and authorized CSN members before being

given access to the information available in the system. During the law enforcement

organization registration process, the FTC collects name, mailing address, email address, and

contact information associated with the organization requester, organization administrator, and

the approving authority within the applying organization. In addition, the FTC also gathers the

static IP address range that the organization's computers will use when accessing the Internet.

Law enforcement users’ access to the CSN is restricted to the IP address range provided at

registration in order to reduce the risk of unauthorized access. During the individual law

enforcement user registration process, the FTC collects the law enforcer’s name, work address,

telephone number, and email address, as well as a copy of their government issued ID or badge.

If the consumer indicates that they received a text message, they are redirected to ReportFraud to file their complaint.

For more information, see Pay.gov Privacy Impact Assessment.

In addition to law enforcement users, relevant sections of CSN may be accessed by approved

data contributors periodically to upload and contribute bulk consumer complaint data to the

FTC. These approved data contributors only have access to those sections of CSN that enable

submission of bulk complaint data and do not have access to the complaint data maintained in

the system. Name, mailing address, email address, and phone contact information of prospective

and approved data contributors is collected and stored in SNS. Similar to data contributors,

relevant sections of CSN may also be accessed by approved data receivers who

may

periodically login and download requested complaint data that has been exported out of SNS.

This is a manual intervention process; access to this feature is limited and information is not

made available for download without prior review and approval by the FTC.

Similar to CRC and DNC, CSN captures the certain computer system- and network-related

information for security and system auditing purposes. This information, which typically is

collected for any website that maintains logs, is needed to protect the security of the site and

monitor traffic patterns, including threat indicators of attacks on the site. It includes the

following:

• Date and time when the user gained access to CSN

• Name of the domain and host from which the user gained access to CSN

• Internet address of the site from which the user linked directly to the CSN site

• Internet protocol (IP) address of the computer the user was using to access CSN

• User’s Internet browser software information

• User’s computer Operating System information

• User’s login and password

2.2 What types of information other than PII will be collected, disseminated, or

maintained by the project/system? Provide a general description below and be sure

to include all data elements.

The customer service representative with whom the consumer chats and the automated Chatbot

are trained to provide information about technical assistance and to avoid substantive advice or

assistance that could lead to a consumer providing sensitive PII. Consumers are randomly

selected to participate in a customer satisfaction survey after both the telephone and online

complaint process.

Participation is strictly voluntary, and no personal information is collected

in these surveys. The FTC uses aggregate reports of the findings and any specific comments

that consumers chose to provide to improve the quality of FTC services.

2.3 What is the purpose for collection of the information listed above?

The FTC collects and maintains consumer complaints to further its consumer protection

mission. By collecting, maintaining, and analyzing this data, the FTC is better able to target law

enforcement action, provide consumer and business education to protect the public, and identify

trends in consumer fraud and law violations.

The FTC collects and maintains consumer telephone numbers in DNC to make them available

to telemarketers to ensure that telemarketers do not call the numbers on the registry. In addition,

all registration, verification, and deletion transaction history for individual telephone numbers is

maintained to assist law enforcement action. All telemarketers’ identifying information,

including profile information, which includes EINs and SSNs, is maintained to assist law

enforcement investigations. Law enforcement members of CSN have access to this information.

The computer system and network-related Google Analytics information collected by SNS is

used to determine the number of visitors to different sections of the respective websites –

including DNC, CRC, IDT and CSN – to help make the corresponding sites more useful, to

help ensure the proper operation of these sites, and to help resolve Help Desk requests.

SNS

also collects consumers’ IP address information and other session or user data to protect the

integrity and security of the system by monitoring traffic and helping to prevent malicious

attacks. This information is not used to track or record information about individuals.

Information is collected through the live web chat and automated Chatbot features for the

purposes of improving the consumers’ experience, to provide technical assistance regarding

complaints being filed, and to better tailor the online ReportFraud.ftc.gov portal to meet

consumers’ needs. A minimum amount of information is collected to meet this objective.

For complaints submitted by consumers identifying themselves as members of or dependents to

members of the military, the FTC allows consumers to identify their service branch, posting,

status, and pay grade. This information enables CSN law enforcement members to better

investigate and follow-up on complaints submitted by, and fraud directed at, consumers in the

armed forces.

As previously mentioned, the FTC also collects information from law enforcement users who

request access to the CSN. This information includes contact information (e.g. name, address,

etc.), IP address information, and also their login and password. The FTC collects and

maintains this information to help ensure the security of the system. In addition, to foster law

enforcement cooperation, contact information for CSN law enforcement users is made available

to all CSN members, and a list of all CSN member agencies is made available to the public.

When a user opts to submit an Identity Theft Affidavit (Form 14039) to the IRS through IDT,

the FTC collects personal information to complete the form. This information is submitted to

the IRS via the IRS Secure Data Transfer System.

The Identity Theft Report Verification Portal allows CRAs to verify whether questionable

consumer IDT reports were generated in IdentityTheft.gov.

In certain cases, SNS provides banking information from ReportFraud.ftc.gov to the FBI

Recovery Asset Team (RAT) to assist victims in reversing high value fraudulent transactions.

2.4 What are the sources of the information in the system/project? How is the

information collected?

Source of Data

Type of Data Provided & How It Is Collected

Members of the Public

(Consumers)

Complaints maintained in SNS are voluntarily submitted

by consumers (or others acting on their behalf) to either

the FTC or to the FTC’s external data contributors.

For more information on how Google Analytics collects aggregated and anonymized information to analyze web

traffic on the SNS sites, see https://digital.gov/services/dap/common- questions-about-dap-faq/.

For more information about how the IRS handles PII, see the IRS Privacy Policy.

Source of Data

Type of Data Provided & How It Is Collected

Consumer complaint information gathered by the CRC is

collected through the following channels:

•

Customer service representatives at the contact

center enter or update complaints during live

conversations with consumers. The customer

service representatives use a complaint/identity

theft entry/update interface that ensures the

collection of required data elements.

•

Complaints are entered directly by consumers

via the Online ReportFraud.ftc.gov portal ,

which may be accessed from www.ftc.gov or

www.IdentityTheft.gov using computers or

mobile devices.

•

Voluntary consumer surveys hosted by

ForeSee and the CFI Group.

•

Live Web Chat and Chatbot software by

consumers entering information about

technical issues.

Information required for consumers to build a

personalized identity theft recovery plan or

electronically submit an Identity Theft Affidavit (Form

14039) to the IRS via IdentityTheft.gov is collected

when a consumer fills out an identity theft report plan at

www.IdentityTheft.gov.

Consumer complaints relating to cross-border e-

commerce fraud is gathered through

www.econsumer.gov and provides online complaint

forms in English, Spanish, French, German, Polish,

Japanese, and Korean.

Consumers who wish not to receive telemarketing calls

can register their telephone numbers on the DNC, either

online via the DNC website (www.donotcall.gov), or by

calling the toll free phone numbers.

Information required for consumers to build a

personalized identity theft recovery plan or

electronically submit an Identity Theft Affidavit (Form

14039) to the IRS via IdentityTheft.gov is collected

when a consumer fills out an identity theft report plan at

www.IdentityTheft.gov.

Consumer complaints relating to cross-border e-

commerce fraud is gathered through

www.econsumer.gov and provides online complaint

See the FTC Surveys Privacy Impact Assessment for more information.

Source of Data

Type of Data Provided & How It Is Collected

forms in English, Spanish, French, German, Polish,

Japanese, and Korean.

Consumers who wish not to receive telemarketing calls

can register their telephone numbers on the DNC, either

online via the DNC website (www.donotcall.gov), or by

calling the toll free phone numbers.

CSN Customer Service

Representatives

Most physical mail received by the FTC is scanned and

entered into CSN by customer service representatives

using the contact center complaints/identity theft

interface. Physical mail is retained onsite at the FTC for

up to a year, after which it is shredded. An electronic

copy of the scanned mail is attached to a complaint in

CSN and retained under the retention schedule for

complaints.

External data contributors

The major external data contributors to SNS currently

include the following: Better Business Bureau (BBB),

Consumer Financial Protection Bureau (CFPB), State

Attorneys General (currently 21), Privacy Star, and

Green Dot.

Most of the contributors send batched data using CDs,

DVDs, email, or a secured Web interface. The FTC

insists that all data sent by external organizations be

encrypted and securely maintains the original data

contributor files for a period of 90 days after records

from that file have been successfully uploaded into the

SNS database. For data files received via email or Web

service, the FTC encrypts the data at rest. At the end of

this retention period, the FTC purges the original files. If

the files were transmitted via CD, DVD, or similar

portable media, the media is destroyed in a manner that is

consistent with OMB and the National Institute of

Standards and Technology (NIST) security standards.

Telemarketers

Telemarketer information gathered by DNC is provided

by telemarketers and sellers through the telemarketer

internet site (www.telemarketing.donotcall.gov).

External law enforcement

partners

Law enforcement organization and user information for

access to the CSN is provided directly by the law

enforcement member and their respective organization.

Law enforcement officials signing up for access provide

information about their organization and their position

within their organization through the website. Signed

documents confirming this information and certifying

the organization’s agreement to CSN’s policies is done

by mail, PDF by mail, or fax.

A complete list of data contributors is available in the FTC’s annual Consumer Sentinel Network Data Book. SNS

does not receive data from commercial data brokers or information resellers.

Data Access and Sharing

3.1 In the table below, specify the systems/applications and groups (both FTC and non-

FTC) that will have access to or share data in the system/project.

Data Will Be Accessed By

and/or Provided To:

How and Why the Data Will Be Accessed/Shared

FTC employees and on-

site contractors

Within the FTC, SNS data is used by attorneys,

investigators, paralegals, data analysts, and economists to

accomplish their consumer protection missions and

identify potential targets for law enforcement actions. SNS

data also may be used as evidence in legal proceedings and

may be filed in court. In addition, SNS data may be used to

help resolve consumer complaints, locate victims, respond

to inquiries, provide consumer and business education, and

identify trends. SNS data is also used to assist with

consumer redress, periodically review the effectiveness of

the FTC’s current consumer protection regulations, and

develop consumer and business education programs and

publications. Aggregate numbers compiled from SNS data

also help determine the effectiveness of the FTC’s

consumer protection program in accordance with the

Government Performance & Results Act. All internal users

have read-only access.

SNS limits users’ access to the features, functions and data

for which they are authorized. For example, the contractors

involved with data collection can only view the data that

they enter or update, and data contributors only can access

parts of the system that will allow them to contribute their

data. SSNs are not visible to FTC users or external law

enforcement users. The FTC maintains audit logs of each

user’s activity in SNS to make sure that any data access

can be traced for security reasons.

Leidos staff

The FTC’s contractor involved with the design,

development, and maintenance of the system, Leidos, has

access to the SNS data to maintain and support the

ongoing SNS operations including web portal hosting

services and call center services. Leidos staff serve as

Customer Service Representatives for the Consumer

Response Center (CRC). For example, a call center

Customer Service Representative interacts directly with

consumers and records the data into the SNS system.

Customer services representatives also have the ability to

enter consumer complaint information in to the system

and update consumer complaint records already entered,

which they do when they received updated information

from the consumer complainant.

Telemarketers

Telephone numbers included in the DNC Registry are

shared with telemarketers to ensure that telemarketers do

not call those numbers. Telemarketers with currently valid

Data Will Be Accessed By

and/or Provided To:

How and Why the Data Will Be Accessed/Shared

subscriptions must, in accordance with the Telemarketing

Sales Rule, access and download consumer telephone

numbers in their subscription at least every 31 days to

ensure that they do not call those numbers.

Information provided by telemarketers to the DNC

Registry is made available to both the FTC and CSN

members for law enforcement purposes. Alleged DNC

violations are publicized every weekday on the Do Not

Call Reported Calls Data webpage. This data contains the

telephone number that made the unwanted call, when the

call was made, the subject matter of the call, whether

the call was reported as a robocall, and the complainant’s

city and state.

Federal agencies and

external law enforcement

partners

The FTC shares SNS data with other federal agencies and

authorized law enforcement agencies.

If a user opts to

submit an Identity Theft Affidavit (Form 14039)

electronically to the IRS via IDT, the information provided

to fill out the affidavit will be shared with the IRS.

Through the CSN, SNS data is shared with authorized

local, state, federal, and international law enforcement

agencies that have entered into a confidentiality and data

security agreement with the FTC. This agreement requires,

amongst other things, that CSN data will be accessed solely

for law enforcement purposes. Certain states that have

entered into a Memorandum of Understanding with the

FTC may download registered consumer telephone

numbers from DNC for their state and use this information

to update their state- specific Do Not Call lists.

However, IDT data is not available to all law enforcement

agencies. For example, the ability to extract data from SNS

will be limited to local, state, and federal law enforcement

agencies in the United States, Canada, and Australia, and

will not be available to other foreign law enforcement users.

Both the FTC Office of International Affairs (OIA) and the

Office of General Counsel (OGC) are consulted on all

decisions regarding sharing data with foreign entities. In

addition, in response to specific law enforcement agency

requests, the FTC will provide those agencies with data in

an encrypted and password-protected format, consistent

with OMB and NIST standards.

The FBI Recovery Asset Team (RAT) will receive specific

banking information regarding complaints within the

ReportFraud portal in order to help victims of scams reverse

For a complete list, see www.ftc.gov/enforcement/consumer-sentinel- network/members.

Data Will Be Accessed By

and/or Provided To:

How and Why the Data Will Be Accessed/Shared

high dollar, fraudulent banking transactions. When a case

meets the criteria for FBI involvement, the complaint will

be shared with the FBI RAT, and clearly set the expectation

that the consumer could receive a contact, as well as how to

validate that the contact is legitimate.

Credit Reporting

Agencies (CRAs) and

consumer organizations

A limited number of employees at three national CRAs

(Experian, Equifax, and TransUnion) have access to the

Identity Theft Report Verification Portal, which verifies

the validity of questionable identity theft reports.

External users access the SNS applications through 256-bit

TLS encryption and strong two-factor authentication.

Consumers’ complaint information may be shared under

very limited circumstances with organizations providing

additional consumer counseling services. Consumers’

information would only be shared with such organizations

if the consumer gives prior express consent and the

organization can properly protect the consumer’s

information.

When a consumer’s IDT report appears to be potentially

fraudulent, a limited number of CRA employees can use

the Identity Theft Report Verification Portal to determine

whether the first name, last name, and IDT report number

match information contained in SNS.

Other external entities

The FTC may be required or authorized to share complaint

data with external entities in other circumstances such as:

responding to requests from Congress, Freedom of

Information Act (FOIA) requests for FOIA-accessible

information from the media (not obtained through a FOIA

request)

, or during the course of litigation or otherwise

where consumer complaints may be disclosed to the subject

of the complaint, to a court, etc. To the extent required or

authorized by law, the FTC redacts all PII before providing

the SNS data. Government agencies also may request SNS

data for a non- law enforcement purpose. Such requests

must be submitted to and approved by the FTC Office of the

General Counsel and are granted only as permitted by law.

Complaint data also may be shared with the entity about

which a consumer complains in order to address the

complaint. In the latter two situations, the FTC only

discloses the data after receiving assurances of

confidentiality from the recipients. In addition, consumers’

complaint information may be shared under very limited

circumstances with organizations providing additional

consumer counseling services. Consumers’ information

would only be shared with such organizations if the

consumer gives prior express consent and the organization

can properly protect the consumer’s information.

As part of the Commission’s consumer education mission, the FTC provides aggregated data to the press to enable

them to inform the public about consumer protection issues. The FTC does not disclose PII during this process.

3.2 Do contractors and/or third party service providers have access to data in the

project/system? If yes, explain what privacy requirements are in place to ensure

that data is properly protected.

FTC contractors with access to the data through collection and/or processing, as well as those

tasked with technical support of SNS, submit to a rigorous security clearance process, sign a

non-disclosure agreement, take annual privacy and security training, and agree to act in

accordance with specified rules of behavior. Leidos personnel who access SNS receive initial

training in security awareness and agree to comply with security practices as part of their

orientation. They also sign Rules of Behavior for the use of SNS systems and applications prior

to being given access to those systems and applications. Leidos personnel receive refresher

training annually. Customer Service Representatives also receive security awareness training on

sensitive information and PII handling during orientation. The Leidos personnel with access to

SNS are aware of and understand the ramifications and penalties for infractions of the rules

regarding privacy and data security. Any failure to comply with the Rules of Behavior is

considered a security incident.

3.3 If you answered “yes” to 3.2, describe the privacy incident response plan maintained

by the contractor’s organization or third party service provider.

FTC contractors (including Leidos staff) who access SNS are contractually bound to follow the

rules and policies set by the FTC for privacy incident response. Contractors must also follow

the reporting and other procedures in the FTC’s Breach Notification Response Plan.

Notice and Consent

4.1 How are individuals provided with notice prior to the collection of their PII? If

notice is not provided, explain why.

Through Privacy Act notices available on the online complaint forms and through messages and

menu items for the toll-free numbers, the FTC informs consumers that the information collected

is not mandatory, but that if they do not provide certain information, it may be impossible for

the FTC to refer, respond to, or investigate the consumer’s complaint or request. The FTC

complaint is voluntary. Privacy policy information is made available to the public via a

hyperlink on every SNS website as well as on the ftc.gov website. The SNS privacy policy is

machine-readable (i.e. P3P compliant), and handicap accessible pursuant to Section 508 of the

Rehabilitation Act.

Notice is provided via (check all that apply):

Privacy Act Statement ( Written Oral)

FTC Website Privacy Policy

Privacy Notice (e.g., on Social Media platforms)

Other

(explain):________________________________________________________

Notice is not provided (explain): _________________________________________________

Additional notice is provided through the FTC’s System of Records Notices (SORNs), which

are published in the Federal Register, are posted and accessible online through the FTC’s

Privacy Act page, and through the FTC’s Privacy Policy. In compliance with the Privacy Act,

the Internet sites and toll free phone numbers from which consumers can access the complaint

forms and DNC, as well as the CSN access pages for law enforcement, contain the required

notice of authority, purpose, routine uses, and whether the collection is voluntary or mandatory.

The sites also contain links to the FTC’s Privacy Policy or, in the case of the telemarketer

website for DNC, a privacy notice tailored specifically to their purposes.

4.2 Do individuals have the opportunity to decline to provide information or to consent

to particular uses of their information (other than required or authorized uses)?

All information provided by consumers to the FTC is voluntary. Consumers may choose to

submit some, all, or none of the information requested by the FTC’s complaint forms.

Consumers are informed during the complaint gathering process that if they do not provide

certain information, it may be impossible for the FTC to refer, respond to, or investigate the

consumer’s complaint or request. In IDT, consumers are informed that if they do not provide

their phone number, city and state of residence, and email address – information necessary for

an account – they will not be able to use the services provided to account holders. The data

transmitted to the FTC by other entities is provided in accordance with those entities’ policies

and practices.

Telemarketers must set up a profile by registering an account on the DNC system before they

can access telephone numbers in the National Registry. To set up a profile, telemarketers must

provide organizational information. If telemarketers decline to provide organizational

information, they will not be able to set up a profile or gain access to telephone number

information in the National Registry.

Law enforcement users requesting access to the CSN must go through a comprehensive and

secure registration process and become approved and authorized members before being given

access to the information available in the system. Law enforcement organizations and their

users must provide the required information (see Section 2.1, above). If law enforcement users

decline to provide the required information, they will not be able to complete the registration

process, and they will not be given access to the CSN.

Consumers, telemarketers, and CSN law enforcement users do not have the right to consent to

particular uses of their information. They consent to their information being provided for all

uses described in the applicable privacy policies. Likewise, once registered, CSN users must

enter their login information each time they wish to enter the system online or they will be

denied access. Consumers also can choose to share their information with organizations that

provide additional consumer counseling services. To do so, consumers must give express

consent at the time they submit their complaint.

4.3 Are there procedures in place to allow individuals access to their personally

identifiable information? Explain.

Consumers may request access to or correction of system records about them that are covered

by the Privacy Act by following the FTC’s Privacy Act rules and procedures, which are

published in the Code of Federal Regulations at 16 C.F.R. 4.13 and highlighted in the FTC’s

provide in a complaint by calling the CRC at 1-877-FTC-HELP or 1-877-ID-THEFT. For

identity theft complaints, consumers may log into their IDT account, using two-factor

authentication, to access their complaint information and add, update, or remove their

information as desired. Consumers also may access their registration information by visiting the

DNC website or by calling the DNC’s toll-free telephone numbers. In addition, consumers may

request to remove their telephone numbers from the DNC by calling the toll- free telephone

numbers from the telephone whose number they wish to remove. Telemarketers may correct

their information by visiting the DNC website or by contacting the DNC Help Desk. CSN users

can access or change their identifying information or passwords by logging into the system and

changing the information in their profile.

4.4 Are there procedures in place to allow individuals the ability to correct inaccurate

or erroneous information? What is the process for receiving and responding to

complaints, concerns, or questions from individuals? Explain.

As specified above in Section 4.3, to the extent the Privacy Act applies, the FTC provides a

process for individuals to correct or amend any inaccurate PII maintained by the FTC, including

any information that may be stored in SNS. The FTC’s Privacy Policy provides links to the

FTC’s SORNs, which include information about how to correct or amend records. An

individual may make a request under the Privacy Act for access to information maintained by

the FTC about themselves in Privacy Act systems, including data in SNS. Access to the

information under the Privacy Act is subject to certain exemptions. Individuals may also file

FOIA requests for agency records about them (if they are not exempt from disclosure to them

under those laws). Additionally, individuals may contact the FTC with any complaints,

questions or concerns via phone or email available on www.ftc.gov or contact the Chief Privacy

Officer directly. Where appropriate, the FTC disseminates corrected or amended PII to other

authorized users of that PII, such as external information sharing partners.

Data Accuracy and Security

5.1 Are there procedures in place to ensure that the information maintained is accurate,

complete, and up-to-date?

Consumer complaints collected by the CRC, IDT and DNC, complaints provided by data

contributors, and unsolicited commercial email submitted by consumers are not checked by the

FTC for accuracy or validity. This information is provided voluntarily by consumers and is

made available for law enforcement use and investigation. Telemarketer data submitted to DNC

also is not checked for accuracy when it is submitted. However, telemarketers submitting that

information must certify under penalty of perjury that the information they provide is true,

correct, and complete. Information submitted by law enforcement organizations and their users

who are requesting access to CSN is reviewed by the FTC and Leidos before the application is

approved and the user is granted access.

5.2 Are there administrative procedures and technical safeguards in place to protect the

data in the system/project? What controls are in place to ensure proper use of the

data? Please specify.

Access to the SNS CSN portal is role-based for all SNS users, including FTC staff, external law

enforcement members, call center staff, data providers, and data receivers. In accordance with

OMB and NIST standards, access to the SNS CSN portal is strictly controlled and uses a

minimum of two authentication factors. Authentication factors include unique user names,

passwords, one-time passcodes generated by tokens, approved IP address ranges, and such

other factors as the FTC may determine necessary to secure the system and its data. Similarly,

consumers who wish to access their IDT account must use two-factor authentication. After

logging in using a registered email address and password, a one-time passcode delivered to the

consumers’ telephones must be entered before the consumers gain access to IDT.

Data contributors and data receivers are also authenticated if they access SNS to either

contribute or receive data. Their access is restricted to only uploading or downloading of data.

Consumers are instructed not to provide personal information such as SSNs, credit card

numbers, bank account numbers, drivers’ license numbers, or health information in the

comment portion of complaint forms when filing a complaint online. When a complaint is filed

by a child under the age of 13, any PII in that complaint is deleted and purged.

For DNC

online registration, the online registration wizard only collects consumer telephone numbers

and email addresses.

The following in-place auditing measures and technical safeguards are applied to prevent

misuse of data. These controls include:

• Authenticator/Password Management – Application and monitoring of initial

distribution, composition, history, compromise, and change of default authenticators.

• Account Management – Application and monitoring of account establishment,

activation, modification, disabling, removal (including unnecessary/defunct accounts)

and review.

• Access Enforcement – Application and monitoring of access privileges.

• Least Privilege – Access to SNS data is limited to data necessary for the specific user

to perform his/her specific function.

• Unsuccessful Login Attempts – System automatically locks the account when the

maximum number of unsuccessful attempts are exceeded.

• Audit logs are reviewed for technical and administrative errors.

• Strong password requirement.

The customer service representative with whom the consumer chats and the automated Chatbot

are trained to provide information about technical assistance only and to avoid substantive

advice or assistance that could lead to a consumer providing sensitive PII. If, during the course

of the chat, a consumer submits sensitive PII in a recognizable format, such as SSN, bank

account number or credit card number, that information is automatically redacted and stored

only as Xs. Consumers cannot submit or complete an online complaint using the web chat or

Chatbot function. The Chatbot will also notify the consumers that they will not be contacted as

The FTC may periodically accept complaints about minors from law enforcement partners or other third parties, when

such information is needed to effectuate law enforcement investigations, and when such information is gathered and

shared in a manner that complies with applicable statutes and regulations (e.g., the Children's Online Privacy Protection

Act (COPPA)). In addition, the FTC will accept identity theft complaints filed by an adult on a minor’s behalf.

a result of the automated chat session. The entry to the web chat feature is located and accessed

from the ReportFraud page, where there is also a link to the FTC privacy policy.

Privacy risks associated with unauthorized disclosure of information are mitigated through

implementation of technical controls associated with need-to-know and least privilege, ensuring

that users have no more access to data and no more administrative rights than are required to

affect their official duties. In addition, deterrent controls in the form of warning banners, rules

of behavior, confidentiality agreements and auditing are in place. Procedures are in place to

disable and delete user accounts at the end of use.

5.3 Is PII used in the course of system testing, training, or research? If so, what steps

are taken to minimize and protect PII during this process? .

Not Applicable. PII is not used in the course of testing training, or research within the

SNS system.

Data Retention and Disposal

6.1 Specify the period of time that data is retained in the system/project. What are the

specific procedures for disposing of the data at the end of the retention period?

SNS records will be maintained in accordance with NARA-approved record disposition

schedules. Paper records are destroyed after 60 days. SNS maintains all complaints filed by

consumers (including identity theft and DNC) for a period of 5 years. In those instances, the

record will be maintained until the litigation hold is lifted.

Consumer telephone numbers remain on the National Do Not Call Registry until the consumer

deletes the number. Telephone numbers deleted from the Registry remain in the SNS system to

support investigations by CSN law enforcement members in the United States, Canada, and

Australia of violations of the Telemarketing Sales Rule. Data contributor media is destroyed 90

days after information on the media has been imported into SNS. Original copies of letters and

correspondence from consumers received via the mail are retained for up to one year, and then

destroyed. Additional information collected via IDT to submit an Identity Theft Affidavit

(Form 14039) electronically to the IRS will be maintained in accordance with NARA-approved

record disposition schedules if the consumer creates or has an IDT user account, except for

SSNs, which will be purged from FTC systems within two business days after the IRS confirms

successful receipt of data, and in any event, no later than 15 days after the consumer submits it

to the FTC. All other records, including consumer requests for information, consumer calls

referred to other entities, web chat sessions, and solicitations, are retained for 60 days. The

consumer account information is deleted after the account becomes inactive.

All SNS information that is subject to disposal is destroyed in accordance with OMB and NIST

guidelines.

Website Privacy Evaluation

7.1 Does the project/system employ the use of a website? If so, describe any tracking

technology used by the website and whether the technology is persistent or

temporary (e.g., session cookie, persistent cookie, web beacon). Describe the

purpose of using such tracking technology.

Yes, the system uses Web sites or portals for information collection and access purposes. The

tracking technology used by various Web components of the system (e.g., cookies) is described

below.

For security and system auditing purpose, SNS collects and stores the following computer

system and network related information on each SNS website, including consumersentinel.gov,

donotcall.gov, econsumer.gov, ftccomplaintassistant.gov, and IdentityTheft.gov:

• Date and time when the user gained access to SNS

• Name of the domain and host from which the user gained access to SNS

• Internet address of the site from which the user linked directly to the SNS websites

• Internet protocol (IP)address of the computer the user was using

• User’s web browser software information

• User’s computer Operating System information

The computer system- and network-related information is used to determine the number of

visitors to different sections of the SNS websites, to help make the websites more useful, to help

ensure the proper operation of the websites, and to help resolve helpdesk requests. This

information is not used to track or record information about individuals.

SNS websites – including consumersentinel.gov, donotcall.gov, econsumer.gov,

ftccomplaintassistant.gov, and IdentityTheft.gov – do not use persistent cookies or tracking

mechanisms that collect PII. All of these websites do use session cookies, which are temporary

files that are erased when a user closes her browser. Session cookies typically will store

information in the form of a session identification that does not personally identify the user. The

website uses these session cookies so that telemarketers, sellers, law enforcement agencies and

other entities accessing the site can move from one secure web page to another without having

to log in to each page. Session cookies are necessary to ensure the proper functioning of the

websites. Users may not be able to use the SNS websites if they decline to accept session

cookies. In addition, consumersentinel.gov and IdentityTheft.gov use authentication

confirmation cookies, a type of session cookie that transfers the security and login information

for the consumer from page to page. Because of the high level of security required to protect the

information available in on these sites, these cookies are used to prevent members from having

to re-authenticate themselves at each separate page. For more information, see the FTC’s Use of

Cookies.

IP addresses are collected as part of the web server HTTPS access audit logs. The IP address

information is typically collected for any website that maintains HTTPS access logs. As a

common security practice, SNS collects consumers’ IP address information in order to protect

the integrity and security of the consumer’s web sessions and the web server system by

monitoring web traffic and helping to prevent malicious attacks. This information is also used to

identify services and organizations, such as public libraries, community based, legal assistance,

and others that are connecting consumers with IdentityTheft.gov.

SNS does not use persistent cookies, web beacons, Adobe flash cookies, or other persistent

tracking devices on the system websites. However, the SNS websites that employ Google

Analytics do use persistent and temporary session cookies that collect information about the

user’s web browsing experience.

SNS uses 256-bit TLS encryption when personal information is collected through a website,

page, or online form. Personal information that is collected from consumers, telemarketers and

law enforcement agencies stored in the SNS database is also encrypted.

Privacy Risks and Evaluation

8.1 Considering the type of information collected and sources of collection, what

privacy risks were identified and how were these risks mitigated?

Risk

Mitigation Strategy

Inadvertent disclosure

by external

enforcement members

To mitigate the risk of disclosure by external law

enforcement members, SNS utilizes numerous procedural

controls, which include a confidentiality and data security

agreement. Each member agency and each user agrees (in

writing) to maintain the confidentiality and security of SNS

data and only to use it for law enforcement purposes. In

addition to the confidentiality and data security agreement,

the FTC periodically provides SNS users with training and

information on how SNS data may be used and disclosed.

Consumers providing

unnecessary PII

To mitigate the risk of consumers providing unnecessary PII,

the CRC uses the online ReportFraud portal, which assists

consumers in filing online complaints, and which only

collects the information that is relevant to a given complaint.

To reduce the risks of consumers accidentally providing

sensitive PII, DNC online registration and complaint forms

are designed in a way that consumers can only provide

required information. In addition, consumers are reminded

not to provide sensitive PII in the comments field in each of

these complaint forms and on econsumer.gov. The FTC also

trains the staff and customer service representatives working

with consumers directly to collect only the information

necessary to the specific complaint and not to collect

unnecessary sensitive PII.

Unauthorized access to

IDT

To mitigate the risk of unauthorized access to IDT, the IDT

portal employs a secure two-factor authentication

mechanism to ensure user authenticity. After logging in

using a registered email address and password, users must

enter a one-time code delivered to the user’s telephone

before the user gains access to IDT. This code is delivered

via SMS or voice recording. The two-factor authentication

process is enforced every time a user attempts to gain access

to their IDT account. To mitigate the risk of unauthorized

access to the CSN, CSN employs a well-defined and secure

See https://digital.gov/services/dap/common-questions-about- dap-faq/ for additional information about the cookies

used by Google Analytics.

Risk

Mitigation Strategy

process to enable interested law enforcement organizations

and their users to register and obtain access and thereby

mitigate any associated security risks. This process requires

users to enter a matching passcode that is specifically

assigned to their law enforcement organization, submit valid

and accurate information including email addresses that

match their organization’s email

domain, and submit proper credentials, such as their badge, to

verify that they indeed work for their respective organization.

Inaccuracy of data

provided by

consumers and data

contributors

As to the risk that data provided by consumers and data

contributors might not be accurate, complete, or timely, it is

important to note that SNS accepts self-reported consumer

complaint information and makes the process of filing

complaints as easy as possible for consumers. CSN law

enforcement members understand that they are accessing

self-reported information that may not be accurate.

8.2 Does the project/system employ the use of automated privacy controls or enhanced

capabilities designed to support privacy? Explain.

To protect individuals’ privacy, encryption technology is used to ensure information

confidentiality and integrity. All sensitive data are encrypted during transmission between the

SNS web portals and the end users or external systems using 256-bit Transport Layer Security

(TLS) encryption and Secure Hyper Test Transfer Protocol (HTTPS). Data downloaded or

exported from SNS are encrypted and password protected. In addition, all data stored by SNS

are encrypted at rest using software encryption. All encryption and data transport protocols

meet OMB and NIST standards.

In accordance with OMB and NIST standards, access to the SNS CSN and Identity Theft

portals is strictly controlled and utilizes a minimum of two authentication factors.

Authentication factors include: unique user names, passwords, one-time passcodes generated by

tokens, approved IP address ranges, and such other factors as the FTC may determine are

necessary to ensure the confidentiality and security of the system and its data.

All user access and operations are logged and logs are kept on a centralized logging server. The

logs are used to audit user access and produce relevant security reports. In addition, the SNS

servers are protected through advanced firewalls and Intrusion Prevention Systems (IPS).

To increase efficiency and decrease costs, the SNS system is hosted in multiple secure cloud

environments that provide services to federal and state government entities. These cloud

environments have undergone an extensive Assessment and Authorization process conducted

by a FedRAMP-certified third-party assessment organization.

SNS utilizes Infrastructure as a

Service (IaaS), Platform as a Service (PaaS) and Software as a Service (SaaS) from cloud

service providers. In addition, SNS employs machine-learning technologies to analyze the data

collected from various data sources.

SNS also employs a web chat service called Web Chat. This product allows customer service

The FedRAMP website is available at www.fedramp.gov.

representatives, through encrypted connections, to help consumers filing an online complaint

with their technical issues so that they can better navigate our complaint form. This service does

not include any live screen shares or co-browsing, and consumers cannot use web chat to

complete or submit a consumer complaint.

In addition, SNS uses an automated 24x7 Chatbot service to assist consumers quickly

connecting with the answers to frequently asked questions when they need to file a complaint.

8.3 Has a Privacy Act System of Records Notice (SORN) been published in the Federal

Yes. The Privacy Act SORN corresponding to general consumer complaint collection is

currently designated FTC IV-1 (consumer complaints generally). Consumer complaint data can

be retrieved by the following fields: consumer name, street address, telephone number, email

address, and unique FTC reference number. Telemarketer information is retrieved by the

following fields: organization name, street address, EIN or SSN, telephone number, first or last

name, and email address. CSN member information is retrieved by: member first name or last

name, and organization name. For complaints related to the accuracy of a consumer’s credit

report, SNS allows the consumer to provide an SSN. SNS encrypts the consumer’s SSN, and

the number is not displayed when users search the system. However, the system still allows

users to search for complaints by specific SSNs. Note: telemarketer business entities are not

covered by the Privacy Act.

In addition, the DNC is currently covered by the Privacy Act SORN currently designated as

FTC- IV-3 (National Do Not Call Registry

System-FTC). The login information collected for

CSN is covered by one Privacy Act SORN, which is currently designated FTC-VII-3

(Computer Systems User Identifiable and Access Records).

The above SORNs are published in the Federal Register, and posted and accessible online

through the FTC’s Privacy Act page, www.ftc.gov/privacy. In compliance with the Privacy Act,

the Consumer Sentinel website, which collects information from individuals subject to the

Act,contains the required notice of authority, purpose, routine uses, and whether the collection

is voluntary or mandatory. The system’s various websites and portals also contain links to the

FTC’s Privacy Policy.

8.4 How does the project/system ensure that the information is collected, used, stored,

or disseminated in accordance with stated practices in this PIA?

SNS data is used in accordance with the routine uses outlined in the FTC’s Privacy Policy and

Privacy Act System of Records Notices. In addition, all uses of the SNS data are both relevant

and necessary to the purpose for which the data was collected. All SNS users have a level of

access determined by their need-to-know, with the lowest level of access needed to perform

their work.

Co-browsing, in the context of web browsing, is the joint navigation through the World Wide Web by two or more

people accessing the same web pages at the same time.