Privacy Compliance Review of the Office of the Chief Human Capital Officer

The Department of Homeland Security (DHS) Office of the Chief Human Capital Officer (OCHCO) is responsible for administering human resources services for DHS Headquarters and Components. In response to privacy incidents at OCHCO, the Chief Privacy Officer (CPO) submitted an action memo on March 27, 2014 to the DHS Chief Human Capital Officer (2014 Memo) with 12 recommendations to strengthen the culture of privacy within the office. In April 2015, the CPO initiated a Privacy Compliance Review (PCR) of OCHCO’s implementation of the 12 recommendations and compliance with foundational principles for privacy policy and implementation at DHS. During the course of this PCR, the DHS Privacy Office found that some concerns raised in the 2014 Memo remain and several recommendations from the 2014 Memo have yet to be fully implemented. As a result, the DHS Privacy Office makes an additional 25 recommendations to improve the culture of privacy at OCHCO. The recommendations focus on the areas of transparency/raising awareness, data minimization/retention limits, use limitations, data integrity, data security, and accountability.

SEPTEMBER 2015