MANAGEMENT OF FEDERAL INFORMATION RESOURCES

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP87M00539R002303720005-7
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 52
• Document Creation Date: December 22, 2016
• Document Release Date: December 23, 2009
• Sequence Number: 5
• Publication Date: December 12, 1985
• Content Type: MEMO

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v i a ? ii Uiit i%L` I t1RIF- I ^
ROUTING SLIP
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that, as mention is made of paperwork reduction, we
get this easy to read/follow 26 page document!
But I guess there are paper savings, sine t is
printed on 2 sides!)
Remarks To 12: for action as appropriate.
(Merry Christmas.! Interesting memo from OMB in h .
19 Dec 85
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EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503
Executive Registry
85- 4994
December 12, 1985
CIRCULAR NO. A-130
TO THE HEADS OF EXECUTIVE DEPARTMENTS AND ESTABLISHMENTS
SUBJECT: Management of Federal Information Resources
1. Purpose: This Circular establishes policy for the management
of Federal information resources. Procedural and analytic
guidelines for implementing specific aspects of these policies
are included as appendices.
2. Rescissions: This Circular rescinds OMB Circulars No. A-71,
A-90, A-108, and A-121, and all Transmittal Memoranda to those
circulars.
3. Authorities: This Circular is issued pursuant to the
Paperwork Reduction Act of 1980 (44 U.S.C.. 35); the Privacy Act
of 1974 (5 U.S.C. 552a), Sections 111 and 206 of the Federal
Property and Administrative Services Act of 1949 as amended (40
U.S.C. 759 and 487, respectively), the Budget and Accounting Act
of 1921 as amended (31 U.S.C. 11), Executiye Order No. 12046 of
March 27, 1978, and Executive Order No. 12472 of April 3, 1984.
4. Applicability and Scope:
a. The policies in this Circular apply to the information
activities of all agencies of the executive branch of the Federal
Government.
b. Information classified for national security purposes
should also be-handled in accordance with the appropriate
national security directives. National security emergency
preparedness activities should be conducted in accordance with
Executive Order No. 12472.
adequacy and efficiency; and determine compliance of such
practices with the policies, principles, standards, and
guidelines promulgated by the Director.
5. Background: The Paperwork Reduction Act establishes a broad
mandate for agencies to perform their information management
activities in an efficient, effective, and economical manner. To
assist agencies in an integrated approach to information
resources management, the Act requires that the Director of the
Office of Management and Budget (OMB) develop and implement
uniform and consistent information resources management policies;
oversee the development and promote the use of information
management principles, standards, and guidelines; evaluate agency
information management practices in order to determine their
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6. Definitions: As used in this Circular--
a. The term "agency" means any executive department,-
military department, government corporation, government
controlled corporation, or other establishment in the executive
branch of the government, or any independent regulatory agency.
Within the Executive Office of the President, the term includes
only the Office of Management and Budget and the Office of
Administration.
b. The term "information" means any communication or
reception-of knowledge such as facts, data, or opinions,
including=numerical, graphic, or narrative forms, whether oral or
maintained in any medium, including computerized data bases,
paper, microform, or magnetic tape.
c. The term "government information" means information
created, collected, processed, transmitted, disseminated, used,
stored, or disposed of by the Federal Government.
i
d. The term "information system" means the organized
collection, processing, transmission, and dissemination of
information in accordance with defined procedures, whether
automated or manual.
e. The term "major information system" means an information
system that requires special continuing management attention
because of its importance to an agency mission; its. high
development, operating or maintenance costs; or its significant
impact on the administration of agency programs, finances,
property,-or other resources.
f. The term "access to information" refers to the function
of providing to members of the public, upon their request, the
government information to which they are entitled under law.
g. The term "dissemination of information" refers to the
function of distributing government information to the public,
whether through printed documents, or electronic or other media.
"Dissemination of information" does not include intra-agency use
of information, interagency sharing of information, or responding
to requests for "access to information."
h. The term "information technology" means the hardware and
software used in connection with government information,.
regardless of the technology involved, whether computers,
telecommunications, micrographics, or others. For the purposes
of this Circular, automatic data processing and
telecommunications activities related to certain critical
national security missions, as defined in 44 U.S.C. 3502 (2) and
10 U.S.C.'2315, are excluded.
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i. The term "information technology facility" means an
organizationally defined set of personnel, hardware, software,
and physical facilities, a primary function of which is thg
operation of information technology.
J. The term "information resources management" means the
planning, budgeting, organizing, directing, training, and control
associated with government information. The term encompasses
both information itself and the related resources, such as
personnel, equipment, funds, and technology.
k. The term "government publication" means informational
matter which is published as an individual document at government
expense, or as required by law.
Other-definitions specific to the subjects of the appendices
appear in the appendices.
7. Basic Considerations and Assumptions
a. The Federal Government is the largest single producer,
consumer, and disseminator of information in the United States.
Because of the size of the government's information activities,
the dependence of government information activities upon the
public's cooperation, and the value of government information to
the entire Nation, the management of Federal information
resources is an issue of continuing importance to the public and
to the government itself.
b. Government information is a valuable national resource.
It. provides citizens with knowledge of their government, society,
and economy--past, present, and future; is a means to ensure the
accountability of government; is vital to the healthy performance
of the economy; is an essential tool for managing the
government's operations; and is itself a commodity often with
economic value In the marketplace.
c. The free flow of information from the government to its
citizens and vice versa is essential to a democratic society. It
is also essential that the government minimize the Federal
paperwork burden on the public, minimize the cost of its
information activities, and maximize the usefulness of government
information.
d. In order to minimize the cost and maximize the
usefulness of government information activities, the expected
public and private benefits derived from government information,
insofar as they are calculable, should exceed the public and
private costs of the information.
e. Although certain functions are inherently governmental
in nature, being so intimately related to the public interest as
to mandate performance by Federal employees, the government
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should look first to private sources, where -available, to provide
the commercial goods and services needed by the government to.act,
.on the public's behalf, particularly when cost compari?son`s.--
indicate that private performance will be the most economical..
f. The use of -up-to-date information technology offers
opportunities to improve the management of government programs,
and access to, and dissemination of, government information..
g. Because the public disclosure of government information
is essential to the operation of a democracy, the public's right
of access to government information must be protected in the
management.of Federal information resources.
h. The individual's right to privacy must be protected in
Federal Government information activities involving personal
information,.
i. The open and efficient exchange of.gov-ernment scientific
and technical information, subject to applicable national
security controls and proprietary rights others may.have in-such
information, fosters excellence in scientific research and the
effective ruse of Federal research and development funds.
3. The value of preserving government records is a function
of the degree to which preservation protects the legal and
financial rights of the government or its citizens, and provides
an official record of Federal agency activities for agency
management, public accountability, and historical purposes..
k. Federal Government information resources management
policies and activities can affect, and be affected by, the
information policies and activities of other nations.
8. Policies
a. Information Management. Agencies shall:
(1) Create or collect only that information necessary
for the proper performance of agency functions and that has
practical. utility, and only after planning for its processing,
transmission, dissemination, use, storage, and disposition;
.(2) Seek to satisfy new information needs through
legally authorized interagency or intergovernmental sharing of
information, or through commercial sources, where appropriate,
before creating or collecting new information;
(3) Limit the collection of individually identifiable
information and proprietary information to that which is legally
authorized and necessary for the proper performance of agency
functions;
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(4) Maintain and protect individually identifiable
information and proprietary information in a manner that
precludes:
(a) Unwarranted intrusion upon personal privacy
(see Appendix I); and
(b) Violation of confidentiality;
(5) Provide individuals with access to, and the
ability to amend errors in, systems of records, consistent with
the Privacy Act;.
(6) Provide public access to government information,
consistent with the Freedom of Information Act;
(7) Ensure that agency personnel are trained to
safeguard information resources;
(8) Disseminate information, as required by law,
describing agency organization, activities, programs, meetings,
systems of records, and other information holdings, and how the
public may gain access to agency information resources;
(9) Disseminate such information, products and services
(a) Specifically required by law; or
(b) Necessary for the proper performance of
agency functions, provided that the latter do not duplicate
similar products or services that are or would otherwise be
provided by other government or private sector organizations;
(10) Disseminate significant new, or terminate
significant existing, information products and services only
after providing adequate notice to the public;
(11) Disseminate such government information products
and services:
(a) In a manner that ensures that members of the
public whom the agency has an obligation to reach have a
reasonable ability to acquire the information;
(b) In the manner most cost effective for the
government, including placing maximum feasible reliance on the
private sector for the dissemination of the products or services
in accordance with 0MB Circular No. A-76; and
(c) So as to recover costs of disseminating the
products or services through user charges, where appropriate, in
accordance with 0MB Circular No. A-25;
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12) Establish procedures for:
(a) Reviewing periodically the continued need for
and.manner of dissemination of the agency's information products
or services; and
I (b) Ensuring that government publications are
made available to depository libraries as required by law.
b. Information Systems and Information Technology
Management. Agencies shall:
(1) Establish multiyear strategic planning
processes for acquiring and operating information technology that
meet program and mission needs, reflect budget constraints, and,
form the.bases for their budget requests;
1 Y
1 (2) Establish systems of management control that
document the requirements that each major information system is
intended to serve; and provide for periodic review of , 'those
requirements over the life of the system in order to determine
whether the requirements continue to exist and the system
continues to meet the purposes for which it was developed;
(3) Make the official whose program an
information system supports responsible and accountable for the
products of that system;
(4) Meet information processing needs through
interagency sharing and from commercial sources, when it is cost
effective, before acquiring'new information processing capacity;
(5) Share available information processing
capacity with other agencies to the extent practicable and
legally permissible;
(6) Acquire information technology in a
competitive manner that minimizes total life cycle costs;
(7) Ensure that existing and planned major
information systems do not unnecessarily duplicate information
systems available from other agencies or from the private sector;
(8) Acquire off-the-shelf software from
commercial sources, unless the cost effectiveness of developing
custom software is clear and has. been documented;
(9) Acquire or develop information systems in a
manner that facilitates necessary compatibility;
(10) Assure that information systems operate
effectively and accurately;
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(11) Establish a level of security for all agency
information systems commensurate with the sensitivity of the
information and the risk and magnitude of loss or harm that could
result from improper operation of the information systems (See
Appendix III);
(12) Assure that only authorized personnel have
access to information systems;
(13) Plan to provide information systems with
reasonable continuity of support should their normal operations
be disrupted in an emergency;
(14) Use Federal Information Processing and
Telecommunications Standards except where it can be demonstrated
that the costs of using a standard exceed the benefits or the
standard will impede the agency in accomplishing its mission;
(15) Not require program managers to use specific
information technology facilities or services unless it is clear
and is convincingly documented, subject to periodic review, that
such use is the most cost effective method for meeting program
requirements;
(16) Account for the full costs of operating
information technology facilities and recover such costs from
government users as provided in Appendix II;
(17) Not prescribe Federal information system
requirements that unduly restrict the prerogatives of heads of
State and local government units;
(18) Seek opportunities to improve the operation
of government programs or to realize savings for the government
and the public through the application of up-to-date information
technology to government information activities.
9. Assignment of Responsibilities:
a. All Federal Agencies. The head of each agency shall:
(1) Have primary responsibility for managing agency
information resources;
(2) Ensure that the information policies, principles,
standards, guidelines, rules, and regulations prescribed by 0MB
are implemented appropriately within the agency;
(3) Develop internal agency information policies and
procedures and oversee, evaluate, and otherwise periodically
review agency information resources management activities for
conformity with the policies set forth in this Circular;
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(4) Develop agency policies and procedures that
provide for timely acquisition of required information
technology;
(5) Maintain an inventory of the agencies' major
information systems and information dissemination programs;
1(6) Create, maintain, and dispose of a record of
agency activities in accordance with the Federal Records Act of
1950, as amended;
(7) Identify to the Director, OMB, statutory,
regulatory, and other impediments to efficient management of
Federal information resources and recommend to the Director
legislation, policies, procedures, and other guidance to improve
such management;
(8) Assist 0MB in the performance of its functions
under the Paperwork Reduction Act, including. making services,
personnel, and facilities available to 0MB for this purpose to
the extent practicable;
,(9) Appoint a senior official, as required by 44
U.S.C. 3506(b), who shall report directly to the agency head, to
carry out the responsibilities of the,agency under the Paperwork
Reduction Act. The head of the agency shall keep the Director,
OMB, advised as to the name, title, authority, responsibilities,
and organizational resources of the senior official. For
purposes of this paragraph military departments and the.Office of
the Secretary of Defense may each appoint one official.
b. Department of State. The Secretary of State shall:
(1) Advise the Director, OMB, on the development of
United States positions and policies on international information
policy issues affecting Federal Government information activities
and ensure that such positions and policies are consistent with
Federal information resources management policy;
(2) Ensure, in consultation with the Secretary of
Commerce, that the United States is represented in the
development of international information technology standards,
and advise the Director, OMB, of such activities.
c. Department of Commerce. The Secretary of Commerce
shall:
(1) Develop and issue Federal Information Processing
Standards and guidelines necessary to ensure the efficient and
effective acquisition, management, security, and use of
information technology;
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(2) Advise the Director, OMB, on the development of
policies relating to the, procurement and management of Federal
telecommunications resources;
(3) Provide 0MB and the agencies with scientific and
technical advisory services relating to the development and use
of information technology;
(4) Conduct studies and evaluations, concerning
telecommunications technology, and concerning the improvement,
expansion, testing, operation, and use of Federal
telecommunications systems and advise the Director, OMB, and
appropriate agencies of the recommendations that result from such
studies;
(5) Develop, in consultation with the Secretary of
State and the Director, OMB, plans, policies, and programs
relating to international telecommunications issues affecting
government information activities;
.(6) Identify needs for standardization of
telecommunications and information processing technology, and
develop standards, in consultation with the Secretary of Defense
and the Administrator of General Services, to ensure efficient
application of such technology;
(7) Ensure that the Federal Government is represented
in the development of national and, in consultation with the
Secretary of State, international information technology
standards, and advise the Director, OMB, of such activities.
d. Department of Defense. The Secretary of Defense shall
develop, in consultation with the Administrator of General
Services, uniform Federal telecommunications standards and
guidelines to ensure national security, emergency preparedness,
and continuity of government.
e. General Services Administration. The Administrator of
General Services shall:
(1) Advise the Director, OMB, and agency heads on
matters affecting the procurement of information technology;
(2) Coordinate and, when required, provide for the
purchase, lease, and maintenance of information technology
required by Federal agencies;
(3) Develop criteria for timely procurement of
information technology and delegate procurement authority to
agencies that comply with the criteria;
(4) Provide guidelines and regulations for Federal
agencies, as authorized by law, on the acquisition, maintenance,
and.disposition of information technology;
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(5)' Develop policies and guidelines that facilitate
the sharing of information technology among agencies as required
by this Circular;
(6) Review agencies'. information resources management
activities to meet the objectives of the triennial reviews
required by the Paperwork Reduction Act and report the results to
the Director, OMB;
(7) Manage the Automatic Data Processing Fund and the
Federal Telecommunications Fund in accordance with the Federal
Property and Administrative Services Act, as amended;
(8) Establish procedures for approval, implementation,
and dissemination of Federal telecommunications standards and
guidelines and for implementation of Federal Information
Processing Standards.
f. Office of Personnel Management. The Director, Office of
Personnel Management, shall:
(1) Develop and conduct training programs for Federal
personnel on information resources management, including end user
computing;;-
(2) Evaluate periodically future personnel management
and staffing requirements for Federal information resources
management;
(3) Establish personnel security policies and develop
training programs for Federal personnel associated with the
design, operation, or maintenance of information systems.
g. National Archives and Records Administration. The
Archivist of the United States shall:
.(1) Administer the Federal records management program
in accordance with the National Archives and Records Act;,
(2) Assist the Director, OMB, in developing standards
and guidelines relating to the records management program.
h. Office of Management and Budget. The Director of the
Office of:Management and Budget shall:
(1) Provide overall leadership and coordination of
Federal information resources management within the executive'
branch;
(2) Serve as the President's principal adviser on
procurement and management of Federal telecommunications systems,
and develop and establish policies for procurement and,management
of such systems;
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(3) Issue policies.., procedures, and guidelines to
assist agencies in achieving integrated, effective, and efficient
information resources management;
(4) Initiate and review proposals for changes in
legislation
regulations
and a
enc
roced
t
i
,
,
g
y p
ures
mprove
o
Federal information resources management;
(5)
Review and approve
or disapprove
agency proposals
for collection
of information from
the public,
as defined in
5
CFR 1320.7;
(6) Develop and publish annually, in consultation with
the Administrator of General Services, a five-year plan for
meeting the information technology needs of the Federal
government;
(7) Evaluate agencies' information resources
management and identify cross-cutting information policy issues
through the review of agency information programs, information
collection budgets, information technology acquisition plans,
fiscal budgets, and by other means;
(8) Provide policy oversight for the Federal records
management function conducted by the National Archives and
Records Administration and coordinate records management policies
and programs with other information activities;
(9) Review, with the advice and assistance of the
Administrator of General Services, selected agencies' information
resources management activities to meet the objectives of the
triennial reviews required by the Paperwork Reduction Act;
(10) Review agencies' policies, practices, and.
programs pertaining to the security, protection, sharing, and
disclosure of information, in order to ensure compliance with the
Privacy Act and related statutes;
(11) Resolve information technology procurement
disputes between agencies and the General Services Administration
pursuant to Section 111 of the Federal Property and
Administrative Services Act;
(12) Review proposed U.S. government position and
policy statements on international issues affecting Federal
Government information activities and advise the Secretary of
State as to their consistency with Federal information resources
management policy.
10. Oversight. The Director, OMB, will use information
technology planning reviews, fiscal budget reviews, information
collection budget reviews, management reviews, GSA reviews of
agency information resources management activities, and such
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other measures as he deems necessary. to evaluate the adequacy and
efficiency of each agency's information resources management and
compliance with this Circular.
11. Effective Date. This Circular is effective upon
publication.
12. Inquiries. All questions or inquiries should be, addressed
to Office of Information and Regulatory Affairs, Office of
Management and Budget, Washington,?D.C. 20503. Telephone: (202)
395-3287.
13. Sunset Review Date. This Circular shall have an independent
policy review to ascertain its effectiveness three years from the
date of issuance.
III
Appendix I: Federal Agency Responsibilities for Maintaining
Records about Individuals
Appendix II: Cost Accounting, Cost Recovery, and Interagency
Sharing of Information Technology Facilities
Appendix III: Security of Federal Automated Information Systems
Appendix IV: Analysis of Key Sections
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APPENDIX I
TO OMB CIRCULAR NO. A-130
FEDERAL AGENCY RESPONSIBILITIES FOR MAINTAINING
RECORDS ABOUT INDIVIDUALS
1. Purpose and Scope
This Appendix describes agency responsibilities for implementing
the Privacy Act of 1974, 5 U.S.C. 552a as amended (hereinafter
"the Act"). It applies to all agencies subject to the Act. The
Appendix constitutes a revision to procedures formerly contained
in OMB Circular No. A-108, now rescinded. Note that this
Appendix does not rescind other guidance OMB has issued to help
agencies interpret the Privacy Act's provisions, e.g., Privacy
Act Guidelines (40 Federal Register 28949-28978, July 9, 1975),
or Guidance for Conducting Matching Programs (47 Federal Register
21656-21658, May 19, 1982).
2. Definitions
a. The terms "agency," "individual," "maintain," "record,"
"system of records," and "routine use," as used in this Appendix,
are defined in the Act (5 U.S.C. 552a (a)). The definition of
"agency" in the Act differs somewhat from the definition in the
Circular.
b. The term "minor change to a system of records" means a
change that does not significantly change the system; that is,
does not affect the character or purpose of the system and does
not affect the ability of an individual to gain access to his or
her record or to any information pertaining to him or her which
is contained in the system; e.g., changing the title of the
system manager.
3. Assignment of Responsibilities
a. All Federal Agencies. In addition to meeting the
agency requirements contained in the Act, and the specific
reporting requirements detailed in this Appendix, the head of
each agency shall ensure that the following reviews are conducted
as often as specified below, and be prepared to report to the
Director, OMB, the results of such reviews and the corrective
action taken to resolve problems uncovered. The head of each
agency shall:
(1) Section (m) Contracts. Review every two years a
random sample of agency contracts.that provide for the.
maintenance of a system of records on behalf of the agency to
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accomplish an agency function, in order to ensure that the
wording of each contract makes the provisions of the Act apply.
(5 U.S.'C. 552a (m)(i))
(2) Recordkeeping Practices. Review annually agency
recordkeeping and disposal policies and practices in order to
assure compliance with the Act.
(3) Routine Use Disclosures. Review every three years
the routine use disclosures associated with each system of
records in order to ensure that the recipient's use of such
records continues to be compatible with the purpose for which the
disclosing agency originally collected the information. The
first such review should commence immediately upon the issuance
of this Appendix.
,(u) Exemption of Systems of Records. Review every
three years each system of records for which the agency has
promulgated exemption rules pursuant to Section (j) or (k) of the
Privacy Act in. order to determine whether such exemption is still
needed.
(5) Matching Programs. Review annually each ongoing
matching program in which the agency has participated during the
year, either as a source or as a matching agency, in order to
ensure that the requirements of the Act, the 0MB Matching
Guidelines, and the 0MB Model Control System and Checklist have
been met.
(6) Privacy Act Training. Review annually agency
training practices in order to ensure that all agency personnel
are familiar with the requirements of the Act, with the agency's
implementing regulation, and with any special requirements that
their specific Jobs entail.
(7) Violations. Review annually the actions of agency
personnel that have resulted either in the agency being found
civilly liable under Section (g) of the Act, or an employee being
found criminally liable under the provisions of Section (i) of
the Act, in order to determine the extent.of the problem and to
find the most effective way to prevent recurrences of the
problem.
(8) Systems of Records Notices. Review annually each
system of records notice to ensure that it accurately describes
the system. Where minor changes are needed, ensure that an
amended notice is published in the Federal Register. Agencies
may choose to make one annual comprehensive publication
consolidating such minor changes. This requirement is
distinguished from and in addition to the requirement to report
to 0MB and the Congress major changes to systems of records and
to publish'those changes in the Federal Register (see paragraph
14b of this Appendix).
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b. Department of Commerce. The Secretary of Commerce
shall, consistent with guidelines issued by the Director, OMB,
develop and issue standards and guidelines for assuring the
security of information protected by the Privacy Act in automated
information systems.
c. General Services Administration. The Administrator of
General Services shall, consistent with guidelines issued by the
Director, OMB, issue instructions on what agencies must do in
order to comply with the requirements of Section (m) of the Act
when contracting for the operation of a system of records to
accomplish an agency purpose.
d. Office of Personnel Management. The Director of the
Office of Personnel Management shall, consistent with guidelines
issued by the Director, OMB:
(1) Develop and maintain government-wide standards and
procedures for civilian personnel information processing and
recordkeeping directives to assure conformance with the Act.
(2) Develop and conduct training programs for agency
personnel, including both the conduct of courses in various
substantive areas (e.g., legal, administrative, information
technology) and the development of materials that agencies can
use in their own courses. The assignment of this responsibility
to OPM does not affect the responsibility of individual agency
heads for developing and conducting training programs tailored to
the specific needs of their own personnel.
e. National Archives and Records Administration. The
Archivist of the United States shall, consistent with guidelines
issued by the Director, OMB:
(1) Issue instructions on the format of the agency
notices and rules required to be published under the Act.
(2) Compile and publish annually the rules promulgated
under 5 U.S.C. 552a(f) and agency notices published under 5
U.S.C. 552a (e)(4) in a form available to the public.
(3) Issue procedures governing the transfer of records
to Federal Records Centers for storage, processing, and servicing
pursuant to 44 U.S.C. 3103. For purposes of the Act, such
records are considered to be maintained by the agency that
deposited them. The Archivist may disclose deposited records
only according to. the access rules established by the agency that
deposited them.
f. Office of Management and Budget. The Director of the
Office of Management and Budget will:
(1) Issue guidelines and directives to the agencies to
implement the Act.
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(2) Assist the agencies, at. their request,
implementing their Privacy Act programs.
(3) Review the new and altered system reports agencies
submit pursuant to Section (o) of the.Act.
(4) Compile the annual report of the President to the
Congress in accordance with Section (p) of the Act.
4. Reporting. Requi.r.ements
a. Privacy_Act?_Annual Reports. To provide the necessary
information for the annual report of the President, agencies
shall submit a Privacy Act Annual Report to the Director, OMB,
covering their Privacy Act activities for the calendar year. The
exact format and timing of the report will be established by the
Director, OMB. (5 U.S.C. 552a (p)); but, agencies should, at a
minimum collect; and be prepared to report the following data on
a calendar, year basis:
(1) Total number of active systems of records and
changes to that population during the year, e.g., publications of
new systems, additions and deletions of.routine uses, exemptions,
automation of record systems.
(2) Public comments received on agency publications
and implementation activities.
(3) Number of requests from individuals for access to
records about themselves in systems of records thatcited_the
Privacy Act in support of their._.requests
(4) Number granted in whole or part, denied in whole,
and for which no record was found.
(:5) Number of amendment requests from individuals to
amend records about them in systems of records that cited the
Privacy. Act in support of their requests.
1(6) Number granted in whole or part, denied in whole,
and for which no record was found.
(7) Number of appeals of access and amendment denials
and the results of such appeals.
-(8) Number of instances in which individuals litigated
the results of appeals of access or amendment, and the "results of
such litigation.
(9) Number and description of matching programs
participated in either as source or matching agency.
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b. New and Altered System Reports. The Act requires
agencies to publish notices in the Federal Register describing
new or altered systems of records, and to submit reports on these
systems to the Director, OMB, and to the Congress.
(1) Altered System of Records. Minor changes to
systems of records need not be reported. For example, a change
in the designation of the system manager due to a reorganization
would not require a report, so long as an individual's ability to
gain access to his or her records is not affected. Other
examples include changing applicable safeguards as a result of a
risk analysis, deleting a routine use when there is no longer a
need for the authorized disclosure. These examples are not
intended to be all-inclusive.
The following changes are those for which a report is required:
(a) An increase or change in the number or types
of individuals on whom records are maintained. For example, a
decision to expand a system that originally covered only
residents of public housing in major cities to cover such
residents nationwide would require a report. Increases
attributable to normal growth should not be reported.
(b) A change that expands the types or categories
of information maintained. For example, a personnel file that
has been expanded to include medical records would require a
report.
(c) A change that alters the purpose for which
the information is used.
(d) A change to equipment configuration (either
hardware or software) that creates.substantially greater access
to the records in the system. For example, locating interactive
terminals at regional offices for accessing a system formerly
accessible only at the headquarters would require a report.
(e) The addition of an exemption (pursuant to
Sections (j) or (k) of the Act). Note that, in submitting a
rulemaking for an exemption as part of a report of a new or
altered system, agencies will meet the reporting requirements of
Executive Order No. 12291 and need not make a separate submission
under that order.
When an agency makes a change to an information technology
installation, telecommunication network, or any other general
changes in information collection, processing, dissemination, or
storage that affect multiple systems of records, it may submit a
single consolidated new or altered system report, with changes to
existing notices and supporting documentation included in the
submission.
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(2) Contents of the Report. The report for a new or
altered system has three elements: a transmittal letter, a
narrative statement,. and supporting documentation that includes a
copy of the proposed Federal Register notice. There is no-
prescribed format for either the letter or the narrativef
statement. The notice must appear in the format prescribed by
the office of the Federal Register's Document Drafting Handbook.
(a) Transmittal Letter. The transmittal,.letter
should be signed by the senior agency official responsible for
implementation of the Act within the agency and should contain
the name and telephone number of the individual who can best
answer questions about the system. The letter should contain the
agency's assurance that the proposed system does not duptlicate
any existing agency systems. It should also state that a copy of
the report has been distributed to the. Speaker of the House and
the President of the Senate as the Act requires. The letter may
also include requests for waiver of the reporting time period.
(b) Narrative Statement. The narrative statement
should be brief. It should make reference, as appropriate, to
information in the supporting documentation rather than restating
such information. The statement should:
1 Describe the purpose for which the agency
is establishing the system of records.
2 Identify the authority under which the
system is maintained. The agency should avoid citing
housekeeping statutes, but rather cite the underlying
programmatic authority for collecting, maintaining, and using the
information. When the system is being operated to support an
agency housekeeping program, e.g., a carpool locator, the agency
may, however, cite a general housekeeping statute that authorizes
the agency head to keep such records as are necessary.
3 Provide the agency's evaluation of the
.probable or ;potential effects of the proposal on the privacy of
individuals.
4 Describe the relationship of the
proposal, if any,, to the other branches of the Federal Government
and to State and local governments,.
5 Provide 'a brief description of the steps
taken by the agency to minimize the risk of unauthoriz'ed?access
to the system of records. A more detailed .assessment of the
risks and specific administrative., technical, pr-oc,edural, and
physical;saf'eguar'd?'s established shall be made available to OMB
upon request.
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6 Explain how each proposed routine use
satisfies the compatibility requirement of subsection (a)(7) of
the Act. For altered systems, this requirement pertains ojly to
any newly proposed routine uses.
7 Provide OMB control numbers, expiration
dates, and titles of any OMB approved information collection
requirements contained in the system of records. If the request
for OMB clearance of an information collection is pending, the
agency may simply state the title of the collection and the date
it was submitted for OMB clearance.
(c) Supporting Documentation. Attach the
following to all new or altered system reports:
1 An advance copy of the new or altered
system notice (consistent with the provisions of 5 U.S.C. 552a
(e)('1)) that the agency proposes to publish for the new or
altered system. For proposed altered systems the documentation
should be in the same form as the agency proposes to publish in
the public notice.
2 An advance copy of any new rules or
changes to published rules (consistent with the provision of 5
U.S.C. 552a (f), (j), and (k)) that the agency proposes to issue
for the new or altered system. If no changes to existing rules
are required, the agency shall so state in the narrative portion
of the report. Proposed changes to existing rules shall be
provided in the same form as the agency proposes to publish for
formal notice and comment.
(3) Timing and Distribution for Submitting New and
Altered System Reports. Submit reports on new and altered
systems of records not later than 60 days prior to establishment
of a new system-or the implementation of an altered system (5
U.S.C. 552a (o)). Submit three copies of each report to:
President of the Senate
Washington, D.C. 20510
Speaker of the House of Representatives
Washington, D.C. 20515
Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
Washington, D.C. 20503
Agencies may assume that OMB concurs in Privacy Act aspects of
their proposal if OMB has not commented within 60 days from the
date the transmittal letter was signed. Agencies may publish
system and routine use notices as well as exemption rules in the
Federal Register at the same time that they send the new or
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altered system report to OMB and the Congress. The 60 day period
for 0MB and Congressional review and the 30 day notice and
comment period for-routine.uses and exemptions will then run
concurrently.
(14) Waivers of Report Time Period. The Director, OMB,
may grant a waiver of the 6O day period if the agency asks for
the waiver and can demonstrate compelling reasons. Agencies may
assume that 0MB concurs in their :request if OMB has not commented
within 30 days of the date the transmittal letter was signed.
When a waiver is granted, the agency is not thereby relieved of
any other responsibility or liability under the Act. Note that
0MB cannot waive'time periods specifically established by the
Act. Agencies will'still have to meet the statutory notice and
comment periods required for establishing a routine use or
claiming an exemption.
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APPENDIX II
TO OMB CIRCULAR NO. A-130
COST ACCOUNTING, COST RECOVERY, AND INTERAGENCY
SHARING OF INFORMATION-TECHNOLOGY FACILITIES
1. Purpose
This Appendix establishes procedures for cost accounting, cost
recovery, and interagency sharing of Federal information
technology facilities. The Appendix revises procedures formerly
contained in OMB Circular No. A-121, now rescinded.
2. Applicability
This Appendix applies to all information technology facilities
that are operated by or on behalf of a Federal agency; provide
information technology service to more than one user; operate one
or more general management computers; and have obligations in
excess of $3 million per year.
3. Definitions
a. The term "information technology facility" means an
organizationally defined set of personnel, hardware, software,
and physical facilities, a primary function of which is the
operation of information technology. An information technology
facility includes:
(1) The personnel who operate computers or
telecommunications systems; develop or maintain software; provide
user liaison and training; schedule computers, prepare and
control input data; control, reproduce, and distribute output
data; maintain tape and disk libraries; provide security,
maintenance, and custodial services; and directly manage or
provide direct administrative support to personnel engaged in
these activities.
(2) The owned or leased computer and tele-
communications hardware, including central processing units;
associated peripheral equipment such as disk drives, tape drives,
drum storage, printers, card readers, and consoles; data entry
equipment; data reproduction, decollation, booking, and binding
equipment; telecommunications equipment including control units,
terminals, modems, and dedicated telephone and satellite links
provided by the facility to enable data transfer and access to
users. Hardware acquired and maintained by users of the facility
is excluded.
(3) The software, including operating system software,
utilities, sorts, language processors, access methods, data base
processors, and other similar multi-user software required by the
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facility for support of the facility and/or for general use by
users of the facility. All software acquired or maintained by
users of the facility is excluded.
(41) The physical facilities, including computer rooms;
tape and disk libraries; stockrooms and warehouse space;~ i office
space; physical fixtures.
b. The term "full costs" means all significant expenses
incurred in the operation of an information technology facility.
The following elements are included:
(1) Personnel, including salaries, overtime,'and
fringe benefits of civilian and military personnel; training; and
travel.
,,(2) Equipment, including depreciation for owned,
capitalized equipment; equipment rental or lease; and direct
expenses for noncapitalized equipment.
(3) Software, including depreciation for capitalized
costs of developing, converting, or acquiring software; rental of
for software; and direct expenses for noncapitalized
acquisition of software.
(u) Supplies, including office supplies; data
processing materials; and miscellaneous expenses.
(5) Contracted services, including technical and
consulting services; equipment maintenance; data entry support;
operations support; facilities management; maintenance of
r(6) Space occupancy, including rental and lease of
buildings, general office furniture, and equipment; building
maintenance; heating, air conditioning and other utilities;
telephone-services; power conditioning and distribution equipment
and alternate power sources; and building security and custodial
services.a
(7) Intra-agency services, including normal agency
support services that are paid by the installation.
(8) Interagency services, including services provided
by other- agencies and departments that are paid by the 4
installation.
c. The term "user" means an organizational or programmatic
entity that receives service from an information technology
facility." A user may be either internal or external to the
agency organization responsible for the facility, but normally
does not report either to the manager or director of the facility
or to the same immediate supervisor.
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d. The term "general management computer" means a digital
computer that is used for any.. purpose other than as a part of a
process control system, space system, mobile system, or a system
meeting one of the exclusions identified in the Department of
Defense Authorization Act of 1982.
It. Accounting and Reimbursement for Sharing of Information
Technology Facilities
a. Interagency Sharing. Agencies shall:
(1) Share their information technology facilities with
users from other agencies to the maximum extent feasible;
(2) Document sharing arrangements, where the total
annual reimbursement exceeds $500,000, with individual written
agreements that identify:
(a) Services available for sharing;
(b) Service priority procedures and terms (e.g.,
quality performance standards) to be provided to each user;
provided; and
agreement;
(c)
(d)
(e)
Prices to be charged for providing services;
Reimbursement arrangements for services
Arrangements for terminating the sharing
(3) Provide standard terms and conditions to users
obtaining similar services insofar as possible; ,
(4) Include such sharing arrangements, when fully
documented and part of a formal sharing program, in
justifications to 0MB for resource requests (see 0MB Circular No.
A-11, revised) and allocations. Direct funding by a shared
facility should be requested only where exceptional circumstances
preclude the user agency from using alternative sources.
b. Cost Accounting. Agencies shall account for the full
cost of the operation of information technology facilities.
c. User Cost Distribution System. Agencies shall
implement a system to distribute the full cost of
providing services to all users. That system will:
(1) Be consistent with guidance provided in the
Federal Information Processing Standards Publication No. 96,
"Guidelines for Developing and Implementing a Charging System for
Data Processing Services" (National Bureau of Standards,
Department of Commerce, 1982).
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(2) Price each service provided by the facility to the
users of that service on an equitable basis commensurate with the
amount of resources'required to provide that service and the
priority of service provided. The price of individual
transactions may be estimated provided that they are periodically
reconciled to assure that the full costs of operations are
equitably distributed among all users.
(3) Directly distribute to the recipient of the
services the full costs of dedicated services, including
applications developed and maintained; software unique to
a single application; and telecommunications equipment, including
control units, terminals, modems, and dedicated telephone or
satellite links provided by the facility to enable data transfer
and computer access to users.
d. Cost Recovery. Consistent with statutory authority,
agencies shall:
(1) Submit periodic statements to all users of agency
information technology facilities specifying the costs of
services provided;
(2) Recover full costs from Federal users of the
facility; and
(3) Recover costs from nonfederal users of the
facilities consistent with 0MB Circular No. A-25.
e. Accounting for Reimbursements Received. Agencies
shall:
(1) Include resource requests for the amount of
planned information technology use in user budget and
appropriation requests;
(2) Assure that shared facilities reduce budget and
appropriation requests by the amount of planned reimbursements
from users;
(3) Prepare, at the close of each fiscal year,, a
report that documents in the agency's official records the full
past year cost of operating information technology facilities
that recover more than $500,000 per year from sharing
reimbursements; and
(4) Use the portion of reimbursements arising from
equipment and software depreciation for the replacement of
equipment and software capital assets, provided such usage is
included in the agency's budget.
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5. Selection of Information Technology Facilities to Support
New Applications.
In selecting information technology facilities to support new
applications, agencies shall establish a management control
procedure for determining which facility will be used to support
each significant application. This procedure shall ensure that:
(a) All alternative facilities are considered, including
other Federal agency and nonfederal facilities and services;
(b) Agency, rules do not require that priority be given to
the use of in-house facilities; and
(c) The user of the application has primary responsibility
for selecting the facility.
6. Assignment of Responsibilities
a. All Federal Agencies. The head of each agency shall:
(1) Establish policies and procedures and assign
responsibilities to implement the requirements of this Appendix;
and
(2) Ensure that contracts awarded for the operation of
information technology facilities include provisions for
compliance with the requirements of this Appendix.
b. General Services Administration. The Administrator of
General Services shall:
(1) Ensure that information technology facilities
designated as Federal Data Processing Centers comply with the
procedures established by this Appendix;
(2) Ensure that provisions consistent with this
Appendix are included in contracts for the operation of
information technology facilities when acquiring services on
behalf of an agency;
7. Implementation Requirements
Agencies, shall implement the provisions of this Appendix
effective at the beginning of fiscal year 1987.
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APPENDIX III
TO OMB CIRCULAR NO. A-130
SECURITY OF FEDERAL AUTOMATED INFORMATION SYSTEMS
1. Purpose
This Appendix establishes a minimum set of controls to be
included in Federal automated information systems security
programs; assigns responsibilities for the security of agency
automated information systems; and clarifies the relationship
between such agency security programs and internal control
systems established in accordance with OMB Circular No. A-123,
Internal Control Systems. The Appendix revises procedures
formerly contained in Transmittal Memorandum No. 1 to OMB
Circular No. A-71, now rescinded, and incorporates
responsibilities from applicable national security directives.
2. Definitions
a. The term "automated information system" means an
information system (defined in Section 6d of the Circular) that
is automated.
b. The term "information technology installation" means
one or more computer or office automation systems including
related telecommunications, peripheral and storage units, central
processing units, and operating and support system software.
Information technology installations may range from information
technology facilities such as large centralized computer centers
to individual stand-alone microprocessors such as personal
computers.
c. The term "sensitive data" means data that require
protection due to the risk and magnitude of loss or harm that
.could result from inadvertent or deliberate disclosure,
alteration, or destruction of the data. The term includes data
whose improper use or disclosure could adversely affect the
ability of an agency to accomplish its mission, proprietary data,
records about individuals requiring protection under the Privacy
Act, and'data not releasable under the Freedom of Information
Act.
d. The term "sensitive application" means an application
of information technology that requires protection because it
processes sensitive data, or because of the risk and magnitude of
loss or harm that could result from improper operation or
deliberate manipulation of the application.
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e. The term "security specifications" means a detailed
description of the safeguards required, to protect a sensitive
application.
3. Automated Information Systems Security Programs
Agencies shall assure an adequate level of security for all
agency automated information systems, whether maintained in-house
or commercially. Specifically, agencies shall:
)Assure that automated information systems operate
effectively and accurately;
- Assure that there are appropriate technical, personnel,
administrative, environmental, and telecommunications safeguards
in automated information systems; and
- ;Assure the continuity of operation of automated
information systems that support critical agency functions.
Agencies shall implement and maintain an automated information
systems security program, including the preparation of policies,
standards,.and procedures. This program will be consistent with
government-wide policies, procedures, and standards issued by the,
Office of Management and Budget, the Department of Commerce, the
Department.of Defense, the General Services? Administration, and
the Office of Personnel Management. Agency programs shall
incorporate additional requirements for securing national
security information in accordance with appropriate national
security directives. Agency programs shall, at a minimum,
include four primary elements: applications security, personnel
security,-information technology installation security, and
security awareness and training.
a. Applications Security
;(1) Management Control Process and Sensitivity
Evaluation. Agencies shall establish a management control
process to assure that appropriate administrative, physical, and
technical safeguards are incorporated into all new applications,
and into significant modifications to existing applications.
Management officials who are the primary users of applications
should evaluate. the sensitivity of new or existing applications
being substantially modified. For those applications considered
sensitive, the management control process shall, at a minimum,
include security specifications and design reviews and systems
tests.
(a) Security Specifications. Agencies shall
define and approve security requirements and specifications prior
to acquiring or starting formal development of the applications.
The results of risk analyses performed at the information
technology installation where the applications will be, processed
should be taken into account when defining and approving security
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specifications for the applications. Other vulnerabilities of
the applications, such as in telecommunications links, shall also
be considered in defining security requirements. The views and
recommendations of the information technology user organization,
the information technology installation, and the individual
responsible for security at the installation shall be considered
prior to the approval of securityspecifications for the
applications.
(b) Design Reviews and System Tests. Agencies
shall conduct and approve design reviews and system tests, prior
to placing the application into operation, to assure the proposed
design meets the'approved security specifications. The objective
of the system tests should be to verify that required
administrative, technical, and physical safeguards are
operationally adequate. The results of the design reviews and
system tests shall be fully documented and maintained in the
official agency records.
(c) Certification. Upon completion of the system
tests, an agency official shall certify that the system meets all
applicable Federal policies, regulations, and standards, and that
the results of the tests demonstrate that the installed security
safeguards are adequate for the application.
(2) Periodic Review and Recertification. Agencies
shall conduct periodic audits or reviews of sensitive
applications and recertify the adequacy of security safeguards.
Audits or reviews shall evaluate the adequacy of implemented
safeguards, assure they are functioning properly,. identify
vulnerabilities that could heighten threats to sensitive data or
valuable resources, and assist with the implementation of new
safeguards where required. They are intended to provide a basis
for recertification of the security of the application.
Recertification shall be fully documented and maintained in the
official agency-records. Audits or reviews and recertifications
shall be performed at least every three years. They should be
considered as part of agency vulnerability assessments and
internal control reviews conducted in accordance with OMB
Circular No. A-123. Security or other control weaknesses
identified shall be included in the annual internal control
assurance letter and report required by Circular No. A-123.
(3) Contingency Plans. Agencies shall establish
policies and assign responsibilities to assure that appropriate
contingency plans are developed and maintained by end users of
information technology applications. The intent of such plans is
to assure that users can continue to perform essential functions
in the event their information technology support is interrupted.
Such plans should be consistent with disaster recovery and
continuity of operations plans maintained by the installation at
which the application is processed.
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b. Personnel Security. Agencies shall-establish .and
manage .personnel security policies and- procedures to'assur.e an
adequate level of security for Federal automated i"nfformati.on
systems.' Such policies and procedures shall include requirements
for screening all individuals partieipat:ing in the design,
development, operation, or maintenance of sen,sit-i-ve applications
as well as those having access t.o~se'nsitive data.. The level of
screening required :by these.po:licies should vary from .minimal
checks to full background investigations, depending upon'the
sensitivity of the information to be handled and "the risk and
magnitude of loss or harm that could be caused by ,the individual..
These policies shall be established for both Federal and(
contractor :personnel.. Personnel security :po1?i.c.ies for Federal
employees shall be consistent with policies issued by the'Office
of-Personnel Management.
c. Information' Technology Installation Security. Agencies
shall assure that-an appropriate level of security is maintained
at all information technology installations operated by or on
behalf of the Federal Government (e..g.?,,government-owned,
contractor-operated installations)..
,.(1 ) Assigning Responsibility. Agencies shall assign
responsibility for the .security of each installation 'to a
management official knowledgeable in information technology and
security -matters..
(2) Periodic Risk Analysis. Agencies.shall estab.lish
and maintain a program for the conduct of per.iod.ic risk analyses
at each installation to ensure 'that appropriate, cost effective
.safeguards are incorporated into existing and new installations.
The objective of a risk analysis is to provide a measure of the
relative vulnerabilities ,and threats 'to-an installation so that
security,re.sources can be effectively"distr?ibuted'to,minimize
potential loss. Risk analyses may vary from an informal, review
of a microcomputer installation to a formal, fully quantified
risk analysis of :a large scale computer system. The results of
these analyses should be documented and taken into consideration
by management officials when certifying sensitive 'applications
processed at the installation. Such analyses should also
be consulted during the evaluation of general controls over the
management of information technology installations conducted in
accordance with 0MB Circular N.o.. A-123. A risk analysis shall be
performed:
(a) Prior to the approval of design
specifications for new installations;
(b) Whenever a significant change occurs to the
installations (e.g., adding a local area network; changing from
batch to online processing; adding dial-up capability). Agency
criteria for defining: significant change shall be commensurate
with the sensitivity.of the data processed by the installation.
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(c) At periodic intervals established by the
agency commensurate with the sensitivity of the data processed,
but not to exceed every five years if no risk analysis has-been
performed during that period.
(3) Disaster and Continuity Plan. Agencies shall
maintain disaster recovery and continuity of operations plans for
all information technology installations. The objective of these
plans should be to provide reasonable continuity of data
`pr'ocessing support should events occur that prevent normal
operations at the installation. For large installations and
installations that support essential agency functions, the plans
should be fully documented and operationally tested periodically,
at a frequency commensurate with the risk and magnitude of loss
or harm that could result from disruption of information
technology support.
(4) Acquisition Specifications. Agencies shall
assure that appropriate technical, administrative, physical, and
personnel security requirements are included in specifications
for the acquisition or operation of information technology
installations, equipment, software, and related services, whether
procured by the agency or by GSA. These security requirements
shall be reviewed and approved by the management official
responsible for security at the installation making the
acquisition.
d. Security Awareness and Training Programs. Agencies
shall establish a security awareness and training program to
assure that agency and contractor personnel involved in the
management, operation, programming, maintenance, or use of
information technology are aware of their security
responsibilities and know how to fulfill them. Users of
information technology systems should be apprised of the
vulnerabilities of such systems and trained in techniques to
enhance security.
4. Assignment of Responsibilities
a. Department of Commerce. The Secretary of Commerce
shall:
(1) Develop and issue standards and guidelines for
assuring, the security of Federal automated information systems;
(2) Establish standards, approved in accordance with
applicable national security directives, for systems used to
process sensitive information the loss of which could adversely
affect the national security interest; and
(3) Provide technical assistance to Federal agencies
in implementing Department of Commerce standards and guidelines.
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b. Department of Defense. The Secretary of Defense shall:
(1) Act,..in accordance with applicable national
security directives, as executive agent of the.government.Por the
security of telecommunications and automated information systems
that process information the loss of which could adversely affect
the national security interest; and
(2) Provide technical material and assistance to
Federal agencies concerning security of Federal
telecommunications and automated information systems.
c. General' Services Administration. The Administrator of
General Services shall:
i ?
(1) Issue policies and regulations for the physical
and environmental security of computer rooms in Federal buildings
consistent with standards issued by the Department of Commerce
and the Department of Defense.
(2) Assure that agency procurement requests for
computers, software, telecommunications services, and related
services include security requirements. Delegations of
procurement authority to agencies by GSA under mandatory--
programs, dollar threshold delegations, certification programs,
or other so-called blanket delegations shall include requirements
for agency specification of security requirements.
(3) Assure that information technology equipment,
software,-computer room construction, guard or custodial
services, telecommunications services, and any other related
services procured by GSA meet the security requirements
established and specified by the user agency and are consistent
with other applicable policies and standards issued by OMB, the
Department'of Commerce, the Department of Defense, and the Office
of Personnel Management.
(4) Issue appropriate standards for the security of
Federal t,plecommunications systems. Standards related to systems
used to communicate sensitive information, the loss of which
could adversely affect the national security interest, shall be
developed and issued in accordance with applicable national
security directives.
d.? Office of Personnel Management. The Director, Office
of Personnel Management, shall maintain personnel security
policies for Federal personnel associated with the design,
programming, operation, maintenance, or use of Federal automated
information systems. Requirements for personnel checks imposed.
by these policies should vary commensurate with the risk"and
magnitude of loss or harm that could be caused by the individual.
The checks may range from merely normal reemployment screening
procedures to full background investigations.
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5. Reports
In their annual internal control report to the President and the
Congress, required under 0MB Circular No. A-123, agencies shall:
a. Describe any security or other control weaknesses
identified during audits or reviews of sensitive applications or
when conducting risk analyses of installations; and
b. Provide assurance that there is adequate security of
agency automated information systems.
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APPENDIX IV
TO OMB.CIRCULAR NO. A-130
ANALYSIS OF KEY SECTIONS
1. Purpose
The purpose of this Appendix is to provide a general context and
explanation for the contents of the key sections of the Circular.
2. Background
The Paperwork Reduction Act of 1980, P.L. 96-511, 94 Stat 2812,
codified at Chapter 35 of Title 44 of the United States Code,
establishes a broad mandate for agencies to perform their
information activities in an efficient, effective, and economical
manner. Section 3504 of the Act provides authority to the
Director, Office of Management and?Budget (OMB), to develop and
implement uniform and consistent information resources management
policies; oversee the development and promote the use of
information management principles, standards, and guidelines;
evaluate agency information management practices in order to
determine their adequacy and efficiency; and determine compliance
of such practices with the policies, principles, standards, and
guidelines promulgated by the Director.
The Circular implements OMB authority under the Act with respect
to Section 3504(b), general information policy, Section 3504(e),
records management, Section 3504(f), privacy, and Section
3504(g), Federal automatic data processing and
telecommunications; the Privacy Act of 1974 (5 U.S.C. 552a);
Sections 111 and 206 of the Federal Property and Administrative
Services Act of 1949, as amended (40 U.S.C. 759 and 487,
respectively ); the Budget and Accounting Act of 1921 (31 U.S.C.
1 et seq.); and Executive Order No. 12046 of March 27, 1978 and
Executive Order No. 12472 of April 3, 1984, Assignment of
National Security and Emergency Telecommunications Functions.
The Circular complements 5 CFR 1320, Controlling Paperwork Burden
on the Public, which implements other sections of the Paperwork
Reduction Act dealing with controlling the reporting and
recordkeeping burden placed on the public.
In addition, the Circular revises and consolidates policy and
procedures in five existing OMB directives and rescinds those
directives, as follows:
A-71 - Responsibilities for the Administration and
Management of Automatic Data Processing Activities
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Transmittal Memorandum No. 1 to Circular No. A-71 - Security
of Federal Automated Information Systems
A-90 - Cooperating with State and Local Governments to
Coordinate and Improve Information Systems
A-108 - Responsibilities for~the.Maintenance of Records
about Individuals by Federal Agencies
A-121 - Cost Accounting, Cost Recovery, and Interagency
Sharing of Data Processing Facilities
OMB's review of the five existing policy'directives led to the,
conclusion that much, but not all, of their content was
procedural in nature, concerned chiefly with how policies were to
be carried-out. OMB determined that it was important clearly to
distinguish the statement of policies from the procedures for
implementing those policies. For this reason, the main body of
the Circular consists of basic considerations and assumptions,
policies,3and assignments of responsibility,; the appendices to
the Circular consist of procedures for implementing various
policies and with analysis of key sections.
OMB developed the main body of the Circular relying upon
comments on the Federal Register notice as well as other forms of
Federal agency and public input, principally meetings with
interested parties. For the procedural revisions, OMB relied on
the assistance of interagency-task groups.
The revised contents of OMB Circular No. A-71, dealing with
assignments of responsibilities, are in the main body of this
Circular. The contents of OMB Circular No. A-90 are rescinded
entirely, with the exception of a policy statement at Section 8
(b)(17) of this Circular. Revisions of the procedural aspects of
the other;threepolicy directives--Transmittal Memorandum. No. 1.
to A-71, A-108,-and A-121--are appendices to this Circular.
Appendices I, II, and III have the same prescriptive force as the
Circular;, Appendix IV is an explanatory document.
On September 17, 1984, the President signed National Security
Decision Directive (NSDD) No. 145, National Policy on
Telecommunications and Automated Information Systems Security..
The NSDD requires that the Director, OMB, review for consistency
with the.NSDD, and amend as appropriate, OMB Circular No. A-71,
Transmittal Memorandum No. 1. The Circular and Appendix
III satisfy the NSDD requirement.
3. Analysis '
Section 6.3 Definitions
f. Access to information. g. Dissemination of
information. The Circular defines "access to information" as the
function of-providing to members of the public, upon their
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request, the government information to which they are entitled
under law. Access refers to those situations in which the
government agency's?role is passive; access is what the
government's responsibilities are when the public comes to the
government and asks for information the government has and the
public is entitled to. "Dissemination," in the Circular's usage,
refers to the function of distributing government information;
dissemination connotes an active outreach by a government agency.
Dissemination refers to those situations in`which the government
provides the public with information without the public having to
come and ask for it.
The distinction between access and dissemination is posed in
order to elaborate the responsibilities of Federal agencies for
providing information to the public. Two fundamentally different
situations exist: one in which the public goes to the agency to
ask for information the agency holds and may or may not have
disseminated; and one in which the agency chooses to take the
information it holds to the public. In the first instance--
access--Congress has provided specific statutory policy in the
Freedom of Information Act (FOIA) and in the Privacy Act. These
laws and policies concerning access to government information are
explicit, well known, and now so widely accepted in practice by
Federal agencies as not to require policy elaboration in this
Circular. Agencies should know that, if members of the public
ask for information subject to FOIA or the Privacy Act, the
agencies should normally provide the information forthwith,
because the public has a formal legal process for forcing the
agencies to yield the information.
The relationship between access to and dissemination of
information is explained below, in the discussion of 8a(8)
through (12).
Section 7. Basic Considerations and Assumptions
Basic considerations and assumptions are statements that provide
the underpinnings for the prescriptive policies in Section 8;
they are not themselves policy statements. They are either
derived from statutes or legislative history, or represent
executive branch management philosophy as embodied in the
Circular.
Statements 7-a through.7-d provide the general context
for management of Federal information resources.
Statement 7-e summarizes policy found in OMB Circular
No. A-76, Performance of Commercial Activities.
Statement 7-f states a general predisposition to use
up-to-date information technology to manage Federal
information resources.
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Statements 7-g and 7-h pertain to the Privacy At and
the Freedom of Information Act, respectively.
Statement 7-i pertains to the National Science and
Technology Policy, Organization and Priorities Act.
Statement 7-j pertains to the Federal Records Act.
Statement 7-k states a relationship between Federal
information policy and international information
policy.
Section 8. Policies.
This section is divided into two subsections that generally
correspond to the twofold definition of information resources
management in Section 6-b, namely, information itself and the
resources associated with information.
a. Information Management. The Paperwork Reduction Act
acknowledges that information is a valuable resource and should
be managed as such. Proceeding from this premise, this
subsection states policies concerning the management of Federal
information.
(1) and (2). Information Collection and Sharing. The
Circular's basic considerations and assumptions (Section 7)
establish the value of government information activities.
Without question, some information created or collected by
Federal agencies is so vital that the American form of
government, the economy, national security, and citizens' safety
and wellbeing could not continue to exist in its absence.
Nothing in this Circular is intended to diminish or derogate the
creation or collection of such information, nor to serve as a
pretext under which a Federal agency could damage the Nation's
critical needs by failing to create or collect such information.
At the same time, the Paperwork Reduction Act was designed to
remedy deficiencies Congress perceived in Federal information
activities. In the words of the report of the House Committee on
Government Operations (Report No. 96-835, p. 3):
The legislation is the result of a growing concern that the
way the Government collects, uses, and disseminates
information must be improved. Inefficiencies in current
Federal information practices drastically reduce the
effectiveness of the Government while, at the same time,
drowning our citizens in a sea of forms, questionnaires, and.
reports.
The Act intends that the creation or collection of information be
carried out within the context of efficient, effective., and
economical management. When Federal agencies create or collect
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information--just as when they perform any other vital functions
--they consume scarce resources and such activities must be
continually scrutinized 'in light of good management,princi,ples.
The applicable principles provided in the purposes of the Act
are:
to minimize the Federal,_paperwork burden for
individuals, small businesses, State and local
governments, and other persons;
to minimize the cost to the Federal Government of
collecting, maintaining, using, and disseminating
information; and
to maximize the usefulness of information collected by
the Federal Government. (44 U.S.C. 3501)
Agencies must justify the creation or collection of information
in the light of their statutory functions. Policy statement
8a(9) uses the standard, "necessary for the proper performance of
agency functions," taken directly from the Paperwork Reduction
Act (44 U.S.C. 3504 (c)(2)). Further, the policy statement
includes the requirement that the information have practical
utility, as defined in the Paperwork Reduction Act (44 U.S.C.
3502 (15)) and elaborated in Controlling Paperwork Burdens on the
Public (5 CFR 1320). Note that practical utility includes
characteristics pertaining to the quality of information such as
accuracy, adequacy, and reliability, and that, in the case of
general purpose statistics or recordkeeping, practical utility
means that actual uses can be demonstrated (5 CFR 1320.7 (q)).
Good management and the requirement of practical utility dictate
that agencies must plan from the outset for the steps in the
information life cycle. The Act also stipulates that agencies
must "formulate plans for tabulating the information in a manner
which will enhance its usefulness to other agencies and to the
public" (44 U.S.C. 3507 (a)(1)(C)). When creating or collecting
information, agencies must plan how they will process and
transmit the information, how they will use it, what provisions
they will make for access to it, whether and how they will
disseminate it, how they will store it, and finally, how the
information will ultimately be disposed of. While agencies
cannot at the outset achieve absolute certitude in planning for
each of these processes, the requirement for information
resources planning is clearly contained in the Act (44 U.S.C.
3506 (c)(1)), and the absence of adequate planning is sufficient
reason not to create or collect information in the first place.
Before creating or collecting new information, agencies should
look first to other agencies and the private sector so as not to
duplicate existing information sources or services that would
satisfy their needs. The Act requires that agencies shall not
conduct or sponsor information collections unless they have
eliminated collections "which seek to obtain information
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available from another source within the Federal Government" ((44
U.S.G. 3507 (a)(1)(A))., Each,, agency must also "ensure its
information systems.-do not overlap each other or duplicate the
systems of other agencies" (44 U.S.C. 3506 (o)(2)). The Act also
contains provisions governing the sharing of information between
agencies (44 U.S.C: 3510). Applying the policy of OMB Circular
No. A-76, the Circular also requires agencies to examine the
possibility of acquiring the necessary information from private
sector sources.
This is not to say that information creation or collection
functions should be indiscriminately turned over to other
agencies or to the private sector, but rather to say that
agencies have an obligation to examine other potential sources of
information which may satisfy agency needs. Some information can
only be created or collected by Federal agencies themselves in
the exercise of the government's sovereign powers. For some
information, the government can satisfy its legitimate needs only
when a Federal agency is the creation or collection agent. But
other information needs can be met, and in many cases are
routinely met, through existing services and sources in other
agencies or the private sector. In-many cases ;here is no
inherently governmental function that is served by having
information collected by a Federal agency; agencies should and do
consider acquiring information collection services from the
private sector. The Circular emphasizes that these sources
should always be looked to first in the interests of efficiency
and economy.
(3) through (6). Privacy Act and Freedom of
Information Act. These statements contain policy statements
pertaining to the Privacy Act and incorporating the policies of
OMB Circular No. A-108, which is rescinded and superseded.
Agencies are to ensure that they meet the requirements of the
Privacy Act regarding collection of individually identifiable
information. Stich information is to be maintained and protected
so as to preclude intrusion into the privacy of individuals.
Individuals must be accorded access and amendment rights to
records,,as provided in the Privacy Act. Appendix I prescribes
procedures for the maintenance of records about individuals in
accordance with the Privacy Act,
In addition to Privacy Act considerations, statements (3) and (4)
include provisions concerning proprietary information. Agencies
are to minimize their collection of proprietary information,
consistent with legal requirements and operational necessity and,
when. such information must be collected, agencies must provide
for its protection.
(7). Training. Agency personnel must receive proper
training to safeguard information resources. Training
is particularly important in vies of. the changing nature of..
information resources management. The devel opYment of end user
computing and office autor~a ;icn, for example, ;dace the
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management of information and information technology in the hands
of nearly all agency personnel rather than in the hands of a few
employees at centralized facilities such as large computer
centers. Policies and procedures for computer security, records
management, protection of privacy, and other safeguards need to
be incorporated into information resources management training
programs.
(8) through (12). Information Dissemination.
(8) and (9). General Policy. How does the
public know what information is available from Federal agencies?
That is, given the distinction the Circular makes between access
and dissemination, what is the the relationship between the two?
How does the public know what government information is
accessible? The answer is: through the government's
dissemination of information on what is available and how to gain
to access it.
The Freedom of Information Act requires each agency to publish
currently in the Federal Register, for the guidance of the
public, descriptions of agency organization; where and how the
public may obtain information; the general course and methods by
which agency functions are determined, including all procedural
requirements; rules of procedure; descriptions of forms and how
to obtain them; substantive regulations; statements of general
policy; and revisions to all the foregoing (5 U.S.C. 552 (a)(1)).
The Privacy Act also requires publication of information
concerning systems of records (see Appendix I); the Government in
the Sunshine Act requires agencies to make public, announcement of
meetings (5 U.S.C. 552b (e)(1)). The Paperwork Reduction Act (44
U.S.C. 3507 (a)(2)) and Controlling Paperwork Burdens on the
Public (5 CFR 1320) require agencies to publish notices when they
submit information collection requests for 0MB approval.
In sum, every Federal agency has obligations to disseminate basic
information to the public concerning what the agency does, how
its programs operate, what the public must do to comply with laws
or regulations, how to receive benefits, and how the public can
use agency services. These obligations are the basic linkage
between access to, and dissemination of, government information.
Beyond generic requirements, specific laws affect agency
dissemination of information in two ways. First, for some
agencies their basic enabling legislation stipulates that
information dissemination is part of their statutory mission.
General purpose statistical agencies, for example, have
information dissemination as part of their very reason for
existence. These agencies conduct substantial information
dissemination programs in order to carry out, their necessary
functions. In contrast, other agencies such as some regulatory
agencies have basic information access, but minimal information
dissemination, responsibilities; the existence of substantial
information dissemination programs in such agencies would be
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unusual. Second, statutes may sometimes require that agencies
produce and disseminate , specific information products or
services. For example, the law may state that the President or
head of an agency shall make reports to the Congress on given
subjects; these would be legally required disseminations of
information.
Beyond generic and specific statutory requirements, agencies have
positive obligations to disseminate information as a necessary
part of performing their functions. Each agency head must
clarify the nature of these obligations for the agency's
particular mission and set appropriate boundaries for
dissemination functions. Before deciding to disseminate;an
information product or service, and periodically thereafter, an
agency must be able to demonstrate that the dissemination of the
product or service passes the test of either being required by
law or being necessary for the proper performance of agency
functions.-
In conformity with the purposes of the Paperwork Reduction Act,
the agency's positive obligations to disseminate information must
be discharged within a responsible management framework of
vinimizing costs to the Federal Government while maximizing the
usefulness of the information. Efficient, effective, and
economical dissemination does not translate into diminishing or
limiting the flow of information from the agency to the public..
To the contrary, good management of information resources should
result in more useful information flowing with greater facility
to the public, at less cost to the taxpayer.
Given an adequate basis for dissemination, agencies must also ask
themselves whether a proposed or existing information product or
service substantially duplicates similar products or services
that would otherwise be available, either from another agency or
from the private sector. This requirement of non-duplication,
originating in the Paperwork Reduction Act, husbands scarce
resources, and leads to more efficient, effective, and economical
information dissemination by the government. .I
Similarly; the fact that an agency has created or collected
information is not itself a valid reason for creating a program,
product, or service to disseminate the information to the public.
Agencies create and collect much information, often for purely
internal governmental purposes, that is not intended for
dissemination, for which there is no public demand, and the
dissemination of which would serve no public purpose and would
not be cost-justified; e.g., compilations of routine time and
attendance records for Federal employees, or publication,of the
thousands,,of pages of common carrier tariff filings by regulatory
agencies.' While such information may be subject to access upon
request under provisions of agency statutes,.the Freedom of
Information Act, or the Privacy Act, the agency must demonstrate
in each case the need actively to disseminate such information.
Over time, changes in laws, economic conditions, or information
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technology can result in changes in public demand, public
purpose, or dissemination costs; for example, an agency's shift
to electronic filing of reports, perhaps carried out primarily in
order to improve internal information management, might generate
8 public demand for electronic dissemination that could be
satisfied at minimal cost to the government and also improve the
performance of the agency's information access function. The
decision to disseminate information, however, entails potentially
significant costs, must be addressed separately from the decision
to create or collect information, and must hinge upon a
determination that dissemination is necessary for proper
performance of agency functions.
If agencies do contemplate disseminating particular information,
they should plan for its dissemination when creating or
collecting the information (see 8a(1)). Planning for
dissemination should proceed from the Paperwork Reduction Act
premises of minimizing the cost to the government while
maximizing the usefulness of information. The focus of
information dissemination plans should be on elevating to a
policy level decisions regarding the agency's positive
obligations to disseminate information and ensuring that the
agency discharges the obligations in the most efficient,
effective, and economical manner.
(10) Adequate Notice. Because, many government
information activities are important to the government and to the
public, agencies must exercise care not to act capriciously with
respect to information products and services. When agencies
intend to commence offering new products or services, they should
provide adequate advance notice so that the public may comment as
to the need for the product or service. For example, if,private
sector interests believe they are already offering or are about
to offer the same or a similar product or service--in which event
the government may potentially be entering into unfair
competition--such notice will allow these interests to present
their case before the product or service is launched. By the
same token, if many members of the public greatly depend on a
particular product or service, they should be permitted to voice
their views to an agency that is contemplating termination of the
product or service.
The Circular refers to "significant" information products and
services-. It is not the Circular's intent that agencies should
follow notice and comment procedures when terminating relatively
inconsequential information products and services; examples might
be minor brochures or flyers, products and services that were
never intended to be continuing,' or for which there is now little
or no public audience. Agencies should determine for themselves
whether information products and services are "significant," and
in some cases may wish to establish procedures and threshold
criteria for making such determinations. If a product or service
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is considered significant, as determined ultimately by the agency
head, the agency may be well advised to follow notice and comment
procedures prior to.-initiation or termination.
(11)(a). Reaching the Public; Avoiding Information
Monopolies. When agencies have justified and made the basic
decision to disseminate information, they must also satisfy
conditions regarding the manner of dissemination. First,-
agencies must take steps to ensure that members of the public
whom the agency has an obligation to reach have a reasonable
ability to acquire the information. The audiences for
information products and services will, vary, and agencies, should
tailor the dissemination methods so as to place the information
into the hands of those whom the agency intends to receive it.
Federal agencies are often the sole holders of certain
information; hence, when they disseminate, they are sole
suppliers and in a position of natural monopoly. When agencies
use private sector contractors to accomplish dissemination, they
must take-care that they do not permit contractors to exercise
monopolistic controls in ways that defeat the agencies'
information dissemination obligations, for example, by setting
unreasonably high prices. In some cases agencies may need to
formulatejcontractual terms with a sole supplier contractor so
that the contractor functions as a mere intermediary for,the
agency in.dealing with end users in the public.
(11)(b). Reliance on the Private Sector. In
disseminating information--as with other activities--agencies
must act in the most cost effective manner, which.include,s
maximum feasible reliance on the private sector. This is merely
an application to agency information dissemination programs of
the policy stated in 0MB Circular No. A-76, Performance of
Commercial Activities, and summarized in Section 7f of trkis
Circular. It is "the general policy of the government to rely on
commercial sources to supply the products and services the
government needs," including products and services the government
needs in order to disseminate information to the public., For
example, before an agency establishes a service for electronic
dissemination of government information via an online computer
system, the agency should compare the cost of contracting for
operation of the service versus in-house performance and- .
determine whether in-house performance is less costly both for
the government and for the public who will receive the service.
Policies contained in 0MB Circular No. A-76 are applicable to
information dissemination, including the policy that inherently
governmental functions should be, performed by government,
employees.. The'general policy of reliance on the private sector
is balanced by the "inherent governmental function" policy, and
the Circular in no way intends to abrogate the latter. Where
agencies determine that information dissemination activities are
inherently, governmental, the agencies themselves should carry out
the activities.
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(11)(c). User Charges.. The Federal Government is
the sole possessor and supplier of certain types of information,
which is frequently of substantial commercial value.
Dissemination of such information, or its dissemination in a
specific form or medium, may represent a government service from
which identifiable recipients derive special benefits, in which
case they may be subject to OMB Circular No. A-25, User Charges.
For example, where the information is already substantially
available in printed form, agencies may consider dissemination in
electronic form to be a service of special benefit, the costs of
which should be recovered through user charges. Many agencies do
not have consistent, agency-wide policies and procedures for
setting user charges for information products and services with a
view to cost recovery. Agencies must establish user charges for
the costs of information dissemination, and recover such costs,
where appropriate. Whether user charges are appropriate depends,
in principle, on whether identifiable recipients will receive
special benefits from information products and services.
The requirement to establish user charges is not, however,
intended to make the ability to pay the sole criterion for
determining whether the public receives government information.
Agencies must balance the requirement to establish user charges
and the level of fees charged against other policies,
specifically, the proper performance of agency functions and the
need to ensure that information products and services reach the
public for whom they are intended (see Section 8a (11)(a)). If
an agency has a positive obligation to place a given product or
service in the hands of certain specific groups or members of the
public and also determines that user charges will constitute a
significant barrier to discharging this obligation, the agency
may have grounds for reducing or eliminating its user charges for
the product or service, or for exempting some recipients from the
charge.
(12). Periodic Review and Depository Libraries.
Agencies must also establish procedures for periodically
reviewing their information dissemination programs. Agency
information dissemination plans must ask whether the agency
should disseminate a given information product or service at all;
if the agency is already disseminating the product or service,
reviews should ask whether the agency should continue to do so;
or whether the manner or medium of dissemination is the most
efficient, effective, and economical.
In,addition, agencies must establish procedures to ensure
compliance with 44 U.S.C. 1902,.which requires that government
publications (defined in 44 U.S.C. 190.1 and repeated in Section
6k of the Circular) be made available to the Federal depository
libraries through the Government Printing Office. The depository
libraries provide a kind of information "safety net" to the
public, an existing institutional mechanism that guarantees a
minimum level of availability of government information to all
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members of the public. Providing publications to the depository
library program complies with, the law and costs executive
agencies virtually nothing.
b. Information Systems and Information Technology
Management. This subsection states policies concerning the
planning, acquisition, operation,-:and management of Federal
information systems and technology. The Federal information
systems and technology budget, which was $14 billion in FY 1985,
-is projected. to increase at a rate faster than that of the
overall Federal budget. With outlays at these levels and
agenciesIbecoming increasingly dependent upon information
technology to accomplish their missions,. it is essential. that
planning processes be applied to the acquisition and application
of information technology. }
(1). Planning. The Paperwork Reduction Act mandates a
strongericentral role in information resources planning.,
Specifically, the Act requires that OMB: (1) publish a five-year
government-wide automatic data processing and telecommunications
plan; (2) review and coordinate agency proposals for the
acquisition and use of information technology; and (3) promote
the use of the technology to improve governmental efficiency and
effectiveness. In order to meet these objectives, it is'-
necessary to initiate a government-wide process for developing
and institutionalizing information technology planning that is
based in agency programs and missions. The planning must also be
tied to the budget so that budgetary decisions derive from plans,
and conversely, so that budgetary constraints are reflected in
the plans. The process must further ensure that sufficient
information is available to the central agencies to enable them
to:monitor compliance with Federal policies and identify major
issues, including cross-cutting issues where more active
.centralized planning and management may be appropriate. Hence,
agencies must institute information planning processes tied to
both the conduct of programs and the preparation of the agency's
budget.
(2) and (3). Management Controls and Accountability.
Basic management controls for agency information systems-are
fundamental to sound information resources management. These
controls should ensure the documentation and periodic review of
major information systems, as well as periodic cost-benefit
evaluation of overall information resources management in light
of agency missions. In order to provide greater incentive for
management efficiencies, accountability for information systems
should be vested in the officials responsible for operating the
programs that the systems support.
Program managers depend upon information systems to carry out
their programs, and yet frequently they do not have direct
control over the technical and operational support for those
systems., Program managers often depend upon agency computer
centers or contracted service organizations, the heads of which
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may not be directly accountable to the program managers in a
formal organizational sense. .,Program managers are nonetheless
responsible for conducting their programs and, to the extent
successful conduct of the programs entails support from
information systems, program managers must be held accountable
for acquiring that support. The responsibilities of program
managers are therefore presumed to include securing information
systems support as needed, and planning for contingencies.
Technical support organizations have a concomitant responsibility
to meet their commitments, contractual or otherwise, to their
program clients, but the program official has the ultimate
responsibility for delivering a program's product or service.
(4) and (5). Sharing Information Processing Capacity.
OMB Circular No. A-121, which is rescinded and superseded,
required only,that the holder of excess automatic data processing
capacity. share such capacity. Because the holder of excess
capacity has little incentive to seek opportunities for sharing,
however, the new policy requires both that the holder share
capacity and that the agency seeking, information processing
capacity fulfill its needs from other agencies or the private
sector, whenever possible, before acquiring the new capacity
itself. The policy establishes an order gf preference in meeting
needs--look first to existing sources before acquiring new
capacity--but is not intended to assert blindly that sharing or
commercial sources are the sole considerations. Agencies must
also consider whether existing sources are more cost effective
and whether they in fact will meet agency specific needs.
Procedural aspects of these policy statements are found in
Appendix II.
(6) and (7). Life Cycle Costing; and Avoiding .
Duplication. Agencies frequently develop information technology
incrementally, through a series of interim upgrades, without
regard for longer term considerations such as the information
systems' life cycle. As part of their planning, agencies need to
consider the full information. system life,cycle when determining
the cost of information technology. While competitive
procurement is generally to be valued, its costs should be taken
into account, including the cost to program effectiveness of
unnecessarily lengthy procurement processes. Other conditions,
such as the need for compatibility, may also be legitimate
limitations on the competitive process. Similarly, agency
planning. should ensure that information systems are not
unnecessarily duplicative of systems available elsewhere in
government or from the private sector.
(8). Software Management. The prevailing agency
practice of developing customized computer software is a source
of inefficiency, as the General Accounting Office and others have
noted. While some agency applications can only be satisfied with
customized software, the tendency to prefer custom development is
excessively costly in terms of initial development, continued
maintenance, and eventual conversion to new technology, because
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it requires the agency to bear the full cost of developing and
maintaining the software it use's. While recognizing that off-
the-shelf software has pitfalls, such as uncertainty of continued
maintenance, managers are generally to prefer acquiring generic,
off-the-shelf software available from the private sector instead
of developing their own.
,(9). Necessary Compatibility. Agencies often acquire
technology that is incapable of communicating with other systems
with which the agencies need to communicate. Compatibility among
information systems has consequently emerged as a significant
information resources management problem. Agencies must acquire
or develop information systems in a manner that enhances
necessary compatibility. The qualifier "necessary" is used
because compatibility is not an unrestricted goal; information
systems need to be compatible with other systems only to the
extent that they must communicate with those systems.
(10) through (13). Security. Security of information
systems means both the protection of information while it is
within the systems and also the assurance that the systems do
exactly what they are supposed to do and nothing more.
Information system security entails management controls to ensure
the integrity of operations including such matters as proper
access to the information in the systems and proper handling of
input and output. In this sense, security of information systems
is first and foremost a management issue and only secondly a
technical problem of computer security.
The recent introduction of smaller and more powerful computer
systems and new communications technology and transmission media,
together with the greater involvement of end users in managing
information resources, have increased the potential vulnerability
of Federal information systems and hence the level of management
concern. Protecting personal, proprietary, and other sensitive
data from unauthorized access or misuse; detecting and preventing
computer related fraud and abuse; and assuring continuity of
operations of major information system3 in the event of emergency
related disruptions are increasingly serious policy issues.
Policy previously found in Transmittal Memorandum No, 1 to OMB
Circular No. A-71 is here revised; procedural aspects of the
policy are'in Appendix III to the Circular.
The General Accounting Office reported"in its review of the
first-year implementation of the Federal Managers Financial
Integrity Act (FIA) that internal controls in automatic data
processing. systems received inadequate coverage in FIA
evaluations. GAO noted that some agencies were uncertain of the
relationship between (a) 0MB Circular No. A-71, Transmittal-
Memorandum No. 1, Security of Federal Automated Information
Systems, and (b) 0MB Circular No. A-123, Internal Control
Systems. The relationship between security of automated
information systems and agency internal control reports is now
stated clearly in Appendix III.
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Appendix III provides a,minimal set of, requirements for the
security of all Federal automated information systems. The
Appendix also requires agencies to incorporate additional
requirements for the security of information classified for
national security purposes, in accordance with appropriate
national security directives.
(141). Standards. The National Bureau of Standards,
Department of Commerce, develops and issues Federal Information
Processing Standards. The National Communications System
develops and the General Services Administration issues Federal
Telecommunications Standards. Some standards are mandatory for
Federal agencies, while others are voluntary. Agencies may waive
the use of Federal standards under certain conditions and
pursuant to certain procedures, which vary depending upon the
individual standard. In general, 0MB strongly recommends use of
these standards government-wide. Such standards can contribute
to overall government economy and efficiency by increasing
compatibility in computer and telecommunications networks,
improving the transportability of software, and enabling computer
systems to be developed using components of different
manufacturers. These advantages can result in reduced
procurement costs for equipment and services, improved
competition, and better utilization of staff training and skills.
While government-wide standards can result In management
efficiencies, agencies should be mindful that standards can also
have the untoward effects of regulations, as noted in 0MB
Circular No. A-119. Agencies should continuously assess relative
costs and benefits of standards and their effects upon the
agency's accomplishment of its mission. Note also that national
security directives prescribe standards for computer security.
(15) Avoiding Information Technology Monopolies. Many
agencies operate one or more central information technology
facilities to support agency programs. In these agencies,
program managers are often required to use the central
facilities. The manager of such a monopoly facility has a lesser
incentive to control costs, since he or she has a captive
clientele. The program manager has little leverage to ensure
that information processing resources are efficiently allocated
since he or she cannot seek, or can seek only with great
difficulty, alternative sources of supply. When users are
dependent on effective technology support to perform their
functions, control over selection of facility is essential and
consistent with holding users responsible for producing their
government information products. To provide incentives
conducive to more businesslike procedures in information
technology facilities, agencies should avoid monopolistic
information processing arrangements and should enter into them
only if their cost effectiveness is clear and they are subject to
periodic review. Appendix II specifies certain procedures with
respect to this policy.
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(16) Cost Recovery. This policy constitutes a'revision
to policy stated in OMB,Circular No. A,-121. Whereas Circular No..
A-121 required only-that costs for automatic data processing:
facilities be allocated to users, agencies must now recover the
costs of information technology facilities from government users.
Viable management of a large information technology facility
requires that managers know the amount of resources devoted to
each user when providing services. Furthermore, effective
management of the use of information technology requires that the
user have responsibility for and control over the resources
consumed by use of the facility. Experience with Circular No. A-
121 showed 0MB that allocating costs had little effect on
agencies'~behavior;.recovering.costs means that actual transfers
of funds will take place between suppliers and users of
information technology facilities. Procedural aspects of the
policy appear in Appendix II.
1(17) Coordination with State and Local Governments.
This policy reaffirms policy previously found in 0MB Circular No.-
A790, Transmittal Memorandum No. 1. The interagency group that
worked on the revision of Circular No. A-90 recommended, and 0MB
agreed, that the Circular should be rescinded except for a single
policy statement prohibiting Federal agencies from placing
unnecessary restrictions on the information systems that State
and local governments use to carry out federally financed program
activities.
(18) Application of Up-to-date-Information Technology.
Recent availability of low cost, highly efficient and effective
electronic information technology can greatly increase worker
productivity and facilitate operation of Federal agency programs.
The Circular states a predisposition, based in the Paperwork
Reduction;Aet, in favor of applying such technology to the
information life cycle within a responsible management. context.
Two broad areas of information technology merit further
discussion: (1) electronic information collection and r
dissemination, and (2) end user computing.
Electronic Collection and Dissemination of
Information. Federal agencies are moving rapidly to provide for
collection and dissemination of information through electronic
media. In developing this Circular, 0MB considered whether it
was necessary to provide specific policies concerning electronic
collection and dissemination of governmental information. 0MB
concluded that, except for the general predisposition in~favor of
applying new technological developments to information resources
management, the policies that apply to information collection and
dissemination in other media also apply to electronic collection
and dissemination. It is important, however, that agencies
recognize the necessity of systematically thinking through the
application of policies stated elsewhere in this Circular to
electronic collection and dissemination of information. For
example, when developing electronic.collection'programs, agencies
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should give particular attention to issues such as privacy,
public access, and records management.. When developing
electronic dissemination programs, agencies should ensure that
access is provided to each class of users upon reasonable terms,
avoid problems arising from monopolistic control, ensure maximum
reliance upon the private sector, and take necessary steps for
cost accounting and cost recovery
- End User Computing. Federal agencies are also
moving rapidly to acquire end user computing capabilities. 0MB
endorses the managed innovation approach to end user computing
presented in GSA's publication Managing End User Computing in the
Federal Government (June 1983). Because end user computing
places management of information in the hands of individual
agency personnel rather than in a central automatic data
processing organization, the Circular requires. that agencies
train end users in their responsibilities for safeguarding
information; Appendix III deals in part with the security of end
user computing.
Section 9. Assignment of Responsibilities.
This section assigns responsibilities for the management of
Federal information resources addressed in this Circular. 0MB
Circular No. A-71 is rescinded and its contents are revised and
incorporated into this section along with responsibilities
assigned under the Paperwork Reduction Act; Section 111 of the
Federal Property and Administrative Services Act, as amended; and
Executive Order No. 12046. Certain assignments of responsibility
from 0MB to other agencies,, as noted below, are also included.
Following are principal noteworthy aspects of this section.
Responsibility for Managing Information Resources.
Statement 9a(l) is a key element in the Circular because it
establishes that the locus of responsibility for actual
management of Federal information resources is the head of each
agency. This means, for example, that the determination of what
is "necessary for the proper performance of agency functions"
with respect to information creation or collection (8a(1)) and
information dissemination (8a(9)) lies with the head of the
agency. In the Circular 0MB sets the policy framework within
which such determinations are to be made and the standards. and
provisions for reviewing the determinations, but the management
decisions and their implementation belong properly with the
agency holding the information resources.
Triennial Reviews. The Paperwork Reduction Act provides
that the Director of 0MB ". . .,shall, with the advice and
assistance of the Administrator of General Services, selectively
review, at least once every three years, the information
management activities of each agency to ascertain their adequacy
and efficiency." (44 U.S.C. 3513) The Administrator of
Information and Regulatory Affairs, OMB, and the Deputy
Administrator of the General Services Administration, in an
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exchange of correspondence dated June 13 and July ?2,.1983,
concurred that GSA has the necessary statutory authority to
conduct reviews of Federal agency information resources _
management activities. Separate triennial reviews of agency
activities' by OMB and GSA would; be unnecessarily duplicative,
which would not be consistent with the Act. Accordingly, the
triennial reviews conducted by GSk will be designed to meet OMB's
requirements under the Paperwork Reduction Act as well as GSA's
own needs.
Senior Officials for Information Resources Management. In
accordance with 44 U.S.C. 3506(b) and 5 CFR 1320.8, agencies are
required to designate a senior official to carry out
responsibilities under the Paperwork Reduction Act. The
designation of the official is intended to assure clear
accountability for setting policy for agency information
resources management activities, provide for greater coordination
among the agency's information. activities, and ensure greater
visibility of such activities within the agency. The
responsibilities of the senior official for information resources
management were identified in OMB Bulletin No. 81-21, which has
expired. Those responsibilities are now established in this
Circular.
International Information Policy. The Circular deals with
the management of information resources held by the Federal
government. While the creation, collection, processing,
transmission, dissemination,, use, storage, and disposition of
information by the Federal government has international
ramifications, Federal government information resources
management\,policy is not the same as "U.S. information policy,"
which refers to J.S. national interests in the information field
vis-a-vis the policies and interests of other nations. The
Circular formally acknowledges this distinction and assigns
responsibilities for international information policy only
insofar as-,it relates to Federal government information resources
management policy.
Timely Technology Procurement. Inherent in effective
management of information technology. is the ability of program
managers to acquire technology in a timely manner. GSA is
assigned the responsibility in Section ,9 to develop criteria that
will streamline procurement pOocedures.and delegate procurement
authority to agencies that comply with those procedures. All
Federal agencies are directed in Section 9 to develop internal
policies and procedures that further provide for tim)ly
acquisition of information technology.'
Records Management. The Paperwork Reduction Act makes the
management of Federal records an integral part of information
resources management. While, no new policies are embodied in this
Circular, responsibilities have been assigned in order to ensure
that agency records management programs are considered-within the
context of Federal information resources management.
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Section 10. Oversight.
The broad scope of the Circular dictates a strategy of focusing
oversight on a series of aspects of information resources
management rather than on a single comprehensive reporting
scheme. 0MB intends to use existing mechanisms, such as the
fiscal budget, information collection budget, and management
reviews, to examine agency compliance with the Circular. For
example, during 1984 the management reviews for the FY 1986
budget year concentrated on five cross-cutting information
issues: overall. information resources management strategy,
telecommunications, software management, "electronic filing," and
end user computing. 0MB issued data call bulletins requesting
information specific to these issues, targeted the issues for
special attention during the management reviews, and requested
individual agencies to submit management improvement plans on
specific aspects of the issues. Pursuit of this kind of
selective oversight strategy permits 0MB and the agencies the
flexibility to shift the focus of oversight as information issues
and the technological environment change.
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