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Guide to Privacy, the Freedom of Information Act, and Records Management

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Guide to Privacy, the Freedom of Information Act, and Records Management Summary of Changes Handbook AS-353, Guide to Privacy, the Freedom of Information Act, and Records Management Handbook AS-353, Guide to Privacy, the Freedom of Information Act, and Records Management, has been updated with Postal Bulletin articles through February 6, 2014 as follows: The chapter, subchapter, in Postal part, Bulletin with an appendix, or issue issue date section... titled... was... number... of.... Appendix — Privacy Act System of Records Section E Complete Text of revised to account for the collection of 22382 2-6-14 Systems of Records applicant ID numbers from applicants who file an inquiry or complaint. Guide to Privacy,Transmittal the FreedomLetter of Information Act, and Records Management Handbook AS-353 February 2014 Transmittal Letter A. Introduction. Key strategies of the Postal Service’s Transformation Plan are to achieve growth by adding value for customers and to improve the workplace environment. The proper collection, use, and protection of customer and employee information are key parts of that value proposition. B. Instructions. This handbook replaces the original publication dated September 2005. C. Explanation. This handbook provides direction and guidance for Postal Service™ employees, suppliers, or other authorized users with access to Postal Service records and information resources. The handbook also provides direction and guidance for customers, employees, suppliers, or other individuals about how their information is collected, maintained, used, disclosed, and safeguarded. This version of the handbook includes a completely revised appendix of Privacy Act systems of records, as last published in their entirety in the Federal Register. In addition, chapters 1 through 4 were revised to clarify current procedures. For ease of use, rules involving special categories of records, such as customer names and addresses, were relocated from chapter 4 to a new chapter 5. D. Distribution. This handbook is available online on both the USPS® Intranet (http://blue.usps.gov/cpim/) and the FOIA page at usps.com (http://www.usps.com/foia). E. Comments. Submit questions, comments, or suggestions about this handbook to: MARY ANNE GIBBONS GENERAL COUNSEL AND EXECUTIVE VICE PRESIDENT US POSTAL SERVICE 475 L'ENFANT PLZ SW RM 6004 WASHINGTON DC 20260 PHONE: 202-268-2950 F. Effective Date. This handbook is effective February 2014. Mary Anne Gibbons General Counsel and Executive Vice President Contents 1 Introduction. 1 1-1 Purpose of This Handbook. 1 1-2 Customer Trust and Privacy Protection . 1 1-3 Handbook Application . 1 1-4 Roles and Responsibilities . 2 1-4.1 General Responsibility . 2 1-4.2 Specific Responsibility . 2 1-4.2.1 Officers, Managers, and Employees . 2 1-4.2.2 Suppliers, Business Partners, and Customers. 2 1-4.2.3 Chief FOIA Officer. 2 1-4.2.4 Chief Privacy Officer. 3 1-4.2.5 Manager, Records Office . 3 1-4.2.6 Freedom of Information Act Requester Service Centers . 3 1-4.2.7 Freedom of Information Act Public Liaison . 4 1-4.2.8 Freedom of Information Act Coordinator . 4 1-4.2.9 Records Custodian. 5 1-4.2.10 Manager, Corporate Information Security Office . 5 1-4.2.11 General Counsel . 5 1-4.2.12 Chief Postal Inspector . 5 1-4.2.13 Office of Inspector General . 6 1-5 Definitions . 6 1-5.1 Record. 6 1-5.2 System of Records . 6 1-5.3 Customers. 6 1-5.4 Individual . 6 1-5.5 Legal Hold Notice . 7 1-5.6 Retention Period . 7 2 Laws, Guidelines, and Policies . 9 2-1 The Best of Public and Private Practices . 9 2-2 Mail Protections . 9 2-3 Federal Laws. 9 2-3.1 Postal Reorganization Act. 9 2-3.2 Privacy Act . 9 2-3.3 Freedom of Information Act . 10 2-3.4 E-Government Act of 2002 . 10 2-3.5 Gramm-Leach-Bliley Act. 11 February 2014 iii Guide to Privacy, the Freedom of Information Act, and Records Management 2-3.6 Children’s Online Privacy Protection Act . 11 2-4 Federal Agency Guidelines . 11 2-4.1 Federal Trade Commission Privacy Principles . 11 2-4.2 Office of Management and Budget Privacy Guidelines . 12 2-5 Postal Service Policies . 12 2-5.1 Customer Privacy Policy . 12 2-5.2 Marketing E-mail Policy . 12 2-5.3 Supplier Policy . 13 2-5.4 Monitoring of Postal Service Equipment. 13 3 Privacy Procedures . 15 3-1 General . 15 3-2 Collecting Information from Customers, Employees, or Other Individuals. 15 3-2.1 Collection . 15 3-2.2 Privacy Notice . 15 3-2.3 Customer Choice . 16 3-3 Managing Information Relating to Customers, Employees, or Other Individuals. 17 3-3.1 General . 17 3-3.2 Managing a System of Records . 17 3-3.3 Creating, Amending, or Deleting a System of Records . 18 3-3.4 Privacy Impact Assessment and Security. 19 3-4 Requests by Customers, Employees, or Other Individuals for Information About Themselves . 19 3-4.1 Requests to Access Information . 19 3-4.2 Requests to Amend Information . 23 3-4.3 Appeals and Customer Redress . 25 3-4.4 Fees. 25 3-5 Disclosing Customer, Employee, or Other Individuals’ Information to Third Parties . 25 3-5.1 General . 25 3-5.2 Internal.
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