WhiteHouse.gov Privacy Impact Assessment for Use of Third-Party Websites and Applications
1. OVERVIEW & PURPOSE
The White House has official pages or accounts on a variety of popular social network and media sites and applications to share content and engage with the American public. Third parties design and operate these sites (“third-party sites”), and the White House is one of many users on these sites. Additionally, the White House uses applications and tools provided by third-parties on WhiteHouse.gov (“third-party tools”) to share content and engage with the American public. Consistent with the policy articulated in OMB Memorandum M-10-23, this Privacy Impact Assessment (PIA) analyzes the White House’s use of third-party sites and tools and how this use could result in personally identifiable information (PII) becoming available to the White House. Appendix A of this PIA will serve as a listing, to be updated periodically, of third-party sites and tools used by the White House.
The White House uses a variety of third-party sites and tools, which fall into a few general categories:
- Social networks — Sites where users may create their own pages, share their own content, and access content and applications created and shared by other uses on the site. These sites include, but are not limited to, Facebook, MySpace, LinkedIn, Twitter, and Digg.
- Video, image, and document sharing platforms — Sites where users may upload images, videos, and other content to share with the general public, who can view the content without having an account. These sites may require an account for users to comment on images or video. These sites include, but are not limited to, YouTube, Flickr, Vimeo, Hulu, Ustream, Socrata, and SlideShare.
- Submission and rating applications — Sites and applications that allow users to solicit content from the general public or user community, and empower the general public or user community to rate content submitted by other users. This includes, but is not limited to IdeaScale.
We will revise or update this privacy impact assessment if our practices change, if new risks to privacy develop, or as we develop better ways to keep you informed. If we decide to change this assessment, we will post a new assessment on our site and change the date at the bottom. Changes to the policy shall not apply retroactively.
2. INFORMATION MADE AVAILABLE TO THE WHITE HOUSE THROUGH THIRD-PARTY SITES AND TOOLS
2.1 What information is made available to the White House?
The information made available to the White House depends on how users of third-party sites interact with official White House pages on those sites or use third-party tools on WhiteHouse.gov. If users visit a White House page on a third-party site to examine the content on that page and do not otherwise interact with the page (e.g., post comments, submit messages, “friend” or “follow” the White House), no PII about the user will be made available to the White House. If users “follow,” “friend,” or take a similar action with respect to the official White House page on a third-party site, the fact that the user made that selection will often be publicly available, depending on the policies of the third-party site. The White House does not record or search for which users “follow,” “friend,” or take similar actions with respect to its official pages. Whenever possible, the White House elects not to have non-public information made available to it. To our knowledge, none of third-party sites used by the White House make non-public information available to the White House based upon a user’s “following,” “friending,” or taking similar action with respect to the White House. If you become aware of a third-party site used by the White House that makes non-public information available to the White House, please contact us at [link to privacy contact form]. If users interact with a White House page or interact with a third-party tool on WhiteHouse.gov — for example by participating in a discussion or live chat, leaving a comment, or submitting an idea to be rated — the content published by the user will be made available to the White House (and often the general public). In addition to whatever information the user chooses to publish, the user’s account name or similar identifying information will often be made available to the White House and the public.
2.2 What are the sources of information that could be made available to the White House?
The information on these sites that could be made available to the White House is voluntarily published or submitted by users and almost always is available to the general public or the user community for the site. It may contain PII if users choose to publish that information. Some third-party sites or tools may collect PII during the registration process, but the White House does not solicit or collect this information. With the exception of Twitter and Digg, where official White House accounts may “follow” other accounts to more easily view the publicly available information they are publishing, the White House does not “friend” or take a similar action with respect to individual accounts, except for those controlled by other units of the federal government.
2.3 Do individuals have the opportunity and/or right to decline to provide information?
Participating in these third-party sites and utilizing third-party tools is voluntary. If a member of the public wishes to communicate without using a third-party site or tool, there will often be a dedicated point of submission on whitehouse.gov or the Contact form is also available when there is not a specific point of submission. The White House does not require users to submit PII through a third-party site or tool to obtain services, information, or assistance from the White House.
3. INTENDED USE OF INFORMATION
3.1 Describe how information in the system will or may be used.
The White House uses third-party sites or tools to publish content in a way that is easy to discover and share, as well as to engage the American public to understand their questions, views, and ideas. These uses will generally not implicate PII published or submitted by users, except for the username, first name, and/or location of the user. The White House generally does not use third-party sites or tools to receive or respond to requests for individually-tailored government assistance or actions, such as responding to questions about specific grant applications or individual benefits.
3.2 How will individuals be informed about how information will be used?
4. RETENTION OF INFORMATION
4.1 For what information will be retained by the White House?
The White House maintains some information that users publish when engaging with the White House on official White House pages. The White House maintains this information to comply with the Presidential Records Act. This information may contain PII, such as an individual’s username and any PII they elect to publish. The White House does not record any PII about users who merely visit a White House page on a third-party site or who only “follow,” “friend,” or take a similar action with respect to the official White House page on a third-party site — PII may only be recorded when it is voluntarily submitted to or published on the White House page on a third-party site.
4.2 What are the plans for the retention or disposal of the information?
This information will likely be retained by the White House until the end of the current Administration, at which time it will be transferred to the National Archives and Records Administration (NARA) in accordance with the Presidential Records Act (PRA). NARA may eventually release this material to the public, but is required, in accordance with the PRA and the Freedom of Information Act (FOIA), to withhold any information that would constitute a clearly unwarranted invasion of personal privacy if released. NARA may also dispose of this information if it determines it to lack value, in accordance with the PRA; the White House may also dispose of it on the same grounds after notifying NARA in accordance with the PRA. Access to this information may be requested under the Freedom of Information Act five years after the end of the current Administration.
5. SHARING OF INFORMATION
5.1 Which external entities will have access to the information?
The information at issue is almost always publicly available on the third-party sites. For that reasons, users should not publish PII they are uncomfortable sharing broadly, and should never publish sensitive PII such as social security numbers, or financial and health information. The White House will never solicit this kind of sensitive PII through a third-party site.
Information you voluntarily publish or submit to the White House on third-party sites, such as your name and comments on public issues, may be treated as public information. The White House may, for example, publish compilations of comments collected through official White House pages on third-party sites or provide them to national leaders, members of the press or other individuals outside of the federal government. We exercise discretion to protect voluntarily submitted information if its disclosure would raise privacy concerns. Except as described above, we do not sell, rent, exchange, or otherwise disclose this information to persons or organizations outside the Executive Office of the President. In some cases, we may share information with other federal agencies in response to lawful law enforcement requests or to protect WhiteHouse.gov from security threats. Additionally, if you seek assistance on a matter within the jurisdiction of a federal agency, we may share your information with that agency for the limited purpose of addressing your request for assistance. Additionally, archived information may be transferred to NARA at the conclusion of an Administration.
6. SECURITY OF INFORMATION
6.1 How is access to the information maintained by the White House secured?
We take reasonable precautions to protect our site and information automatically collected by WhiteHouse.gov or voluntarily submitted to WhiteHouse.gov or an official White House page on a third-party site. For example, we restrict access to information collected by or submitted to WhiteHouse.gov or official White House pages of on third-party sites to employees who access it to perform their official duties. Access to official White House accounts on third-party sites is limited to the staff who administer those accounts, and all official White House accounts are clearly labeled. We also utilize commonly used practices and technical controls to protect this information, along with WhiteHouse.gov itself. These practices and controls include, but are not limited to, encrypting the transfer of personal information over the Internet via Secure Sockets Layer (SSL), using high-strength firewalls and intrusion detection systems (IDS) to safeguard personal information and maintaining strict technical controls and procedures to ensure the integrity of all data on WhiteHouse.gov. We periodically review our processes and systems to verify compliance with industry best practices and ensure the highest level of security for our website.
7. ADDITIONAL PRIVACY RISKS
The use of third-party sites and tools will almost always present certain risks that users should take into account before deciding to use a particular site or tool. By their very nature, online tools such as social networks and sharing platforms are designed to give users the option to share personal information in ways that enrich the user’s experience. While the White House takes appropriate steps to protect individual privacy, many of the risks will depend on how users decide to use the sites and tools.
Consequently, individuals should review the privacy policies of these third-party sites before using them and ensure that they understand how their information is being used. Individuals should also adjust privacy settings on their account on third-party sites to match their preferences. If you have questions, suggestions, or comments relating to this Privacy Impact Assessment, please contact us.
APPENDIX A: Third Party sites with official White House presences; read our blog post explaining these sites.
- Facebook (Privacy)
- MySpace (Privacy)
- LinkedIn: (Privacy)
- Digg: (Privacy)
- GitHub: (Privacy)
- Foursquare: (Privacy)
- Google+: (Privacy)
- iHispano.com: (Privacy)
- AMightRiver.com: (Privacy)
- Quora: (Privacy)
- SoundCloud: (Privacy)
- Thunderclap: (Privacy)
- Tumblr: (Privacy)
Video & Multimedia
- YouTube (Privacy)
- Vimeo (Privacy)
- Hulu (Privacy)
- Flickr: (Privacy)
- iTunes: (Privacy)
- UStream: (Privacy)
- Pinterest: (Privacy)
- Vine: (Privacy)
- Instagram: (Privacy)