ICP Training - July 23, 2009. What USDA Information is PII? Core PII, Verification PII
1. USDA PII (Personally Identifiable Information) Indiana Conservation Partnership (ICP)
Webinar Training – July 23, 2009
2. ICP Training - July 23, 2009 What USDA Information is PII? Core PII, Verification PII & Privacy-Protected Data Tax ID Numbers
ID Number’s Last 4
Name connected with PII
Mother’s maiden Name
Tract #, or Farm #
DCP Base Acres
Operatorship of a specific farm/tract
Specific crop acres
Actual Crop production
Any information that reveals wealth/poverty, or operation success/failure
3. ICP Training - July 23, 2009 What is NOT considered PII? Names and address of program participants
(FSA will furnish its entire county N & A lists through Kansas City)
Amounts that program participants were paid
Any information not protected by FOIA Exemptions 1-9, or Section 1619
4. ICP Training - July 23, 2009 Policy for Sharing USDA Data with Conservation Partners USDA allows sharing of PII information with any of the following:
Any USDA agency personnel
Other entity personnel that have signed a confidentiality agreement with USDA and are contracted to do work for USDA (i.e. SWCD employees).
5. ICP Training - July 23, 2009 What USDA Data Can Be Accessed? Personnel authorized to access USDA PII information have access to anything in the USDA files necessary for them to complete the work they have been contracted to do for USDA.
If information is NOT required for USDA contracted work, then it should not be accessed.
6. ICP Training - July 23, 2009 Example: SWCD Technician working on USDA conservation practice may access anything needed to perform the planning/installation of the practice.
SWCD Technician MAY NOT access USDA data to assist a producer applying for a 319 grant.
7. ICP Training - July 23, 2009 What about Conservation Partners that have not signed USDA Confidentiality Agreements? Through state law (I.C. § 5-14-3-2(a)(b)) State Agencies must protect records that are required to be kept confidential under Federal law.
8. ICP Training - July 23, 2009 SWCD Board Meetings To comply with federal and state law, SWCD Boards must not disclose USDA protected data through their board meeting minutes. Options:
Adjourn to executive session to discuss USDA PII information (i.e. CRP Conservation Plans)
Redact PII data from regular session minutes
9. ICP Training - July 23, 2009 Consent to Disclose to a Third Party Provisions allow a written consent for USDA to disclose information contained in a system of records to a designated third party. (Consent to Disclose)