The Fair Information Practice Principles (FIPPs) are a collection of widely accepted principles that agencies should use when evaluating information systems, processes, programs, and activities that affect individual privacy. The FIPPs are not OMB requirements; rather, they are principles that should be applied by each agency according to the agency’s particular mission and privacy program requirements.

Rooted in a 1973 Federal Government report from the Department of Health, Education, and Welfare Advisory Committee, “Records, Computers and the Rights of Citizens,” the FIPPs have informed Federal statute and the laws of many U.S. states and foreign nations, and have been incorporated in the policies of many organizations around the world. The precise expression of the FIPPs has varied over time and in different contexts.

However, the FIPPs retain a consistent set of core principles that are broadly relevant to agencies’ information management practices.

For purposes of this Agency, the FIPPs are as follows:

a. Access and Amendment:

HUD should provide individuals with appropriate access to their own PII and the opportunity to correct or amend that PII.

b. Accountability:

HUD should be accountable for complying with these principles and applicable privacy requirements, and should appropriately monitor, audit, and document compliance. HUD should also clearly define the roles and responsibilities with respect to PII for all employees and contractors and should provide appropriate training to all employees and contractors who have access to PII. The Privacy Office is responsible for ensuring privacy awareness training is provided to all contractor and third party personnel as well as ensuring role-based privacy training is provided to all personnel with privacy responsibilities.

c. Authority:

HUD should only create, collect, use, process, store, maintain, disseminate, or disclose PII if they have authority to do so, and should identify this authority in the appropriate documentation.

d. Minimization:

HUD should only create, collect, use, process, store, maintain, disseminate, or disclose PII that is directly relevant and necessary to accomplish a legally authorized purpose, and should only maintain PII for as long as is necessary to accomplish the purpose. Where feasible and within the limits of technology, HUD should locate and remove/redact specified PII and/or use anonymization and de-identification techniques to permit use of the retained information while reducing its sensitivity and reducing the risk resulting from disclosure. HUD’s Privacy Office maintains an inventory of PII holdings and uses the privacy impact assessment (PIA) and SORN processes to identify methods to further reduce the data the Department collects and to ensure, to the maximum extent practicable, that such holdings are accurate, relevant, timely, and complete. Records containing PII must be maintained in accordance with National Archives and Records Administration (NARA) and HUD-approved retention, disposition, and destruction schedules to further support the goals of privacy and security.

HUD should not collect Social Security Numbers (SSNs) unless it is both necessary and authorized. Any forms used to collect SSNs should include a Social Security Number Justification Memo explaining why collection of SSNs is necessary and which authorities permit the collection. See Section 2.2.5 of this Handbook for further details.

e. Quality and Integrity:

HUD should create, collect, use, process, store, maintain, disseminate, or disclose PII with such accuracy, relevance, timeliness, and completeness as is reasonably necessary to ensure fairness to the individual.

f. Individual participation:

HUD should involve the individual in the process of using PII and, to the extent practicable, seek individual consent for the creation, collection, use, processing, storage, maintenance, dissemination, or disclosure of PII. HUD should also establish and maintain procedures to receive and address individuals’ privacy-related complaints and inquiries.

g. Purpose Specification and Use Limitation:

HUD should provide notice of the specific purpose for which PII is collected and should only use, process, store, maintain, disseminate, or disclose PII for a purpose that is explained in the notice and is compatible with the purpose for which the PII was collected, or that is otherwise legally authorized.

h. Security:

HUD should establish administrative, technical, and physical safeguards to protect PII commensurate with the risk and magnitude of the harm that would result from its unauthorized access, use, modification, loss, destruction, dissemination, or disclosure.

i. Transparency:

HUD should be transparent about information policies and practices with respect to PII, and should provide clear and accessible notice regarding creation, collection, use, processing, storage, maintenance, dissemination, and disclosure of PII.

j. Federal Record Rights:

In accordance with Federal requirements, HUD should provide notice describing the individual data subject’s rights in relation to personal data as follows:

• The individual data subject has access to the personal data held by HUD about them.
• The individual data subject can correct a record that is inaccurate, irrelevant, or incomplete. Additionally, HUD should provide public access to information and instructions regarding the process and contacts for making a request to correct any record pertaining to the individual. See 4.0 of this Handbook for further guidance regarding Privacy Act requests.

k. System of Records Notice:

A System of Records is a group of any records under the control of any agency from which information is retrieved by the name of the individual or by some identifying number, symbol, or other identifier assigned to the individual. HUD adheres to the Privacy Act requirements for publishing notices of its systems of records in the Federal Register, which are referred to as SORNs. Each SORN describes what, why, and how HUD collects, maintains, uses, and disseminates records in the system. Some systems maintain information on HUD employees while others maintain information from or about individuals outside of HUD. There are also Government-wide systems that are maintained by other Federal agencies and hold the operating authority over the records such as the Office of Personnel Management's (OPM) Employee Performance File system.

l. Privacy Impact Assessments:

A Privacy Impact Assessment (PIA) is an analysis of how information in identifiable form is collected, maintained, stored, and disseminated, in addition to examining and evaluating the privacy risks and the protections and processes for handling information to mitigate those privacy risks. A PIA is required for each HUD information system, General Support System (GSS), or electronic collection that collects, maintains, uses, and/or disseminates PII about US citizens, Federal employees, and HUD contractors. In the case where no PII is collected, the PIA will serve as a conclusive determination that privacy requirements do not apply to the system.

¹ Rooted in the United States Department of Health, Education and Welfare's seminal 1973 report, "Records, Computers and the Rights of Citizens" (1973), these principles are at the core of the Privacy Act of 1974 and are mirrored in the laws of many U S states, as well as in those of many foreign nations and international organizations. A number of private and not-for-profit organizations have also incorporated these principles into their privacy policies. See also guidance at https://www.dhs.gov/xlibrary/assets/privacy/privacy_policyguide_2008-01.pdf.