PIA - Online Voluntary Leave Transfer Program/Emergency Leave Transfer Program (OVLTP/ELTP)

DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration

PRIVACY IMPACT ASSESSMENT

Online Voluntary Leave Transfer Program /Emergency Leave Transfer Program (OVLTP/ELTP)

August 8, 2010

Overview of the OVLTP/ELTP

The Federal Aviation Act of 1958 gives the Federal Aviation Administration (FAA) the responsibility to carry out safety programs to ensure the safest, most efficient aerospace system in the world. The FAA is responsible for:

• Regulating civil aviation to promote safety;
• Encouraging and developing civil aeronautics, including new aviation technology;
• Developing and operating a system of air traffic control and navigation for both civil and military aircraft;
• Developing and carrying out programs to control aircraft noise and other environmental effects of civil aviation; and
• Regulating United States (U.S.) commercial space transportation.

One of the programs that helps the FAA fulfill these responsibilities is the Online voluntary leave Transfer Program/Emergency Leave Transfer Program (OVLTP/ELTP), which provides an online procedure by which employees with adequate sick leave balances may donate some of their annual leave hours to qualified employees who have inadequate or depleted sick leave balances and must remain out of the office for medical reasons. Also, the ELTP provides help to current FAA employees adversely affected under: (a) Operation Enduring Freedom, or (b) Operation Noble Eagle, or (c) an emerging disaster that was a result of the September 11, 2001 terrorist actions to an employee who has a family member who was directly affected.

This system only processes electronic FAA-to-FAA leave balance transfers. Paper-based transfers and transfers to or from non-FAA personnel are not processed through this system.  

Information, Including Personally Identifiable Information, in OVLTP/ELTP

The OVLTP/ELTP system contains both personally identifiable information (PII) and non-PII of FAA employees who have been approved to accept leave donations under the Voluntary Leave Transfer Program (leave recipients), and FAA employees who have volunteered to transfer available leave to FAA employees who are eligible for such donations (leave donors).

Information collected in the OVLTP/ELTP system about leave recipients includes:

• Full name
• Social Security Number
• Email address
• Alternate contacts Name, Phone, Email address, and Relationship
• Brief description of medical condition(s) and medical contact information
• Leave balance and other limited payroll information

Information collected in the OVLTP/ELTP system about leave donors includes:

• Full name
• Social Security Number
• Email address
• Leave balance and other limited payroll information

The PII is entered into the OVLTP/ELTP system electronically through a data entry screen that is accessed through the FAA's Intranet's Employee website.

Why OVLTP/ELTP Collects PII Information

The OVLTP/ELTP is an FAA-internal system used to administer the FAA's electronic Leave Transfer Program. The FAA's participation in the program is mandated by 5 U.S.C. 6331-6340; 5 CFR part 630, subpart I, but participation by leave recipients and donors is voluntary.

OVLTP was established to help ease the financial burdens of FAA employees who have exhausted their available paid leave and have a personal or family member with a medical emergency that will require that FAA employee to take a length of leave outside of their available leave balance. The leave recipients are employees absent from duty for prolonged periods due to a certified medical condition that causes a substantial loss of income. This program allows FAA employees to voluntarily donate annual leave or sick leave to approved leave recipients.

The Emergency Leave Transfer Program (ELTP) was established to help current FAA employees who were adversely affected under: (a) Operation Enduring Freedom, (b) Operation Noble Eagle, or (c) an emerging disaster affecting a family member that was a result of the September 11, 2001 terrorist actions. This program allows employees to voluntarily donate accrued annual or sick leave to ELTP leave recipients.

Input into the OVLTP/ELTP system is a voluntary alternative to paper-based processes that are used under the pre-existing Voluntary Leave Transfer Program (VLTP) and Emergency Leave Transfer Program (ELTP).

Note: An MOU is in place for the personnel data (names, leave balance etc.) that serves as the basis for the OVLTP/ELTP system between the AWALAN and the DOT=>IR.  

Legal Authority for Information Collection

49 U.S.C. 322. 5 U.S.C. 5101, et seq.; 31 U.S.C. 3512. Executive Orders 12107, 12196, and 12564 and 5 U.S.C. chapters 11, 31, 33, 43, 61, 63, and 83.

How OVLTP/ELTP Uses Information

The OVLTP/ELTP system receives feeds from the DOT IR system, which contains the total available leave time associated with each FAA employee.

A prospective leave donor is able to look up his or her own Annual and/or Sick leave balances within the OVLTP/ELTP system as this data is present in the system due to the feed from the DOT IR system. This information assists the employee in validating his or her own up-to-date leave balances in preparation to make a donation to any FAA employee that is an approved recipient.

For a person to be included in the system as a leave recipient, the individual must first submit their request-related data into the system. After that data has been entered, the system generates an email to the manager of the potential leave recipient requesting review and approval. If the manager approves the request, the request is then passed onto HR staff for review and approval. If HR approves the request, the leave recipient will be added into the system as a formal leave recipient.

When a leave donor completes an online transaction, he or she is able to see the full list of eligible FAA leave recipients, broken down by FAA regional offices. The leave donor is able to see the individual's full name and the requested leave time. The leave donor is then able to select who he or she would like to donate to. When the leave donor submits their donor request, the request must then be approved by the donor's supervisor and HR. If the donor's request is approved by the donor's manager and HR, the payroll liaisons will receive notification that a pending donation request is outstanding. At that time, the payroll liaisons are able to view the details of the request and the request can be processed. The amount of donated leave, as well as identifying information for the donor and recipient, is displayed electronically to payroll liaisons who accomplish the transfer within the external payroll system, FPPS.

The use of a SSN for both donors and recipients is currently necessary for the proper payroll action of increasing and decreasing employees leave balances within the DOI/FPPS system, resulting in an accurate Leave and Earnings Statements posting to Employee Express by the DOI/FPPS system. Due to the fact that the system encrypts SSNs, using the system to process leave donations reduces the risk of unauthorized disclosures of SSNs by eliminating the need for personnel to manually deliver paper forms containing SSNs.  

How OVLTP/ELTP Shares Information

The PII and the medical information contained in OVLTP/ELTP is shared with the supervisor of the leave recipients, the pertinent leave coordinators in HR, and with the payroll liaisons. Donors do not systematically receive an overview of the circumstances behind the requests.

Payroll liaisons receive notice when leave request are approved, and can view the details of the request. For the leave recipient, these details include the person's full name, SSN, and their available leave time. For the leave donor, this data includes the person's full name, SSN, their available leave time, and the amount of time he or she is donating. Payroll liaisons then use the SSNs and full names of both parties to manually transfer the donation within FPPS, the external payroll system.

Other than the manual adjustments made to leave time by the payroll liaison, no other data is shared downstream from OVLTP/ELTP.

Note: An MOU is in place for the personnel data (names, leave balance etc.) that serves as the basis for the OVLTP/ELTP system between the AWALAN and the DOT IR.  

How OVLTP/ELTP Provides Notice and Consent 1

Prior to an employee entering a request to either receive or donate leave, the individual passes through screens that explain the system's purpose and the fact that the program is voluntary. To receive a user ID and password to use the OVLTP/ELTP system, either to request or donate leave, the employee must first conscientiously apply for and receive a user ID and password, and then negotiate through the initial logon screen that included the application's rules of behavior.

By requesting a user ID, the employee consents to the use of his or her data for the primary purpose of participating in the FAA's electronic leave donation program. There is no secondary use for the data collected through this system.

The user is also told that the OVLTP/ELTP system is voluntary, but if he/she does not want to use the online system, there is a paper-based process available that may be used to accomplish donations. If the individual is also not comfortable with that process, they can simply not participate in the program.  

How OVLTP/ELTP Ensures Data Accuracy

The OVLTP/ELTP downloads the pertinent name and leave balance information for leave recipients and donors directly from the FPPS-based personnel and payroll tables located on the DOT IR system. If that data is incorrect, it must be adjusted upstream in DOT IR.

The OVLTP/ELTP program makes internal calculations to ensure that donor applicants cannot donate more leave than they have, or than they can legally donate, given their own leave balances. Requests for assistance in cases of medical need are accompanied by medical contact information that supervisors may use to verify circumstances. Additionally, HR must actively review each request and donation before approval can be granted.

Under the provisions of the Privacy Act, individuals may request searches of the OVLTP/ELTP file to determine if any records have been added that may pertain to them.  

How OVLTP/ELTP Provides Redress

Under the provisions of the Privacy Act, individuals may request searches of the OVLTP/ELTP system to determine if any records have been added that may pertain to them.

Notification procedure: Individuals wishing to know if their records appear in this system may inquire in person or in writing to the appropriate system manager. Included in the request must be the following:

• Name,
• Mailing address,
• Phone number or email address
• A description of the records sought, and if possible, the location of the records.

Contesting record procedures: Individuals wanting to contest information about themselves that is contained in this system should make their requests in writing, detailing the reasons for why the records should be corrected. Requests should be submitted to the attention of the FAA official responsible for the record at the address appearing in this notice.

Federal Aviation Administration
Privacy Office
800 Independence Ave. SW
Washington DC, 20591

For questions relating to privacy go to the FAA Privacy Policy: http://www.faa.gov/privacy/.  

How OVLTP/ELTP Secures PII Information

OVLTP/ELTP takes appropriate security measures to safeguard PII and other sensitive data. Medical information fields and SSN fields are encrypted in the database, and an FAA Order 1370.92 compliant password is required to access the system.

In addition, OVLTP/ELTP limits access to PII according to job function.  

How Long OVLTP/ELTP Retains PII

Data in OVLTP/ELTP is currently maintained under GRS 1, Item 37. All donation-related data is purged one year after the case closes.  

OVLTP/ELTP System of Records Notice (SORN)

OVLTP/ELTP is a system of records subject to the Privacy Act as it is searched by Name and SSN. The SORNs applicable to OVLTP/ELTP are as follows:

• DOT 11, Integrated Personnel and Payroll Systems, IPPS
• DOT 19, Federal Personnel and Payroll Systems (FPPS)
• OPM GOVT 10, Employee Medical File System Records

1-   According to the Privacy Act of 1974, 5 U.S.C. 552a(b), "No agency shall disclose any record which is contained in a system of records by any means of communication to any person, or to another agency, except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains [subject to 12 exceptions listed under subsection (b)(112)]."