2025-04894NoticeWallet

Bank Tracks Staff Secrets: Privacy Act Yawns Alive

Published Date: 3/21/2025

Notice

Summary

The Export-Import Bank is launching a new system to keep track of employee security info, like background checks and clearances, starting March 21, 2025. This affects anyone working or volunteering with EXIM who needs access to sensitive info or facilities. You can comment on this new system within 30 days, but no extra costs are expected.

Analyzed Economic Effects

5 provisions identified: 2 benefits, 3 costs, 0 mixed.

New system will store lots of sensitive personal data

EXIM is launching a new personnel security records system called EXIM PERSEC IQ that will store extensive personal information about applicants and staff, including full name, Social Security number, birth date and place, employment and education history, criminal history, mental health history, drug-use history, financial information, fingerprints, and security-clearance details. The notice says this system will be used to document suitability, background investigations, clearances, and security violations.

Records can be shared broadly with other agencies and parties

EXIM's notice says records in EXIM PERSEC IQ may be disclosed under routine uses to entities such as the Department of Justice, courts and adjudicative bodies, other Federal, State, local, tribal, foreign agencies, contractors performing work for EXIM, the news media (factual information), and intelligence or law‑enforcement partners, as well as for breach response. These routine uses are described in the system notice.

Who is covered: broad set of workers and applicants

The system will cover a wide group: applicants for employment or contracts, Federal employees, temporary hires, contractors, students, interns (paid and unpaid), volunteers, affiliates, individuals performing services in EXIM facilities (e.g., building security, office cleaning, building contractors), former individuals in these positions, and people accused or found in security violations. Retrieval of records requires an individual name or Social Security number.

Security-clearance records retention limited to 5 years

The notice says records created to support favorable eligibility determinations, periodic reinvestigations, or continuous evaluation for security clearances will be destroyed 5 years after the employee or contractor relationship ends, although records may be kept longer if required for business use. Records are otherwise retained and disposed of under NARA schedules (General Records Schedule 5.6 items: 180, 181).

Records stored in FedRAMP cloud with encryption and access controls

EXIM PERSEC IQ will be hosted in a FedRAMP-authorized environment (primary: Equinix colocation in Ashburn, VA; alternate: Amazon AWS US-West-2 FedRAMP) and EXIM states PII will be encrypted at rest and in transit using AWS services (RDS, KMS, TLS/HTTPS). Access is limited by role-based accounts, Single Sign-On, and Personal Identity Verification (PIV) cards, and the system maintains audit trails.

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Key Dates

Published Date
3/21/2025

Department and Agencies

Department
Independent Agency
Agency
Export-Import Bank
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