Antitrust Division
Privacy Impact Assessment
for the
ATR iManage Document Management System-Cloud (ATR IDMS-C)
Issued by:
Sarah Oldfield
Senior Component Official for Privacy
Approved by:
Date approved:
Katherine M. Harman-Stokes
Director (Acting), Office of Privacy and Civil Liberties
U.S. Department of Justice
February 29, 2024
(May 2022 DOJ PIA Template)
Department of Justice Privacy Impact Assessment
Antitrust Division/iManage Document Management System-Cloud
Points of Contact and Signatures
COMPONENT PRIVACY POINT OF
PIA AUTHOR (if different from POC)
CONTACT (POC)
Name
: Sherod Emerson
Name: Sarah Oldfield
Office: Information System Security Officer, CSS
Office: Deputy Chief Legal Advisor, OCLA
Phone: 240-565-5807
Phone: 202-305-8915
Bldg./Room Number: LSB
Bldg./Room Number: RFK/3304
Email: sherod.emerson2@usdoj.gov
Email: sarah.oldfield@usdoj.gov
SECURITY REVIEW OFFICIAL (Component
CIO/OBD Executive Officer/OCIO Staff
Director/JMD Staff Director)
Name:
Kobie Crawl
Office:
Director of Technology and CIO,
Technology Directorate
Phone:
202-227-1017
Bldg./Room Number:
LSB/3622
Email:
kobie.craw[email protected]
Digitally signed by KOBIE
KOBIE
CRAWL
Date: 2024.04.08
CRAWL
Signature:
_______________________________
08:56:49 -04'00'
SENIOR COMPONENT OFFICIAL FOR
PRIVACY
(if designated; otherwise POC)
Name:
Sarah Oldfield
Office:
Deputy Chief Legal Advisor, OCLA
Phone:
202-305-8915
Bldg./Room Number:
RFK/3304
Email:
sarah.old[email protected]
Digitally signed by
Signature:
SARAH
SARAH OLDFIELD
Date: 2024.04.08
__________________________________
OLDFIELD
12:10:31 -04'00'
Date signed:
________________________________
Date signed: _____________________________
DOJ PIA APPROVING OFFICIAL
Katherine M. Harman-Stokes
Director (Acting)
Office of Privacy and Civil Liberties
U.S. Department of Justice
(202) 616-5485
Signature: _______________________________
Digitally signed by KATHERINE
HARMAN-STOKES
KATHERINE
HARMAN-STOKES
Date: 2024.04.01 13:08:52 -04'00'
Date signed: _______________________________
THIS PAGE IS FOR INTERNAL ROUTING PURPOSES AND DOCUMENTATION OF
APPROVALS. UPON FINAL APPROVAL, COMPONENTS SHOULD REMOVE THIS PAGE
PRIOR TO PUBLICATION OF THE PIA.
Department of Justice Privacy Impact Assessment
Antitrust Division/iManage Document Management System-Cloud
Page 1
[This PIA should be completed in accordance with the DOJ Privacy Impact Assessments Official Guidance
(and any supplemental guidance) at https://www.justice.gov/opcl/file/631431/download.] The following
questions are intended to define the scope of the information in the information technology, specifically the
nature of the information and the sources from which it is obtained. The responses should be written in plain
language and should be as comprehensive as necessary to describe the information technology.]
Section 1: Executive Summary
Provide a high-level overview of the information technology (e.g., application, tool, automated
process) in non-technical terms that describes the information technology, its purpose, how the
information technology operates to achieve that purpose, the general types of information involved,
how information may be used and shared, and why a Privacy Impact Assessment was conducted.
(Note: this section is an overview; the questions below elicit more detail.)
The Antitrust Division (ATR) uses the iManage Document Management System-Cloud (IDMS-C)
(Infrastructure as a Service) as a virtual librarian to file, manage, and securely access ATR documents.
ATR currently has over 4 million documents in iManage that can be searched and cataloged. These
documents comprise, but are not limited to, investigative files, litigation and court materials, internal
personnel files, records, and other administrative data.
Once a document is entered into IDMS-C, it is indexed and searchable by content as well as metadata.
Additionally, IDMS-C tracks data about the documents, such as creation, modification, and whether a
document is “checked-out.” Security measures are also applied when files are saved to ensure
document integrity and availability. IDMS-C is a non-public system, with access limited to Division
personnel.
This Privacy Impact Assessment (PIA) was prepared because IDMS-C contains information in
identifiable form relating to DOJ personnel and members of the public. As required by Section 208 of
the E-Government Act of 2002, this PIA explains how such data is stored, managed, and shared, in
accordance with Federal privacy and information protection guidelines.
Section 2: Purpose and Use of the Information Technology
2.1 Explain in more detail than above the purpose of the information technology, why the
information is being collected, maintained, or disseminated, and how the information will
help achieve the Component’s purpose, for example, for criminal or civil law enforcement
purposes, intelligence activities, and administrative matters, to conduct analyses to identify
previously unknown areas of concern or patterns.
ATR IDMS-C operates as a subsystem within ATR’s Cloud Computing Environment’s
(ATR CCE) network boundary. ATR IDMS-C stores information in support of ATR’s
mission to enforce antitrust laws. It enables users to combine emails, office files, and case
documents into project files for matter-centric collaboration to assist ATR in more
effectively managing and controlling data and documents.
All authorized ATR personnel are provided initial accounts and ATR IDMS-C-specific
Department of Justice Privacy Impact Assessment
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training upon onboarding. The primary users of ATR IDMS-C are ATR attorneys and
paralegals, who use the database to store, manage, and manipulate documents collected and
generated by ATR personnel in connection with investigations and cases. Other users
include ATR office support personnel such as Human Resources (HR), Acquisitions
Management Section, and Budget and Fiscal Section personnel, who use the application to
manage and store day-to-day office management, accounting, and personnel files. Once
users establish files and folders, they have the ability to grant or deny other users access to
those controlled files.
Data in ATR IDMS-C, which may include investigative files, litigation and court materials,
internal personnel files, records, and other administrative data, is kept in the form of general
records, emails, memos, and other documents. Because ATR IDMS-C is not the primary
information system in which ATR stores documents obtained in or relating to an
investigation or litigation, certain documents are stored only as copies rather than original
documents within the system.
ATR IDMS-C processes and stores a variety of personally identifiable information (PII). For
example, documents from investigative and case files may contain PII about members of the
public, such as personal contact information or date of birth. Documents in ATR IDMS-C
may also contain medical or health information, or tax identification numbers, if relevant to a
particular matter. Documents maintained by ATR human resources personnel, such as
applicant and personnel records, contain the standard PII necessary for human resources
administration, including dates of birth, social security numbers, personal contact
information, employment history, salary and benefit information, and performance ratings.
ATR uses the FileSite version (Full client installation on the workstation), which is
accessible to all ATR personnel. ATR IDMS-C is managed and supported by the Litigation
Support Section (LSS) and the Engineering and Operations Section (EOS) within ATR’s
Executive Office.
2.2 Indicate the legal authorities, policies, or agreements that authorize collection of the
information. (Check all that apply and include citations/references.)
Authority
Citation/Reference
Statute
Executive Order
Federal regulation
Agreement, memorandum of
understanding, or other documented
arrangement
Other (summarize and provide copy
of relevant portion)
Section 3: Information in the Information Technology
-
- -
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3.1 Indicate below what types of information that may be personally identifiable in Column (1)
will foreseeably be collected, handled, disseminated, stored and/or accessed by this
information technology, regardless of the source of the information, whether the types of
information are specifically requested to be collected, and whether particular fields are
provided to organize or facilitate the information collection. Please check all that apply in
Column (2) and indicate to whom the information relates in Column (3). Note: This list is
provided for convenience; it is not exhaustive. Please add to “other” any other types of
information.
(1) General Categories of
Information that May Be
Personally Identifiable
(2)
Information is collected,
processed,
disseminated, stored
and/or accessed by this
information technology
(please check each
applicable row)
(3) The information relates to:
(4) Comments
A. DOJ/Component Employees,
Contractors, and Detailees;
B. Other Federal Government
Personnel;
C. Members of the Public US
Citizens or Lawful Permanent
Residents (USPERs);
D. Members of the Public Non
USPERs
Example: Personal email
address
X B, C and D
Email addresses of members of the
public (US and non-USPERs)
Name
X
A, B, C, D
Date of birth or age
X
A, C, D
Place of birth
X
A, C, D
Gender
X
A, C, D
Race, ethnicity, or citizenship
X
A, C, D
Religion
Social Security Number (full,
last 4 digits or otherwise
truncated)
X A
HR stores and accesses SSNs of ATR
employees in ATR IDMS-C
Tax Identification Number
(TIN)
X C, D
Driver’s license
X
C, D
Alien registration number
X
C, D
Passport number
X
C, D
Mother’s maiden name
Vehicle identifiers
Personal mailing address
X
A, C, D
Personal e-mail address
X
A, C, D
Personal phone number
X
A, C, D
Medical records number
X
A, C, D
Medical notes or other medical
or health information
X A, C, D
Financial account information
X
A, C, D
Applicant information
X
A, C, D
Education records
Military status or other
information
X A, C, D
Employment status, history, or
similar information
X A, C, D
-
- -
Department of Justice Privacy Impact Assessment
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(1) General Categories of
Information that May Be
Personally Identifiable
(2)
Information is collected,
processed,
disseminated, stored
and/or accessed by this
information technology
(please check each
applicable row)
(3) The information relates to:
(4) Comments
A. DOJ/Component Employees,
Contractors, and Detailees;
B. Other Federal Government
Personnel;
C. Members of the Public US
Citizens or Lawful Permanent
Residents (USPERs);
D. Members of the Public Non
USPERs
Employment performance
ratings or other performance
information, e.g., performance
improvement plan
X A
Certificates
X
C, D
Legal documents
X
C, D
Device identifiers, e.g., mobile
devices
Web uniform resource
locator(s)
X C, D
Foreign activities
X
C, D
Criminal records information,
e.g., criminal history, arrests,
criminal charges
X C, D
Juvenile criminal records
information
Civil law enforcement
information, e.g., allegations of
civil law violations
X C, D
Whistleblower, e.g., tip,
complaint, or referral
X C, D
Grand jury information
Information concerning
witnesses to criminal matters,
e.g., witness statements,
witness contact information
X C, D
Procurement/contracting
records
X C, D
Proprietary or business
information
X C, D
Location information,
including continuous or
intermittent location tracking
capabilities
Biometric data:
- Photographs or
photographic identifiers
- Video containing biometric
data
- Fingerprints
- Palm prints
- Iris image
- Dental profile
- Voice recording/signatures
- Scars, marks, tattoos
-
- -
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(1) General Categories of
Information that May Be
Personally Identifiable
(2)
Information is collected,
processed,
disseminated, stored
and/or accessed by this
information technology
(please check each
applicable row)
(3) The information relates to:
(4) Comments
A. DOJ/Component Employees,
Contractors, and Detailees;
B. Other Federal Government
Personnel;
C. Members of the Public US
Citizens or Lawful Permanent
Residents (USPERs);
D. Members of the Public Non
USPERs
- Vascular scan, e.g., palm
or finger vein biometric
data
- DNA profiles
- Other (specify)
System admin/audit data:
1
- User ID
X
A, C, D
- User passwords/codes
- IP address
X
A, C, D
- Date/time of access
X
A, C, D
- Queries run
X
A, C, D
- Contents of files
X
A, C, D
Other (please list the type of
info and describe as
completely as possible):
3.2 Indicate below the Department’s source(s) of the information. (Check all that apply.)
Directly from the individual to whom the information pertains:
In person
9
Hard copy: mail/fax
9
Online
9
Phone
9
Email
9
Other (specify):
Government sources:
9
Within the Component Other DOJ Components
9
Other federal entities
Foreign (identify and provide the
international agreement,
memorandum of understanding,
or other documented arrangement
State, local, tribal
9
related to the transfer)
Other (specify):
1
System administrators include ATR account managers (Category A individuals) and vendor system administrators
(Category C, D individuals). Vendor administrators have no access to ATR systems or passwords.
Department of Justice Privacy Impact Assessment
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Non-government sources:
Members of the public
9
Public media, Internet
9
Private sector
9
Commercial data
brokers
9
Other (specify):
Section 4: Information Sharing
4.1 Indicate with whom the Component intends to share the information and how the
information will be shared or accessed, such as on a case-by-case basis by manual secure
electronic transmission, external user authorized accounts (i.e., direct log-in access),
interconnected systems, or electronic bulk transfer.
Recipient
How information will be shared
Case-
by
-
case
Bulk
transfer
Direct
log-in
access
Explain specifics of the sharing,
as well as how these disclosures
will support and are compatible
with the purposes of the
collection.
Within the Component
9
9
ATR personnel will share information
stored in ATR IDMS
-C among ATR
personnel
and offices on a case-by-
case
basis via email. ATR users have control
over their documents
within
ATR IDMS-
C and
can grant access to others to
view
and manipulate
documents they own
(via
direct
log-in
access). However, they are
required to abide by organizational rules
for sharing of case data and will need
Section Chief/Assistant Chief approval to
share case information outside
the
authorized group.
DOJ Components
9
ATR users will share ATR IDMS-C
information
with other DOJ
components
on
a case-by-case basis via email in
accordance with organizational rules.
Federal entities
9
ATR users will share ATR IDMS-C
information
with other federal
partners on
a
case-by-case basis in
accordance with
organizational rules.
State, local, tribal gov't entities
9
ATR users will share ATR IDMS-C
information
with others on a case-by-
case
basis via email in accordance with
organizational rules.
Public
9
Certain information will become public
in litigation according
to civil
procedure,
evidence,
and court rules, and court
orders.
Department of Justice Privacy Impact Assessment
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Recipient
How information will be shared
Case-
by
-
case
Bulk
transfer
Direct
log-in
access
Explain specifics of the sharing,
as well as how these disclosures
will support and are compatible
with the purposes of the
collection.
Counsel, parties, witnesses,
and possibly courts or other
judicial tribunals for litigation
purposes
9
9
ATR
will share case documents with
the
parties
and
court as required by discovery
rules or court orders
.
Private sector
9
ATR will share information with
private sector
individuals who have
been
hired as experts or have other
legitimate reasons for access, upon
approval of the case manager or other
appropriate ATR authorities. ATR
generally,
will provide access to data
via
email upon case manager approval.
Foreign governments
Foreign entities
9
While rare, ATR may share information
from
ATR IDMS-
C on a case by case
basis with foreign entities or partners
who have legitimate reasons for access
and upon approval of the case manager
and appropriate DOJ/ATR authorities.
ATR generally will provide data via
email upon case manager approval.
Other (specify):
9
9
A third-party application within ATR
IDMS
-C enables an approved ATR
administrator to conduct automated
searches of ATR IDMS-C for records.
4.2 If the information will be released to the public for “Open Data” purposes, e.g., on data.gov
(a clearinghouse for data from the Executive Branch of the federal government), and/or for
research or statistical analysis purposes, explain whether—and, if so, how—the
information will be de-identified, aggregated, or otherwise privacy protected.
Any data that resides in ATR IDMS-C is processed and accessed in accordance with legal
requirements, federal regulations, and Department policy. ATR provides only statistics and
case filings to the “Open Data” site (www.data.gov).
Section 5: Notice, Consent, Access, and Amendment
5.1 What, if any, kind of notice will be provided to individuals informing them about the
collection, use, sharing or other processing of their PII, e.g., a Federal Register System of
Records Notice (SORN), providing generalized notice to the public, a Privacy Act §
552a(e)(3) notice for individuals, or both? Will any other notices be provided? If no notice is
provided, please explain.
An ATR SORN provides generalized notice to the public.
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Page 8
ATR-006, “Antitrust Management Information System (AMIS) - Monthly Report,” 63 Fed.
Reg. 8659 (2-20-1998), 66 Fed. Reg. 8425 (1-31-2001), 66 Fed. Reg. 17200 (3-29-2001),
82 FR 24147 (5-25-2017). Exemptions Claimed Pursuant to 5 U.S.C. 552a(k)(2). See 28
C.F.R. § 16.88.
5.2 What, if any, opportunities will there be for individuals to voluntarily participate in the
collection, use or dissemination of information in the system, for example, to consent to
collection or specific uses of their information? If no opportunities, please explain why.
All information within ATR IDMS-C is generally second sourced and is captured,
organized, and managed by individual users. Individuals involved in investigations and
litigations are properly notified in accordance with Federal criminal and civil procedure
and court rules. All information collected is part of existing or requested case data, as
captured or requested through voluntary requests, subpoenas, discovery requests, search
warrants, civil investigative demands, or second requests under the Hart-Scott-Rodino
Antitrust Improvement Act (“HSR” Act).
2
For compulsory data-gathering mechanisms,
individuals do not have the opportunity to decline to provide the requested data and
documents. Certain information may be provided voluntarily by the data subject.
3
As
required by law, ATR provides data subjects with appropriate notice of information
collection under the Privacy Act, 5 U.S.C. § 552a(e)(3), e.g., when individuals submit
applications for employment. Notice is not provided to individuals for information
collected from public sources, because that information is publicly available.
5.3 What, if any, procedures exist to allow individuals to gain access to information in the
system pertaining to them, request amendment or correction of said information, and receive
notification of these procedures (e.g., Freedom of Information Act or Privacy Act
procedures)? If no procedures exist, please explain why.
ATR follows Department procedures regarding requests for access to, or amendment of,
records pertaining to an individual, including those maintained within a system of records
in accordance with the Privacy Act. See https://www.justice.gov/opcl/doj-privacy-act-
requests. Privacy Act requests for access to records are processed under both the Privacy
Act and the Freedom of Information Act (FOIA), 5 U.S.C. § 552. All such requests are
submitted to ATR’s FOIA/Privacy Act Unit (https://www.justice.gov/atr/antitrust-foia) for
processing and response.
Section 6: Maintenance of Privacy and Security Controls
6.1 The Department uses administrative, technical, and physical controls to protect information.
Indicate the controls below. (Check all that apply).
2
The HSR Act, 15 U.S.C. § 18a, requires parties to certain transactions to notify ATR and the Federal Trade Commission
of the transaction and to provide certain documents, and it permits the agencies to make a request for additional
information and documents (a “second request”).
3
This type of information includes interviews of witnesses that are conducted on a voluntary basis (as compared to
depositions, for example) and summarized in memos. It also includes memos to HR Managers capturing information
obtained during job interviews.
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9
The information is secured in accordance with Federal Information Security
Modernization Act (FISMA) requirements, including development of written security
and privacy risk assessments pursuant to National Institute of Standards and
Technology (NIST) guidelines, the development and implementation of privacy controls
and an assessment of the efficacy of applicable privacy controls. Provide date of most
recent Authorization to Operate (ATO): January 17, 2024
If an ATO has not been completed, but is underway, provide status or expected
completion date:
Unless such information is sensitive and release of the information could pose risks to
the Component, summarize any outstanding plans of actions and milestones (POAMs)
for any privacy controls resulting from the ATO process or risk assessment
and provide
a link to the applicable POAM documentation
:
There are no POA&Ms associated with Privacy Controls.
This system is not subject to the ATO processes and/or it is unclear whether NIST
privacy controls have been implemented and assessed. Please explain:
This system has been assigned a security category as defined in Federal Information
P
rocessing Standards (FIPS) Publication 199,
Standards for Security Categorization of
Federal Information
and Information Systems
, based on the information it contains and
consistent with FIPS 199
. Specify and provide a high-
level summary of the justification,
which may be
detailed in the system security and privacy plan: ATR IDMS-C is
categorized as a moderate system based on a review of the
aggregate impact levels for
confidentiality, integrity, and ava
ilability.
9
Monitoring, testing, or evaluation has been undertaken to safeguard the information
and prevent its misuse. Specify:
IDMS
-C has completed all required security and functional testing and evaluation in
accordance with Department IT
development procedures. Additionally, the system has
undergone a full securi
ty assessment in accordance with the DOJ Security and Privacy
Assessment and Authorization Handbook. The system operates within the boundary of ATR
CCE, where it is subject to full system monitoring and auditing in accordance with ATR and
Department guidelines. All system documentation supporting these activities are maintained
within the Department’s system of record, Joint Cybersecurity Authorizatio
n and
Management (JCAM) application.
9
Auditing procedures are in place to ensure compliance with security and privacy
standards. Explain how often system logs are reviewed or auditing procedures
conducted:
IDMS
-
C audits at multiple layers, including the network and application processing levels.
All logs are generally reviewed on a weekly basis by onsite administrators and then gathered
and centrally managed using the Department’s audit analysis solution, SPLUNK. All logs are
forwarded to the DOJ Security Operations Center (JSOC) for automated analysis and review.
9
Contractors that have access to the system are subject to information security, privacy
and other provisions in their contract binding them under the Privacy Act
, other
applicable laws,
and as required by DOJ policy.
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All contractors granted access to IDMS-C are required to sign the DOJ General and
Privileged Rules of Behavior, as determined by their role.
Each Component is required to implement foundational privacy-related training for all
Component
personnel, including employees, interns, and contractors, when personnel
on
-
board and to implement refresher privacy training annually. Indicate whether there
is additional training specific to this system, and if so, please describe:
All IDMS
-
C users are subject to organizational and Department annual computer security
awareness and privacy specific training that includes sign off and acknowledgment of the
DOJ General and Privileged Rules of Behavior. In addition, all ATR users are required to
9
undergo formal onboarding training that includes IDMS-C specific training.
6.2 Explain key privacy and security administrative, technical, or physical controls that are
designed to minimize privacy risks. For example, how are access controls being utilized to
reduce the risk of unauthorized access and disclosure, what types of controls will protect PII
in transmission, and how will regular auditing of role-based access be used to detect possible
unauthorized access?
All ATR IDMS-C users are required to undergo training and sign formal Rules of Behavior
prior to being granted access to data within ATR IDMS-C. All users are required to use
multi-factor authentication or unique usernames and passwords to access their ATR IDMS-
C accounts. ATR IDMS-C uses CCE active directory services to support a single sign-on
solution for all ATR IDMS-C accounts.
All data is encrypted at rest and during transmission outside ATR’s secure boundary. Data
access is restrictive; users require formal approval and authorization to access information
on a case-by-case basis for data they do not own. Users can access only data which they
own or are authorized by the data owner to access. Additionally, users manage their own
data within ATR IDMS-C and can only grant to other users access to the data they own and
control.
In addition, case data is through the use of Access Control Lists that require approval by
specific data owners for granting of user access. Finally, access and audit logs are
maintained within the system and are reviewed by administrators as required by DOJ
policies for unauthorized access and other security and performance related concerns.
6.3 Indicate how long the information will be retained to accomplish the intended purpose, and
how it will be disposed of at the end of the retention period. (Reference the applicable
retention schedule approved by the National Archives and Records Administration, if
available.)
Individual users are responsible for ensuring that records processed or disseminated
through ATR IDMS-C are appropriately retained or destroyed. Requirements governing
retention and disposition of ATR documents and information are documented within ATR
Directive 2710.1: Procedures for Handling Division Documents and Information,
consistent with National Archives and Records Administration regulations and rules,
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including records schedules.
Section 7: Privacy Act
7.1 Indicate whether information related to U.S. citizens or aliens lawfully admitted for
permanent residence will be retrieved by a personal identifier (i.e., indicate whether
information maintained by this information technology will qualify as “records” maintained
in a “system of records,” as defined in the Privacy Act of 1974, as amended).
_____ No. ___X__ Yes.
7.2 Please cite and provide a link (if possible) to existing SORNs that cover the records, and/or
explain if a new SORN is being published:
ATR-006, “Antitrust Management Information System (AMIS) - Monthly Report,” 63 Fed.
Reg. 8659 (2-20-1998), 66 Fed. Reg. 8425 (1-31-2001), 66 Fed. Reg. 17200 (3-29-2001),
82 FR 24147 (5-25-2017). Exemptions Claimed Pursuant to 5 U.S.C. 552a(k)(2). See 28
C.F.R. § 16.88.
Section 8: Privacy
Risks and Mitigation
When considering the proposed use of the information, its purpose, and the benefit to the
Department of the collection and use of this information, what privacy risks are associated with the
collection, use, access, dissemination, and maintenance of the information and how are those risks
being mitigated?
Note: When answering this question, please specifically address privacy risks and mitigation
measures in light of, among other things, the following:
• Specific information being collected and data minimization strategies, including decisions
made to collect fewer data types and/or minimizing the length of time the information will be
retained (in accordance with applicable record retention schedules),
• Sources of the information,
• Specific uses or sharing,
• Privacy notices to individuals, and
• Decisions concerning security and privacy administrative, technical, and physical controls
over the information.
ATR uses ATR IDMS-C as an internal documen
t management repository. The privacy risks
associated with information collected within ATR IDMS-C primarily relate to the loss of
confidentiality and integrity of the data. Access by unauthorized entities to sensitive data,
including personal information collected for internal personnel management use, investigation,
or litigation potentially could lead to destruction or corruption of that data, compromised
identities, exposure of sensitive court records and personal data, and/or disruption to an ongoing
investigation or litigation.
To mitigate this risk, only authorized ATR users can access ATR IDMS-C and individual
document access is further limited by Access Control Lists which are implemented and
Department of Justice Privacy Impact Assessment
Antitrust Division/iManage Document Management System-Cloud
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maintained by each data owner. Additionally, ATR uses a number of proven protection
methods, including secure communications through DOJ’s Justice Unified Network
(JUTNET), malicious code protection and intrusion detection software, active monitoring
controls, encryption, and enhanced access control techniques to ensure data is protected in
accordance with DOJ IT security standards and applicable U.S. Government standards.
Additionally, EOS uses a specific script to audit and review access to specific data within
ATR IDMS-C records.
The types of information collected within ATR IDMS-C vary greatly based on the data
owner’s needs. To mitigate the risk of overcollection, information collected is limited to
what is necessary for each specific matter. ATR also complies with applicable record
retention schedules and guidance, to prevent the storage of records within ATR IDMS-C for
longer than is necessary. Finally, ATR provides user training to users of ATR IDMS-C to
mitigate the risk of overcollection.
ATR IDMS-C does contain SSNs captured in support of employee payroll processing and for
other human resources purposes to comply with National Finance Center, Office of
Personnel Management, and other human resources law and regulatory requirements. To
mitigate the risk posed by the processing of SSNs, access to SSNs is limited to HR personnel
and all documents containing SSNs are controlled through access control lists and user
permissions. Documents containing SSNs are also secured using encryption (sending
external via email).