Removal of Personally Identifiable Information (PII) in the Automated Fluid Minerals Support System (AFMSS)

December 8, 2020

In Reply Refer To:
3160 (310) P  

EMS TRANSMISSION 12/09/2020

Information Bulletin No. 2021-008               

To:          All State and Field Office Officials

From:      Assistant Director, Energy, Minerals, and Realty Management                    

Subject:   Removal of Personally Identifiable Information (PII) in the Automated Fluid Minerals Support System (AFMSS)

The purpose of this Information Bulletin is to notify all State and Field Offices and users of AFMSS to immediately cease entering PII[1] into this Information Technology (IT) system as it was not designed to host this data. The Bureau of Land Management (BLM) AFMSS team will take measures to expeditiously remove all existing PII information from AFMSS and the system will be reset to reject PII data now and in the future. The BLM will take the following steps to ensure that PII data is not entered or maintained with the rollout of AFMSS II and decommissioning of AFMSS I:

1.  No PII data will be stored or placed into AFMSS II.
2. Monthly PII reports will be delivered to the Application Owner that summarize the condition of PII data in AFMSS II.
3. Immediate action will be taken to remove any PII data when found in AFMSS II.
4. No PII data will be migrated from AFMSS I into AFMSS II.
5. When the PII data is removed from AFMSS II, the system operational and maintenance support will need to begin scanning data to ensure no PII data remains.
6. The BLM will complete a Privacy Impact Assessment (PIA) every three years per the Department of the Interior’s (DOI) guidance on the AFMSS system.

Background

AFMSS is the system of record for the lifecycle of fluid mineral development operations on the public lands and federal mineral estate. However, AFMSS is not the system of record for all information related to fluid mineral program operations; for example, AFMSS is not the system of record for lease and royalty information and operations.

Currently, AFMSS contains information beyond the scope of the AFMSS System of Record Notice (SORN) and the Privacy Impact Assessment (PIA). This information includes Private Landowner contact information and Indian Mineral Allottee information.

To comply with Federal privacy and information technology requirements consistent with the AFMSS SORN, existing PII and data input fields for PII will be removed from AFMSS, eliminating the user’s ability to input PII into defined data fields. Additionally, users are to cease any entry of PII into text or entry fields. Non-PII information critical to processing permits, reviewing bonds, accounting for production, and other fluid mineral program operations will continue to be available in AFMSS. In instances when PII is needed to complete program operations, the BLM employee must access information from an approved source (e.g., well file) or an approved system of record. For example, when confidential surface owner information (PII) is required to schedule an onsite or conduct an inspection, the BLM staff should refer to the APD, well file, or contact the operator to obtain this information.

The DOI requires PIAs to be conducted and maintained on all IT systems whether already in existence, in development, or undergoing modification in order to adequately evaluate privacy risks, ensure the protection of privacy information, and consider privacy implications throughout the information system development life cycle. See the DOI PIA Guide for additional guidance on conducting a PIA or meeting the requirements of the E-Government Act of 2002. DOI’s Privacy Threshold Analysis, Form DI-4012, may be used to evaluate the privacy implications of the system. If the system demonstrates that it has privacy sensitive information, further documentation is required by completing the Privacy Impact Assessment, Form DI-4001. See the DOI PTA Guide for additional guidance on conducting a PTA, or if necessary, see the DOI PIA Guide on conducting a PIA and meeting the requirements of the E-Government Act of 2002.

Management of all records and data are according to established records retention and disposal policies.  Refer to the National Archives and Records Administration’s (NARA) General Records Schedule (GRS), DOI’s Departmental Records Schedule (DRS) and the BLM’s records schedule, commonly known as the DRS/GRS/BLM Combined Records Schedule.  However, there are special requirements for trust records for DOI bureaus.

Indian Fiduciary Trust Records (IFTRs) are permanent records and offices may not destroy them. Field offices should send Indian Trust Records to the National Archives Records Center/Federal Records Center (NARA/FRC) according to the appropriate records schedule.

If there are any questions concerning this IB, please contact Donna Dixon, Chief, Fluid Minerals Division at (505) 206-1808 or dbdixon@blm.gov, or Ashanti Murphy-Jones, Associate Privacy Officer (Acting) at (202) 365-1429 or a1murphy@blm.gov.

Signed By:                                                                  Authenticated By:

Nicholas E. Douglas                                                   Ambyr Fowler

Assistant Director                                                       Division of Regulatory Affairs (HQ-630)

Energy, Minerals, and Realty Management