CFPB.009-Employee Administrative Records System

The Electronic Privacy Information Center (EPIC) and the National Consumer Law Center (NCLC) oppose the CFPB's proposed routine use 18, arguing it allows for the disclosure of sensitive personnel data without the protections of the Freedom of Information Act (FOIA). They contend that the proposal violates the Privacy Act of 1974, fails to meet data minimization requirements, and creates significant privacy and safety risks for CFPB employees and their families.

The National Treasury Employees Union (NTEU) opposes the proposed routine use because it is too vague and broad, potentially allowing for the disclosure of sensitive employee information to the media and public without advance notice. They argue that the proposal lacks specific justification, fails to meet OMB's narrowing requirements, and could be used for retaliatory purposes against employees.

Danielle Dixon, a CFPB employee, opposes the proposed modification to the Employee Administrative Records System because she believes it allows for the disclosure of private personnel records to the media without sufficient notice, clarity, or protection against retaliation. She argues that the modification violates the Privacy Act and Fair Information Practice Principles, and she recommends using the FOIA process with Exemption 6 protections instead.

The commenter, a CFPB union member writing in a personal capacity, opposes the proposed action because they believe the SORN allows for the weaponization of private personnel files against employees who speak out. They argue that this lack of privacy will chill whistleblowing regarding waste, fraud, and abuse, ultimately harming American consumers.

The commenter, writing in a personal capacity, opposes the proposed changes to the System of Records Notice (SORN) regarding employee administrative records. They argue that the proposal allows for the weaponization of sensitive personal information by political appointees and would create significant privacy risks and legal liabilities for the government.

A CFPB employee and union member opposes the proposed Employee Administrative Records System, specifically Routine Use 18, arguing that it lacks sufficient privacy protections and could be used to retaliate against employees for protected speech. The commenter contends that the policy is unnecessary because FOIA requests already provide a mechanism for disclosure that includes a balancing test for personal privacy.

Danielle Dixon, a CFPB employee, opposes the proposed modification because she believes it violates the Privacy Act and exposes employees to retaliation and privacy invasions. She argues that the disclosure of personnel records to the media is incompatible with the records' original purpose and requests that the Bureau use FOIA processes with proper notice and protections instead.

The commenter opposes the proposed Routine Use (18) because it grants the CFPB subjective discretion to disclose employee records to the media, which they argue violates the Privacy Act and creates risks to due process and employee privacy. They argue that the agency should instead rely on existing FOIA processes and statutory frameworks to balance transparency with individual liberties.

An individual commenter opposes the proposed addition of Routine Use 18 to the Bureau's Privacy Act System of Records. They argue that the proposal lacks sufficient guardrails to protect employee privacy and that information of public interest should instead be requested through the FOIA process.

A current CFPB employee opposes the proposed Routine Use (18) because they believe it will chill protected speech and whistleblowing by allowing the Bureau to disclose personnel records to the media. The commenter argues that the proposal lacks notice to employees, violates Privacy Act purpose-compatibility requirements, and uses overly vague "public interest" standards.