USPS Retail Survey Lacks Privacy Act Safeguards?

It appears USPS Headquarters has developed a retail survey for PS-07 Lead Sales and Service Associates (LSSA) , Clerk Finance Station, and Window Service Technicians. Some concerns are being raised about this survey including a lack of Privacy Act notice on the website.

From PostalReporter Reader (s)

Some USPS managers are requiring all window clerks to answer an online survey regardless of how many hours they work the window. I clicked on the link, https://USPSLSSA.questionpro.com, and didn’t see a valid ‘Privacy Act Notice.’ Specifically, content items b, c, d, and e listed in section 3-2.2.b.1 for a ‘Privacy Act Notice’ are missing. Since the retail clerks have to enter their POS ID, they are personally identifiable and should receive a ‘Privacy Act Notice.’

Here is what the notice says:

The purpose of this survey is to collect data that will assist us in understanding the roles and responsibilities of the LSSA staying within the appropriate job description. The survey will also help measure the LSSA’s level of engagement with other retail clerks and our valued customers. This initiative is also in partnership with National APWU.

Handbook AS-353 Guide to Privacy, the Freedom of Information Act, and Records Management

3-2.2 Privacy Notice

The following describes privacy notice requirements.

a. General. When the Postal Service asks customers, employees, or other individuals to provide information about themselves and that information is maintained in a system of records, the Postal Service must provide an appropriate privacy notice. The Privacy Office must approve all new forms (hard copy and electronic) that collect customer, employee, or other individuals’ information. This includes hard copy and electronic forms, new forms, and forms scheduled for revision and reprinting.

b. Content. The privacy notice must contain the following information:

1. For individual consumers, employees, or other individuals, the privacy notice must explain:

a. The reason the information is being collected.
b. Whether providing it is mandatory or voluntary, and the effects of not providing it.
c. The disclosures (known as routine uses) that may be made of the information.
d. Which statute or executive order authorizes the collection.
e. That the customer privacy policy is available on usps.com.

Exhibit 3-2.2
Procedures to Provide a Privacy Notice

Online
For employees, a privacy notice that meets the content requirement of section 3-2.2b must be available on the screen near where data is collected.