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Replace systemOfRecords with 53 UII #91
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This was required in the reports for the Digital Strategy, and I many instances where agencies placed all of their projects under a generic bucket UII that existed within their system, rendering it not very useful. |
Replacing "System of Records Notice" with UII defeats the purpose of using the SOR(N) field to identify to the public the access provisions of datasets that are subject to restricted access. SORNs are an important part of the information asset management function that we're trying to promote with this process, and ensure that the Chief Privacy Officer is involved with the data transparency efforts of any agency. If the intent is to link the data inventory to the agency's IT portfolio, that is a different objective. Note that UIIs are supposedly persistent, but agencies frequently consolidate and split IT investments in their capital planning and investment control processes and supporting IT applications. These applications are not integrated with information management practices and data inventories. Referential integrity between the two databases/lists will be a manual process unless & until something changes. Note further that FY 2013 (BY 2015) Exhibit 300 guidance requires the listing of hyperlinks for open datasets related to major IT investments. If the intent is to require something different, this should be rolled in to the BY 2016 CPIC process. |
Okay, clearly bad idea to replace it. Let's take that off the table and leave the extensible SORN field. Now, the proposal is adding PrimaryITInvestmentUII as an optional, extensible field for tracking purposes. |
Accepted the addition of an optional PrimaryITInvestmentUII into the final 1.0 schema being submitted internally for approval. |
It was suggested that an Exhibit 53 Unique Investment Identifier be required for each dataset, in place of the existing systemOfRecords field, which suggests linking to a dataset's System of Records notice.
Thoughts?
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