5. Oversight

1. Policy Development 2. Policy Implementation 3. Operations
4. Compliance
5. Oversight 6. Redress
7. Outreach 8. Coordination 9. SME
  10. Training  

Annual Audit

The oversight function is one of the most important roles of a P/CRCL Officer. Consider many of the fusion center news articles and you can see how important diligent oversight can be in avoiding negative media attention. Conducting an audit on an annual basis is a best practice in proper oversight. Recall that an audit measures your center's actual record in implementing the P/CRCL Policy whereas a compliance review measures your fusion center's capability in P/CRCL issues.

The Constitution Project published Fusion Center Recommendations (38pp | 7mb | PDF) that focus on data collection, data storage, and accountability. This document can assist in orienting you to the public perception of fusion centers and addressing concerns.

Compliance Verification

The Privacy, Civil Rights, and Civil Liberties Compliance Verification for the Intelligence Enterprise (52pp | 4mb | PDF) assists intelligence enterprises in complying with all applicable privacy, civil rights, and civil liberties protection laws, regulations, and policies. The checklist provides a suggested methodology for conducting the review of an agency's intelligence enterprise and identifies areas of concern.

Under the P/CRCL Policy Template (62pp | 1.4mb | PDF) each fusion center is required to conduct an audit, at least annually, on P/CRCL issues. Whereas the Compliance Verification Tool provides insight into whether your fusion center has the necessary capabilities related to P/CRCL protections, an audit attempts to determine to what degree your fusion center is properly implementing the P/CRCL policies and procedures outlined in the P/CRCL policy. DHS is currently in the process of developing guidance on how to conduct a fusion center audit. In the meantime, please review the Toolbox section on Audits.

External Oversight Functions

In addition, having an understanding of the issues that may raise red flags will assist in managing your fusion center's oversight of P/CRCL. Monitoring the issues that garner federal oversight interest by keeping up-to-date on Congressional oversight committees actions will help you guide your program.

The Privacy Civil Liberties Oversight Board (PCLOB) (2pp | 177kb | PDF), an independent agency within the executive branch, was initially established to ensure that actions in the executive branch related to terrorism (12pp | 224kb | PDF) are balanced with the need to protect privacy and civil liberties. One of its mandates (2pp | 12kb | PDF) is to ensure that concerns related to privacy and civil liberties are appropriately considered in the implementation of all laws, regulations, and policies related to war against terrorism.

Source: The DHS Office for Civil Rights and Civil Liberties and the DHS Privacy Office.
Last date page updated: 08/13/13 (CRCL)

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