Comment from Electronic Privacy Information Center (EPIC)
Electronic Privacy Information Center (EPIC)OpposeAdvocacy
Summary: 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 Electronic Privacy Information Center (“EPIC”) and the National Consumer Law Center (“NCLC”) submit the attached comments in response to the Consumer Financial Protection Bureau (“CFPB” or “the Bureau”)’s notice of a modified system of records titled “CFPB.009-Employee Administrative Records System.”