Comment from Dixon, Danielle

Comment on Proposed Modification to CFPB.009 — Employee Administrative Records System FR Doc. 2026-10113 Submitted by: Danielle Dixon, CFPB Communications/Policy Staff I am a CFPB employee with 6 years of service. My personnel records, HR files, and work history are maintained in CFPB.009. I oppose this proposed modification. 1. The routine use is unclear and not compatible with the purpose of these records. CFPB.009 is maintained to administer payroll, benefits, and other personnel-related functions, not to provide employee information to the media. I do not want to be subject to retaliatory action for standing up for myself. Under the Privacy Act, a routine use is permitted only if it is compatible with the purpose for which the records were originally collected. See 5 U.S.C. § 552a(b)(3). Disclosing employment records to news organizations does not further a personnel-related purpose. In addition, the phrase “specific circumstances” is not defined and provides the agency with broad discretion without clear standards or limitations. This lack of clarity is inconsistent with the guidance in OMB Circular A-108 and the Fair Information Practice Principles. 2. Why can't FOIA be enough? FOIA Exemption 6 exists to shield personnel records from public release because disclosure would constitute a “clearly unwarranted invasion of personal privacy.” Using that same standard as the floor for releasing my records inverts its purpose and contradicts the Bureau’s own privacy policy commitments to data minimization and use limitation. 3. This relaxes protected activity and creates host work environmenta and is a retaliation risk - personally and professionally. My records include time and attendance, leave, personnel actions, and organizational placement — information that can reveal union participation or protected concerted activity. Authorizing media disclosure of those records without restriction exposes employees like me to third-party retaliation and chills the exercise of federal labor rights. If I were in witness protection this would be of major concern. This should not be apart of our contract of employment. I did not join this agency to later be told I have no choice specifically this matter!! This is not speculative; it reflects what is already happening to federal workers. 4. I have no notice and no recourse. Under this routine use, the Bureau could disclose my records to a reporter before I know it is happening. I would have no opportunity to identify errors, protect privileged information, or seek review. If CFPB sees fit, at their discretion, to release my information challenging this offense would come after the damage has already been done. This is as if my identity is being stolen and I have to go through hell to rebuild my life and presence in the world. This is not right!! This violates the FIPPs’ Individual Participation principle and basic due process. What should happen instead: * Use FOIA as the lawful, accountable process for public disclosure, with Exemption 6 protections applied on a case-by-case basis. * Require pre-disclosure notice before releasing any employee’s records, including written notice to the employee, identification of the specific records at issue, the basis for release, and an opportunity to respond. * Withdraw or narrow any retained media-disclosure authority by enumerating specific triggering conditions rather than leaving the determination to unreviewable discretion. As a Communications/Policy professional, I understand that transparency serves the public interest. But transparency about the Bureau’s work is not the same as exposing individual employees’ private records without cause, notice, or limit. I urge the Bureau to withdraw this routine use as written. Danielle Dixon CFPB Employee Washington, DC