OMB M-05-24 - Implementation of Homeland Security Presidential Directive (HSPD) 12 - Policy for a Common Indentification Standard for Federal Employees and Contractors

EXECUTIVE OFFICE OF THE PRESIDENT
O F F I C E O F M AN AG E M E N T AN D B U D G E T
W ASHINGTON, D.C. 20503

THE DIRECTOR

M-05-24
August 5, 2005
MEMORANDUM FOR THE HEADS OF ALL DEPARTMENTS AND AGENCIES
FROM:

Joshua B. Bolten
Director

SUBJECT:

Implementation of Homeland Security Presidential Directive (HSPD)
12 – Policy for a Common Identification Standard for Federal
Employees and Contractors

On August 27, 2004, the President signed HSPD-12 “Policy for a Common Identification
Standard for Federal Employees and Contractors” (the Directive). The Directive requires the
development and agency implementation of a mandatory, government-wide standard for secure
and reliable forms of identification for Federal employees and contractors. As required by the
Directive, the Department of Commerce issued Federal Information Processing Standard 201
(the Standard). This memorandum provides implementing instructions for the Directive and the
Standard.
Inconsistent agency approaches to facility security and computer security are inefficient
and costly, and increase risks to the Federal government. Successful implementation of the
Directive and the Standard will increase the security of your Federal facilities and information
systems. As noted in the attached guidance, this standard identification applies to your
employees and contractors who work at your facilities or have access to your information
systems. Following implementation, Federal departments and agencies will be able to recognize
and accept this common identification standard.
It is important to note the use of standard identification does not replace your existing law
or OMB policy responsibilities; including the laws and policies governing personnel security,
acquisition, and information technology security law.
If you have questions about this guidance, contact Jeanette Thornton, Policy Analyst,
Information Policy and Technology Branch, Office of Management and Budget. Phone (202)
395-3562, fax (202) 395-5167, or e-mail: eauth@omb.eop.gov.
eauth@omb.eop.gov
Attachments
A) HSPD-12 Implementation Guidance for Federal Departments and Agencies
B) HSPD-12 Policy for a Common Identification Standard for Federal Employees and
Contractors

Attachment A
HSPD-12 IMPLEMENTATION GUIDANCE FOR FEDERAL DEPARTMENTS AND
AGENCIES

1.
2.
3.
4.
5.
6.
7.

To whom does the Directive apply?
What is the schedule for implementing the Directive?
How should I implement Part 1 of the Standard?
How should I implement Part 2 of the Standard?
What acquisition services are available?
How must I consider privacy in implementing the Directive?
Is there anything else I must consider or know?

1. To whom does the Directive apply?
As defined below, Department and Agency heads must conduct a background investigation,
adjudicate the results, and issue identity credentials to their employees and contractors who
require long-term access to Federally controlled facilities and/or information systems.
A. Departments and Agencies
• “Executive departments” and agencies listed in title 5 U.S.C. § 101, and the
Department of Homeland Security; “independent establishments” as defined by title 5
U.S.C. §104(1); and the United States Postal Service (title 39 U.S.C § 201).
Does not apply to:
• “Government corporations” as defined by title 5 U.S.C. § 103(1) are encouraged, but
not required to implement this Directive.
B. Employee
• Federal employees, as defined in title 5 U.S.C § 2105 “Employee,” within a
department or agency.
• Individuals employed by, detailed to or assigned to a department or an agency.
• Within the Department of Defense (DoD) and the Department of State (DoS),
members of the Armed Forces, Foreign Service, and DoD and DoS civilian
employees (including both appropriated fund and non-appropriated fund employees).
• Applicability to other agency specific categories of individuals (e.g., short-term (i.e.
less than 6 months) guest researchers; volunteers; or intermittent, temporary or
seasonal employees) is an agency risk-based decision.
Does not apply to:
• Within DoD and DoS, family members and other eligible beneficiaries.
• Occasional visitors to Federal facilities to whom you would issue temporary
identification.

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C. Contractor
• Individual under contract to a department or agency, requiring routine access to
federally controlled facilities and/or federally controlled information systems to
whom you would issue Federal agency identity credentials, consistent with your
existing security policies.
Does not apply to:
• Individuals under contract to a department or agency, requiring only intermittent
access to federally controlled facilities.
D. Federally Controlled Facilities
• Federally-owned buildings or leased space, whether for single or multi-tenant
occupancy, and its grounds and approaches, all or any portion of which is under the
jurisdiction, custody or control of a department or agency covered by this Directive.
• Federally controlled commercial space shared with non-government tenants. For
example, if a department or agency leased the 10th floor of a commercial building, the
Directive applies to the 10th floor only.
• Government-owned contractor-operated facilities, including laboratories engaged in
national defense research and production activities.
• Facilities under a management and operating contract. Such as for the operation,
maintenance, or support of a Government-owned or-controlled research,
development, special production, or testing establishment.
E. Federally Controlled Information Systems
• Information technology system (or information system), as defined by the Federal
Information Security Management Act of 2002 (44 U.S.C. § 3502(8)).
• Information systems used or operated by an agency or by a contractor of an agency or
other organization on behalf of an agency (44 U.S.C. § 3544(a)(1)(A)).
• Applicability for access to Federal systems from a non-Federally controlled facility
(e.g. a researcher up-loading data through a secure website or a contractor accessing a
government system from their own facility) should be based on the risk determination
required by existing National Institute of Standards and Technology (NIST)
guidance. 1
Does not apply to:
• Identification associated with national security systems as defined by the Federal
Information Security Management Act of 2002 (44 U.S.C. § 3542(2)(A)). 2

1

Federal Information Processing Standard (FIPS 199): Standards for Security Categorization for Federal
Information and Information Systems, 2/04, http://www.csrc.nist.gov/publications/fips/fips199/FIPS-PUB-199final.pdf.
2
See NIST Special Publication 800-59: Guideline for Identifying an Information System as a National Security
System, 8/03, http://www.csrc.nist.gov/publications/nistpubs/800-59/SP800-59.pdf.

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2. What is the schedule for implementing the Directive?
A. The Department of Commerce’s National Institute of Standards and Technology
(NIST) shall meet the following milestones:
Date
2/25/05
6/25/05
8/5/05

Department of Commerce Action
HSPD-12 Standard Published –Federal Information
Processing Standard 201 (FIPS 201) 3
Technical reference implementation released
Conformance testing information released

B. All covered departments and agencies shall complete the following actions:
Date
6/27/05
8/26/05
10/27/05
10/27/06
10/27/07
10/27/08

Agency Action
Implementation plans submitted to OMB
Provide list of other potential uses of Standard (see question 7)
Comply with FIPS 201, Part 1 (see question 3)
Begin compliance with FIPS 201, Part 2 (see question 4)
Verify and/or complete background investigations for all current
employees and contractors (see question 3)
Complete background investigations for all Federal department or
agency employees employed over 15 years (see question 3)

C. The General Services Administration (GSA) shall complete the following actions:
Date
7/31/05
10/27/05

General Services Administration Action
Establish authentication acquisition services (see question 5)
Sponsor Federal Acquisition Regulation (FAR) amendment
implementing the Standard.

3. How should I implement Part 1 of the Standard?
The Standard, required by HSPD-12, contains two parts to guide department and agency
implementation. The requirements of part 2 build upon the requirements of part 1.
They are:
•

Part 1: Common Identification, Security and Privacy Requirements – minimum
requirements for a Federal personal identification system that meets the control and
security objectives of the Directive, including the personal identity proofing, registration,
and issuance process for employees and contractors.

3

FIPS 201: Personal Identity Verification for Federal Employees and Contractors, 2/25/05,
http://www.csrc.nist.gov/publications/fips/fips201/FIPS-201-022505.pdf. All technical documents are available at
http://www.csrc.nist.gov/piv-project/.

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•

Part 2: Government-wide Uniformity and Interoperability – Detailed specifications
to support technical interoperability among departments and agencies, including card
elements, system interfaces, and security controls required to securely store and retrieve
data from the card.

For all new employees, contractors and other applicable individuals your department or
agency must by October 27, 2005:
A. Adopt and accredit a registration process consistent with the identity proofing,
registration and accreditation requirements in section 2.2 of the Standard and forthcoming
technical guidance issued by NIST, regardless of whether your agency will be ready to
issue standard compliant identity credentials by October 27, 2005. This registration
process will apply to all new identity credentials issued (i.e. no new identity credentials
can be issued until these conditions are met). 4
B. Initiate the National Agency Check with Written Inquiries (NACI) or other
suitability or national security investigation prior to credential issuance. Before
issuing the credential, agencies should receive notification of results of the National
Agency Checks. 5 If you do not receive the results in 5 days, the identity credential can be
issued based on the FBI National Criminal History Check (fingerprint check). 6
Identity credentials issued to individuals without a completed NACI or equivalent must
be electronically distinguishable (i.e. information is stored in the data on the card) from
identity credentials issued to individuals who have a completed investigation. The
Department of Commerce will provide the electronic format for this information.
Agencies shall not re-adjudicate individuals transferring from another department or
agency provided: 1) possession of a valid Federal identity credential can be verified by
the individual’s former department or agency, and 2) the individual has undergone the
required NACI or other suitability or national security investigation at individual’s
former agency.
Since Foreign National employees and contractors may not have lived in the United
States long enough for a NACI to be meaningful, agencies should conduct an equivalent
investigation, consistent with your existing policy. OMB will establish an interagency
working group to explore whether guidance is necessary with respect to background
investigations for foreign national employees and contractors.

4

NIST Special Publication 800-79: Guidelines for the Certification and Accreditation of PIV Card Issuing
Organizations, 7/05, http://www.csrc.nist.gov/piv-project/publications/sp800-79.pdf.
5
The National Agency Checks are the Security/Suitability Investigations Index (SII), Defense Clearance and
Investigation Index (DCII), FBI Name Check, and FBI National Criminal History Fingerprint Check. The National
Agency Check with Written Inquiries includes all of the National Agency Checks plus searches of records covering
specific areas of an individual’s background during the past five years.
6
Section 2.2 of the Standard has been revised to clarify for the initial credential issuance, only the fingerprint check
must be completed.

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C. Include language implementing the Standard in applicable new contracts. All new
contracts (including exercised options) requiring contractors (as defined in 1.C. above) to
have long term access to federally controlled facilities or access to federally controlled
information systems shall include a requirement to comply with the Directive and
Standard for affected contractor personnel. Agencies must comply with the forthcoming
Federal Acquisition Regulation sections on these requirements.
For current employees, contractors and other applicable individuals, your department or
agency must by October 27, 2005:
D. For current employees, develop a plan and begin the required background investigations
for all current employees who do not have an initiated or successfully adjudicated
investigation (i.e., “completed National Agency Check with Written Inquires or other
Office of Personnel Management [OPM] or National Security community investigation”)
on record. By October 27, 2007 verify and/or complete background investigations for all
current employees.
At card renewal (every 5 years), the NACI requirements should be followed in
accordance with OPM guidance. Currently OPM does not have a requirement to
reinvestigate employees, not otherwise subject to an investigation (e.g. for a security
clearance).
For individuals who have been Federal department or agency employees over 15 years, a
new investigation may be delayed, commensurate with risk, but must be completed no
later than October 27, 2008.
E. For current contractors and other applicable individuals, develop a plan and begin
the required background investigations for all current contractors who do not have a
successfully adjudicated investigation on record. Phase in this requirement to coincide
with the contract renewal cycle, but no later than October 27, 2007.

4. How should I implement Part 2 of the Standard?
By October 27, 2006, all departments and agencies must begin deploying products and
operational systems meeting these requirements:
A. Issue and require the use of identity credentials for all new employees and
contractors, compliant with Parts 1 and Part 2 of the Standard. For current employees
and contractors, phase in issuance and use of identity credentials meeting the Standard to
end no later than October 27, 2007.

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B. Implement the technical requirements of the Standard in the areas of personal
authentication, access controls and card management, consistent with the Standard (i.e.
sections 3, 4, and 5) and NIST Special Publication 800-73. 7
C. Risk Based Facility Access – Use the appropriate card authentication mechanism
described in section 6 of the Standard, with minimal reliance on visual authentication to
the maximum extent practicable (section 6.2.1). Officials who control access shall
determine the appropriate mechanism based on risk determinations.
D. Use of Digital Certificates – Compliance with the Standard requires the activation of at
least one digital certificate on the identity credential for access control. This digital
certificate (and any optional digital certificates on the identity credential) must originate
from:
1) An agency certification authority cross-certified with the Federal Bridge
Certification Authority at medium assurance or higher by December 31, 2005; or
2) An approved Shared Service Provider. 8
Agencies must require the use of the identity credential for system access. Prioritize this
requirement based on risk, using your authentication risk assessments required by
previous OMB guidance and the categorization required by FIPS 199. 9 Document the
results and make available to your Chief Information Officer, security office and
Inspector General’s Office upon request.
You are already required to have rules of behavior in place (including the consequences
for violation) before employees and contractors are granted access to systems. 10 All
employees and contractors must have access to this documentation.

5. What acquisition services are available?
A. Requirement to use federally approved products and services – To ensure
government-wide interoperability, all departments and agencies must acquire products
and services that are approved to be compliant with the Standard and included on the
approved products list. A forthcoming Federal Acquisition Regulation will require the
use of only approved products and services.

7

NIST Special Publication 800-73: Integrated Circuit Card for Personal Identity Verification, 4/8/05,
http://www.csrc.nist.gov/publications/nistpubs/800-73/SP800-73-Final.pdf.
8
OMB Memorandum M-05-05: Electronic Signatures: How to Mitigate the Risk of Commercial Managed
Services, 12/20/04, http://www.whitehouse.gov/omb/memoranda/fy2005/m05-05.pdf.
9
OMB Memorandum M-04-04: E-Authentication Guidance for Federal Agencies, 12/16/03,
http://www.whitehouse.gov/omb/memoranda/fy04/m04-04.pdf and FIPS 199: Standards for Security Categorization
for Federal Information and Information Systems, 2/04, http://www.csrc.nist.gov/publications/fips/fips199/FIPSPUB-199-final.pdf.
10
See OMB Circular A-130 at http://www.whitehouse.gov/omb/circulars/a130/a130trans4.pdf.

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B. Use of GSA Acquisition Services – GSA has been designated as the “executive agent for
Government-wide acquisitions of information technology" under section 5112(e) of the
Clinger-Cohen Act of 1996 (40 U.S.C. § 11302(e)) for the products and services required
by the Directive. GSA will report to OMB annually on the activities undertaken as an
executive agent.
GSA will make approved products and services available through blanket purchase
agreements (BPA) under Federal Supply Schedule 70 for Information Technology, a
schedule under the Multiple Award Schedules (MAS) Program. When developing BPAs,
GSA will ensure all approved suppliers provide products and services that meet all
applicable federal standards and requirements.
Departments and agencies are encouraged to use the acquisition services provided by
GSA. Any agency making procurements outside of GSA vehicles for approved products
must certify the products and services procured meet all applicable federal standards and
requirements, ensure interoperability and conformance to applicable federal standards for
the lifecycle of the components, and maintain a written plan for ensuring ongoing
conformance to applicable federal standards for the lifecycle of the components.
C. Sponsorship – For small departments and agencies and agencies who share facilities
with another agency it may not be cost effective to procure your own products or
services. GSA will identify agency sponsors who will provide a range of services to
agencies. The extent and cost of services to be provided will be determined by agreement
between the sponsor and the customer agency.

6. How must I consider privacy in implementing the Directive?
You are already required under the Privacy Act of 1974 (5 U.S.C. § 552a), the E-Government
Act of 2002 (44 U.S.C. ch. 36), existing OMB policy and section 2.4 of the Standard to satisfy
privacy and security requirements. Implementing the Directive does not alter these requirements.
In addition, prior to identification issuance you must:
A. Ensure personal information collected for employee and contractor identification
purposes is handled consistent with the Privacy Act of 1974 (5 U.S.C. § 552a).
B. Assign an individual to be responsible for overseeing the privacy-related matters
associated with implementing this Directive.
C. Submit to OMB, and make publicly available, a comprehensive privacy impact
assessment (PIA) of your HSPD-12 program, including analysis of the information
technology systems used to implement the Directive. The PIA must comply with section
208 of the E-Government Act of 2002 (44 U.S.C. ch. 36) and OMB Memorandum M-0322 of September 26, 2003, “OMB Guidance for Implementing the Privacy Provisions of
the E-Government Act of 2002.” You must periodically review and update the privacy
impact assessment. Email your completed PIA to pia@omb.eop.gov.

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D. Update the pertinent employee and contractor identification systems of records notices
(SORNs) to reflect any changes in the disclosure of information to other Federal agencies
(i.e. routine uses), consistent with Privacy Act of 1974 (5 U.S.C. § 552a) and OMB
Circular A-130, Appendix 1. 11 These SORNs should be periodically re-reviewed to
ensure accuracy.
E. Collect information using only forms approved by OMB under the Paperwork Reduction
Act (PRA) of 1995 (44 U.S.C. ch. 35), where applicable. Departments and agencies are
encouraged to use Standard Form 85, Office of Personnel Management Questionnaire for
Non-Sensitive Positions (OMB No. 3206-0005) or the Standard Form 85P, Office of
Personnel Management Questionnaire for Positions of Public Trust (OMB No. 32060005) when collecting information. If you plan to collect information from individuals
covered by the PRA using a new form you must obtain OMB approval of the collection
under the PRA process.
F. Develop, implement and post in multiple locations (e.g., agency intranet site, human
resource offices, regional offices, provide at contractor orientation, etc.) your
department’s or agency’s identification privacy act statement/notice, complaint
procedures, appeals procedures for those denied identification or whose identification
credentials are revoked, and sanctions for employees violating agency privacy policies.
G. Adhere to control objectives in section 2.1 of the Standard. Your department or agency
may have a wide variety of uses of the credential not intended or anticipated by the
Directive. These uses must be appropriately described and justified in your SORN(s) and
PIA.
Note: OMB has established a small working group to develop model language for common
portions of the SORN, PIAs and Privacy Act Statements for department and agency use when
implementing the Directive. These products will be completed no later than October 27, 2005.

7. Is there anything else I must consider or know?
A. Paragraph 5 of the Directive asks departments or agencies to “identify those Federally
controlled facilities, Federally controlled information systems, and other Federal
applications that are important for security and for which use of the Standard in
circumstances not covered by this Directive should be considered” by August 26, 2005.
This determination should be consistent with the privacy requirements specified in
question 6 of this guidance and should include any uses of the Standard not meeting the
control objectives listed in the Standard. If you have identified other facilities,
information systems or applications, submit them to the Assistant to the President for
Homeland Security, with an electronic copy to the Office of Management and Budget at
eauth@omb.eop.gov.
11

See http://www.whitehouse.gov/omb/circulars/a130/a130trans4.pdf.

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B. Annual Reporting – The applicability section of the Standard requires annual reporting
on the numbers of agency issued credentials, to include the respective numbers of
agency-issued 1) general credentials and 2) special-risk credentials (issued under the
Special-Risk Security Provision on page v of the Standard). Future OMB guidance will
address this requirement.
C. Biometrics Implementation – This OMB guidance is being issued before finalization of
NIST Special Publication 800-76: Biometric Data Specifications for Personal Identity
Verification. Agencies may defer the capture of biometrics for the identity credential
until the NIST guidance is final.
D. Employees Serving Undercover – Agencies with employees who serve undercover shall
implement this Directive in a manner consistent with maintenance of the cover, and to the
extent consistent with applicable law and policy.
E. Relationship to Personnel Security Clearances –The directive reaffirms the existing
requirement, first enumerated in Executive Order 10450 of April 27, 1953 to conduct
background investigations on all Federal employees. This investigation is used to
determine suitability. Thus, the investigation required by the directive is not the same as
the investigations required for personnel security clearances or for public trust
determinations. The issuance of a security clearance is a discrete privilege and should be
done in accordance with applicable standards. Personnel security investigations for the
purpose of issuing security clearances or for the purpose of making public trust
determinations can be sufficient for the required background investigations required by
the directive.
F. Applying guidance to temporary employees and contractors – The requirements for
temporary employees and contractors should be viewed as the minimum requirements,
dependent on risk and other factors. Agencies who employ temporary personnel (e.g.
contract employment under special arrangements with schools, businesses, state and local
governments, etc.) should apply this guidance as follows:
•

Employed greater than 6 months – Apply all sections of this guidance, including
the background investigation requirements in the Standard (e.g. “completed National
Agency Check with Written Inquires [NACI] or other Office of Personnel
Management or National Security community investigation”).

•

Employed 6 months or less
a) Apply adequate controls to systems and facilities (i.e. ensuring temporary staff
has limited/controlled access to facilities and information systems).
b) Provide temporary employees and contractors with clear documentation on the
rules of behavior and consequences for violation before granting access to
facilities and/or systems.
c) Document any security violations involving these employees, and report them to
the appropriate authority within 24 hours.

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d) Identity credentials issued to these individuals must be visually and electronically
distinguishable from identity credentials issued to individuals to whom the
Standard does apply. Agencies should be careful not to develop policies which
overlap or contradict the Standard’s processes for identity proofing and issuance.
•

Occasional visitors
a) Apply adequate controls to systems and facilities (i.e. ensuring visitors have
limited/controlled access to facilities and information systems).
b) Develop agency-specific visitor policies (as appropriate).

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Attachment B
HOMELAND SECURITY PRESIDENTIAL DIRECTIVE/HSPD-12
August 27, 2004
Subject:
Contractors

Policy for a Common Identification Standard for Federal Employees and

(1) Wide variations in the quality and security of forms of identification used to gain access to
secure Federal and other facilities where there is potential for terrorist attacks need to be
eliminated. Therefore, it is the policy of the United States to enhance security, increase
Government efficiency, reduce identity fraud, and protect personal privacy by establishing a
mandatory, Government-wide standard for secure and reliable forms of identification issued by
the Federal Government to its employees and contractors (including contractor employees).
(2) To implement the policy set forth in paragraph (1), the Secretary of Commerce shall
promulgate in accordance with applicable law a Federal standard for secure and reliable forms of
identification (the "Standard") not later than 6 months after the date of this directive in
consultation with the Secretary of State, the Secretary of Defense, the Attorney General, the
Secretary of Homeland Security, the Director of the Office of Management and Budget (OMB),
and the Director of the Office of Science and Technology Policy. The Secretary of Commerce
shall periodically review the Standard and update the Standard as appropriate in consultation
with the affected agencies.
(3) "Secure and reliable forms of identification" for purposes of this directive means
identification that (a) is issued based on sound criteria for verifying an individual employee's
identity; (b) is strongly resistant to identity fraud, tampering, counterfeiting, and terrorist
exploitation; (c) can be rapidly authenticated electronically; and (d) is issued only by providers
whose reliability has been established by an official accreditation process. The Standard will
include graduated criteria, from least secure to most secure, to ensure flexibility in selecting the
appropriate level of security for each application. The Standard shall not apply to identification
associated with national security systems as defined by 44 U.S.C. 3542(b) (2).
(4) Not later than 4 months following promulgation of the Standard, the heads of executive
departments and agencies shall have a program in place to ensure that identification issued by
their departments and agencies to Federal employees and contractors meets the Standard. As
promptly as possible, but in no case later than 8 months after the date of promulgation of the
Standard, the heads of executive departments and agencies shall, to the maximum extent
practicable, require the use of identification by Federal employees and contractors that meets the
Standard in gaining physical access to Federally controlled facilities and logical access to
Federally controlled information systems. Departments and agencies shall implement this
directive in a manner consistent with ongoing Government-wide activities, policies and guidance
issued by OMB, which shall ensure compliance.

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(5) Not later than 6 months following promulgation of the Standard, the heads of executive
departments and agencies shall identify to the Assistant to the President for Homeland Security
and the Director of OMB those Federally controlled facilities, Federally controlled information
systems, and other Federal applications that are important for security and for which use of the
Standard in circumstances not covered by this directive should be considered. Not later than 7
months following the promulgation of the Standard, the Assistant to the President for Homeland
Security and the Director of OMB shall make recommendations to the President concerning
possible use of the Standard for such additional Federal applications.
(6) This directive shall be implemented in a manner consistent with the Constitution and
applicable laws, including the Privacy Act (5 U.S.C. 552a) and other statutes protecting the
rights of Americans.
(7) Nothing in this directive alters, or impedes the ability to carry out, the authorities of the
Federal departments and agencies to perform their responsibilities under law and consistent with
applicable legal authorities and presidential guidance. This directive is intended only to improve
the internal management of the executive branch of the Federal Government, and it is not
intended to, and does not, create any right or benefit enforceable at law or in equity by any party
against the United States, its departments, agencies, entities, officers, employees or agents, or
any other person.
(8) The Assistant to the President for Homeland Security shall report to me not later than 7
months after the promulgation of the Standard on progress made to implement this directive, and
shall thereafter report to me on such progress or any recommended changes from time to time as
appropriate.
GEORGE W. BUSH
# # #

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