Privacy Policy Development & Implementation

privacyJustice organizations that develop integrated justice information sharing systems and strategies must develop or expand policies that protect the privacy of the information maintained within those systems. 

The specter of the theft or inappropriate use or disclosure of private and confidential information prompts many organizations, including justice agencies, to reexamine their privacy policies and to update them if necessary, or to create responsible and effective policies if none exist. 

In addition, a high priority for the justice community is to convert privacy policy to a form understandable to computers—in other words, supporting privacy policy implementation through automation. 

Policy Development

The primary objective of a privacy policy is to demonstrate how an agency intends to abide by existing laws and public expectations for handling personally identifiable information, PII for short, which can be used to uniquely identify an individual. PII protection is particularly important in the criminal justice environment, as those from whom the information is collected—such as crime victims, witnesses and others—are often not willing participants in the criminal justice process.  Information in expunged or sealed criminal records should also be protected by strong privacy policies. These policies should address how a justice entity intends to deal with gaps or vulnerabilities in existing laws that govern PII management. 

For years, SEARCH has assisted States and supported national efforts to develop privacy policies by conducting conferences and workshops; convening task forces; developing reports and guides; participating in privacy initiatives of national working groups; and providing expert assistance. 

privacyIn particular, SEARCH has participated in helping develop privacy resources under the Global Justice Information Sharing Initiative.  SEARCH developed a Guide to Conducting Privacy Impact Assessments for State, Local, and Tribal Information Sharing Initiatives, which Global adopted and published as a resource in its privacy toolkit.  This guide allows justice practitioners to examine the privacy implications of their information systems and information-sharing collaborations so they can design and implement policies to address vulnerabilities identified through the assessment process. It also includes a privacy impact assessment template that jurisdictions can use to conduct their assessments.

PIA Guide
PIA Template 

Technical Implementation

Meanwhile, converting privacy policy to a form understandable to computers continues to be a significant technical challenge and priority for the justice community.  The Global Privacy Technical Framework fills this need by providing a comprehensive approach and powerful tools to help justice and public safety practitioners automate the enforcement of policy provisions that protect privacy, as well as civil rights and civil liberties. The goal is to provide an approach and framework to protect privacy that is applicable to information sharing in the justice environment and that can be readily implemented using existing information technology architectures, standards, and software tools. 

SEARCH participated in developing the Global framework and is available to assist agencies with implementing it—particularly since it can be implemented using existing IT architectures, standards (GRA, NIEM, GFIPM), and software tools.  

Additional Resources

Need advice on developing a privacy policy, or the technical aspects of implementing it in an information sharing system? Want resource materials? SEARCH is here to help through the following tools, resources and publications:

Karen Lissy

Ms. Karen Lissy is a Justice Information Services Specialist for the Law and Policy Program of SEARCH, The National Consortium for Justice Information and Statistics. In this position, she provides assistance to state and local justice and public safety agencies to collect, curate, and use National Incident-Based Reporting System (NIBRS) data and computerized criminal history record (CCH/CHRI) information for policy analysis and development.

She also guides justice and related organizations in how to craft and implement laws, policies, practices, and technology applications to effectively collect and use CCH and related justice/public safety data; address legal, policy, and regulatory issues associated with CCH data; better manage and operate criminal justice information and identification systems; and develop security and privacy policies that protect justice information sharing systems.

Ms. Lissy has nearly two decades of research and data analysis experience, having led projects and tasks in support of two agencies within the U.S. Department of Justice’s Office of Justice Programs (the Bureau of Justice Statistics and National Institute of Justice), as well as the Centers of Disease Control and Prevention, and multiple foundations, including Ford, Annie E. Casey, and Hewlett. Prior to joining SEARCH in October 2020, Ms. Lissy served as a Social Science Researcher at RTI International, as a regional Crime Analyst for the Redmond (WA) Police Department, and as Director of a research program with the Harvard Center for Risk Analysis. Beginning in 2012, Ms. Lissy’s work has focused on improving data in law enforcement to answer policy questions and improve community/police relations.

Ms. Lissy earned a Bachelor’s degree in Public Policy from Duke University, and a Master’s in Public Health from the University of North Carolina at Chapel Hill.

Michael Mackay

Mr. Michael Mackay is an Information Sharing Developer for SEARCH, The National Consortium for Justice Information and Statistics. As part of the Software and Data Engineering Program (SDEP) team, he plans, develops, implements, and deploys information sharing systems on behalf of SEARCH clients in local, state, tribal, and Federal government settings. He also provides programming, configuration, and testing assistance, and consults on implementation architecture and design with clients. 

Mr. Mackay supports justice, public safety, and homeland security information sharing nationwide through SDEP services that include software architecture and systems design, application development, deployment and support, data management services, and direct technical assistance and training. These services offer capabilities that include federated query, authentication access/control, subscription/notification, process/workflow automation, data analysis, and more. 

Prior to joining SEARCH in 2021, Mr. Mackay worked as a Software Engineering Intern for TDM Business Toole Suite, where he provided software development support using Java frameworks, implemented relational database models using MySQL, and designed GUI components using NetBeans. 

Mr. Mackay will work in an Agile development environment, a methodology that SEARCH embraces that focuses on incremental development and delivery, collaboration in a team approach, and rapid and flexible response to change throughout the development cycle. 

Mr. Mackay earned a bachelor’s degree in Computer Science and Applied Mathematics and Statistics from Stony Brook University, New York.