Revise HUD’s Controlled Unclassified Information Policy to include the anti-gag provision.

Revise HUD’s Controlled Unclassified Information Policy to state that (a) nondisclosure forms and agreements must include the anti-gag provision as required by law and (b) confidentiality clauses in personnel settlement agreements must include the anti-gag provision if the clause restricts disclosure of any other information beyond the terms and conditions of the agreement itself.

HUD’s Privacy Office should require program offices to periodically review systems in all environments (testing, development, production) for unnecessary disclosure of personally identifiable information (PII).

We recommend that the Chief Procurement Officer update HUD’s field service manager contract monitoring plan and FSM qualitative monitoring databases used to monitor contractor performance to align with the QASP and contractual requirements as noted in recommendation 1G below.

Update and obtain final NARA approval of all HUD records retention schedules, including the Capstone email schedule, to comply with Federal requirements, including OMB M-19-21.

Develop and approve an enterprise strategy to meet all M-19-21 electronic transition requirements.

Issue a formal policy and requirements for managing CUI.

Complete the development of performance measures and establish a formal records evaluation process to measure the effectiveness and progress of the records management program.

Develop the technical capability to identify, inventory, and monitor the existence of PII within the HUD environment

Develop and implement a process to inventory all agency PII holdings not less than annually.