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This session provides an overview of OMB memos regarding cookie usage on government websites, focusing on their impact on web analytics and user customization. It discusses three tiers of cookies as defined by OMB M-10-22, including session and persistent cookies, and explores the potential benefits of enhanced web services akin to those of private sectors. Additionally, it addresses updates already made to privacy notices and disclaimers and outlines critical decisions for the EPA regarding cookie implementation policies, ensuring compliance with federal requirements.
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Cookies…Food for Thought Amanda Sweda and Charlotte Cottrill WWG – Chicago 2010
Purpose of Session • Overview of OMB memos and cookies • Discussion of Relationship between Cookies and Web Analytics/Metrics • What We Have Already Done • What We Need to Do – Decision Points and Actions
What are the OMB Memos? • OMB M-10-22 Guidance for Online Use of Web Measurement and Customization Technologies: http://www.whitehouse.gov/omb/assets/memoranda_2010/m10-22.pdf • OMB M-10-23 Guidance for Agency Use of Third-Party Websites and Applications: http://www.whitehouse.gov/omb/assets/memoranda_2010/m10-23.pdf
Cookies in OMB M-10-22 • Three types of Cookies Covered by M-10-22 • Session Cookies – Tier 1 • Persistent Cookies – Tier 2 • Persistent Cookies with PII – Tier 3
Relationship with Web Analytics • Allows customization of pages • Allows gov’t websites to provide services similar to non-gov’t sites…on pages like My EPA, My Environment • Allows for expansion of some of our current web analytics and supports future capabilities
What We Have Already Done • Privacy and Security Notice has been updated • to accurately reflect the Privacy Impact Assessment (PIA) requirements • to include third party information and a list of social media tools used at EPA • Exit Disclaimer and Third Party Disclaimer • EPA has exit disclaimer (widely used) http://www.epa.gov/epahome/exitepa.htm and new third party disclaimer http://www.epa.gov/epahome/thirdparty.html • We are working with OEA and OGC to finalize and merge the two disclaimers. In progress.
What We Need to Decide • Will EPA use persistent cookies (Tier 2) on all EPA pages? • If EPA uses persistent cookies, will it be an opt out option or an opt in option? • Will we allow persistent cookies with PII (Tier 3) with a waiver?
What Will Be Done… • Cookies Procedure must be updated regardless of decisions to accurately reflect the OMB requirements in the memos. • Privacy and Security notice will need to be updated if persistent cookies are allowed • Exit Disclaimer will be updated
Contacts: Amanda Sweda sweda.amanda@epa.gov (202) 566-0678 Charlotte Cottrill Cottrill.charlotte@epa.gov (202) 566-0684