HHS IRM Policy for Use of Broadcast Messages, Spamming and Targeted Audiences
January 8, 2001
HHS-IRM-2000-0004
TABLE OF CONTENTS
- Purpose
- Background
- Scope
- Policy
1. Purpose
This document establishes the policies and procedures to regulate the distribution
of e-mail when addressed to large numbers of Department of Health and Human
Services (HHS) staff. It addresses e-mail generated both from within and
outside the Department.
2. Background
Since 1994, Office of Information Resources Management (OIRM) within the
office of Assistant for Secretary for Management and Budget (ASMB) has been
sending out electronic mail messages to all or selected subsets of HHS employees.
These e-mail broadcasts are made possible by the use of custom software
that automates the collection of e-mail addresses from across the Department
and the creation and transmission of the needed e-mail messages themselves.
This system was originally established to support the needs of the Secretary
to communicate with all HHS employees. While most messages have been distributed
in the SecretaryÆs or Deputy SecretaryÆs names, an increasing number have
been from other sources. Additionally there have been increasing inquiries
about sending messages from other sources within the Department.
The objective in establishing rules is to balance the legitimate needs
of the Government to distribute information related to the DepartmentÆs
mission against the attendant costs when many employees must sort through
messages of questionable relevance to their work. Messages sent to employees
have entailed cost impacts of: recipients taking time to review them, computer
resources to process them, and support staff to keep the systems safe and
operational. Given these potentially conflicting demands it has been necessary
to maintain a cost-effective balance to maximize the efficiency of the DepartmentÆs
operations. The Department has not yet been the subject of repeated significant
"spamming" or other efforts to disseminate large amounts of non-Governmental
mail. However, the Department needs to plan for it and promulgate policies
to manage large-scale mailings both from within and outside the organization.
Despite the degree of automation achieved in the current system, significant
manual effort is still involved to assure successful transmission, monitor,
and re-direct employee responses to the broadcasts.
In July 1996 the Secretary signed a memorandum to OPDIV heads requesting
their assistance in improving the ease of electronic communication across
the Department. Specifically, the Secretary asked the OPDIV heads to give
attention to improving the quality and availability of electronic directory
information. Also, in May 1996, a technical note on the HHS electronic directory
was adopted by the HHS Information Resources Management Advisory Council
and approved by the ASMB. The technical note, which is a mandatory technical
standard and applies to all DHHS organizations, stated in part: "The Department
maintains a central directory in electronic form of all DHHS employees.
This directory contains access and descriptive information, such as phone
number, electronic mail address, and organization for each employee. Each
OPDIV is responsible for maintaining accurate, complete information on their
employees and providing it to the central directory on a timely basis."
The note can be found at http://www.os.dhhs.gov/progorg/oirm/hhsdir96.htm.
The e-mail broadcast system depends on the accuracy of the central HHS
staff directory to reach the maximum number of employees. All employeesÆ
e-mail addresses in the Departmental directory is not sufficient to ensure
that targeted e-mail broadcasts (e.g., to the Metropolitan Washington area
or the Southwest Complex) reach their intended audience if key directory
information (e.g., phone number, building name) needed to differentiate
employees into appropriate groups is not accurate (see Appendix A).
Broadcast messages are by their nature indiscriminate in terms of knowing
ahead of time the employeeÆs interests. This is unavoidable and a balance
must be found between the value of the messages being placed in e-mail and
the time occupied by employees in receiving them. This requires a policy
that limits such transmissions to those for which a reasonable business
need exists, as opposed to simply broadcasting everyone. As the number of
messages increases, coming from numerous sources both in and outside of
the Department, and as the tools for sending e-mail broadcasts become more
widely available, a controlling policy is warranted. This is necessary both
to minimize the potential waste of employeesÆ time in screening these messages
and in maintaining the sense of importance for those that are sent.
3. Scope
This policy establishes the rules and guidelines for the use of e-mail
broadcasts initiated by any HHS employee or contractor using HHS computers,
networks, and software and sent to a large number of individuals. The policy
addresses three areas requiring management of broadcasts: (a) those relating
to HHS business that involve transmission to a large number of employees;
(b) requests from individuals and organizations to use the broadcast capabilities
for other purposes; and (c) the problems associated with the growing ability
of external organizations and individuals to use HHS electronic directory
information to send broadcast messages to HHS employees from outside the
Department. This policy excludes mailings to lists where the recipients
individually requested the mail by signing up for a listserver.
4. Policy
- The
Executive Secretariat (ES), located in the Immediate Office of the Secretary,
shall be the approval authority for all e-mail broadcast requests originating
from the Secretary, Deputy Secretary, Chief of Staff, or White House,
or otherwise involving Secretarial matters.
- (1) Officially sponsored events that do not require Secretarial involvement;
(2) administrative items; and (3) requests to publicize HHS activities
or events that are not officially HHS-sponsored, are referred to the
OPDIV designated approving official (e.g., CIO) of the OPDIV wishing
to send the message. Examples of officially sponsored events would include
Department sponsored courses, blood drives, health insurance information
fairs, and the like.
Any message being sent to more than one OPDIV is sent by the
approving official in the OPDIV (except as noted in 4.5 below) to the
Assistant Secretary for Management and Budget (ASMB) for approval.
- Authority to distribute broadcasts may be delegated to accommodate
urgent needs. For example, the OS Office of Facilities Services will
have delegated authority to send out notices when emergency situations
occur in the Humphrey or Cohen Buildings affecting matters such as water
quality, blocked building access, demonstrations, or the like.
- Each OPDIV may implement procedures, as needed, consistent with the
Departmental policy, to manage the transmission of e-mail broadcasts
within their own organization (that is from within that OPDIV to the
employees of that OPDIV).
- Other cross-OPDIV e-mail broadcasts that are agreed upon by all the
organizations that are to receive the e-mail are transmitted as appropriate
(e.g., broadcasts to all HHS employees within a region or building)
by one and only one of the participating organizations.
- The Assistant Secretary for Public Affairs shall approve all e-mail
broadcasts that include recipients outside the Department, including
those generated by the Operating Divisions.
- Activities and events that are not officially HHS-sponsored may
be transmitted under the following circumstances (all items must apply):
- the activity/event is sponsored by an officially recognized HHS
employee organization (see 6. Applicable Laws/Guidance) or the activity/event
is sponsored by an officially recognized employee organization in
another agency and that agency has endorsed the activity/event;
- the subject is of general interest and not a personal matter (e.g.,
no requests for leave donations, retirement notices, birth or death
announcements, job location changes, etc. shall be sent by the Department);
- adequate notice is provided by the requester to address any policy
or technical questions that are raised;
- the material is formatted as required by HHS standards (current
standards are attached);
- staff and computer resources are available for transmission;
- the content is reviewed by the employeeÆs manager and approved by
the designated OPDIV level clearance authority prior to distribution;
and
- the message content does not fall within the restrictions in 4.8
- Items that are generally not approved for distribution (except at
the direction of the Immediate Office of the Secretary/Executive Secretariat
[IOS/ES]):
- any charitable activities involving cash except for the Combined
Federal Campaign. (e.g., information on an activity like WomenÆs Race
for the Cure would not be broadcast because it involves cash payments
by employees, but broadcasts involving the collection of non-cash
donations, such as clothing, toys, or food may be allowed if other
requirements are met. In accordance with 5 CFR 950.102, the Combined
Federal Campaign is the only authorized solicitation of federal employees
for money. Collections of gifts-in-kind (e.g., food, clothing) are
permissible under this policy);
- messages that are of political, religious, or other similarly sensitive
nature;
- anything for commercial gain;
- reminders of upcoming events/activities that have been previously
broadcast except for notifications of blood drives, unless the reminders
have been formally cleared for re-distribution; and
- security warnings, instructions, or information by a person other
than the responsible security officials.
- Communications from the public are welcomed by e-mail when sent to
the specific individuals or offices that are responsible for the topic
matter of the letter. A directory of addresses can be found at http://directory.psc.gov/.
General mailings that are directed at everyone in the Department, or
to large components of it and interfere with the operations of the Department
are subject to being blocked without prior notice to the sender. Requests
from outside the Department for e-mail distribution shall be addressed
to the office in HHS that has direct responsibility for the topic of
the message. If no such HHS office exists, then it is likely that the
topic of the message is not appropriate for handling within this Department.
These messages shall be directed to ASMB/OIRM for resolution.
- Mail that is considered by the recipient to be interfering with Government
operations may be referred by ASMB/OIRM to the appropriate ethics office,
law enforcement office, OIG Office of Investigations, and/or the Internet
Service Provider of the sender. Offensive e-mail such as e-mail of a
violent, pornographic, racist, or sexist nature violates the Departments
efforts to maintain a family friendly workplace and shall not be distributed.
If it is, the sender may be subject to adverse personnel action (for
employees) and /or prosecution.
- Individual employees or contractors are not authorized to transmit
e-mail broadcast messages except through formal approval as specified
in Section 4. Unauthorized or inappropriate use of HHS IT resources
could result in loss of use or limitations on use of equipment, disciplinary
or adverse actions, criminal penalties and/or employees or other users
being held financially liable for the cost of inappropriate use.
- Wherever possible, information should be placed on the Departmental
and OPDIV Intranets or the Internet in lieu of using e-mail broadcasts.
If an e-mail broadcast is sent, it shall reference web universal resource
locators (urls) rather than attaching a document, to the extent possible.
5. Roles and Responsibilities
- The
HHS Executive Secretariat (ES)
The ES shall clear all email broadcast requests originating from the
Secretary, Deputy Secretary, Chief of Staff, or White House, or otherwise
involving Secretarial matters.
- The Assistant
Secretary for Management and Budget (ASMB)
The ASMB shall have final responsibility for decisions on whether to
send or not send any given message except for messages covered in 5.1
above.
- The Assistant Secretary
for Public Affairs (ASPA)
ASPA shall review and approve any broadcast messages that will be sent
to recipients outside the Department.
- The Office of Information
Resources Management (OIRM)
OIRM is responsible for:
- Maintaining office support to coordinate with the OPDIV approving
officials for broadcasts;
- Maintaining procedures for requesters to submit e-mail broadcast
requests. These procedures may change over time without re-issuance
of this policy.
- Maintaining a centralized capability for HHS wide-scale broadcasts;
- Sending a message to the requesting organization, when disapproving
a request to send a broadcast message, stating that the request could
not be accommodated, along with the reason for disapproval. (Questions
and disputes are referred back to the HHS ASMB).
- Submitting Organization
(for e-mail broadcasts distributed by the Department)
The submitting organization is responsible for proofreading, fact checking,
formatting and clearance of any document proposed for transmission.
Additionally, the submitting organization
is required to identify an individual to receive and handle any e-mail
or telephone responses to each specific message. Documents shall be
submitted with sufficient lead time and formatted as specified in the
submission procedures (see Appendix B).
- OPDIV Head
Each OPDIV Head is responsible for:
- Designating a central point of contact for clearance approval on
broadcasts and notifies HHS OIRM who has been designated;
- Promulgating and enforcing appropriate e-mail policies and procedures,
as needed, consistent with the Departmental policy, for broadcasts
from within their OPDIV; and
- Assuring that this policy is followed and recommending changes,
as needed, to the HHS CIO.
- Employees
Employees are responsible for not sending broadcasts except as directed
in this policy at section 4.11.
6. Applicable Laws/Guidance
HHS General Administration Manual, Chapter 25-10: DHEW Employee Welfare
and Recreation Associations.
7. Information and Assistance
Direct questions, comments, suggestions or requests for further information
to the Deputy Assistant Secretary for Information Resources Management,
(202) 690-6162.
8. Effective Date/Implementation
The effective date of this policy is the date the policy is approved.
These policies and procedures will not be implemented in any recognized
bargaining unit until the union has been provided notice of the proposed
changes and given an opportunity to fully exercise its representational
rights.
The HHS policies contained in this issuance shall be exercised in accordance
with Public Law 93-638, the Indian Self-Determination and Education Assistance
Act, as amended, and the Secretary's policy statement dated August 7,
1997, as amended, titled "Department Policy on Consultation with American
Indian/Alaska Native Tribes and Indian Organizations." It is HHS' policy
to consult with Indian people to the greatest practicable extent and to
the extent permitted by law before taking actions that affect these governments
and people; to assess the impact of the Department's plans, projects,
programs and activities on tribal and other available resources; and to
remove any procedural impediments to working directly with tribal governments
or Indian people.
9. Approved
_____/s/_____________________________ 01/08/01
John J. Callahan
Assistant Secretary for Management and Budget
E-mail broadcast - Transmission of a single electronic mail message
to large numbers of HHS employees or external recipients. The intended
meaning here is messages sent indiscriminately with the intent to reach
all or most of the e-mail addresses in an organization or geographic area.
The use of listservers to reach multiple recipients where those on the
list have chosen to subscribe are excluded. This also excludes targeted
messages to lists of employees maintained for specific business purposes
(e.g., security-related messages to a list of security officers).
Spam - Spam, in general usage, refers to commercial senders of
massive amounts of e-mail to all addresses they can find. It is frequently
sent from addresses that are forged to bypass filters intended to block
them. The content of spam often involves commercial scams, gambling, and
the sale of pornography.
Appendix A: Existing Departmentally
Maintained Distribution Lists
At this time OS/ASMB/OIRM maintains the following lists:
List name
|
Geographic area of coverage
|
HHS-L
|
All HHS
|
METROWASHINGTON-L
|
Metro DC area including area codes 202,301,703,410
|
METRODC-L
|
Metro DC like above but without 410 (Baltimore)
|
SWCOMPLEX-L
|
Washington, DC (includes all HHS employees in DC)
|
HHH-COHEN-SWITZER-L
|
HHH, Cohen, and Switzer Buildings
|
HHH-BUILDING-L
|
Humphrey Building
|
COHEN-L
|
Cohen Building
|
SWITZER-L
|
Switzer Building
|
PARKLAWN-L
|
Parklawn Building
|
HHS-OS-L
|
Office of the Secretary û all employees
|
OS-AOA-ACF-L
|
OS, AoA, ACF û all employees
|
Appendix B: Submission Procedures
for E-mail Broadcasts to be Distributed by the Department
As specified in the "Policy on Use of Broadcast Messages, Spamming,
and Targeted Audiences," broadcast messages must be:
- Requested by an official HHS office or activity
- Approved by the sending OPDIVÆs designated approving official. Each
OPDIV can delegate this at their discretion but a single point of contact
for each OPDIV needs to be listed with broadcast.request@os.dhhs.gov.
Technical specifications and requirements for messages:
For distribution across OPDIVs, the message must meet all the following
criteria (unless waived by IOS/ES):
- Messages must be in plain ASCII and entirely contained in a message
of less than 20,000 characters. Each line must be no longer than 72
characters and terminated by a hard carriage return. No special characters
are allowed (e.g., underscores, italics, etc.) This is necessary to
assure that the message is readable to all systems receiving it.
- Attachments shall not be allowed. Attachments double the impact on
e-mail systems. Instead of attachments, the message should contain a
web url(s) that links to the attachments.
- All messages must clearly indicate the originating office and subject
at the top of the message.
- All messages must use a subject line of no more than 23 characters
in length. (Some systems truncate after 23 characters.)
- Graphics composed of ASCII characters are strongly discouraged since
they tend to appear garbled on various systems.
- Messages must be sent from an address with a working mailbox to receive
replies.
- References to web sites should be preceded with http:// or https://.
(This will allow them to be automatically hyperlinked in many mail systems.)
PROCEDURES: E-mail requests from within the Department may be addressed
to broadcast.request@os.dhhs.gov.
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