Office of Disability Employment Policy (ODEP) Interim Policy for Disability.gov blog

Office of Disability Employment Policy (ODEP) Interim Policy for Disability.gov blog

1. Purpose. This Interim Policy for the Federal web portal Disabilty.gov creates and provides for the maintenance of a blog sponsored by the Office of Disability Employment Policy (ODEP) as part of the Disability.gov Web site.
2. Scope. This Policy establishes an external blog within the Federal initiative Disability.gov and is intended with a public-facing.
   1. The Disability.gov Working Group, which consists of representatives from the Office of Disability Employment Policy (ODEP), the Office of Public Affairs (OPA), the Office of the Solicitor (SOL) and operates at the direction of the Deputy Secretary of Labor, is responsible for this blog, as further detailed in paragraph 9 below.
   2. Any individual who has access to Disability.gov is eligible to voluntarily participate in the Disability.gov blog.Voluntary participants in this blog must agree to the “Terms of Use Agreement” to subscribe to this blog, and shall be hereafter referred to as a “blog user.”
   3. The appendices at the end of this Policy provide amplification and support to blog users in understanding, implementing, and managing a successful blog as follows:
      1. Appendix A – Blog Terms of Use Agreement is the document required to be displayed in the Disability.gov blog which governs access to, publishing of, viewing of, and participation in this blog.
      2. Appendix B – Blog Comment Policy is the document required to be displayed in the Disability.gov blog which governs content management within this blog.
      3. Appendix C – Terms & Definitions conveniently displays and defines technical terminology related to understanding, implementing, and managing the Disability.gov blog.
   4. Personal blogging on non-DOL servers by off-duty DOL employees is outside the scope of this Policy, and is subject to requirements regarding use of official title or affiliation with the Department. Specifically, the Government-wide Standards of Ethical Conduct for Executive Branch Employees provides that a federal employee may not use or permit the use of his/her Government position or title or any authority associated with his/her public office in a manner that could be construed to imply that his/her agency or the Government sanctions or endorses his/her personal views or activities. See 5 C.F.R. § 2635.702(b). Official activities or statements must be appropriately and officially authorized.
3. Applicability. This Policy applies to all blog users, as defined by subparagraph 2.a herein.
4. Background. A “blog” is derived from the term Web Log and is generally an informal means of transmitting information, graphics, and video about different subjects of interest.Blog users may post “comments” in response to blog posts from the blog’s authors or editors.
5. Policy. This Policy governs the establishment and availability to blog users of a blog for people with disabilities, their family members, service providers and others about disability-related topics including programs, polices, services, laws and regulations that impact people with disabilities.
   1. This blog will be viewable by the public at large. Topics posted to this blog will be relevant to people with disabilities, their family members, caregivers, employers, service providers, educators and others.
   2. All activity pertaining to this blog will be monitored by the Blog editor with the assistance of blog authors and blog administrators. For example, he/she will edit blog posts and moderate comments in accordance with this Policy.
   3. Both the Blog Terms of Use (Appendix A) and the Blog Comment Policy (Appendix B) will be clearly and uniformly posted on the blog.
   4. It is expected that comments may express views ranging from full support to total opposition for current policies or activities related to programs, policies, services, laws and regulations that impact people with disabilities. Full discourse will be allowed within the limits of the Internal Blog Comment Policy (Appendix B).
   5. Comments violating the Blog Comment Policy (Appendix B) will be removed.
   6. A record will be kept by the Disability.gov Working Group, using the blog software, of the full text of all comments received.
   7. The blog software, and its display of all posts and comments, must meet the requirements of Section 508 of the Rehabilitation Act as they pertain to computer programs and Internet Web services. (Subpart B — Technical Standards, § 1194.22 Web-based intranet and internet information and applications).
   8. Blogs are subject to the Federal Records Act and the DOL’s Web records Policy. All postings and all comments, whether published or rejected, are considered records.
   9. On a continuing basis, ODEP will collect and report, as requested, access and usage metrics to assess trends and to measure the effectiveness of the blog as a communication tool.
   10. Blog authors and users are not to include any Personally Identifiable Information (PII) in their posts, such as social security numbers, birth dates, personal e-mail address(es), home addresses, or personal telephone numbers.
   11. The Disability.gov blog will be open to blog users, as defined by subparagraph 2.a herein
   12. Blog users will be able to view all blog content and comments without logging into the blog system.
   13. Blog readers do not have to be subscribers of Disability.gov’s blog to post comments on blog entries.
6. Authority.This Policy is issued under the President’s Memorandum on Transparency and Open Government, dated January 21, 2009.
7. Applicable Laws and Regulations. The following laws and regulations, in addition to the programmatic laws administered by DOL, may be applicable to the Disabilty.gov blog:
   1. Federal Records Act. This law requires the proper maintenance and disposition of agency records to ensure adequate and proper documentation of the policies and transactions of the Federal Government. There are criminal sanctions for improper handling of Federal Records. (44 USC 2101 et seq., 2501 et seq., 2701 et seq., 2901 et seq., 3101 et seq. and 36 CFR Parts 1220, 1222, 1228, and 1234)
   2. Privacy Act. This law establishes fair information practices for the collection, maintenance, and use of personal information by federal agencies. It provides for civil and criminal penalties for failure to comply. (5 USC 552a)
   3. Hatch Act prohibits partisan political statements made by federal employees. The Act’s prohibitions, among others, preclude federal employees from using official authority or influence to interfere with an election, solicit, or discourage political activity of anyone with business before their agency, solicit or receive political contributions (may be done in certain limited situations by federal labor or other employee organizations), be candidates for public office in partisan elections, and engage in political activity while on duty or in a government office. (See 5 CFR Part 734.)
   4. Office of Management and Budget Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies, October 1, 2001. All DOL public Web site materials must be in compliance with the OMB guidelines on information quality, ensuring that the information is being presented in an accurate, clear, complete, and unbiased manner and is protected from unauthorized access or revision.
   5. Office of Government Ethics Regulations. Government employees and representatives of the federal government may not officially endorse outside entities, their products, or services, or imply official sanction of personal activities (5 CFR 2635.702). They may not disclose nonpublic information. (5 CFR 2635.703), and they may use government property and official time only for official purposes. (5 CFR 2635.704)
   6. Freedom of Information Act, (5 USC 552)
   7. Paperwork Reduction Act. Prohibition on calling for answers to identical questions posed to ten or more persons who are not federal employees without proper OMB clearance. (44 USC 3501 et seq.)
   8. Rehabilitation Act. Section 508 of the Rehabilitation Act of 1973 as amended. This law requires that agencies seek to ensure that individuals with disabilities have access to and use of information and data that is comparable to the access to and use of the information and data by individuals who do not have disabilities. (Pub. L. 93-112 as amended)
   9. Trade Secrets Act. A broadly worded statute that carries a criminal penalty for the unauthorized disclosure of commercial information by federal employees. (18 USC 1905)
   10. E-Government Act of 2002. Enhances the management and promotion of electronic Government services and processes by establishing a Federal Chief Information Officer within the Office of Management and Budget, and by establishing a broad framework of measures that require using Internet-based information technology to enhance citizen access to Government information and services, and for other purposes. A principal purpose of this Act is to promote use of the Internet and other information technologies to provide increased opportunities for citizen participation in Government. (PL 107-347)
   11. Department of Labor Manual Series – Information Technology Accessibility Management. Establishes policies and procedures within the U.S. Department of Labor (DOL) to implement Section 508 of the Rehabilitation Act of 1973, as amended (29 USC 794d). Section 508 requires Federal agencies to ensure that their electronic and information technology (EIT) products are accessible to people with disabilities, unless an undue burden would be imposed on the agency. (DLMS 9-600)
   12. Department of Labor Manual Series – Appropriate Use of IT. The Department has an Appropriate Use Policy that allows personal use of office equipment, the Internet, and e-mail during work hours on a limited basis if it does not interfere with an employee’s performance. Because this limited use is considered a privilege, employees have no inherent right or entitlement to use DOL office equipment for personal use. In addition, blog users do not have a right or expectation of privacy while using any Government office equipment at any time, including accessing the Internet and using e-mail. (DLMS 9, Chapter 900)
   13. This list is not exhaustive. Agencies should consult the Office of the Solicitor (SOL) for specific questions about the application of these or other laws.
8. Other Requirements.
   1. Records management, retention, and archiving. All records, including information posted, received, and/or connected in any way with this internal blog that meet the definition of a record, will adhere, and conform to applicable recordkeeping requirements. Refer to sub paragraph 7.a in this document for amplification.
9. Responsibilities.
   1. The Disability.gov Working Group will:
      1. Establish criteria for blog subjects.
      2. Solicit volunteer blog authors for content.
      3. Coordinate contributors (guest blog authors) and their content.
      4. Ensure monitoring and editing of blog posts, and moderation of blog comments, if necessary.
      5. Designate one or more Blog editors.
   2. The Blog editor(s) will:
      1. Coordinate with the blog authors, contributors (guest blog authors), and blog administrators on a weekly basis (or more frequently as needed or requested) to cooperate on the content production process, provide support as needed, suggest new topics,and assist in responding to blog comments.
      2. Review each post and comment. This will primarily be for internal governance policy considerations and legal issues. Other editing will be very light, essentially only to correct spelling or grammatical mistakes or edit content or comments, in accordance with Appendix B (Internal Blog Comment Policy).
      3. Add/update/edit/delete any posts.
      4. Add/update/edit/delete any comments (responses to blog posts).
      5. Create/edit/delete any categories.
      6. Receive e-mail notifications about comments added to a blog post.
   3. The Blog author(s) will:
      1. Add/update/edit/delete any posts and or other blog content.
      2. Add/update/edit/delete comments in accordance with the Internal Blog Comment Policy (Appendix B) and other DOL and federal regulations (e.g., removal of impermissible partisan political statements made by federal employees, in accordance with the Hatch Act).
      3. Create/edit/delete any categories.
      4. Receive e-mail notifications about comments added to a blog post.
      5. Post blog entries at least weekly and more frequently, when possible.
   4. Blog contributors (guest blog authors) only contribute content. Contributors will not have the capability to add/update/edit/delete posts.
   5. ODEP will:
      1. i) Manage and coordinate the implementation of this Policy in Disability.gov.
      2. ii) Coordinate review with the Office of the Solicitor for legal issues.
      3. iii) Establish and maintain DOL’s internal blog platform and software application, including the look and feel of pages for the posts, comments, Comment Policy, blog description, archives section, and others, as required.
      4. iv) Designate one or more ODEP federal employees as blog administrator(s). The ODEP blog administrators will have access to the complete system and will be able to perform the following actions:
         1. Create/edit/delete users.
         2. Grant/modify permission levels to users.
         3. Create/update/edit/delete any blogs.
         4. Add/update/edit/delete any posts.
         5. Add/update/delete any comments.
         6. Create/edit/edit/delete any categories.
         7. Generate reports.
         8. Establish and collect “metrics.”
         9. Send E-mail notifications.
      5. Establish recordkeeping requirements in consultation with the DOL Records Manager.
   6. The Office of the Solicitor will provide legal advice and assistance for activities under this Policy.

Appendix A – Disability.gov Blog Terms of Use Agreement

The following “Terms of Use Agreement” will be linked from every page in the blog:

Disabilty.govBlog

The Disability.gov blog is intended to be a forum to discuss disability-related topics and solicit ideas, feedback, questions and comments on disability matters including Federal programs, policies, laws and regulations that impact people with disabilities. Disability.gov’s blog is part of the Federal government’s commitment to ensuring that a broad range of Americans are active and informed participants in discussions about disability-related issues.

Blog Sponsor: Disability.gov Working Group

As part of the federal government’s commitment to transparency and open government, the Disability.gov Working Group and the Department of Labor have established a blog on disability-related topics  for people with disabilities, their family members, employers, service providers and others to voluntarily participate in online conversations about programs, policies, laws and regulations that impact people with disabilities. By accessing or participating in this internal blog, you agree to abide by the following terms.  The Disability.gov Working Group is responsible for managing the content on the blog.

1. Disability.gov’s blog is designed to offer a forum for online conversations about disability matters. Blog users and posters must comply with all Department of Labor internal governance policies applicable federal laws.  Blog users and posters are encouraged to write in an honest, informal tone and to foster productive, candid dialogue that can help users learn from one another.
2. Disability.gov’s blog is for and about the people with disabilities. The dialogue should be about programs, policies, services, laws and regulations that impact people with disabilities, and other disability-related topics.
3. You understand and agree that neither the Department of Labor nor the United States government is responsible for the content of the comments or posts to these blogs by you or any other blog user. Neither the Department of Labor nor the United States vouches for the accuracy or reliability of any comments or posts. The Department of Labor or the United States will not be liable for any loss that arises from relying on information provided on this blog, and you agree not to hold Department of Labor, the United States or any employee or agent of either the Department or United States responsible for any comments or posts.
4. If you choose to comment or post to the Disability.gov blog, you agree that you will identify yourself and that you understand you will not retain any rights to or ownership in the content you provide in your post.
5. If you post data, quotes, or other information, you are acknowledging and agreeing that you own or have the right to use and to allow the Department of Labor to use such items as permitted by these terms. You also acknowledge that such items have not been manipulated or altered in any manner so as to distort or misrepresent any individual or thing depicted in them.
6. Disability.gov partners may participate in ongoing conversations as their work schedules allow.
7. While the posting of comments is -moderated, and the blog’s author, editors, and administrators reserve the right to delete or edit any comment or post to Disability.gov’s blogs if it is found not to comply with the posted Comment Policy.
8. The Office of Disability Employment Policy and the Disability.gov Working Group reserve the right to revise these terms at any time. Changes to the rules will be effective when posted on Disability.gov. Your continued use of Disability.gov’s blog will be considered acceptance of those changes. 
9. The Office of Disability Employment Policy and the Disability.gov Working Group may discontinue or suspend this external blog at any time.

Appendix B – External Blog Comment Policy

The following “Blog Comment Policy” will be linked from every page in the blog:

“We encourage your comments; your ideas and concerns are important to ensure that a broad range Americans are active and informed participants in discussions about disability-related issues.

Opinions and comments expressed by the author in entries and responses published in this blog are not intended nor are to be construed as policy, law, rulemaking, setting a precedent, or a request for information or advice to the public on behalf of the Secretary, Department of Labor, a Department of Labor employee, or any other representative or entity of the United States Government at any time.

This is a moderated blog. Comments are accepted and encouraged Blog users do not have to be subscribers of Disability.gov’s blog to post comments on blog entries. When comments are posted on the blog, the blog poster will be asked to enter in his or her name and email address, but this information will not be displayed along with their comments. The information is only used for the blog owner in case of the need to remove an entry for any reason. DOL expects that participants will treat each other with respect. All comments posted will be reviewed on a daily basis before they are posted. While the clear intent is to allow open and frank discussion on issues and subjects raised by the author, in the interest of time and space, the author reserves the right to select comments to be removed. We will remove comments that contain vulgar language, personal attacks of any kind, innuendo, or offensive terms that target specific groups. We will remove comments that are spam, are off topic, or that promote non-governmental financial interests. Comments that make unsupported accusations will also be removed.

To protect your own privacy and the privacy of others, do not include personal phone numbers, personal e-mail addresses, or any other Personally Identifiable Information (PII) in the body of your comment. If comments contain such information, a reasonable attempt will be made to remove any PII. Do not include contract-sensitive or government-held proprietary information in comments. Subscribers should also understand that any comment submission is considered a public communication subject to disclosure under law and, as such, any confidentiality or promise thereof, implied or otherwise, is not guaranteed nor offered.

If you do not see your comment, unfortunately, we are not able to contact you individually with an explanation as to why your comment was not published.

Comments containing questions or requests to United States Government officials may or may not be answered directly on this blog or via other means. The author reserves the right to respond directly to questions, or not. While this blog’s aim is to foster transparency, discourse, and employee involvement, it is not intended to replace or substitute for other channels of communications within the United States Government and its agencies, offices, entities, and programs.

Thank you for taking the time to read this Comment Policy. We encourage your participation in our discussion and look forward to an active exchange of ideas.

Any entries made and comments posted on this blog express the views of each respective author of the comment and not the Department of Labor or the United States Government.”

Appendix C – Terms & Definitions

The following terms and definitions (adapted from Wikipedia and the DOL blog software) may be helpful when understanding the implementation and management of blogs within Disability.gov.

1. Administrator (ODEP) is responsible for the administration and management of the Disability.gov blog system (server and software). Provides technical support to blog authors and editors. Also exercises systems administrator rights and privileges over all Disability.gov blogs. Monitors and edits/deletes blog posts and comments in accordance with Disability.gov’s Blog Policy. The ODEP Administrators will have access to the complete blog system.
2. Author (synonymous with blogger) refers to the individual who posts material and monitors others’ submissions to the blog. Within the Disability.gov system, the author is the person primarily responsible for maintaining the blog, its upkeep, reviewing comments to it, and compliance with all applicable requirements.
3. Blog (short for “Web Log”) refers to an easily, instantly and frequently updated Web site usually focused around a topic, industry or personality. An informal means of transmitting information, graphics, and video about different subjects of interest, blogs are defined by their format: a series of entries posted to a single page in reverse-chronological order. Blogs generally represent the interests of the agency author or reflect the purpose of the Web site that hosts the blog.
4. Blogging refers to the act of blogging, i.e. authoring and posting content on a blog.
5. Blog user is any individual who has access to Disability.gov and who voluntarily participates in Disability.gov’s blog by agreeing to the Terms of Use Agreement and subscribing to the blog.
6. Category refers to the categories that blog entries can be assigned to, such as Jobs, transportation, health, etc. so that viewers can select on those terms and see all blog entries that relate to that category.
7. Comments refer to responses to a blog post submitted by a blog’s readers or written in response to readers by the blog’s author. Individual pages on the blog displaying the author’s post usually have links to comments on specific postings.
8. Contributor refers to a blog user who is invited by the Editor to write a blog post or posts on a temporary basis. The Contributor will create the content for the posts and submit the content to the Editor, and the Editor reviews, approves and enters the post in the blog.  To edit the post, the Contributor will submit the content to the Editor and the Editor updates the posts. For example, if the Author for a blog is on vacation, a Contributor could fill in during his or her absence.
9. Editor collaborates with his/her Authors by providing support and additional manpower, if needed. Also responsible for monitoring and editing blog posts and comments in accordance with the Disability.gov Blog Policy. The editor interfaces with the agency head and DOL OPA for blog implementation and vetting. Regularly meets with OPA and Authors to support ongoing Disability.gov blog efforts.
10. External blog is a blog accessible and viewable by the public at large.
11. Link uses hypertext to establish a selectable connection from one word, picture, or information object to another.
12. Permalink refers to a link to a blog post’s unique Web page. It is the unique URL of a single post on a blog, used when anyone wants to link specifically to a post rather than to the most recently updated page of a blog. A permanent and direct link to a particular blog post.
13. PII (Personally Identifiable Information) means any information about an individual that includes, but is not limited to, financial transactions, medical or criminal history, and information that can be used to distinguish or trace an individual’s identity, such as his or her name, Social Security number, date and place of birth, mother’s maiden name, biometric records, etc, including any other personal information that is linked or linkable to an individual.
14. Subscribers, as defined above, are Disability.gov blog users  who are registered in the blog system. Blog users do not have to be subscribers of Disability.gov’s blog to post comments on blog entries. When comments are posted on the blog, the blog poster will be asked to enter in his or her name and email address, but this information will not be displayed along with their comments. The information is only used for the blog owner in case of the need to remove an entry for any reason.