Terms of Service
TOUCHPOINTS TERMS OF SERVICE FOR HIGH IMPACT SERVICE PROVIDERS
ADMINISTERED BY THE U.S. GENERAL SERVICES ADMINISTRATION
Version 1.0, updated: 07/18/2019
1.0 SERVICE SUMMARY
“Touchpoints” is an open-source software application created and maintained by the U.S.
General Services Administration (GSA) provided to agencies at no-cost for the terms of service
outlined in this document. Touchpoints enables government agencies to solicit and process
user feedback to support the continuous improvement of public systems, services, processes,
The following terms of service (“Terms”) governing GSA’s Touchpoints website and services,
including the content, documentation, code, and related materials are offered subject to your
acceptance of the Terms, as well as any relevant sections of the Touchpoints Site Policies
(collectively, the “Agreement”). Access to or use of Touchpoints services or its content
constitutes acceptance to this Agreement.
Initially, Touchpoints is for use by High Impact Service Providers and other agencies beginning
to collect customer feedback in line with OMB Circular A-11 Section 280.
2.0 DATA COLLECTION, USE, AND SECURITY
2.1 REPORTING AND DATA MANAGEMENT
Touchpoints collects customer feedback submissions as they’re submitted in the
application as a table.
You can export this raw data as a .CSV file and use for their own
Two weeks prior to each quarterly reporting deadline for FY19 and FY20 (or the current
reporting schedule as defined in A-11 guidance), Feedback Analytics program staff will
contact each HISP, request they review their data for the previous reporting period and
ask the agency to submit any additional qualitative details, transactional context, or
other data elements required by OMB.
Following review, HISPs will need to approve their data as ready for submission to OMB.
For now, the approval process will be communicated by the Feedback Analytics team to
HISP staff via email. Touchpoints will pursue development of an automated mechanism
for HISPs to mark their data approved for submission to OMB.
Once approved by agency, the Feedback Analytics team will submit certified data to
OMB on its behalf on or before the day of the submission deadline.
The Feedback Analytics team will continue to investigate ways to automate, streamline,
and reduce the reporting burden for agencies while still giving them the ability to certify
their data before it is reported.
Touchpoints is covered by a FIPS 199 Moderate LATO (Lightweight Authority to
Operate). Details can be found in the Touchpoints System Security Plan (SSP) document.
Agencies may request a copy of the SSP by contacting the Touchpoints team at
Touchpoints is pursuing a 1-year full ATO after the LATO.
Data is encrypted via HTTPS while in transit.
Data is encrypted in cloud.gov’s database at rest through the Amazon Relational
Database Service (RDS).
Users are logged out of the Touchpoints application after 15 minutes of inactivity
Touchpoints uses a variety of security methods to protect this U.S. government service
and agency data to ensure the service remains available to all users. These methods
include monitoring and recording network traffic (any data going in and out of
Touchpoints) to identify unauthorized attempts to change information or otherwise
Unauthorized access or use of Touchpoints (e.g. use for criminal purposes or to cause
damage) is against the law, and may subject individuals to criminal prosecution and
2.3 DATA PRIVACY AND MANAGEMENT
Although GSA will own the data generated by these collections, it agrees not to disclose
the data or allow access to any person outside the Feedback Analytics team except
pursuant to a Freedom of Information Act (FOIA) request, Government Accountability
Office or Inspector General engagements as appropriate, and as authorized by Federal
statute or regulation or pursuant to a court order from a court of competent
Agency users own any data that they export and download from their Touchpoints
For the purposes of data security and data use, GSA assumes all liability for its
government staff and contractors with access to the data.
Outside of GSA’s described use of sharing certified data with OMB in the manner
described in OMB Circular A-11 Section 280, GSA shall not disclose, release, reveal,
show, sell, rent, lease, loan, or otherwise grant access to the information and data
shared and/or emanating from the activities covered by this Agreement to any person.
GSA further agrees that access to the data generated in these collections shall be limited
to the minimum number of individuals required to manage the Touchpoints service.
Touchpoints provides the ability for agency Service Managers to “flag” survey
submissions in the event they contain spam, irrelevant, or abusive content. Flagged
responses will be omitted from the online Submissions table viewable in Touchpoints,
and excluded from downloadable CSV reports. Records of these submissions may be
retained by GSA in audit logs for security compliance and applicable data retention
GSA will retain survey instrument and submission data as advised in the following record
352.2 – Information Hosting Records
This group of records is focused on the information services that GSA
provides to others outside of GSA. Examples include Data.gov and
USA.gov. Such activities include creating and maintaining web content for
both the public and outside the agency, and related records in developing
and managing and closing down such a service.
352.2/011 - Publicly-posted Information (DAA-0352-2016-0001-0004)
This series consists of content (information and documents) in a variety
of formats posted by GSA on agency web sites hosted by GSA, and
content posted on, or submitted via, those web sites by the public.
Included are static web pages, historically insignificant public dialogues
such as forums, surveys, and comment postings, regulatory or statutorily
mandated public postings, and related records. This schedule item
covers copies of content received from agencies and posted by GSA on
the web sites. The record copy of the content (retained by the
originating agency) is covered by the records schedules of the agencies
that originated the content. The content posted to the web sites by the
public is covered by this schedule item.
Temporary. Cutoff at the end of the fiscal year in which the posting
becomes superseded, obsolete, or canceled. Destroy 3 years after cutoff.
Longer retention is authorized in order to comply with requirements for
public posting stipulated by regulation, agency directives, OMB or GAO
mandates, or similar authorities.
352.2/021 – Information Service Program Management Records
This series of records is concerned with creating and managing an
information resource (e.g., Data.gov and USA.gov) for use or reference by
the public and/or Federal agencies in carrying out their work. Included
are change management decisions, planning documents, promotional
materials, review reports, correspondence, and related records.
Temporary. Cut off at the end of the fiscal year. Destroy 3 years after
cutoff. Longer retention is authorized if required for statutory or
authoritative reasons, such as directives agreements, contracts, OMB or
GAO requirements, or similar authorities.
GSA may maintain data sets developed from the data and store them under the security
parameters described above so long as GSA removes any personally identifiable
information, confidential or sensitive information from such data sets (as defined by the
customer agency point of contact), in the event personally identifiable information or
other sensitive information was inadvertently included in the dataset collected by GSA.
3.0 USE OF TOUCHPOINTS
You should identify an “Organization Manager.” This person will be given detailed
information about the tool and participate in a demo. After answering a few key
questions, a Touchpoints account will be created for this user and training will be given
as needed in order to commence the onboarding process.
The Feedback Analytics team will reach out to this Organization Manager to begin to
develop the agency’s internal account structure (additional owners, service managers,
people that may view submissions only, etc.). Additional individuals identified by agency
staff will be given Touchpoints accounts as relevant. Agency shall be responsible for
notifying Feedback Analytics staff of user accounts that should be deactivated due to
reassignment or separation from service.
The Feedback Analytics team will provide approximately 20 hours of onboarding
support to discuss Touchpoints account management, identification of initial survey
point, and will coordinate PRA approval of A-11 survey questions on behalf of agency.
Each HISP is entitled to up to 3 A-11 form survey collections through Touchpoints in
FY19 and FY20, with an unlimited amount of responses.
At this time, Touchpoints generates a survey URL for distribution to customers (e.g, via
an agency’s email servers or social media accounts), on a kiosk (via agency-owned
hardware such as tablets, phones, or computers available at service centers) or
embedded in a website online. In the future, Touchpoints will explore methods for
receiving submission via other feedback channels or accepting feedback from manually
A-11 surveys administered in Touchpoints are limited to:
No more than 12 survey questions in total per survey: seven (7) A-11 questions +
two (2) free response + approximately (3) custom questions
"Custom Questions" must be limited to questions that would be
considered a non-substantive, non-sensitive question related to
operational information that helps to put the customer feedback into a
useable context for the agency. This could include asking which service
center location was visited, or which service or inquiry type the
interaction was related to. The Feedback Analytics team reserves the
right to deem whether a question is appropriate under the PRA clearance
that GSA operates for this tool.
Seven (7) question language can be altered for relevancy to point of
interaction/channel (e.g., questions on employee interaction can be removed for
interactions that are self-service / web-based touchpoints)
Agency customers will be required to provide the Feedback Analytics team with
information needed in order to develop PRA supporting statements. The Feedback
Analytics team will provide this form, review agency completed information, and submit
for PRA clearance via the GSA A-11 generic government-wide clearance.
Agencies will be provided with the final PRA supporting statements for their records, but
are not required to submit these documents. GSA will assume the burden hours and
manage all ICR approvals, updates, and renewals for the A-11 form in Touchpoints. The
Feedback Analytics team will insert the OMB control number into the survey
Agencies will need to notify the Feedback Analytics team if they wish to make any
changes to the information collection. This would include any change to the instrument
itself (e.g., question wording), or the delivery mechanism (e.g., potential sample) that
would result in changes to the clearance of the information collection.
The GSA RegSec team will review internal GSA PRA within five (5) business days.
4.0 SERVICE PURPOSE AND POTENTIAL USERS
This project provides a means for agencies to manage customer and stakeholder feedback in an
efficient, timely manner in compliance with Section 280 of OMB Circular A-11 at
Section 280.7 establishes seven domains for measuring customer experience.
Overall: (1) Satisfaction, (2) Confidence/Trust
Service: (3) Quality
Process: (4) Ease/Simplicity, (5) Efficiency/Speed, (6) Equity/Transparency
People: (7) Employee Helpfulness
High Impact Service Providers listed at https://www.performance.gov/cx/HISPList.pdf are
required to ask questions in these domains of their customers. However, all agencies are
encouraged to conduct their customer experience measurement in line with these standard
In order to increase adoption of these measures and establish efficiency and cost savings in
their administration and collection, the Office of Products and Programs Feedback Analytics
team is supporting High Impact Service Providers, and in the future, other interested agencies,
in administering their customer feedback collections. OIRA supports GSA owning a generic
clearance for section 280 customer feedback surveys on behalf of other agencies. OIRA believes
it will both increase the quality of customer feedback collections and streamline workload for
both agencies and OIRA. These collections will be submitted under the GSA burden hour
Following review and disposition of public comments on the 60-day Information Collection
notice, GSA will submit to OMB a 30-day notice to solicit additional public comments.
Following completion for this new collection, GSA can submit individual information collection
requests (ICRs) on behalf of the following agencies for approval: Department of Agriculture,
Department of Commerce, Department of Defense, Department of Education, Department of
Energy, Department of Health and Human Services, Department of Homeland Security,
Department of Housing and Urban Development, Department of the Interior, Department of
Justice, Department of Labor Department of State, United States Agency for International
Development, the General Services Administration, Department of Transportation, Department
of the Treasury, Department of Veterans Affairs, Environmental Protection Agency, National
Aeronautics and Space Administration, the Consumer Financial Protection Bureau, National
Science Foundation, Nuclear Regulatory Commission, the Small Business Administration, the
Office of Personnel Management, and Social Security Administration.
GSA will only submit collections if they meet the following criteria.
The collections are voluntary;
The collections are low-burden for respondents (based on considerations of total
burden hours or burden-hours per respondent) and are low-cost for both the
respondent and the Federal Government;
The collections are non-controversial and do not raise issues of concern to other Federal
Any collection is targeted to the solicitation of opinions from respondents who have
experience with the program or may have experience with the program in the near
Personally identifiable information (PII) is collected only to the extent necessary and is
Information gathered is intended to be used for general service improvement and
program management purposes
Upon agreement between OMB and the agency ,all or a subset of information may be
released as part of A-11, Section 280 requirements only on performance.gov. Additional
release of data must be done coordinated with OMB.
These collections will allow for ongoing, collaborative and actionable communications between
the Agency, its customers and stakeholders, and OMB as it monitors agency compliance on
Section 280. It will also allow feedback to contribute directly to the improvement of program
management. These responses will inform efforts to improve or maintain the quality of service
offered to the public. If this information is not collected, vital feedback from customers and
stakeholders on services will be unavailable.
5.0 SERVICE BENEFIT
Through the use of Touchpoints for customer feedback collection, GSA aims to deliver the
following benefits for agencies:
Reduction in time and logistics required to start customer feedback collection - no
procurement of an external tool is needed
Cost saved from ability to avoid procurement staff time and actual cost of feedback
collection tool itself
Cost savings from centralized analysis and summarization of data in reports provided to
agencies, reducing agency burden
Confidence in tool’s compliance with applicable government security and data
Streamlined approvals and support in navigating Paperwork Reduction Act (PRA)
Guidance and improved quality in collection itself from support of Feedback Analytics
team in determining where in customer journey it makes sense to collect feedback, how
to adapt/modify A-11 survey for compliance and in a manner that is actionable
Reduction in reporting burden for HISP agency staff: Feedback Analytics team will clean
and provide data to both agency and OMB as outlined by A-11 Section 280
6.0 SERVICE DETAIL
If they do not do so immediately, Agencies are able to add up to 2 additional A-11
surveys to evaluate their HISP designated service via Touchpoints for a maximum of 3
surveys per quarter for FY19 Q3 and Q4.
Agency users can contact the Feedback Analytics team at
The team will respond to customer service inquiries within two (2) business days.
At this time, the level of service outlined in this agreement is available to agencies at no cost.
This service is covered under the appropriation of the Office of Products and Platforms and
Cross-Agency Priority Goal funds. If agencies request additional support, and as the capacity
grows to increase the services provided, GSA may explore a reimbursable service option.
8.0 RIGHT TO LIMIT
Users of the website and services must have a valid government email address from a federal
or District of Columbia government agency. If GSA reasonably believes that you are not a
federal or District of Columbia government employee, or a contractor acting within the scope of
its contract with the federal or District of Columbia government, GSA may permanently block
your use of the website and services.
Use of the APIs may be subject to certain limitations on access, calls, or use as set forth within
this Agreement or otherwise provided by GSA. If GSA reasonably believes that you have
attempted to exceed or circumvent these limits, your ability to use the API may be permanently
or temporarily blocked.
GSA may monitor your use of its services to improve the service or to ensure compliance with
9.0 SERVICE TERMINATION
If you wish to terminate this Agreement, you may do so by refraining from further use of the
website and services. GSA reserves the right (though not the obligation) to (1) refuse to provide
the services to you if it is GSA’s opinion that use violates any GSA policy, or (2) terminate or
deny you access to and use of all or part of the services at any time for any reason in its sole
discretion. Any hosted applications may also be shut down or removed. All provisions of this
Agreement which by their nature should survive termination shall survive termination
including, without limitation, warranty disclaimers, indemnity, and limitations of liability.
GSA reserves the right, at its sole discretion, to modify or replace this Agreement, in whole or in
part. Your continued use of or access to the Touchpoints services following the posting of any
changes to this Agreement constitutes acceptance of those modified terms. GSA may, in the
future, offer new services or features. Such new features or services shall be subject to the
terms and conditions of this Agreement.
11.0 DISCLAIMER OF WARRANTIES
Touchpoints services are provided “as is” and on an “as-available” basis. GSA hereby disclaims
all warranties of any kind, express or implied, including without limitation the warranties of
merchantability, fitness for a particular purpose, and non-infringement. GSA makes no warranty
that the services will be error free or that access thereto will be continuous or uninterrupted.
12.0 LIMITATIONS ON LIABILITY
For the purposes of data security and data use, GSA assumes all liability for its government staff
and contractors with access to the data.
In no event other than data security related matters will GSA be liable with respect to any
subject matter of this Agreement under any contract, negligence, strict liability, or other legal
or equitable theory for: (1) any special, incidental, or consequential damages; (2) the cost of
procurement of substitute products or services; or (3) for interruption of use or loss or
corruption of data.
13.0 GENERAL REPRESENTATIONS
You hereby warrant that (1) your use of the website and services will be in strict accordance
with the Agreement and all applicable laws and regulations, and (2) your use of the website and
services will not infringe or misappropriate the intellectual property rights of any third party.
This Agreement constitutes the entire Agreement between GSA and you concerning the use of
the Touchpoints website and Feedback Analytics Program services, and may only be modified
by the posting of a revised version of this page by GSA.
15.0 NO WAIVER OF RIGHTS
GSA’s failure to exercise or enforce any right or provision of this agreement shall not constitute
waiver of such right or provision.