POGO outlines its concerns with the International Boundary and Water Commission's Sensitive Information Protection Manual in a letter to the IBWC Commissioner
Commissioner Arturo Duran
International Boundary and Water Commission
United States Section
4171 North Mesa, Suite C-100
El Paso, TX 79902-1441
RE: USIBWC's Sensitive Information Protection Manual
Dear Commissioner Duran:
The Project On Government Oversight (POGO) has several concerns with the International Boundary and Water Commission's (IBWC) Sensitive Information Protection Manual (hereafter referred to as the "Manual") distributed internally to employees on July 8, 2005.  The Manual casts an excessive blanket of secrecy over the activities of the IBWC and will unnecessarily stifle employee speech because of the fear of "administrative or disciplinary action and/or criminal prosecution." (Manual Part IV Section I.4.) This secrecy will hinder the effectiveness of the IBWC as well as make it more difficult to hold the agency accountable to the American public. As the 9/11 Commission report notes, public disclosure is "democracy's best oversight mechanism." 
The Manual is troubling in another sense. The agency does not have a history of secrecy. While some information at the IBWC may need protection, great care must be taken when crafting and implementing information security policies at agencies which, by and large, do not need them. Secrecy should be the exception in a democratic government, not the norm, especially when the agency in question has nothing to do with sensitive defense or intelligence activities. Regardless of the agency, secrecy is often used to cover up waste of taxpayer money, abuse of employees or other kinds of malfeasance. Secrecy should be kept to a minimum and used only when absolutely necessary.
Here are troubling aspects of the Manual:
The information designations outlined in the Sensitive Information Protection Manual are too vague and overreaching. "Sensitive Information" is defined as:
Given this definition, "sensitive information" can be a catch-all for every piece of information within the IBWC. An anonymous critique of the Manual astutely notes, this definition is "impermissibly vague and broad. One could argue that any disclosure that would embarrass the IBWC 'adversely' impacts the agency and its programs." 
We look forward to your written response to these concerns. Please contact me or Nick Schwellenbach at (202) 347-1122 if you have any questions or comments.
Project On Government Oversight