DHS Rubber Ethics Standards
Two things which caught my eye.
1. DHS IG caught an employee who, despite e-mails with ethics, still engaged in problematic contract negotiations with her future non-DHS employee. E-mail in DHS is well archived and discoverable. [Non-public DHS data/e-mail inconsistent with public statements]
2. Interesting info on how DHS gets around classification guidelines. This has bearing on Congressman Conyers FOIA request on particular DHS domestic abuses, not just DoJ in Katrina. [ConyersBlog in re domestic investigation of law enforcement misconduct during Katrina.]
"The trend" is that the guidelines are clear, well known, and people in DHS go through the motions of compliance, but they still cross the line.
These aren't loopholes, they're loopie.