Att B_HHS Privacy Impact Assessment

06.1 HHS Privacy Impact Assessment  (Form)  / [NIOSH Dose Reconstruction System]	Primavera ProSight

 

PIA SUMMARY

 

1

The following required questions with an asterisk (*) represent the information necessary to complete the PIA Summary for transmission to the Office of Management and Budget (OMB) and public posting in accordance with OMB Memorandum (M) 03-22.

Note: If a question or its response is not applicable, please answer “N/A” to that question where possible. If no personally identifiable information (PII) is contained in the system, please answer questions in the PIA Summary Tab and then promote the PIA to the Senior Official for Privacy who will authorize the PIA. If this system contains PII, all remaining questions on the PIA Form Tabs must be completed prior to signature and promotion.

 

2	Summary of PIA Required Questions

*Is this a new PIA?:

Yes

If this is an existing PIA, please provide a reason for revision:

*1. Date of this Submission:

05/01/2009

*2. OPDIV Name:

NIOSH/OCAS

*3. Unique Project Identifier (UPI) Number for current fiscal year:

009-20-01-05-02-9522-00

*4. Privacy Act System of Records Notice (SORN) Number (If response to Q.21 is Yes, a SORN number is required for Q.4):

Privacy Act System Notice 09-20-0147

*5. OMB Information Collection Approval Number:

OMB No. 0920-0530

*6. Other Identifying Number(s):

*7. System Name (Align with system item name):

NIOSH Dose Reconstruction System

*9. System Point of Contact (POC). The System POC is the person to whom questions about the system and the responses to this PIA may be addressed:

Leroy Turner

	Point of Contact Information
	POC Name Leroy Turner

*10. Provide an overview of the system:

NIOSH established the Office of Compensation Analysis and Support (OCAS) to assist with implementing a program created by the Energy Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA or The Act) which provides compensation and medical benefits for nuclear weapons workers who may have developed certain work-related illnesses. OCAS works closely with the Department of Energy (DOE), Department of Labor (DOL), and the Department of Justice (DOJ). The mission of the NIOSH Dose Reconstruction System is to determine eligibility for compensation and support the process of and track claims for compensation and medical benefits from the Department of Labor (DOL) for government nuclear weapons workers under the EEOICPA for radiation dose reconstruction.

*13. Indicate if the system is new or an existing one being modified:

Existing

*17. Does/Will the system collect, maintain (store), disseminate and/or pass through PII within any database(s), record(s), file(s) or website(s) hosted by this system?:

Yes

Note: This question seeks to identify any, and all, personal information associated with the system. This includes any PII, whether or not it is subject to the Privacy Act, whether the individuals are employees, the public, research subjects, or business partners, and whether provided voluntarily or collected by mandate. Later questions will try to understand the character of the data and its applicability to the requirements under the Privacy Act or other legislation.

The following information in identifiable form is submitted by claimants and/or their families is collected by the system: Date of Birth SSN Photographic Identifiers Drivers License Biometric Identifiers Mother's Maiden Name Mailing Address Phone Number Medical Notes Medical Records Numbers Legal Documents Device Identifiers Web URLs Email Address Education Records Military Status Employment Status Other: Financial Information related to claims processing

*21. Is the system subject to the Privacy Act? (If response to Q.19 is Yes, response to Q.21 must be Yes and a SORN number is required for Q.4):

Yes Privacy Act System Notice 09-20-0147

*23. If the system shares or discloses PII, please specify with whom and for what purpose(s):

Department of Labor (DOL) for the purpose of determining eligibility for compensation. Department of Justice (DOJ) for the purpose of enforcement of the law and defense of the interests of the United States according to the law and for notifying uranium workers eligible for benefits under the RECA that they may also receive compensation from DOL under The Act. DHHS/Office of the Secretary for approval of a special exposure cohort class definition. Oak Ridge Associated Universities (ORAU) – contractor for Dose Reconstruction Contract See for more information: http://www.cdc.gov/NIOSH/OCAS/pdfs/orau/drcntrt.pdf

*30. Please describe in detail: (1) the information the agency will collect, maintain, or disseminate; (2) why and for what purpose the agency will use the information; (3) in this description, explicitly indicate whether the information contains PII; and (4) whether submission of personal information is voluntary or mandatory:

The system collects PII information that is submitted by former government nuclear weapons workers and/or their families under the EEOICPA to facilitate radiation dose reconstruction to determine eligibility so that a claim for compensation and medical benefits can be filed with the Department of Labor. The mandatory PII information that we collect, maintain and disseminate, (name, date of birth, social security number, mailing address, phone number, medical records numbers, medical notes, legal documents, e-mail address, and employment status) is used to perform dose reconstruction under EEOICPA and other analysis required to process financial claims brought against the US government by individual claimants.

*31. Please describe in detail any processes in place to: (1) notify and obtain consent from the individuals whose PII is in the system when major changes occur to the system (e.g., disclosure and/or data uses have changed since the notice at the time of the original collection); (2) notify and obtain consent from individuals regarding what PII is being collected from them; and (3) how the information will be used or shared. (Note: Please describe in what format individuals will be given notice of consent [e.g., written notice, electronic notice, etc.])

There is no process to notify affected individuals when any system changes are made. All PII contained in this system had previously been collected by the site where the individual worked. Release of their PII at that time was a condition of employment. Claimants under the EEOICPA act sign a Privacy Act advisement that provides notice that the project will store and use their PII data. Department of Energy personnel access the Site Research Database (SRDB) to determine if there are any classification issues with the documents being stored. Upon request, we provide documents to the Department of Labor to support EEOICPA, Part E – chemical exposure. Documents that are accessed may contain PII data.

*32. Does the system host a website?:

No

*37. Does the website have any information or pages directed at children under the age of thirteen?:

No

*50. Are there policies or guidelines in place with regard to the retention and destruction of PII? (Refer to the C&A package and/or the Records Retention and Destruction section in SORN):

Yes

*54. Briefly describe in detail how the PII will be secured on the system using administrative, technical, and physical controls.:

A unique ID and password is required to access the information on the CDC network. All users on the CDC network are required to take Privacy Act training prior to being granted access. This is covered in DOSEREC Computer Security Plan and NIOSH Dose Reconstruction System Policies and Procedures Guide

 

PIA REQUIRED INFORMATION

 

1	HHS Privacy Impact Assessment (PIA)

The PIA determines if Personally Identifiable Information (PII) is contained within a system, what kind of PII, what is done with that information, and how that information is protected. Systems with PII are subject to an extensive list of requirements based on privacy laws, regulations, and guidance. The HHS Privacy Act Officer may be contacted for issues related to Freedom of Information Act (FOIA) and the Privacy Act. Respective Operating Division (OPDIV) Privacy Contacts may be contacted for issues related to the Privacy Act. The Office of the Chief Information Officer (OCIO) can be used as a resource for questions related to the administrative, technical, and physical controls of the system. Please note that answers to questions with an asterisk (*) will be submitted to the Office of Management and Budget (OMB) and made publicly available in accordance with OMB Memorandum (M) 03-22.

Note: If a question or its response is not applicable, please answer “N/A” to that question where possible.

 

2	General Information

*Is this a new PIA?:

Yes

If this is an existing PIA, please provide a reason for revision:

*1. Date of this Submission:

03/XX/09

*2. OPDIV Name:

NIOSH/OCAS

*3. Unique Project Identifier (UPI) Number for current fiscal year:

009-20-01-05-02-9522-00

If the system does not have a UPI, please explain why it does not:

*4. Privacy Act System of Records Notice (SORN) Number (If response to Q.21 is Yes, a SORN number is required for Q.4):

Privacy Act System Notice 09-20-0147

*5. OMB Information Collection Approval Number:

OMB No. 0920-0530

OMB Collection Approval Number Expiration Date:

Exp. Date 1/31/09

*6. Other Identifying Number(s):

*7. System Name: (Align with system item name)

NIOSH Dose Reconstruction System

8. System Location: (OPDIV or contractor office building, room, city, and state)

OPDIV, Taft Laboratory, 4676 Columbia Parkway, Cincinnati, Ohio Room 208

	System Location:
	OPDIV or contractor office building OPDIV, NIOSH _Taft Laboratory, 4676 Columbia Parkway
	Room 208
	City Cincinnati
	State Ohio

*9. System Point of Contact (POC). The System POC is the person to whom questions about the system and the responses to this PIA may be addressed:

Leroy Turner

	Point of Contact Information
	POC Name Leroy Turner

The following information will not be made publicly available:

	POC Title IT Team Leader
	POC Organization NIOSH/OCAS
	POC Phone 513-533-6811
	POC Email [email protected]

*10. Provide an overview of the system:

NIOSH established the Office of Compensation Analysis and Support (OCAS) to assist with implementing a program created by the Energy Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA or The Act) which provides compensation and medical benefits for nuclear weapons workers who may have developed certain work-related illnesses. OCAS works closely with the Department of Energy (DOE), Department of Labor (DOL), and the Department of Justice (DOJ). The mission of the NIOSH Dose Reconstruction System is to determine eligibility for compensation and support the process of and track claims for compensation and medical benefits from the Department of Labor (DOL) for government nuclear weapons workers under the EEOICPA for radiation dose reconstruction.

 

SYSTEM CHARACTERIZATION AND DATA CATEGORIZATION

 

1	System Characterization and Data Configuration

11. Does HHS own the system?:

Yes

If no, identify the system owner:

12. Does HHS operate the system?:

Yes

If no, identify the system operator:

*13. Indicate if the system is new or an existing one being modified:

Existing

14. Identify the life-cycle phase of this system:

Operation/Maintenance

15. Have any of the following major changes occurred to the system since the PIA was last submitted?:

	Please indicate “Yes” or “No” for each category below:	Yes/No
	Conversions	Yes
	Anonymous to Non-Anonymous	No
	Significant System Management Changes	No
	Significant Merging	No
	New Public Access	No
	Commercial Sources	No
	New Interagency Uses	Yes
	Internal Flow or Collection	No
	Alteration in Character of Data	No

16. Is the system a General Support System (GSS), Major Application (MA) or Minor Application?:

General Support System

*17. Does/Will the system collect, maintain (store), disseminate and/or pass through PII within any database(s), record(s), file(s) or website(s) hosted by this system?:

Yes

Note: This question seeks to identify any, and all, personal information associated with the system. This includes any PII, whether or not it is subject to the Privacy Act, whether the individuals are employees, the public, research subjects, or whether it is personal information about business partners, and whether provided voluntarily or collected by mandate. Later questions will try to understand the character of the data and its applicability to the requirements under the Privacy Act or other legislation.

The following information in identifiable form is submitted by claimants and/or their families is collected by the system: Date of Birth SSN Photographic Identifiers Drivers License Biometric Identifiers Mother's Maiden Name Mailing Address Phone Number Medical Notes Medical Records Numbers Legal Documents Device Identifiers Web URLs Email Address Education Records Military Status Employment Status Other: Financial Information related to claims processing

Please indicate "Yes" or "No" for each PII category. If the applicable PII category is not listed, please use the Other field to identify the appropriate category of PII.

	Categories:	Yes/No
	Name	Yes
	Date of Birth	Yes
	Social Security Number (SSN)	Yes
	Photographic Identifiers	Yes
	Driver’s License	Yes
	Biometric Identifiers	Yes
	Mother’s Maiden Name	Yes
	Vehicle Identifiers	No
	Mailing Address	Yes
	Phone Numbers	Yes
	Medical Records Numbers	Yes
	Medical Notes	Yes
	Financial Account Information	No
	Certificates	No
	Legal Documents	Yes
	Device Identifiers	Yes
	Web Uniform Resource Locator(s) (URL)	Yes
	Email Address	Yes
	Education Records	Yes
	Military Status	Yes
	Employment Status	Yes
	Foreign Activities	No
	Other: Financial information related to claims processing	Yes

18. Please indicate the categories of individuals about whom PII is collected, maintained, disseminated and/or passed through. Note: If the applicable PII category is not listed, please use the Other field to identify the appropriate category of PII. Please answer "Yes" or "No" to each of these choices (NA in other is not applicable).

	Categories:	Yes/No
	Employees	Yes
	Public Citizen	Yes
	Patients	Yes
	Business partners/contacts (Federal, state, local agencies)	Yes
	Vendors/Suppliers/Contractors	Yes
	Other	No

19. Are records on the system retrieved by one or more data elements?:

Please indicate "Yes" or "No" for each PII category. If the applicable PII category is not listed, please use the Other field to identify the appropriate category of PII.

	Categories:	Yes/No
	Name	Yes
	Date of Birth	Yes
	SSN	Yes
	Photographic Identifiers	Yes
	Driver’s License	Yes
	Biometric Identifiers	Yes
	Mother’s Maiden Name	Yes
	Vehicle Identifiers	No
	Mailing Address	Yes
	Phone Numbers	Yes
	Medical Records Numbers	Yes
	Medical Notes	Yes
	Financial Account Information	No
	Certificates	No
	Legal Documents	Yes
	Device Identifiers	Yes
	Web URLs	Yes
	Email Address	Yes
	Education Records	Yes
	Military Status	Yes
	Employment Status	Yes
	Foreign Activities	No
	Other: Financial information related to claims processing	Yes

20. Are 10 or more records containing PII maintained, stored or transmitted/passed through this system?:

Yes

21. Is the system subject to the Privacy Act? (If response to Q.19 is Yes, response to Q.21 must be Yes and a SORN number is required for Q.4):

Yes Privacy Act System Notice 09-20-0147

21 A. If yes, but a SORN has not been created, please provide an explanation:

 

INFORMATION SHARING PRACTICES

 

1	Information Sharing Practices

22. Does the system share or disclose PII with other divisions within this agency, external agencies, or other people or organizations outside the agency?:

Yes

	Please indicate “Yes” or “No” for each category below:	Yes/No
	Name	Yes
	Date of Birth	Yes
	SSN	Yes
	Photographic Identifiers	No
	Driver’s License	No
	Biometric Identifiers	No
	Mother’s Maiden Name	Yes
	Vehicle Identifiers	No
	Mailing Address	Yes
	Phone Numbers	Yes
	Medical Records Numbers	Yes
	Medical Notes	Yes
	Financial Account Information	No
	Certificates	No
	Legal Documents	Yes
	Device Identifiers	Yes
	Web URLs	Yes
	Email Address	Yes
	Education Records	No
	Military Status	No
	Employment Status	Yes
	Foreign Activities	No
	Other	No

*23. If the system shares or discloses PII please specify with whom and for what purpose(s):

Department of Labor (DOL) for the purpose of determining eligibility for compensation. Department of Justice (DOJ) for the purpose of enforcement of the law and defense of the interests of the United States according to the law and for notifying uranium workers eligible for benefits under the RECA that they may also receive compensation from DOL under The Act. DHHS/Office of the Secretary for approval of a special exposure cohort class definition. Oak Ridge Associated Universities (ORAU) – contractor for Dose Reconstruction Contract See for more information: http://www.cdc.gov/NIOSH/OCAS/pdfs/orau/drcntrt.pdf

24. If the PII in the system is matched against PII in one or more other computer systems, are computer data matching agreement(s) in place?:

No

25. Is there a process in place to notify organizations or systems that are dependent upon the PII contained in this system when major changes occur (i.e., revisions to PII, or when the system is replaced)?:

Yes

26. Are individuals notified how their PII is going to be used?:

Yes

If yes, please describe the process for allowing individuals to have a choice. If no, please provide an explanation:

Claimants sign a Privacy Act advisement that provides notice that their data will be used on this project.

27. Is there a complaint process in place for individuals who believe their PII has been inappropriately obtained, used, or disclosed, or that the PII is inaccurate?:

No

If yes, please describe briefly the notification process. If no, please provide an explanation:

These data are collected from documents which have been released by the associated site. They contain PII data that are collected as a requirement for employment at that site.

28. Are there processes in place for periodic reviews of PII contained in the system to ensure the data’s integrity, availability, accuracy and relevancy?:

Yes

If yes, please describe briefly the review process. If no, please provide an explanation:

Documents are reviewed for the presence of dosimetry data. When such data are found, it is keyed into the Site Research Database (Site Research Database (SRDB)), along with other PII data. At that time, the NIOSH Claims Tracking System (NOCTS) database is queried to determine if the individual is a claimant. If so, the data are compared against NOCTS for accuracy. If inconsistencies are found, we notify the appropriate personnel in NIOSH for resolution.

29. Are there rules of conduct in place for access to PII on the system?:

Yes

Please indicate "Yes," "No," or "N/A" for each category. If yes, briefly state the purpose for each user to have access:

	Users with access to PII	Yes/No/N/A	Purpose
	User	Yes	To perform dose reconstruction under EEOICPA to determine eligibility for compensation.
	Administrators	Yes	Troubleshooting
	Developers	Yes	Troubleshooting
	Contractors	Yes	To perform dose reconstruction under EEOICPA to determine eligibility for compensation.
	Other	N/A	N/A

*30. Please describe in detail: (1) the information the agency will collect, maintain, or disseminate; (2) why and for what purpose the agency will use the information; (3) in this description, explicitly indicate whether the information contains PII; and (4) whether submission of personal information is voluntary or mandatory:

The system collects PII information that is submitted by former government nuclear weapons workers and/or their families under the EEOICPA to facilitate radiation dose reconstruction to determine eligibility so that a claim for compensation and medical benefits can be filed with the Department of Labor. The mandatory PII information that we collect, maintain and disseminate, (name, date of birth, social security number, mailing address, phone number, medical records numbers, medical notes, legal documents, e-mail address, and employment status) is used to perform dose reconstruction under EEOICPA and other analysis required to process financial claims brought against the US government by individual claimants.

*31. Please describe in detail any processes in place to: (1) notify and obtain consent from the individuals whose PII is in the system when major changes occur to the system (e.g., disclosure and/or data uses have changed since the notice at the time of the original collection); (2) notify and obtain consent from individuals regarding what PII is being collected from them; and (3) how the information will be used or shared. (Note: Please describe in what format individuals will be given notice of consent [e.g., written notice, electronic notice, etc.])

There is no process to notify affected individuals when any system changes are made. All PII contained in this system had previously been collected by the site where the individual worked. Release of their PII at that time was a condition of employment. Claimants under the EEOICPA act sign a Privacy Act advisement that provides notice that the project will store and use their PII data. Department of Energy personnel access the Site Research Database (SRDB) to determine if there are any classification issues with the documents being stored. Upon request, we provide documents to the Department of Labor to support EEOICPA, Part E – chemical exposure. Documents that are accessed may contain PII data.

 

WEBSITE HOSTING PRACTICES

 

1	Website Hosting Practices

*32. Does the system host a website?:

No

	Please indicate “Yes” or “No” for each type of site below:	Yes/ No
	Internet	No
	Intranet	Yes
	Both	No

33. Is the website accessible by the public or other entities (i.e., Federal, state, and/or local agencies, contractors, third party administrators, etc.)?:

No

34. Is a website privacy policy statement (consistent with OMB M-03-22 and Title II and III of the E-Government Act) posted on the website?:

Yes

35. Is the website’s privacy policy in machine-readable format, such as Platform for Privacy Preferences (P3P)?:

Yes

If no, please indicate when the website will be P3P compliant:

36. Does the website employ tracking technologies?:

No

	Please indicate “Yes”, “No”, or “N/A” for each type of cookies below:	Yes/No/N/A
	Web Bugs	No
	Web Beacons	No
	Session Cookies	No
	Persistent Cookies	No
	Other	No

*37. Does the website have any information or pages directed at children under the age of thirteen?:

No

If yes, is there a unique privacy policy for the site, and does the unique privacy policy address the process for obtaining parental consent if any information is collected?:

38. Does the website collect PII from individuals?:

No

	Please indicate “Yes” or “No” for each category below:	Yes/No
	Name	No
	Date of Birth	No
	SSN	No
	Photographic Identifiers	No
	Driver's License	No
	Biometric Identifiers	No
	Mother's Maiden Name	No
	Vehicle Identifiers	No
	Mailing Address	No
	Phone Numbers	No
	Medical Records Numbers	No
	Medical Notes	No
	Financial Account Information	No
	Certificates	No
	Legal Documents	No
	Device Identifiers	No
	Web URLs	No
	Email Address	No
	Education Records	No
	Military Status	No
	Employment Status	No
	Foreign Activities	No
	Other	No

39. Are rules of conduct in place for access to PII on the website?:

Yes

40. Does the website contain links to sites external to the OPDIV that owns and/or operates the system?:

No

If yes, note whether the system provides a disclaimer notice for users that follow external links to websites not owned or operated by the OPDIV.:

 

ADMINISTRATIVE CONTROLS

 

1	Administrative Controls

Note: This PIA uses the terms “Administrative,” “Technical” and “Physical” to refer to security control questions—terms that are used in several Federal laws when referencing security requirements.

 

2

41. Has the system been certified and accredited (C&A)?:

No

41a. If yes, please indicate when the C&A was completed:

41b. If a system requires a C&A and no C&A was completed, is a C&A in progress?:

Yes

42. Is there a system security plan for this system?:

Yes

43. Is there a contingency (or backup) plan for the system?:

Yes

44. Are files backed up regularly?:

Yes

45. Are backup files stored offsite?:

Yes

46. Are there user manuals for the system?:

Yes

47. Have personnel (system owners, managers, operators, contractors and/or program managers) using the system been trained and made aware of their responsibilities for protecting the information being collected and maintained?:

Yes

48. If contractors operate or use the system, do the contracts include clauses ensuring adherence to privacy provisions and practices?:

Yes

49. Are methods in place to ensure least privilege (i.e., “need to know” and accountability)?:

Yes

If yes, please specify method(s).:

Microsoft Windows Security Groups in Active Directory

*50. Are there policies or guidelines in place with regard to the retention and destruction of PII? (Refer to the C&A package and/or the Records Retention and Destruction section in SORN):

Yes

If yes, please provide some detail about these policies/practices.:

There is a CDC policy guide titled CDC Staff Manual on Confidentiality, which covers this subject in detail. http://cin.niosh.cdc.gov/welcome/orientation/Confidentiality%20Booklet.pdf

 

TECHNICAL CONTROLS

 

1	Technical Controls

51. Are technical controls in place to minimize the possibility of unauthorized access, use, or dissemination of the data in the system?:

Yes

	Please indicate “Yes” or “No” for each category below:	Yes/No
	User Identification	Yes
	Passwords	Yes
	Firewall	Yes
	Virtual Private Network (VPN)	Yes
	Encryption	In-Process
	Intrusion Detection System (IDS)	No
	Common Access Cards (CAC)	No
	Smart Cards	In-process
	Biometrics	No
	Public Key Infrastructure (PKI)	No

52. Is there a process in place to monitor and respond to privacy and/or security incidents?:

Yes

If yes, please briefly describe the process:

There is a CDC policy guide titled CDC Staff Manual on Confidentiality, which covers this subject in detail. http://cin.niosh.cdc.gov/welcome/orientation/Confidentiality%20Booklet.pdf CDC Incident Response Plan http://intranet.cdc.gov/ociso/incidents/SBU-CDC_Incident_Response_Plan_v2_0b.pdf

 

PHYSICAL ACCESS

 

1	Physical Access

53. Are physical access controls in place?:

Yes

	Please indicate “Yes” or “No” for each category below:	Yes/No
	Guards	Yes
	Identification Badges	Yes
	Key Cards	Yes
	Cipher Locks	No
	Biometrics	No
	Closed Circuit TV (CCTV)	Yes

*54. Briefly describe in detail how the PII will be secured on the system using administrative, technical, and physical controls.:

A unique ID and password is required to access the information on the CDC network. All users on the CDC network are required to take Privacy Act training prior to being granted access. This is covered in DOSEREC Computer Security Plan and NIOSH Dose Reconstruction System Policies and Procedures Guide IIF is collected and the proper controls are utilized to safeguard sensitive information. E-Authentication Assurance Level = N/A Risk Analysis Date = May 1, 2009

 

APPROVAL/DEMOTION

 

1	System Information

System Name:

 

2	PIA Reviewer Approval/Promotion or Demotion

Promotion/Demotion:

Comments:

Approval/Demotion Point of Contact:

Date:

 

3	Senior Official for Privacy Approval/Promotion or Demotion

Promotion/Demotion:

Comments:

 

4	OPDIV Senior Official for Privacy or Designee Approval

Please print the PIA and obtain the endorsement of the reviewing official below. Once the signature has been collected, retain a hard copy for the OPDIV's records. Submitting the PIA will indicate the reviewing official has endorsed it

This PIA has been reviewed and endorsed by the OPDIV Senior Official for Privacy or Designee (Name and Date):

Name: __________________________________ Date: ________________________________________

	Name:
	Date:

 

5	Department Approval to Publish to the Web

Approved for web publishing
Date Published:
Publicly posted PIA URL or no PIA URL explanation:

 

% COMPLETE

 

1	PIA Completion

PIA Percentage Complete:

PIA Missing Fields: