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pdf06.1 HHS Privacy Impact Assessment (Form) / CDC E-Resources
Primavera ProSight
CDC PIA (April 2011)
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 the system hosts a website, the Website Hosting
Practices section is required to be completed regardless of the presence of personally identifiable information (PII). If no 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?
No
If this is an existing PIA, please provide a reason for revision:
C & A Recertification
*1. Date of this Submission:
04/06/2012
*2. OPDIV Name:
CDC/OSELS/PHITPO
*3. Unique Project Identifier (UPI) Number for current fiscal year:
009-20-01-03-01-1163-00
*4. Privacy Act System of Records Notice (SORN) Number (If response to Q.21 is Yes, a SORN number is required for Q.4):
N/A
*5. OMB Information Collection Approval Number:
N/A
*6. Other Identifying Number(s):
N/A
*7. System Name (Align with system item name):
BioSense 2.0
*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:
Point of Contact Information
POC Name
Taha Kass-Hout
*10. Provide an overview of the system:
Note: If SSN’s(Social Security Numbers) will be collected, maintained (stored), disseminated and/or pass through within any database(s),
record(s), file(s) or website(s) hosted by this system you must complete and submit Attachment A – SSN Elimination or Usage
Approval Request located at http://intranet.cdc.gov/ociso/pandp/policy.html
Note: According to OMB 07-16M, All agencies MUST participate in government-wide effort to eliminate unnecessary use of and explore alternatives to
agency use of Social Security Numbers as a personal identifier for both Federal employees and in Federal programs.
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The key aim of BioSense 2.0 is to accelerate and expand state and local syndromic
surveillance systems. BioSense 2.0 will contribute to nationwide and regional (i.e., multistate) situation awareness for all hazards health-related events (beyond bioterrorism), by
allowing local and state stakeholders direct control and ownership of the system in order to
paint a cohesive regional and national “picture.” This is consistent with the 2006 Pandemic
All Hazards Preparedness Act (PAHPA), and 2007 Homeland Security Presidential Directive
(HSPD-21), both of which call for regional and nationwide public health situation
awareness, through enabling state and local situation awareness capability. Further,
BioSense 2.0 aligns with the priorities identified by the National Biosurveillance Strategy for
Human Health. Successful implementation of BioSense 2.0 will promote a national situation
awareness picture that provides:
•
Aggregate national view
•
More detailed State/Local views and functionalities
•
View neighboring localities and departments
•
View contextualized alerts and assessments
•
Accept new data sources
BioSense 2.0, governed by state and local stakeholders under the Association of State and
Territorial Health Officials (ASTHO), creates an easy way to facilitate the sharing of public
health surveillance data between health jurisdictions. Additionally, BioSense 2.0 will cease
the collection and maintenance of raw clinical data at CDC as with the case with the original
design of BioSense (BioSense 1.0). To achieve this, BioSense 2.0 will emphasize the direct
reporting of data from hospitals to state and local health departments instead of CDC, if
desired by jurisdictions.
*13. Indicate if the system is new or an existing one being modified:
New
*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?
TIP: If the answer to Question 17 is “No” (indicating the system does not contain PII), only the remaining PIA Summary tab questions need to be completed
and submitted. If the system does contain PII, the full PIA must be completed and submitted. (Although note that “Employee systems,” – i.e., systems that
collect PII “permitting the physical or online contacting of a specific individual … employed [by] the Federal Government – only need to complete the PIA
Summary tab.)
No
17a. Is this a GSS PIA included for C&A purposes only, with no ownership of underlying application data? If the response to Q.17a is Yes, the response to
Q.17 should be No and only the PIA Summary must be completed. NOTE: TO BE DETERMINED AND COMPLETED BY OCISO ONLY!!!
*19. Are records on the system retrieved by 1 or more PII data elements?
No
*21. Is the system subject to the Privacy Act? (If the response to Q.19 is Yes, the response to Q.21 must be Yes and a SORN number is required for Q.4)
No
*23. If the system shares or discloses PII, please specify with whom and for what purpose(s):
N/A
*30. Please describe in detail: (1) The information the agency will collect, maintain, or disseminate (clearly state if the information contained in the system
ONLY represents federal contact data); (2) Why and for what purpose the agency will use the information; (3) Explicitly indicate whether the information
contains PII; and (4) Whether submission of personal information is voluntary or mandatory:
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N/A
*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.]):
N/A
*32. Does the system host a website? (Note: If the system hosts a website, the Website Hosting Practices section is required to be completed regardless of
the presence of PII)
Yes
*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)
N/A
*54. Briefly describe in detail how the PII will be secured on the system using administrative, technical, and physical controls:
N/A
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If the response to Question 17 is “NO” and Question 32 is “YES”, you only
need to complete the PIA Summary and Website Hosting section (Questions
32 – 40).
If the response to Question 17 is “YES”, please complete ALL remaining
questions.
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PIA REQUIRE 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?
If this is an existing PIA, please provide a reason for revision:
*1. Date of this Submission:
*2. OPDIV Name:
3. Unique Project Identifier (UPI) Number for current fiscal year:
*4. Privacy Act System of Records Notice (SORN) Number (If response to Q.21 is Yes, a SORN number is required for Q.4):
*5. OMB Information Collection Approval Number:
5a. OMB Collection Approval Number Expiration Date:
*6. Other Identifying Number(s):
*7. System Name: (Align with system item name)
8. System Location: (OPDIV or contractor office building, room, city, and state)
System Location:
OPDIV or contractor office building
Room
City
State
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*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:
Point of Contact Information
POC Name
The following information will not be made publicly available:
POC Title
POC Organization
POC Phone
POC Email
*10. Provide an overview of the system:
Note: If SSN’s(Social Security Numbers) will be collected, maintained (stored), disseminated and/or pass through within any database(s),
record(s), file(s) or website(s) hosted by this system you must complete and submit Attachment A – SSN Elimination or Usage
Approval Request located at http://intranet.cdc.gov/ociso/pandp/policy.html
Note: According to OMB 07-16M, All agencies MUST participate in government-wide effort to eliminate unnecessary use of and explore alternatives to
agency use of Social Security Numbers as a personal identifier for both Federal employees and in Federal programs.
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SYSTEM CHARACTERIZATION AND DATA CATEGORIZATION
1
System Characterization and Data Configuration
11. Does HHS own the system?
11a. If no, identify the system owner:
12. Does HHS operate the system? (If the system is operated at a contractor site, the answer should be No)
12a. If no, identify the system operator:
*13. Indicate if the system is new or an existing one being modified:
14. Identify the life-cycle phase of this system:
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
Anonymous to Non-Anonymous
Significant System Management Changes
Significant Merging
New Public Access
Commercial Sources
New Interagency Uses
Internal Flow or Collection
Alteration in Character of Data
16. Is the system a General Support System (GSS), Major Application (MA), Minor Application (child) or Minor Application (stand-alone)?
*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?
TIP: If the answer to Question 17 is “No” (indicating the system does not contain PII), only the remaining PIA Summary tab questions need to be completed
and submitted. If the system does contain PII, the full PIA must be completed and submitted. (Although note that “Employee systems,” – i.e., systems that
collect PII “permitting the physical or online contacting of a specific individual … employed [by] the Federal Government – only need to complete the PIA
Summary tab.)
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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 (for purposes other than contacting federal
employees)
Date of Birth
Social Security Number (SSN)
Note: According to OMB 07-16M, All agencies MUST participate in
government-wide effort to eliminate unnecessary use of and explore
alternatives to agency use of Social Security Numbers as a personal
identifier for both Federal employees and in Federal programs.
Photographic Identifiers
Driver’s License
Biometric Identifiers
Mother’s Maiden Name
Vehicle Identifiers
Personal Mailing Address
Personal Phone Numbers
Medical Records Numbers
Medical Notes
Financial Account Information
Certificates
Legal Documents
Device Identifiers
Web Uniform Resource Locator(s) (URL)
Personal Email Address
Education Records
Military Status
Employment Status
Foreign Activities
Other
17a. Is this a GSS PIA included for C&A purposes only, with no ownership of underlying application data? If the response to Q.17a is Yes, the response to
Q.17 should be No and only the PIA Summary must be completed. NOTE: TO BE DETERMINED AND COMPLETED BY OCISO ONLY!!!
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
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Employees
Public Citizen
Patients
Business partners/contacts (Federal, state, local
agencies)
Vendors/Suppliers/Contractors
Other
*19. Are records on the system retrieved by 1 or more PII 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 (for purposes other than contacting federal
employees)
Date of Birth
Social Security Number (SSN)
Note: According to OMB 07-16M, All agencies MUST participate in
government-wide effort to eliminate unnecessary use of and explore
alternatives to agency use of Social Security Numbers as a personal
identifier for both Federal employees and in Federal programs.
Photographic Identifiers
Driver’s License
Biometric Identifiers
Mother’s Maiden Name
Vehicle Identifiers
Personal Mailing Address
Personal Phone Numbers
Medical Records Numbers
Medical Notes
Financial Account Information
Certificates
Legal Documents
Device Identifiers
Web URLs
Personal Email Address
Education Records
Military Status
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Employment Status
Foreign Activities
Other
20. Are 10 or more records containing PII maintained, stored or transmitted/passed through this system?
*21. Is the system subject to the Privacy Act? (If the response to Q.19 is Yes, the response to Q.21 must be Yes and a SORN number is required for Q.4)
21a. If yes but a SORN has not been created, please provide an explanation.
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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?
Please indicate “Yes” or “No” for each category below:
Yes/No
Name (for purposes other than contacting federal
employees)
Date of Birth
Social Security Number (SSN)
Note: According to OMB 07-16M, All agencies MUST participate in
government-wide effort to eliminate unnecessary use of and explore
alternatives to agency use of Social Security Numbers as a personal
identifier for both Federal employees and in Federal programs.
Photographic Identifiers
Driver’s License
Biometric Identifiers
Mother’s Maiden Name
Vehicle Identifiers
Personal Mailing Address
Personal Phone Numbers
Medical Records Numbers
Medical Notes
Financial Account Information
Certificates
Legal Documents
Device Identifiers
Web URLs
Personal Email Address
Education Records
Military Status
Employment Status
Foreign Activities
Other
*23. If the system shares or discloses PII please specify with whom and for what purpose(s):
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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?
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)?
26. Are individuals notified how their PII is going to be used?
26a. If yes, please describe the process for allowing individuals to have a choice. If no, please provide an explanation.
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?
27a. If yes, please describe briefly the notification process. If no, please provide an explanation.
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?
28a. If yes, please describe briefly the review process. If no, please provide an explanation.
29. Are there rules of conduct in place for access to PII on the system?
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
Administrators
Developers
Contractors
Other
*30. Please describe in detail: (1) The information the agency will collect, maintain, or disseminate (clearly state if the information contained in the system
ONLY represents federal contact data); (2) Why and for what purpose the agency will use the information; (3) Explicitly indicate whether the information
contains PII; and (4) Whether submission of personal information is voluntary or mandatory:
*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.])
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WEBSITE HOSTING PRACTICES
1
Website Hosting Practices
*32. Does the system host a website? (Note: If the system hosts a website, the Website Hosting Practices section is required to be completed regardless of
the presence of PII)
Please indicate “Yes” or “No” for each
type of site below. If the system hosts
both Internet and Intranet sites,
indicate “Yes” for “Both” only.
Yes/ No
If the system hosts an Internet site, please enter the site
URL. Do not enter any URL(s) for Intranet sites.
Internet
Yes
Intranet
No
Both
No
33. Does the system host a website that is accessible by the public and does not meet the exceptions listed in OMB M-03-22?
Note: OMB M-03-22 Attachment A, Section III, Subsection C requires agencies to post a privacy policy for websites that are accessible to the public, but
provides three exceptions: (1) Websites containing information other than "government information" as defined in OMB Circular A-130; (2) Agency intranet
websites that are accessible only by authorized government users (employees, contractors, consultants, fellows, grantees); and (3) National security systems
defined at 40 U.S.C. 11103 as exempt from the definition of information technology (see section 202(i) of the E-Government Act.).
Yes
34. If the website does not meet one or more of the exceptions described in Q. 33 (i.e., response to Q. 33 is "Yes"), a website privacy policy statement
(consistent with OMB M-03-22 and Title II and III of the E-Government Act) is required. Has a website privacy policy been posted?
(Note: A website privacy policy is required for Internet sites only.)
35. If a website privacy policy is required (i.e., response to Q. 34 is “Yes”), is the privacy policy in machine-readable format, such as Platform for Privacy
Preferences (P3P)?
(Note: Privacy policy in machine-readable format is required for Internet sites only.)
35a. If no, please indicate when the website will be P3P compliant:
36. Does the website employ tracking technologies?
Yes
Please indicate “Yes”, “No”, or “N/A” for each type of
cookie below:
Yes/No/N/A
Web Bugs
No
Web Beacons
No
Session Cookies
Yes
Persistent Cookies
No
Other
*37. Does the website have any information or pages directed at children under the age of thirteen?
No
Page 13 of 17
37a. 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 (for purposes other than contacting federal
employees)
No
Date of Birth
No
Social Security Number (SSN)
No
Note: According to OMB 07-16M, All agencies MUST participate in
government-wide effort to eliminate unnecessary use of and explore
alternatives to agency use of Social Security Numbers as a personal
identifier for both Federal employees and in Federal programs.
Photographic Identifiers
No
Driver's License
No
Biometric Identifiers
No
Mother's Maiden Name
No
Vehicle Identifiers
No
Personal Mailing Address
No
Personal 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
Personal Email Address
No
Education Records
No
Military Status
No
Employment Status
No
Foreign Activities
No
Other
39. Are rules of conduct in place for access to PII on the website?
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N/A
40. Does the website contain links to sites external to HHS that owns and/or operates the system?
No
40a. If yes, note whether the system provides a disclaimer notice for users that follow external links to websites not owned or operated by HHS.
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.
41. Has the system been certified and accredited (C&A)?
41a. If yes, please indicate when the C&A was completed (Note: The C&A date is populated in the System Inventory form via the responsible Security
personnel):
41b. If a system requires a C&A and no C&A was completed, is a C&A in progress?
42. Is there a system security plan for this system?
43. Is there a contingency (or backup) plan for the system?
44. Are files backed up regularly?
45. Are backup files stored offsite?
46. Are there user manuals for the system?
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?
48. If contractors operate or use the system, do the contracts include clauses ensuring adherence to privacy provisions and practices?
49. Are methods in place to ensure least privilege (i.e., “need to know” and accountability)?
49a. If yes, please specify method(s):
*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):
50a. If yes, please provide some detail about these policies/practices:
Page 15 of 17
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?
Please indicate “Yes” or “No” for each category below:
Yes/No
User Identification
Passwords
Firewall
Virtual Private Network (VPN)
Encryption
Intrusion Detection System (IDS)
Common Access Cards (CAC)
Smart Cards
Biometrics
Public Key Infrastructure (PKI)
52. Is there a process in place to monitor and respond to privacy and/or security incidents?
52a. If yes, please briefly describe the process:
PHYSICAL ACCESS
1
Physical Access
53. Are physical access controls in place?
Please indicate “Yes” or “No” for each category below:
Yes/No
Guards
Identification Badges
Key Cards
Cipher Locks
Biometrics
Closed Circuit TV (CCTV)
*54. Briefly describe in detail how the PII will be secured on the system using administrative, technical, and physical controls:
Page 16 of 17
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: _________________________________________________
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:
Page 17 of 17
Date: ____________________
File Type | application/pdf |
File Title | Microsoft Word - 0920-0824_att8_BioSense 2.0_ PIA_2012 |
Author | HHF8 |
File Modified | 2012-06-19 |
File Created | 2012-06-19 |