Integrated Pool Management System - Privacy Impact Assessment

U.S. Department of Housing and

Urban Development

Ginnie Mae

Integrated Pool Management System (IPMS)

Privacy Impact Assessment

October 19, 2012

Document Endorsement

I have carefully assessed the Privacy Impact Assessment (PIA) for Integrated Pool Management System (IPMS). This document has been completed in accordance with the requirement set forth by the E-Government Act of 2002 and OMB Memorandum 03-22 which requires that "Privacy Impact Assessments" (PIAs) be conducted for all new and/ or significantly altered IT Systems, and Information Collection Requests.

ENDORSEMENT SECTION

Please check the appropriate statement.

	The document is accepted.
	The document is accepted pending the changes noted.
	The document is not accepted.

Based on our authority and judgment, the data captured in this document is current and accurate.

Thomas Weakland
System Owner		Date
Office of Securities Operations
Daniel Kahn
Ginnie mae		Date
office of securities operations
Departmental Privacy Act Officer		Date
Office of the Chief Information Officer
U. S. Department of Housing and Urban Development

table of contents

Document Endorsement 2

table of contents 3

SECTION 1: BACKGROUND 4

Importance of Privacy Protection – Legislative Mandates: 4

What is the Privacy Impact Assessment (PIA) Process? 5

Who Completes the PIA? 5

When is a Privacy Impact Assessment (PIA) Required? 5

What are the Privacy Act Requirements? 6

Why is the PIA Summary Made Publicly Available? 6

SECTION 2 – COMPLETING A PRIVACY IMPACT ASSESSMENT 7

Question 2: Type of electronic system or information collection. 9

Question 3: Explain by Line of Business why the personally identifiable information being collected? How will it be used? 10

Question 5: Will you share the information with others? (e.g., another agency for a programmatic purpose, internal HUD application/module or outside the government)? 12

Question 6: Can individuals “opt-out” by declining to provide personal information or by consenting only to particular use (e.g., allowing their financial information to be used for basic rent eligibility determination, but for not for sharing with other government agencies)? 12

Question 7: How will the privacy of the information be protected/ secured? What are the administrative and technological controls? 13

Question 8: If privacy information is involved, by what data element(s) is it retrieved from the system? 13

SECTION 3 - DETERMINATION BY HUD PRIVACY Act officer 14

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

PRIVACY IMPACT ASSESSMENT (PIA) FOR:

Integrated Pool management system

(for IT Systems: [Insert OMB Unique Identifier]

and [Insert PCAS #] )

19 October 2012

SECTION 1: BACKGROUND

Importance of Privacy Protection – Legislative Mandates:

HUD is responsible for ensuring the privacy and confidentiality of the information it collects on members of the public, beneficiaries of HUD programs, business partners, and its own employees. These people have a right to expect that HUD will collect, maintain, use, and disseminate identifiable personal information only as authorized by law and as necessary to carry out agency responsibilities.

The information HUD collects is protected by the following legislation and regulations:

• Privacy Act of 1974, as amended affords individuals the right to privacy in records that are maintained and used by Federal agencies. (See http://www.usdoj.gov/foia/privstat.htm; see also HUD Handbook1325.1 at www.hudclips.org);

• Computer Matching and Privacy Protection Act of 1988 is an amendment to the Privacy Act that specifies the conditions under which private information may (or may not) be shared among government agencies. (See http://www.usdoj.gov/foia/privstat.htm);

• Freedom of Information Act of 1966, as amended (http://www.usdoj.gov/oip/foia_updates/Vol_XVII_4/page2.htm) provides for the disclosure of information maintained by Federal agencies to the public, while allowing limited protections for privacy. See also HUD’s Freedom of Information Act Handbook (HUD Handbook 1327.1 at www.hudclips.org);

• E-Government Act of 2002 requires Federal agencies to conduct Privacy Impact Assessments (PIAs) on its electronic systems. (See http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=107_cong_public_laws&docid=f:publ347.107.pdf; see also the summary of the E-Government Act at http://www.whitehouse.gov/omb/egov/pres_state2.htm);

• Federal Information Security Management Act of 2002 (which superceded the Computer Security Act of 1987) provides a comprehensive framework for ensuring the effectiveness of information security controls over information resources that support Federal operations and assets, etc. See also the codified version of Information Security regulations at Title 44 U.S. Code chapter 35 subchapter II (http://uscode.house.gov/search/criteria.php); and

• OMB Circular A-130, Management of Federal Information Resources, Appendix I (http://www.whitehouse.gov/omb/circulars/a130/appendix_i.pdf) defines Federal Agency responsibilities for maintaining records about individuals.

Access to personally identifiable information will be restricted to those staff that has a need to access the data to carry out their duties; and they will be held accountable for ensuring privacy and confidentiality of the data.

What is the Privacy Impact Assessment (PIA) Process?

The Privacy Impact Assessment (PIA) is a process that evaluates issues related to the privacy of personally identifiable information in electronic systems. See background on PIAs and the 7 questions that need to be answered, at: http://www.hud.gov/offices/cio/privacy/pia/pia.cfm. Personally identifiable information is defined as information that actually identifies an individual, e.g., name, address, social security number (SSN), or identifying number or code; or other personal/ sensitive information such as race, marital status, financial information, home telephone number, personal e-mail address, etc. Of particular concern is the combination of multiple identifying elements. For example, knowing name + SSN + birth date + financial information would pose more risk to privacy than just name + SSN alone.

The PIA:

• Identifies the type of personally identifiable information in the system (including any ability to combine multiple identifying elements on an individual);

• Identifies who has access to that information (whether full access or limited access rights); and

• Describes the administrative controls that ensure that only information that is necessary and relevant to HUD’s mission is included.

Who Completes the PIA?

Both the program area System Owner and IT Project Leader work together to complete the PIA. The System Owner describes what personal data types are collected, how the data is used, and who has access to the personal data. The IT Project Leader describes whether technical implementation of the System Owner’s requirements presents any risks to privacy, and what controls are in place to restrict access of personally identifiable information.

When is a Privacy Impact Assessment (PIA) Required?

1. New Systems: Any new system that will contain personal information on members of the public requires a PIA, per OMB requirements (this covers both major and non-major systems).

2. Existing Systems: Where there are significant modifications involving personal information on members of the public, or where significant changes been made to the system that may create a new privacy risk, a PIA is required.

3. Information Collection Requests, per the Paperwork Reduction Act (PRA): Agencies must obtain OMB approval for new information collections from ten or more members of the public. If the information collection is both a new collection and automated, then a PIA is required.

What are the Privacy Act Requirements?

Privacy Act. The Privacy Act of 1974, as amended (http://www.usdoj.gov/foia/privstat.htm) requires that agencies publish a Federal Register Notice for public comment on any intended information collection. Privacy Act Systems of Records are created when information pertaining to an individual is collected and maintained by the Department, and is retrieved by the name of the individual or by some other identifying number, symbol, or other identifying particular assigned to an individual. The E-Government Act of 2002 requires PIAs for electronic systems as well as information collection requests that are automated. So, there is a relationship between the new PIA requirement (when automation is involved) and the long-standing Privacy Act System of Records Notices (for both paper-based and automated records that are of a private nature). For additional information, contact the Departmental Privacy Act Officer in the Office of the Chief Information Officer.

Why is the PIA Summary Made Publicly Available?

The E-Government Act of 2002 requires that the analysis and determinations resulting from the PIA be made publicly available. The Privacy Advocate in HUD’s Office of the Chief Information Officer (OCIO) is responsible for publishing the PIA summary on HUD’s web site. See: http://www.hud.gov/offices/cio/privacy/pia/pia.cfm.

SECTION 2 – COMPLETING A PRIVACY IMPACT ASSESSMENT

Program Area: Ginnie Mae Office of Securities Operations

Subject Matter Expert in the Program Area: Sharon Strange

Program Area Manager: Dan Kahn

IT Project Leader: James Thompson

For IT Systems:

• Name of system: Integrated Pool Management System

• PCAS #: N/A

• OMB Unique Project Identifier #: N/A

• System Code: P240

• Development Date: N/A, this is an existing system

• Expected Production Date: N/A, this is an existing system

For Information Collection Requests: N/A

• Name of Information Collection Request:

• OMB Control #:

Question 1: Provide a general description of the system that describes: The following questions are intended to define the scope of the information in the system (or information collection), specifically the nature of the information and the sources from which it is obtained.

1. What is the personal information being collected?

1. Loan origination data:  Borrower/co-borrower name, social security number, date of birth, and property address

2. Issuer:  Name, title, and phone number of the issuer involved in the pooling, certification, and monthly reporting process.

2. From whom is the information collected (i.e., government employees, contractors, or consultants)?
   
   Information is collected from Ginnie Mae issuers.

3. What is the functionality of the system and the purpose that the records and/or system serve?
   
   The Integrated Pool Management System (IPMS) is a Ginnie Mae system that has three major component subsystems: New Pool Processing, Pool Reporting, and Generalized Mortgage Backed Securities.
   
   The New Pool Processing Subsystem provides a facility to enter Ginnie Mae’s commitment authority as guaranteed b Congress; monitor Ginnie Mae’s available commitment as it is used; track an Issuer’s available commitment authority/ monitor Issuer’s status codes; review Issuers’ new pool submissions, edit underlying mortgage submissions, and authorize the issuance of new pools. The subsystem complies with all new pool edit requirements defined in the Ginnie Mae MBS Guide.
   
   The Pool Reporting Subsystem maintains pool level details for all Ginnie Mae I and Ginnie Mae II pools and loan packages, and Platinum pools. The module also carries the loan package information for Multiple Issuer Pools.
   
   The Generalized Mortgage-Backed Securities subsystem performs three major functions, Central Registry, Transfer Processing, and Principal and Interest Payment Process which includes tax reporting.

d. How information is transmitted to and from the system?

Information is transmitted to IPMS via scheduled and secured Connect:Direct sessions. Data is either received as a feed from GinnieNET or data entered directly into the system.

e What are the interconnections with other systems.

GinnieNET (GNET) and Enterprise Wide Operational Data Store (EWODS).

f. What specific legal authorities, arrangement, and/or agreement authorize the collection of information (i.e. must include authorities that cover all information collection activities, including Social Security Numbers)?

Ginnie Mae uses the information collected to carry out its functions as guarantor of securities under Section 306(g) of the National Housing Act, 12 U.S.C. 1721(g).

Question 2: Type of electronic system or information collection.

If a new electronic system (or one in development) (implemented after April 2003, the effective date of the E-Government Act of 2002)?	Yes	No
Does the system require authentication?
Is the system browser-based?
Is the system external-facing (with external users that require authentication)?

If this is existing electronic system has the system undergone any changes (since April 17, 2003)? If an existing system, when was the system developed? ________		Yes	No
Do the changes to the system involve a change in the type of records maintained, the individuals on whom records are maintained, or the use or dissemination of information from the system?
If yes, please explain:
For your new and/or existing electronic system, please indicate if any of the following changes have occurred: Mark any of the following conditions for your existing system that OMB defines as a “trigger” for requiring a PIA or PIA update (if not applicable, mark N/A):
N/A	Conversion: When paper-based records that contain personal information are converted to an electronic system
N/A	From Anonymous (Non-Identifiable) to “Non-Anonymous” (Personally Identifiable): When any systems application transforms an existing database or data collection so that previously anonymous data becomes personally identifiable
N/A	Significant System Management Changes: When new uses of an existing electronic system significantly change how personal information is managed in the system. (Example #1: when new “relational” databases could combine multiple identifying data elements to more easily identify an individual. Example #2: when a web portal extracts data elements from separate databases, and thereby creates a more open environment for exposure of personal data)
N/A	Merging Databases: When government databases are merged, centralized, matched, or otherwise significantly manipulated so that personal information becomes more accessible (with special concern for the ability to combine multiple identifying elements)
N/A	New Public Access: When new public access is given to members of the public or to business partners (even if the system is protected by password, digital certificate, or other user-authentication technology)
N/A	Commercial Sources: When agencies systematically incorporate into databases any personal data from commercial or public sources (ad hoc queries of such sources using existing technology does not trigger the need for a PIA)
N/A	New Inter-agency Uses: When agencies work together (such as the federal E-Gov initiatives), the lead agency should prepare the PIA
N/A	Business Process Re-engineering: When altering a business process results in significant new uses, disclosures, or additions of personal data
N/A	Alteration in Character of Data: When adding new personal data raises the risks to personal privacy (for example, adding financial information to an existing database that contains name and address)

D. If an Information Collection Request (ICR): Is this a new Request that will collect data that will be in an automated system? Agencies must obtain OMB approval for information collections from 10 or more members of the public. The E-Government Act of 2002 requires a PIA for ICRs only if the collection of information is a new request and the collected data will be in an automated system.
	Yes, this is a new ICR and the data will be automated
X	No, the ICR does not require a PIA because it is not new or automated)
	Comment:

Question 3: Explain by Line of Business why the personally identifiable information being collected? How will it be used?

Mark any that apply:

Homeownership:

	Credit checks (eligibility for loans)
	Loan applications and case-binder files (via lenders) – including borrower SSNs, salary, employment, race, and other information
	Loan servicing (MIP collections/refunds and debt servicing for defaulted loans assigned to HUD)
	Loan default tracking
	Issuing mortgage and loan insurance
X	Other (specify): Ginnie Mae uses this information to administer and carry out its functions as Guarantor of securities backed by mortgage loans.
	Comment:

Rental Housing Assistance:

	Eligibility for rental assistance or other HUD program benefits
	Characteristics on those receiving rental assistance (for example, race/ethnicity, # of children, age)
	Property inspections
	Other (specify):
	Comment:

Grants:

	Grant application scoring and selection – if any personal information on the grantee is included
	Disbursement of funds to grantees – if any personal information is included
	Other (specify):
	Comment:

Fair Housing:

	Housing discrimination complaints and resulting case files
	Other (specify):
	Comment:

Internal operations:

	Employee payroll or personnel records
	Payment for employee travel expenses
	Payment for services or products (to contractors) – if any personal information on the payee is included
	Computer security files – with personal information in the database, collected in order to grant user IDs
	Other (specify):
	Comment:

Other lines of business (specify uses):

Question 4: Will you share the information with others? (e.g., another agency for a programmatic purpose, internal HUD application/module or outside the government)?

Mark any that apply:

X	Federal agencies?
	State, local, or tribal governments?
	Public Housing Agencies (PHAs) or Section 8 property owners/agents?
	FHA-approved lenders?
	Credit bureaus?
	Local and national organizations?
	Non-profits?
	Faith-based organizations?
	Builders/ developers?
	HUD module/application? (specify the module(s)/application(s) name)
	Others? (specify):.
	Comment:

Question 5: Can individuals “opt-out” by declining to provide personal information or by consenting only to particular use (e.g., allowing their financial information to be used for basic rent eligibility determination, but for not for sharing with other government agencies)?

	Yes, they can “opt-out” by declining to provide private information or by consenting only to particular use
X	No, they can’t “opt-out” – all personal information is required
	Comment: Individuals do not have the opportunity/right to decline the information required. The information is required by the IRS for pool investors.

If Yes, please explain the issues and circumstances of being able to opt-out (either for specific data elements or specific uses of the data): _________________________________________

____________________________________________________________________________

Question 6: How will the privacy of the information be protected/ secured? What are the administrative and technological controls?

Mark any that apply and give details if requested:

X	System users must log-in with a password (Please specify password type): 8 character password length requiring 1 upper case alphabetic character, 1 lower case alphabetic character, 1 digit and 1 special character. Passwords require changing every 90 days.
X	When an employee leaves: How soon is the user ID terminated? (1 day, 1 week, 1 month, unknown)? User IDs are disabled immediately after an employee is terminated or transferred. Disabled IDs are removed after 6 months of non-usage. How do you know that the former employee no longer has access to your system? (explain your procedures or describe your plan to improve): IPMS is a mainframe that is not accessible to anyone except those that have been explicitly provisioned access.
X	Are access rights selectively granted, depending on duties and need-to-know? If Yes, specify the approximate # of authorized users who have either: Full access rights to all data in the system: 0 Limited/restricted access rights to only selected data: At time of writing, 20.
X	Are disks, tapes, and printouts that contain personal information locked in cabinets when not in use? Yes. (explain your procedures, or describe your plan to improve): Digital and non-digital media are placed into locked cabinets when not in use or if the
	If data from your system is shared with another system or data warehouse, who is responsible for protecting the privacy of data that came from your system but now resides in another? Explain the existing privacy protections, or your plans to improve:
	Other methods of protecting privacy (specify):
	Comment:

Question 7: If privacy information is involved, by what data element(s) is it retrieved from the system?

Mark any that apply

	Name:
	Social Security Number (SSN)
	Identification number (specify type): Driver License/State ID#, Tax ID/EIN
	Birth date
	Race/ ethnicity
	Marital status
	Spouse name
	Home address
	Home telephone
	Personal e-mail address
	Other (specify): Financial (Loan data), Tax, Income data
X	None
	Comment: While PII passes through the IPMS app, users do not have privileges, nor does the system provide functionality to retrieve privacy information via any single data element.

Question 8: What type of Notice(s) are provided to the individual on the scope of information collected, the opportunity to consent to uses of said information, the opportunity to decline to provide information.

1. Was any form of notice provided to the individual prior to collection of information? If yes, please provide a copy of the notice as an appendix. (A notice may include a posted privacy policy, a Privacy Act notice on form(s), and/or a system of records notice published in the Federal Register.) If notice was not published, why not?
   
   No. In this system, users do not have privileges, nor does the system provide functionality to retrieve any information by the name of an individual or by any identifying number, symbol, or other identifying particular assigned to the individual.
   
   Information regarding pool investors is collected by the issuers and passed by the issuers to Bank of New York Mellon. BNYM did not notify these individuals and is not responsible for notifying the individuals.

2. Do individuals have an opportunity and/or right to decline to provide information? No. Individuals do not have the opportunity/right to decline the information required. The information is required by the IRS for pool investors.
   
   No.

3. Do individuals have an opportunity to consent to particular uses of the information, and if so, what is the procedure by which an individual would provide such consent? No. Individuals do not have an opportunity to consent to the uses of the information. The pool investor information is required by the IRS.
   
   No.

SECTION 3 - DETERMINATION BY HUD PRIVACY Act officer