Attachment 1_06_1 HHS Privacy Impact Assessment-NIH NIMH Headquarters Network System

Attachment 1_06_1 HHS Privacy Impact Assessment-NIH NIMH NIMH Headquarters Network System.docx

NIMH Office of Autism Research Coordination (OARC) Portfolio Analysis

Attachment 1_06_1 HHS Privacy Impact Assessment-NIH NIMH NIMH Headquarters Network System

OMB: 0925-0682

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06.1 HHS Privacy Impact Assessment (Form) / NIH NIMH NIMH Headquarters Network [System] (Item)

Primavera ProSight

Form Report, printed by: Hermach, William, Oct 31, 2012



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:



PIA Validation



*1. Date of this Submission:



Jul 17, 2012



*2. OPDIV Name:



NIH



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



09-25-0036



*5. OMB Information Collection Approval Number:



N/A



*6. Other Identifying Number(s):



N/A



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



NIMHnet



*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

John Harris





*10. Provide an overview of the system:



The system is a General Support System (GSS) and does not directly collect or store information.



*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?



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.)



Yes



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.






*19. Are records on the system retrieved by 1 or more PII data elements?



Yes



*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)



Yes



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



The system shares and discloses PII with NIMH staff and research partners in support of the NIMH mission. Reference SOR #: 09-25-0036



*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:



The system is a General Support System (GSS) and does not directly collect or store information. The applications/systems residing on the GSS collect and store information. Therefore, individual PIAs have been prepared and submitted for the applications/systems residing on this GSS.



*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.]):



The NIMH procedures involve notification and consent to submit PII to the system during the grant application and administrative processes. Potential grantees must consent to provide PII to the system in order to apply for NIMH grants. NIMH staff consent to have PII stored in the system as a condition of employment during the hiring process. NIMH Web communications staff notifies individuals when major system changes or data use changes occur.



*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)



Yes



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



The PII will be secured on the system using DHHS, NIH and NIMH administrative policies, NIHnet and NIMHnet technical controls, and encryption of sensitive data. The NIMHnet incorporates role based access controls with the principle of least privilege access and limited personnel physical access to the data center systems via card key.



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?



No



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



PIA Validation



*1. Date of this Submission:



Jul 17, 2012



*2. OPDIV Name:



NIH



3. Unique Project Identifier (UPI) Number for current fiscal year (Data is auto-populated from the System Inventory form, UPI table):






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



09-25-0036



*5. OMB Information Collection Approval Number:



N/A



5a. OMB Collection Approval Number Expiration Date:






*6. Other Identifying Number(s):



N/A



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



NIMHnet



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







System Location:




OPDIV or contractor office building

NIMH Headquarters Atrium and NSC buildings



Room

6001 Executive Blvd. and 6101 Executive Blvd.



City

Rockville



State

MD





*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

John Harris





The following information will not be made publicly available:







POC Title

NIMH CIO



POC Organization

ORM/IRTMB



POC Phone

301-443-8101



POC Email

[email protected]





*10. Provide an overview of the system: (Note: The System Inventory form can provide additional information for child dependencies if the system is a GSS)



The system is a General Support System (GSS) and does not directly collect or store information.



SYSTEM CHARACTERIZATION AND DATA CATEGORIZATION


1

System Characterization and Data Configuration


11. Does HHS own the system?



Yes



11a. If no, identify the system owner:



Name: John Harris

Component: National Institutes of Health

Address: 6101 Executive Blvd

Suite 374

Rockvill, MD 20852

Phone: 301-443-8101

Email: [email protected]

FAX:



12. Does HHS operate the system? (If the system is operated at a contractor site, the answer should be No)



Yes



12a. 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:



Operations/Maintenance



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



No







Please indicate “Yes” or “No” for each category below:

Yes/No



Conversions

No



Anonymous to Non-Anonymous

No



Significant System Management Changes

No



Significant Merging

No



New Public Access

No



Commercial Sources

No



New Interagency Uses

No



Internal Flow or Collection

No



Alteration in Character of Data

No





16. Is the system a General Support System (GSS), Major Application (MA), Minor Application (child) or Minor Application (stand-alone)?



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



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.)



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)

Yes



Date of Birth

Yes



Social Security Number (SSN)

No



Photographic Identifiers

Yes



Driver’s License

No



Biometric Identifiers

No



Mother’s Maiden Name

No



Vehicle Identifiers

No



Personal Mailing Address

Yes



Personal Phone Numbers

Yes



Medical Records Numbers

Yes



Medical Notes

Yes



Financial Account Information

Yes



Certificates

No



Legal Documents

Yes



Device Identifiers

No



Web Uniform Resource Locator(s) (URL)

Yes



Personal Email Address

Yes



Education Records

Yes



Military Status

Yes



Employment Status

Yes



Foreign Activities

No



Other

Employment history and other professional qualifications





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.






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

N/A





*19. Are records on the system retrieved by 1 or more PII data elements?



Yes



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)

Yes



Date of Birth

Yes



SSN

No



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

Yes



Financial Account Information

Yes



Certificates

No



Legal Documents

No



Device Identifiers

No



Web URLs

No



Personal Email Address

Yes



Education Records

Yes



Military Status

No



Employment Status

No



Foreign Activities

No



Other

Scientific Discipline and Areas of Expertise





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 the response to Q.19 is Yes, the response to Q.21 must be Yes and a SORN number is required for Q.4)



Yes



21a. 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 (for purposes other than contacting federal employees)

Yes



Date of Birth

No



SSN

No



Photographic Identifiers

No



Driver’s License

No



Biometric Identifiers

No



Mother’s Maiden Name

No



Vehicle Identifiers

No



Personal Mailing Address

Yes



Personal Phone Numbers

Yes



Medical Records Numbers

Yes



Medical Notes

Yes



Financial Account Information

Yes



Certificates

No



Legal Documents

No



Device Identifiers

No



Web URLs

Yes



Personal Email Address

Yes



Education Records

Yes



Military Status

No



Employment Status

Yes



Foreign Activities

No



Other

Scientific Discipline





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



The system shares and discloses PII with NIMH staff and research partners in support of the NIMH mission. Reference SOR #: 09-25-0036



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?



Yes



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



26a. If yes, please describe the process for allowing individuals to have a choice. If no, please provide an explanation.



There is privacy policy and privacy act note on the applicable web pages, with a link to information on whom to contact for help.



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?



Yes



27a. If yes, please describe briefly the notification process. If no, please provide an explanation.



Individuals notify the main NIMH contact number, Webmaster or CIO



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



28a. If yes, please describe briefly the review process. If no, please provide an explanation.



Program Officers and administrative staff regularly review and update the information.



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

Administrative functions, information dissemination and grants review



Administrators

Yes

Systems Administration



Developers

Yes

Application Development



Contractors

Yes

Systems and Applications Development



Other

No

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:



The system is a General Support System (GSS) and does not directly collect or store information. The applications/systems residing on the GSS collect and store information. Therefore, individual PIAs have been prepared and submitted for the applications/systems residing on this GSS.



*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.])



The NIMH procedures involve notification and consent to submit PII to the system during the grant application and administrative processes. Potential grantees must consent to provide PII to the system in order to apply for NIMH grants. NIMH staff consent to have PII stored in the system as a condition of employment during the hiring process. NIMH Web communications staff notifies individuals when major system changes or data use changes occur.



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)



Yes







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

www.nimh.nih.gov



Intranet

Yes




Both

Yes






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?



Yes



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)?



Yes



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

N/A





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



No



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?



Yes







Please indicate “Yes” or “No” for each category below:

Yes/No



Name (for purposes other than contacting federal employees)

Yes



Date of Birth

No



SSN

No



Photographic Identifiers

No



Driver's License

No



Biometric Identifiers

No



Mother's Maiden Name

No



Vehicle Identifiers

No



Personal Mailing Address

Yes



Personal Phone Numbers

Yes



Medical Records Numbers

No



Medical Notes

Yes



Financial Account Information

No



Certificates

No



Legal Documents

No



Device Identifiers

No



Web URLs

No



Personal Email Address

Yes



Education Records

No



Military Status

No



Employment Status

No



Foreign Activities

No



Other

Scientific Discipline and Research Areas of Expertise





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 HHS that owns and/or operates the system?



Yes



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.



Yes



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)?



Yes



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



Dec 7, 2011



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



Not Applicable



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



49a. If yes, please specify method(s):



Only preauthorized users have access to the system and therefore access to the data. Only authorized system administrators have access to modify or delete the data.



*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



50a. If yes, please provide some detail about these policies/practices:



The NIH Records Retention Policy provides detail about the retention and destruction of PII in the system.



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

Yes



Intrusion Detection System (IDS)

Yes



Common Access Cards (CAC)

No



Smart Cards

No



Biometrics

No



Public Key Infrastructure (PKI)

Yes





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



Yes



52a. If yes, please briefly describe the process:



The NIH Incident Handling Procedures; The NIH Incident Response Team (IRT) handles all security incidents.



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

Yes



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:



The PII will be secured on the system using DHHS, NIH and NIMH administrative policies, NIHnet and NIMHnet technical controls, and encryption of sensitive data. The NIMHnet incorporates role based access controls with the principle of least privilege access and limited personnel physical access to the data center systems via card key.



APPROVAL/DEMOTION


1

System Information


System Name:

NIMHnet



2

PIA Reviewer Approval/Promotion or Demotion


Promotion/Demotion:

Promote



Comments:




Approval/Demotion Point of Contact:

William Hermach



Date:

Jul 17, 2012



3

Senior Official for Privacy Approval/Promotion or Demotion


Promotion/Demotion:

Promote



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:

Karen Plá



Date:

Sep 28, 2012





5

Department Approval to Publish to the Web


Approved for web publishing


Date Published:


Publicly posted PIA URL or no PIA URL explanation:




PIA % COMPLETE


1

PIA Completion


PIA Percentage Complete:

100.00



PIA Missing Fields:



File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitlePrimavera ProSight Report
AuthorHermach, William
File Modified0000-00-00
File Created2021-01-28

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