Atttachment 2 - Privacy Impact Assessment

Attachment 2: NIH ECR Program Privacy Impact Assessment

06.1 HHS Privacy Impact Assessment (Form) / NIH CSR Early Career Reviewer database (ECR) (Item)	Primavera ProSight
Form Report, printed by: Nair, Prema, Jun 7, 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?

Yes

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

Not Applicable

*1. Date of this Submission:

Sep 9, 2011

*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):

NIH CSR Early Career Reviewers Database

*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	Doug Sur

*10. Provide an overview of the system:

This database provides a pool of potential reviewers for study sections. The data is pulled from IMPAC II (Information for Management, Planning, Analysis and Coordination). IMPAC II is the grants management database used by NIH (National Insititutes of Health). The data is entered manually and the database has querry and reporting functionality. When a potential reviewer is identified the system allows for an email to be sent to the reviewer requesting their paticipation in a meeting. When a reviewer responds to a web form the database can be automatically updated with the response.

*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.)

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.

No

*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):

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:

(1). The data collected are: Name, Email, Institution, Professional Title, expertise keywords. The system also maintains data collected from IMPAC II: commons Identification number and profile Identification number.

(2). The system shares PII, with internal staff for the purpose of generating participants for review meetings.

(3). Yes

(4). The personal information is voluntary.

*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.]):

(1). Individuals voluntarily provide consent of use of PII (even during major system changes) when they provide data on a web form. Individuals provide notice of consent electronically (web form).

(2). All individuals are notified orally via a phone call as to the purpose and intent of the database, as well as, obtaining consent. In addition, all individuals are provided a letter notifying them of why the data is being collected and the purpose of the data collection.

(3). The information is shared internal for purpose of obtaining participants for study section meetings via queries from the system database.

*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:

Technical Control: User ID and passwords have to be used for network authentication.

Administrative Control: Role-based access. Training materials are being developed.

Physical Controls: Security guards, ID badges, Cipher locks and close circuit TV at the data center.

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:

Not Applicable

*1. Date of this Submission:

Sep 9, 2011

*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):

N/A

*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)

NIH CSR Early Career Reviewers Database

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

	System Location:
	OPDIV or contractor office building	Sterling Data Center
	Room	CSR Cage-2.01
	City	Sterling
	State	Virginia

*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	Doug Sur

The following information will not be made publicly available:

	POC Title	CSR Software Manager
	POC Organization	NIH/CSR/IMB
	POC Phone	301-915-6308
	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)

This database provides a pool of potential reviewers for study sections. The data is pulled from IMPAC II (Information for Management, Planning, Analysis and Coordination). IMPAC II is the grants management database used by NIH (National Insititutes of Health). The data is entered manually and the database has querry and reporting functionality. When a potential reviewer is identified the system allows for an email to be sent to the reviewer requesting their paticipation in a meeting. When a reviewer responds to a web form the database can be automatically updated with the response.

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:

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:

N/A

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

New

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)?

Minor Application (child)

*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	No
	Social Security Number (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	No
	Financial Account Information	No
	Certificates	No
	Legal Documents	No
	Device Identifiers	No
	Web Uniform Resource Locator(s) (URL)	No
	Personal Email Address	Yes
	Education Records	No
	Military Status	No
	Employment Status	No
	Foreign Activities	No
	Other	N/A

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.

No

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	No
	Public Citizen	Yes
	Patients	No
	Business partners/contacts (Federal, state, local agencies)	No
	Vendors/Suppliers/Contractors	No
	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	No
	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	No
	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	N/A

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?

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
	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	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	N/A

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

N/A

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.

The individual voluntarily provides that data in a web form, with the knowledge that it will be used to determine reviewers for scientific meetings.

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 can contact the CSR Early Career Reviewer via email or contact CSR via the "about us" link on the CSR internet.

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.

As data is inputed, CSR staff reviews the integrity, accuracy, and relevancy of the data.

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 locate potential early career reviewers
	Administrators	Yes	To maintain the system
	Developers	Yes	To maintain and enhance the system
	Contractors	Yes	To maintain and enhance the system
	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:

(1). The data collected are: Name, Email, Institution, Professional Title, expertise keywords. The system also maintains data collected from IMPAC II: commons Identification number and profile Identification number.

(2). The system shares PII, with internal staff for the purpose of generating participants for review meetings.

(3). Yes

(4). The personal information is voluntary.

*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.])

(1). Individuals voluntarily provide consent of use of PII (even during major system changes) when they provide data on a web form. Individuals provide notice of consent electronically (web form).

(2). All individuals are notified orally via a phone call as to the purpose and intent of the database, as well as, obtaining consent. In addition, all individuals are provided a letter notifying them of why the data is being collected and the purpose of the data collection.

(3). The information is shared internal for purpose of obtaining participants for study section meetings via queries from the system database.

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
	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.).

No

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?

Not Applicable

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)?

Not Applicable

35a. If no, please indicate when the website will be P3P compliant:

Not Applicable

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?

N/A

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	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	Yes
	Education Records	No
	Military Status	No
	Employment Status	No
	Foreign Activities	No
	Other	N/A

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?

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.

N/A

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 (Note: The C&A date is populated in the System Inventory form via the responsible Security personnel):

Aug 6, 2010

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

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

Each user has its own login and password

*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:

In accordance with SORN 09-25-0036: Records are retained and disposed of under the authority of the NIH Records Control Schedule contained in NIH Manuel Chapter 1743, Appendix 1 - "keeping and Destroying Records: (HHS Records Management Manuel, Appendix B-361). item 4000-A-2, which allows records to be destroyed when no longer needed for administrative purposes. Refer to NIH Manual Chapter for specific disposition instructions.

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)	Yes
	Smart Cards	Yes
	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

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

The NIH incident response team notifies the CSR ISSO of any security incidents it detects.

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:

Technical Control: User ID and passwords have to be used for network authentication.

Administrative Control: Role-based access. Training materials are being developed.

Physical Controls: Security guards, ID badges, Cipher locks and close circuit TV at the data center.

APPROVAL/DEMOTION

1	System Information

System Name:

NIH CSR Early Career Reviewers Database

2	PIA Reviewer Approval/Promotion or Demotion

Promotion/Demotion:

Promote

Comments:

Approval/Demotion Point of Contact:

Michael Floissac, CSR Privacy Coordinator

Date:

Sep 9, 2011

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 9, 2011

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: