Attach 21 Privacy Impact Assessment

06.1 HHS Privacy Impact Assessment (Form) /

Primavera ProSight

PIA SUMMARY
Note: The following questions are repeated in the long form (p.3) You only have to answer once. I have highlighted them in the long
form.

1
The following required questions with an asterisk (*) represent the information necessary to complete the PIA Summary
for transmission to the Office of Management and Budget (OMB) and public posting in accordance with OMB
Memorandum (M) 03-22.
Note: If a question or its response is not applicable, please answer “N/A” to that question where possible. If no
personally identifiable information (PII) is contained in the system, please answer questions in the PIA Summary Tab
and then promote the PIA to the Senior Official for Privacy who will authorize the PIA. If this system contains PII, all
remaining questions on the PIA Form Tabs must be completed prior to signature and promotion.

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Summary of PIA Required Questions

*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:
*6. Other Identifying Number(s):
*7. System Name (Align with system item
name):
*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:

POC Name

*10. Provide an overview of the system:
*13. Indicate if the system is new or an
existing one being modified:
*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?:
Note: This question seeks to identify any, and
all, personal information associated with the
system. This includes any PII, whether or not it
is subject to the Privacy Act, whether the
individuals are employees, the public, research
subjects, or business partners, and whether
provided voluntarily or collected by mandate.

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Later questions will try to understand the
character of the data and its applicability to the
requirements under the Privacy Act or other
legislation.
*21. Is the system subject to the Privacy Act?
(If response to Q.19 is Yes, response to Q.21
must be Yes and a SORN number is required for
Q.4):
*23. If the system shares or discloses PII,
please specify with whom and for what
purpose(s):
*30. Please describe in detail: (1) the
information the agency will collect, maintain,
or disseminate; (2) why and for what purpose
the agency will use the information; (3) in this
description, explicitly indicate whether the
information contains PII; and (4) whether
submission of personal information is voluntary
or mandatory:
*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.])
*32. Does the system host a website?:
*37. Does the website have any information or
pages directed at children under the age of
thirteen?:
*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):
*54. Briefly describe in detail how the PII will
be secured on the system using administrative,
technical, and physical controls.:

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PIA REQUIRED INFORMATION
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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.

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General Information

*Is this a new PIA?:

Yes

If this is an existing PIA, please provide a
reason for revision:
*1. Date of this Submission:

4/24/2013

*2. OPDIV Name:

NIH

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

Not applicable

If the system does not have a UPI, please
explain why it does not:
*4. Privacy Act System of Records Notice
(SORN) Number (If response to Q.21 is Yes, a
SORN number is required for Q.4):
*5. OMB Information Collection Approval
Number:

In process

OMB Collection Approval Number Expiration
Date:
*6. Other Identifying Number(s):

NIH OHSR Exempt Number is 11817
Smithsonian Protocol Number is HS13023

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

Social Genome Surveys

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

System Location:
OPDIV or contractor office building

6707 Democracy Blvd

Room

Suite 203

City

Bethesda

State

Maryland

*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:

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Point of Contact Information
POC Name

Dave Kanney, Laura Koehly, Chris Marcum

The following information will not be made publicly available:

POC Title

System Developer- Dave Kanney

POC Organization

NHGRI

POC Phone

301.435.6076

POC Email

[email protected]

*10. Provide an overview of the system:

The system will be used to conduct research surveys. These
surveys are being conducted to help researchers understand how
people think and feel about issues related to genetics and health.

SYSTEM CHARACTERIZATION AND DATA CATEGORIZATION
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System Characterization and Data Configuration

11. Does HHS own the system?:

Yes

If no, identify the system owner:
12. Does HHS operate the system?:

Yes

If no, identify the system operator:
*13. Indicate if the system is new or an
existing one being modified:

New

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

Requirements Analysis

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

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) or Minor

Minor Application

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Application?:
*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, PII is transmitted but it is only used to reference other
questions and it is only temporarily stored.

Note: This question seeks to identify any, and
all, personal information associated with the
system. This includes any PII, whether or not it
is subject to the Privacy Act, whether the
individuals are employees, the public, research
subjects, or whether it is personal information
about business partners, and whether provided
voluntarily or collected by mandate. Later
questions will try to understand the character
of the data and its applicability to the
requirements under the Privacy Act or other
legislation.
Please indicate "Yes" or "No" for each PII category. If the applicable PII category is not listed, please use the Other
field to identify the appropriate category of PII.

Categories:

Yes/No

Name

Yes

Date of Birth

No

Social Security Number (SSN)

No

Photographic Identifiers

No

Driver’s License

No

Biometric Identifiers

No

Mother’s Maiden Name

No

Vehicle Identifiers

No

Mailing Address

No

Phone Numbers

No

Medical Records Numbers

No

Medical Notes

No

Financial Account Information

No

Certificates

No

Legal Documents

No

Device Identifiers

No

Web Uniform Resource Locator(s) (URL)

No

Email Address

No

Education Records

No

Military Status

No

Employment Status

No

Foreign Activities

No

Other

Age, Gender, Race/Ethnicity, Zip Code

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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

No

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

No

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

No

Date of Birth

No

SSN

No

Photographic Identifiers

No

Driver’s License

No

Biometric Identifiers

No

Mother’s Maiden Name

No

Vehicle Identifiers

No

Mailing Address

No

Phone Numbers

No

Medical Records Numbers

No

Medical Notes

No

Financial Account Information

No

Certificates

No

Legal Documents

No

Device Identifiers

No

Web URLs

No

Email Address

No

Education Records

No

Military Status

No

Employment Status

No

Foreign Activities

No
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Other

No

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

Yes

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

No

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

INFORMATION SHARING PRACTICES
1

Information Sharing Practices

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

No

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

Yes/No

Name

No

Date of Birth

No

SSN

No

Photographic Identifiers

No

Driver’s License

No

Biometric Identifiers

No

Mother’s Maiden Name

No

Vehicle Identifiers

No

Mailing Address

No

Phone Numbers

No

Medical Records Numbers

No

Medical Notes

No

Financial Account Information

No

Certificates

No

Legal Documents

No

Device Identifiers

No

Web URLs

No

Email Address

No

Education Records

No

Military Status

No

Employment Status

No

Foreign Activities

No
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Other

No

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

No

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

No

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

No

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

No

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?:

No

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?:

No

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?:

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

User

No

Administrators

No

Developers

No

Contractors

No

Other

No

Purpose

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

Individuals are asked to submit a consent form prior to PII
collection. PII submission is voluntary and is only used as a
means to reference other survey questions. PII is only
temporarily stored.

*31. Please describe in detail any processes in

PII is not retained in the system, therefore, there is no need to
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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.])

notify and obtain consent.

WEBSITE HOSTING PRACTICES
1

Website Hosting Practices

*32. Does the system host a website?:

Yes

Please indicate “Yes” or “No” for each type of
site below:

Yes/ No

Internet

Yes

Intranet

No

Both

No

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

Yes

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

Yes

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

Yes

If no, please indicate when the website will be
P3P compliant:
36. Does the website employ tracking
technologies?:

No

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

No

Web Beacons

No

Session Cookies

Yes

Persistent Cookies

No

Other

No

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

No

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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?:

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

Yes/No

Name

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

Mailing Address

No

Phone Numbers

No

Medical Records Numbers

No

Medical Notes

No

Financial Account Information

No

Certificates

No

Legal Documents

No

Device Identifiers

No

Web URLs

No

Email Address

No

Education Records

No

Military Status

No

Employment Status

No

Foreign Activities

No

Other

Age, Gender, Race/Ethnicity, Zip Code

39. Are rules of conduct in place for access to
PII on the website?:
40. Does the website contain links to sites
external to the OPDIV that owns and/or
operates the system?:
If yes, note whether the system provides a
disclaimer notice for users that follow external
links to websites not owned or operated by the
OPDIV.:

ADMINISTRATIVE CONTROLS
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1

Administrative Controls

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

2
41. Has the system been certified and
accredited (C&A)?:

No

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

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)?:
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):

Yes

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

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:
User Identification

Yes/No

Yes
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Passwords

Yes

Firewall

No

Virtual Private Network (VPN)

No

Encryption

No

Intrusion Detection System (IDS)

No

Common Access Cards (CAC)

No

Smart Cards

No

Biometrics

No

Public Key Infrastructure (PKI)

No

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

Yes

If yes, please briefly describe the process:

NIH Incident Response Team forwards suspected incidents to
the NHGRI Information Systems Security Officer for investigation
and resolution.
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

No

Identification Badges

No

Key Cards

Yes

Cipher Locks

No

Biometrics

No

Closed Circuit TV (CCTV)

Yes

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

Database secured behind locked doors, login/password/id
protected with very limited 'need-to-know' users.
APPROVAL/DEMOTION

1

System Information

System Name:

2

PIA Reviewer Approval/Promotion or Demotion

Promotion/Demotion:
Comments:

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Approval/Demotion Point of Contact:
Date:

3

Senior Official for Privacy Approval/Promotion or Demotion

Promotion/Demotion:
Comments:

4

OPDIV Senior Official for Privacy or Designee Approval

Please print the PIA and obtain the endorsement of the reviewing official below. Once the signature has been collected,
retain a hard copy for the OPDIV's records. Submitting the PIA will indicate the reviewing official has endorsed it
This PIA has been reviewed and endorsed by the OPDIV Senior Official for Privacy or Designee (Name and Date):
Name: __________________________________

Date: ________________________________________

Name:
Date:

5

Department Approval to Publish to the Web

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

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% COMPLETE
1

PIA Completion

PIA Percentage Complete:
PIA Missing Fields:

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