Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.45
Status Draft

Form Number

F-45991

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-3857651-701959

2a Name:

7/1/2014 8:24:38 AM

World Trade Center Health Program (WTCHP)
General Support System (GSS)
Major Application

3

Minor Application (stand-alone)

The subject of this PIA is which of the following?

Minor Application (child)
Electronic Information Collection
Unknown

3a

Identify the Enterprise Performance Lifecycle Phase
of the system.

Implementation
Yes

3b Is this a FISMA-Reportable system?

4

Does the system include a Website or online
application available to and for the use of the general
public?

5

Identify the operator.

6

Point of Contact (POC):

7

Is this a new or existing system?

8

Does the system have Security Authorization (SA)?

8a Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

AD Informatics, NIOSH

POC Name

Ken McKneely

POC Organization NIOSH
POC Email

[email protected]

POC Phone

(404) 498-2513
New
Existing
Yes
No

Oct 3, 2013

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11 Describe the purpose of the system.

The purpose of the World Trade Center Health Program system
is to protect World Trade Center Health Program information
for the medical coverage to the survivors of the September
11th tragedy and their beneficiaries as a result of the James
Zadroga 9/11 Health and Compensation Act of 2010.

Describe the type of information the system will
collect, maintain (store), or share. (Subsequent
Health Care Administration, General Science and Innovations,
12
questions will identify if this information is PII and ask Personal Identity and Authentication
about the specific data elements.)

Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

WTCHP obtains PII voluntarily for billing, processing payments,
tracking applicant status, research studies and eligibility
determinations. WTC Health Program Records are obtained
from individual applicants and enrollees, from medical
providers who have treated eligible individuals, and from data
centers that are repositories of demographic and clinical
information about WTC responders and survivors.
The system stores information on encrypted file servers.
Yes

14 Does the system collect, maintain, use or share PII?

Indicate the type of PII that the system will collect or
15
maintain.

No
Social Security Number

Date of Birth

Name

Photographic Identifiers

Driver's License Number

Biometric Identifiers

Mother's Maiden Name

Vehicle Identifiers

E-Mail Address

Mailing Address

Phone Numbers

Medical Records Number

Medical Notes

Financial Account Info

Certificates

Legal Documents

Education Records

Device Identifiers

Military Status

Employment Status

Foreign Activities

Passport Number

Taxpayer ID

Employees
Public Citizens
16

Indicate the categories of individuals about whom PII
is collected, maintained or shared.

Business Partners/Contacts (Federal, state, local agencies)
Vendors/Suppliers/Contractors
Patients
Other

17 How many individuals' PII is in the system?
18 For what primary purpose is the PII used?

50,000-99,999
PII is obtained voluntarily for billing, processing payments,
tracking applicant status, and eligibility determinations.

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19

Describe the secondary uses for which the PII will be
used (e.g. testing, training or research)

General Science and Innovations

20 Describe the function of the SSN.

N/A

20a Cite the legal authority to use the SSN.

N/A

Public Health Service Act, Section 301, "Research and
Investigation" (42 U.S.C. 241); Occupational Safety and Health
Identify legal authorities governing information use Act, Section 20, "Research and Related Activities" (29 U.S.C.
21
and disclosure specific to the system and program.
669); and the Public Health Service Act, Title XXXIII, "World
Trade Center Health Program" (42 U.S.C. §§ 300mm –
300mm-61).
22

Yes

Are records on the system retrieved by one or more
PII data elements?

No
Published:

Identify the number and title of the Privacy Act
System of Records Notice (SORN) that is being used
22a
to cover the system or identify if a SORN is being
developed.

Published:
Published:
In Progress
Directly from an individual about whom the
information pertains
In-Person
Hard Copy: Mail/Fax
Email
Online
Other
Government Sources

23

Within the OPDIV
Other HHS OPDIV
State/Local/Tribal
Foreign
Other Federal Entities
Other

Identify the sources of PII in the system.

Non-Government Sources
Members of the Public
Commercial Data Broker
Public Media/Internet
Private Sector
Other
23a

Identify the OMB information collection approval
number and expiration date.

24 Is the PII shared with other organizations?

0920-0891, expires 12/31/2014
Yes
No

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Within HHS
Identify with whom the PII is shared or disclosed and
24a
for what purpose.

Other Federal
Agency/Agencies
State or Local
Agency/Agencies
Private Sector

Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
24b Matching Agreement, Memorandum of
Understanding (MOU), or Information Sharing
Agreement (ISA)).
24c

Describe the procedures for accounting for
disclosures

Describe the process in place to notify individuals
25 that their personal information will be collected. If
no prior notice is given, explain the reason.

26

Is the submission of PII by individuals voluntary or
mandatory?

Program applicants receive a copy of the WTCHP Privacy
Notice found here: http://www.cdc.gov/wtc/pdfs/NPP%20_%
20Full%20Page_%20WTC%20Health%20Program.pdf.
In addition program applications include the Privacy Act
Statement.
Voluntary
Mandatory

Describe the method for individuals to opt-out of the
The potential claimants will fill out a voluntary eligibility
collection or use of their PII. If there is no option to
27
worksheet at their local providers office voluntarily and can
object to the information collection, provide a
opt-out of the collection of PII with the Provider.
reason.
If the WTC Health Program makes any changes to disclosures
and/or data uses, a revised Notice of Privacy Practices will be
made electronically available on the WTC Health Program
website and it will be mailed to members WTC Health
Program’s next annual mailing. Individuals can also request to
receive a copy of the current notice as described in the

Describe the process to notify and obtain consent
from the individuals whose PII is in the system when
major changes occur to the system (e.g., disclosure
28 and/or data uses have changed since the notice at
the time of original collection). Alternatively, describe
why they cannot be notified or have their consent
NOTICE OF PRIVACY PRACTICES FOR THE WORLD TRADE
obtained.
CENTER HEALTH PROGRAM
http://www.cdc.gov/wtc/pdfs/NPP%20_%20Full%20Page_%
20WTC%20Health%20Program.pdf

The Privacy Notice received by the applicant advises them that
if he/she believes that his/her privacy rights have
been violated, they may file a complaint with the WTC Health
Program by calling 1-888-982-4748, or by sending a letter to
Describe the process in place to resolve an
P.O. Box 7000 Rensselaer, NY 12144
individual's concerns when they believe their PII has ATTN:
29 been inappropriately obtained, used, or disclosed, or WTC Health Program, HIPAA Complaint.
that the PII is inaccurate. If no process exists, explain They are further advised that theymay also file a complaint
why not.
with the Department of Health and Human Services Office for
Civil Rights by sending a letter to 200 Independence Avenue,
S.W., Washington, D.C. 20201, calling 1-877-696-6775, or
visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
TTY users should call 1-800-537-7697.

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Describe the process in place for periodic reviews of
PII contained in the system to ensure the data's
30
integrity, availability, accuracy and relevancy. If no
processes are in place, explain why not.

31

Identify who will have access to the PII in the system
and the reason why they require access.

The System Administrator will continuously monitor the
replication of files and file server data for integrity, availability,
and accuracy.

Users

To protect World Trade Center Health
Program information for the medical
coverage to the survivors of the
September 11th tragedy and their
beneficiaries as a result of the James
Zadroga 9/11 Health and
Compensation Act of 2010.

Administrators

Troubleshooting and system updates.

Developers
Contractors
Others
Describe the procedures in place to determine which
32 system users (administrators, developers,
The system owner determines access to the system
contractors, etc.) may access PII.
Describe the methods in place to allow those with
33 access to PII to only access the minimum amount of
information necessary to perform their job.
Identify training and awareness provided to
personnel (system owners, managers, operators,
contractors and/or program managers) using the
34
system to make them aware of their responsibilities
for protecting the information being collected and
maintained.
Describe training system users receive (above and
35 beyond general security and privacy awareness
training).
Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?

Describe the process and guidelines in place with
37 regard to the retention and destruction of PII. Cite
specific records retention schedules.

Least privilege and RBAC to limit access to PII.

All personnel with access to the system complete CDC Annual
Security and Privacy Awareness Training.

System users and administrators receive CDC Rules of Behavior
training in addition to Security Awareness Training.
Yes
No
Records are retained and disposed in accordance with CDC
Electronic Records Control Schedule for NIOSH records.
Research records are maintained in the agency for three years
after close of the study. WTC Health Program records are
transferred to Federal Records Center 15 years after the case
file becomes inactive and are destroyed after 75 years.
Paper files that have been scanned to create electronic copies
are disposed of after the copies are verified. Disposal methods
include erasing computer tapes and burning or shredding
paper material.

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Administrative controls: A database software security package
is utilized to control unauthorized access to the system. Access
is granted to only a limited number of physicians, scientists,
and designated support staff, as authorized by the system
manager, to accomplish the stated purposes for which the
data in this system has been collected.

Describe, briefly but with specificity, how the PII will
38 be secured in the system using administrative,
technical, and physical controls.

Physical controls: Hard copy records are kept in locked
cabinets in locked rooms. Guard services in the buildings
provides screening of visitors and personnel. The limited
access, secured computer room contains fire extinguishers and
an overhead sprinkler system. Computer workstations and
automated records are located in secured areas. Electronic
anti-intrusion devices are in operation at the Federal Records
Center.
Technical controls: Data sets are password protected and/or
encrypted. Protection for computerized records both on the
mainframe and the NIOSH Local Area Network (LAN) includes
programmed verification of valid user identification code and
password prior to logging onto the system, mandatory
password changes, limited-login attempts, virus protection,
and user rights/file attribute restrictions. Password protections
imposes user name and password login requirements to
prevent unauthorized access. Each user name is assigned
limited access rights to files and directories at varying levels to
control file sharing. There are routine daily backup procedures
and secure off-site storage is available for backup tapes.

REVIEWER QUESTIONS: The following section contains Reviewer Questions which are not to be filled out unless the user is an OPDIV
Senior Officer for Privacy.

Reviewer Questions
1

Are the questions on the PIA answered correctly, accurately, and completely?

Answer
Yes
No

Reviewer
Notes
2

Does the PIA appropriately communicate the purpose of PII in the system and is the purpose
justified by appropriate legal authorities?

Yes

Do system owners demonstrate appropriate understanding of the impact of the PII in the
system and provide sufficient oversight to employees and contractors?

Yes

No

Reviewer
Notes
3

No

Reviewer
Notes
4

Does the PIA appropriately describe the PII quality and integrity of the data?

Yes
No

Reviewer
Notes

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Reviewer Questions
5

Answer
Yes

Is this a candidate for PII minimization?

No

Reviewer
Notes
6

Does the PIA accurately identify data retention procedures and records retention schedules?

Yes
No

Reviewer
Notes
7

Are the individuals whose PII is in the system provided appropriate participation?

Yes
No

Reviewer
Notes
8

Does the PIA raise any concerns about the security of the PII?

Yes
No

Reviewer
Notes
9

Is applicability of the Privacy Act captured correctly and is a SORN published or does it need
to be?

Yes
No

Reviewer
Notes
10

Is the PII appropriately limited for use internally and with third parties?

Yes
No

Reviewer
Notes
11

Does the PIA demonstrate compliance with all Web privacy requirements?

Yes
No

Reviewer
Notes
12

Were any changes made to the system because of the completion of this PIA?

Yes
No

Reviewer
Notes

General Comments

OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by Beverly E. Walker -S
DN: c=US, o=U.S. Government,
ou=HHS, ou=CDC, ou=People,
0.9.2342.19200300.100.1.1=100144034
3, cn=Beverly E. Walker -S
Date: 2014.08.11 18:21:37 -04'00'

HHS Senior
Agency Official
for Privacy

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