Mvps Pia

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Privacy Impact Assessment Form
v 1.45
Status Draft

Form Number

F-20845

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-7553978-315695

2a Name:

3/24/2015 7:57:12 AM

Message Validation, Processing, and Provisioning System (MVPS
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.

Operations and Maintenance
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

Business Steward

POC Name

Toby Slusher

POC Organization CSELS
POC Email

[email protected]

POC Phone

404.498.2024
New
Existing
Yes
No

Mar 22, 2013

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MVPS system is a multifaceted public health disease
surveillance system that gives public health officials powerful
capabilities to monitor the occurrence and spread of diseases.
Facets of MVPS will be used by numerous state, territorial,
tribal, and local health departments; and by partner
organizations, such as the Council of State and Territorial
Epidemiologists (CSTE).
11 Describe the purpose of the system.

Describe the type of information the system will
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask
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.

The primary goal of the Message Validation, Processing, and
Provisioning System (MVPS) is to develop a common
infrastructure for public health agencies that allows the
Federal, state, and local level public health agencies to store
and exchange data using a common set of business
procedures, metadata, and capabilities that can be defined
from the start.
Contains patient (case) contact data
-Names
-mailing address
-email addresses, phone numbers, medical notes, DOB, Sex/
Race, county, marital status and census tract

The primary goal of the Message Validation, Processing, and
Provisioning System (MVPS) is to develop a common
infrastructure for public health agencies that allows the
Federal, state, and local level public health agencies to store
and exchange data using a common set of business
procedures, metadata, and capabilities that can be defined
from the start and not be introduced ad-hoc.
The MVPS system is a message processing system. Messages
are received and are then validated.
Contains patient (case) contact data; -Names
-mailing address
-email addresses, phone numbers, medical notes, DOB, Sex/
Race, county, marital status and census tract

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

Yes
No

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

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

County

Citizenship/Nationality

Census Tract

Race/Sex

Marital Status

Employees
Public Citizens
16

Business Partners/Contacts (Federal, state, local agencies)

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

Vendors/Suppliers/Contractors
Patients
Other

17 How many individuals' PII is in the system?
18 For what primary purpose is the PII used?
19

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

1,000,000 or more
data is used for research
surveillance, and reporting.

20 Describe the function of the SSN.

N/A

20a Cite the legal authority to use the SSN.

N/A

21

Identify legal authorities governing information use
Public Health Service Act
and disclosure specific to the system and program.

22

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

Yes
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

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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.

0920-0728, Exp. 01/31/2017
Yes

24 Is the PII shared with other organizations?

No
Within HHS

24a

Identify with whom the PII is shared or disclosed and
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?

PII is not collected directly from the individuals. It is collected
from the subjects by the state health departments and
voluntarily shared with CDC by those state entities in its role as
a public health authority.
Voluntary
Mandatory

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Describe the method for individuals to opt-out of the
collection or use of their PII. If there is no option to
27
object to the information collection, provide a
reason.

PII is not collected directly from the individuals. It is collected
from the subjects by the state health departments and
voluntarily shared with CDC by those state entities in its role as
a public health authority.

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
obtained.

PII is not collected directly from the individuals. It is collected
from the subjects by the state health departments and
voluntarily shared with CDC by those state entities in its role as
a public health authority.

Describe the process in place to resolve an
individual's concerns when they believe their PII has
29 been inappropriately obtained, used, or disclosed, or
that the PII is inaccurate. If no process exists, explain
why not.

Written notice or electronic notice cannot be given directly to
patient or subject as the CDC case notification data does not
contain direct personal identifiers (Name, Contact
information). All the communication to the patient or subject
has to go through the reporting jurisdiction.

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.

There is an annual review process for the users that have
access to the data. The user data is the responsibility of the
jurisdiction. The SAMS data is reviewed within the MISO
review process. The source of the the SAMS data is responsible
for updating the data.
User PII data is verified and synchronized with the source
SAMS/MISO systems. Patient PII is currently at rest.

31

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

Users

Access for data analysis, reporting
activities.

Administrators

General access for management of
system resources and users.

Developers
Contractors
Others

Describe the procedures in place to determine which
32 system users (administrators, developers,
Role Based Access Control (RBAC) is utilized
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.

Users are given access according to their jurisdiction and/or
program only has access to that information after proofing and
approval. The data steward oversees the approval process and
determine who get access to the information he or she is
responsible for. The least Privileged modlel is used

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.

Annual Security and Privacy Awareness Training

Describe training system users receive (above and
35 beyond general security and privacy awareness
training).

None

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Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?

Yes
No

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

Records are retained and disposed of in accordance with the
CDC Records Control Schedule. Record copy of study reports
are maintained in agency from two to three years in
accordance with retention schedules. Source documents for
computer are disposed of when no longer needed by program
officials. Disposal methods include erasing computer tapes,
burning or shredding paper materials or transferring records to
the Federal Records Center when no longer needed for
evaluation and analysis. Records are retained for 20 years; for
longer periods if further study is needed

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

PII will be secured using a layered approach. Physical controls
are in-place by virtue of the hosting environment.
Administrative controls are in-place by virtue of a limited user
base (i.e., access is not open). Technical controls are in-place at
the application level to grant access to data based on
authentication and authorization (e.g., role-based access to
jurisdictionally-based data only).

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
5

Is this a candidate for PII minimization?

Yes
No

Reviewer
Notes
6

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

Yes
No

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Reviewer Questions

Answer

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: 2015.05.21 09:16:09 -04'00'

HHS Senior
Agency Official
for Privacy

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