Pia

PRIVACY IMPACT ASSESSMENT (PIA)
For the
Department of Defense Postsecondary Education Complaint System
Office of the Assistant Secretary of Defense

SECTION 1: IS A PIA REQUIRED?
a. Will this Department of Defense (DoD) information system or electronic collection of
information (referred to as an "electronic collection" for the purpose of this form) collect,
maintain, use, and/or disseminate PII about members of the public, Federal personnel,
contractors or foreign nationals employed at U.S. military facilities internationally? Choose
one option from the choices below. (Choose (3) for foreign nationals).
(1) Yes, from members of the general public.
(2) Yes, from Federal personnel* and/or Federal contractors.
(3) Yes, from both members of the general public and Federal personnel and/or Federal contractors.
(4) No
* "Federal personnel" are referred to in the DoD IT Portfolio Repository (DITPR) as "Federal employees."

b. If "No," ensure that DITPR or the authoritative database that updates DITPR is annotated
for the reason(s) why a PIA is not required. If the DoD information system or electronic
collection is not in DITPR, ensure that the reason(s) are recorded in appropriate
documentation.
c. If "Yes," then a PIA is required. Proceed to Section 2.

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SECTION 2: PIA SUMMARY INFORMATION
a. Why is this PIA being created or updated? Choose one:
New DoD Information System

New Electronic Collection

Existing DoD Information System

Existing Electronic Collection

Significantly Modified DoD Information
System

b. Is this DoD information system registered in the DITPR or the DoD Secret Internet Protocol
Router Network (SIPRNET) IT Registry?
Yes, DITPR

Enter DITPR System Identification Number

Yes, SIPRNET

Enter SIPRNET Identification Number

16924

No

c. Does this DoD information system have an IT investment Unique Project Identifier (UPI), required
by section 53 of Office of Management and Budget (OMB) Circular A-11?
No

Yes
If "Yes," enter UPI

If unsure, consult the Component IT Budget Point of Contact to obtain the UPI.

d. Does this DoD information system or electronic collection require a Privacy Act System of
Records Notice (SORN)?
A Privacy Act SORN is required if the information system or electronic collection contains information about U.S. citizens
or lawful permanent U.S. residents that is retrieved by name or other unique identifier. PIA and Privacy Act SORN
information should be consistent.

Yes

If "Yes," enter Privacy Act SORN Identifier

No
DPR 44 DoD

DoD Component-assigned designator, not the Federal Register number.
Consult the Component Privacy Office for additional information or
access DoD Privacy Act SORNs at: http://www.defenselink.mil/privacy/notices/

or
Date of submission for approval to Defense Privacy Office
Consult the Component Privacy Office for this date.

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e. Does this DoD information system or electronic collection have an OMB Control Number?
Contact the Component Information Management Control Officer or DoD Clearance Officer for this information.
This number indicates OMB approval to collect data from 10 or more members of the public in a 12-month period
regardless of form or format.

Yes
Enter OMB Control Number

0704-0501 (Pending renewal)

Enter Expiration Date
No
f. Authority to collect information. A Federal law, Executive Order of the President (EO), or DoD
requirement must authorize the collection and maintenance of a system of records.
(1) If this system has a Privacy Act SORN, the authorities in this PIA and the existing Privacy Act
SORN should be the same.
(2) Cite the authority for this DoD information system or electronic collection to collect, use,
maintain and/or disseminate PII. (If multiple authorities are cited, provide all that apply.)
(a) Whenever possible, cite the specific provisions of the statute and/or EO that
authorizes the operation of the system and the collection of PII.
(b) If a specific statute or EO does not exist, determine if an indirect statutory authority can
be cited. An indirect authority may be cited if the authority requires the operation or administration of
a program, the execution of which will require the collection and maintenance of a system of records.
(c) DoD Components can use their general statutory grants of authority (“internal
housekeeping”) as the primary authority. The requirement, directive, or instruction implementing the
statute within the DoD Component should be identified.
E.O. 13607, Establishing Principles of Excellence for Educational Institutions Serving Service Members,
Veterans, Spouses, and Other Family Members; and DoD Instruction 1322.25, Voluntary Education
Programs.

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g. Summary of DoD information system or electronic collection. Answers to these questions
should be consistent with security guidelines for release of information to the public.
(1) Describe the purpose of this DoD information system or electronic collection and briefly
describe the types of personal information about individuals collected in the system.
The DoD Postsecondary Education Complaint System (PECS) provides Uniformed Service Members,
spouses, and other family members, and members of the U.S. Coast Guard the opportunity to file formal
complaints when educational institutions fail to follow the Principles of Excellence outlined in Executive Order
13607 and the DoD Voluntary Education Partnership MOU. The PECS serves as a collaborative
environment that permits DoD personnel the ability to track, manage and process submitted complaints in
order to meet the requirements of the executive order and the DoD Voluntary Education Partnership MOU
and the Department of Defense Instruction 1322.25, which also establishes the need for PECS and instructs
the Services on handling PECS complaints. The PECS data may also be used to perform statistical and
program analysis.
PII elements collected:
Name, complaint case ID, DoD Identification (DoD ID) number, pay grade, address, street address, city,
state, zip code, country, phone number, age range, email address, service affiliation (service member,
spouse or family member, veteran), service branch, service status, sponsor information (service status,
service branch, and pay grade), type of education benefits used, school name and , school mailing address,
level of study, amount of out-of-pocket tuition or government tuition credit paid (academic year), education
center name, education center mailing address, complaint description and resolution, name and contact
information of person submitting complaint on behalf of a covered individual.

(2) Briefly describe the privacy risks associated with the PII collected and how these risks
are addressed to safeguard privacy.
The privacy risks to the individual associated with the collected PII are unauthorized access to the data or
possible misuse of the data as a result of attacks that include computer hackers, disgruntled employees, and
state-sponsored information warfare.
Records are maintained on a guarded military installation, in a secure building in a controlled area accessible
only to authorized personnel. Physical entry is restricted by the use of cipher locks and passwords and
administrative procedures which are changed periodically. The system is designed with access controls,
comprehensive intrusion detection, and virus protection. The application is accessed only by users who
have authenticated with either DS Logon or Common Access Card (CAC) authentication. Access to any
records in the system is further restricted to only CAC authenticated users, based on role privileges, and who
requires the data in the performance of official duties and have completed information assurance and privacy
training annually. Data is transmitted via Transport Layer Security (TLS) and Secure Sockets Layer (SSL)
encryption to protect session information. Encrypted random tokens are implemented to protect against
session hijacking attempts. PECS does not store PII in memory blocks. PECS does not store PII data in
cookies or temporary files. Cookies are not cached and are deleted at the termination of each session.
PECS database connections are established and terminated at the start and end of each database
transaction.
Furthermore, to ensure the integrity of privacy data, all application data are tracked and logged. All data
accessible to users are audited for modification and are traceable to a specific user and to a specific time.
Physical security for privacy data is provided by PECS' host (eFOIA/INOSC-East infrastructure) at Langley
Air Force Base. As an Air Force establishment, strict physical security measures are always followed.

h. With whom will the PII be shared through data exchange, both within your DoD Component and
outside your Component (e.g., other DoD Components, Federal Agencies)? Indicate all that apply.
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Within the DoD Component.
Specify.

OASD(READINESS), FORCE EDUCATION (VOLUNTARY EDUCATION)

Other DoD Components.

Specify.

Air Force, Army, Marines, Navy, and My Career Advancement Account
(MyCAA),

Other Federal Agencies.

Specify.

US Coast Guard, Federal Trade Commission (FTC), Department of Justice
(DoJ), Department of Veteran Affairs (VA), Department of Education (ED),
and Consumer Financial Protection Bureau (CFPB)

State and Local Agencies.

Specify.
Contractor (Enter name and describe the language in the contract that safeguards PII.)

Specify.

BAM Technologies, in performance of contract duties. Contract requires baseline IA
controls be implemented to ensure PII is safeguarded. Non-disclosures are in place
for all BAM employees working the PECS project.

Other (e.g., commercial providers, colleges).

Specify.
i. Do individuals have the opportunity to object to the collection of their PII?
Yes

No

(1) If "Yes," describe method by which individuals can object to the collection of PII.
The individual can choose to not enter their PII; however, no further action will be taken in order to submit a
complaint.

(2) If "No," state the reason why individuals cannot object.

j. Do individuals have the opportunity to consent to the specific uses of their PII?

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Yes

No

(1) If "Yes," describe the method by which individuals can give or withhold their consent.

(2) If "No," state the reason why individuals cannot give or withhold their consent.

Upon accessing the system, the Privacy Act Statement is displayed which provides information to
the complaint filer on how his/her information will be used and/or shared should the complaint
be submitted. The individual must then take action by either clicking a button in order to
proceed into the collection process, or by simply canceling and exiting the system (if they do not
consent to sharing their information). Without specific information pertaining to a complaint,
the DoD cannot follow up with a school and if the school cannot identify a particular incident it
cannot review for corrections if required. Federal enforcement agencies cannot investigate
incidents that may have occurred that warrant further investigation without specific information.
k. What information is provided to an individual when asked to provide PII data? Indicate all that
apply.
Privacy Act Statement

Privacy Advisory

Other

None

Describe PRIVACY ACT STATEMENT
each
applicable AUTHORITY: E.O. 13607, Establishing Principles of Excellence for Educational Institutions Serving
format.
Service Members, Veterans, Spouses, and Other Family Members; and DoD Instruction 1322.25,
Voluntary Education Programs.
PURPOSE: To provide Uniformed Service Members, spouses, and other family members the
opportunity to file formal complaints when educational institutions fail to follow the Principles of
Excellence outlined in E.O. 13607 and DoD Instruction 1322.25 DoD Voluntary Education Partnership
MOU.
ROUTINE USE(S): To the Federal Trade Commission Consumer Sentinel Network for access by the
Departments of Veterans Affairs, Education, Justice, and the Consumer Financial Protection Bureau
for compliance with Executive Order 13607 and potential enforcement efforts. Information may be
shared with schools listed in a complaint to aid in the resolution of a case. Applicable Routine Use(s)
are: Law Enforcement Routine Use, Congressional Inquiries Disclosure Routine Use, Disclosure
When Requesting Information Routine Use, Disclosure of Requested Information Routine Use,
Disclosure to the Department of Justice for Litigation Routine Use, Disclosure of Information to the
National Archives and Records Administration Routine Use, and Data Breach Remediation Purposes
Routine Use.
The Privacy Act System of Records Notice is DPR 44 DoD, DoD Postsecondary Education Complaint
System (PECS), found at http://dpcld.defense.gov/Privacy/SORNsIndex/DODwideSORNArticleView/
tabid/6797/Article/570751/dpr-44-dod.aspx
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DISCLOSURE: Voluntary. However, failure to provide the information requested may result in a
delay in processing your complaint or the inability of Federal agencies to address your complaint.

NOTE:
Sections 1 and 2 above are to be posted to the Component's Web site. Posting of these
Sections indicates that the PIA has been reviewed to ensure that appropriate safeguards are in
place to protect privacy.
A Component may restrict the publication of Sections 1 and/or 2 if they contain information that
would reveal sensitive information or raise security concerns.

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