Attachment 5 Privacy Impact Assessment

06.1 HHS Privacy Impact Assessment (Form) / NIH NCI Cancer Genetics Services Directory (CGSD) (Item)	Primavera ProSight
Form Report, printed by: Hummel, Eric, May 27, 2013

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?

No

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

PIA Validation

*1. Date of this Submission:

Jul 24, 2012

*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):

N/A

*5. OMB Information Collection Approval Number:

0925-0639

*6. Other Identifying Number(s):

N/A

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

NIH NCI Cancer Genetics Services Directory (CGSD)

*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	Margaret Beckwith, Ph.D.

*10. Provide an overview of the system:

The National Cancer Institute Cancer Genetics Services Directory (CGSD) on the NCI's Website cancer.gov is a searchable collection of information about professionals who provide services related to cancer genetics. These services include cancer risk assessment, genetic counseling, and genetic susceptibility testing. The professionals have applied to be in the directory using an online application form and have met basic criteria outlined on the form. The CGSD is posting data such as investigator name, title, biography, and work contact information that is already publicly available on institutional websites and is not posting or collecting personally identifiable information.

*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):

*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. There are currently 567 genetics professionals listed in the directory. Approximately 30-60 new professionals are added to the directory each year. The applicants are nurses, physicians, genetic counselors, and other professionals who provide services related to cancer genetics. The information collected on the application includes name, professional qualifications, practice locations, and area of specialization. The information is updated annually using a web-based update mailer that mirrors the application form.

2. The information contained in the NCI Cancer Genetics Services Directory is published on the cancer.gov public website. It is a unique resource for cancer patients and their families who are looking for information about their family's risk of cancer and genetic counseling. Collecting applicant information such as name, title, area of expertise, biography, work contact information and verifying it annually by using the NCI CGSD web-based application form and update mailer is important for providing this information to the public and keeping it current.

3. There is no PII in the system.

4. All professionals listed in the directory voluntarily submit applications to be included.

*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.]):

There is no PII in the system.

*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:

Information is secured using username/passwords, least privilege, separation of duties, an intrusion detection system, firewalls, locks, badge access, background investigations. A comprehensive IRT (Incident Response Team) capability is also maintained.

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?

No

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

PIA Validation

*1. Date of this Submission:

Jul 24, 2012

*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):

N/A

*5. OMB Information Collection Approval Number:

0925-0639

5a. OMB Collection Approval Number Expiration Date:

Aug 31, 2014

*6. Other Identifying Number(s):

N/A

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

NIH NCI Cancer Genetics Services Directory (CGSD)

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

	System Location:
	OPDIV or contractor office building	6116 Executive Blvd., Suite 300A
	Room	Room 3094
	City	Rockville
	State	MD

*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	Margaret Beckwith, Ph.D.

The following information will not be made publicly available:

	POC Title	Acting Branch Chief
	POC Organization	NCI/OCE/OCCM
	POC Phone	301-594-2718
	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)

The National Cancer Institute Cancer Genetics Services Directory (CGSD) on the NCI's Website cancer.gov is a searchable collection of information about professionals who provide services related to cancer genetics. These services include cancer risk assessment, genetic counseling, and genetic susceptibility testing. The professionals have applied to be in the directory using an online application form and have met basic criteria outlined on the form. The CGSD is posting data such as investigator name, title, biography, and work contact information that is already publicly available on institutional websites and is not posting or collecting personally identifiable information.

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:

*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	No
	Education Records	No
	Military Status	No
	Employment Status	No
	Foreign Activities	No
	Other	Business location and business contact information

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	No
	Education Records	No
	Military Status	No
	Employment Status	No
	Foreign Activities	No
	Other	Business location and business contact information

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?

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	No
	Education Records	No
	Military Status	No
	Employment Status	No
	Foreign Activities	No
	Other	Business location and contact information

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

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?

Not Applicable

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)?

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

26a. 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?

27a. 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?

28a. 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	Purpose
	User	Yes	Access information about genetics professionals on cancer.gov
	Administrators	Yes	System administrators have to set permissions to the system and make other system changes
	Developers	Yes	Developers work on software that is used to maintain and publish the data
	Contractors	Yes	Contractors enter new professionals and changes to records of others into the maintenance database
	Other	Not Applicable

*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. There are currently 567 genetics professionals listed in the directory. Approximately 30-60 new professionals are added to the directory each year. The applicants are nurses, physicians, genetic counselors, and other professionals who provide services related to cancer genetics. The information collected on the application includes name, professional qualifications, practice locations, and area of specialization. The information is updated annually using a web-based update mailer that mirrors the application form.

2. The information contained in the NCI Cancer Genetics Services Directory is published on the cancer.gov public website. It is a unique resource for cancer patients and their families who are looking for information about their family's risk of cancer and genetic counseling. Collecting applicant information such as name, title, area of expertise, biography, work contact information and verifying it annually by using the NCI CGSD web-based application form and update mailer is important for providing this information to the public and keeping it current.

3. There is no PII in the system.

4. All professionals listed in the directory voluntarily submit applications to be included.

*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.])

There is no PII in the system.

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	www.cancer.gov/cancertopics/genetics/directory
	Intranet	No
	Both	No

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?

Yes

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)?

Yes

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

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	Yes
	Web Beacons	Yes
	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	No
	Education Records	No
	Military Status	No
	Employment Status	No
	Foreign Activities	No
	Other	business location and contact information

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.

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)?

No

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

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?

No

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?

No

49. Are methods in place to ensure least privilege (i.e., “need to know” and accountability)?

Yes

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

Access to information is restricted to administrative interface.

*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:

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	No
	Intrusion Detection System (IDS)	Yes
	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

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

NIH maintains a comprehensive Incident Response Team (IRT) capability.

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)	No

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

Information is secured using username/passwords, least privilege, separation of duties, an intrusion detection system, firewalls, locks, badge access, background investigations. A comprehensive IRT (Incident Response Team) capability is also maintained.

APPROVAL/DEMOTION

1	System Information

System Name:

NIH NCI Cancer Genetics Services Directory (CGSD)

2	PIA Reviewer Approval/Promotion or Demotion

Promotion/Demotion:

Promote

Comments:

Approval/Demotion Point of Contact:

Suzy Milliard

Date:

Jul 24, 2012

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:

PIA % COMPLETE

1	PIA Completion

PIA Percentage Complete:

91.23

PIA Missing Fields:

Information Sharing Practices Tab, Question 23; Information Sharing Practices Tab, Question 25; Information Sharing Practices Tab, Question 26; Information Sharing Practices Tab, Question 27; Information Sharing Practices Tab, Question 28;