Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

TBD

2a Name:

05/07/18

Anthropometric Information on Law Enforcement Officers
General Support System (GSS)
Major Application

3

The subject of this PIA is which of the following?

Minor Application (stand-alone)
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)?

No
Yes
No
Agency
Contractor
POC Title

Branch Chief

POC Name

Hongwei Hsiao

POC Organization CDC/NIOSH
POC Email

[email protected]

POC Phone

304-285-5981
New
Existing
Yes
No

8b Planned Date of Security Authorization
Not Applicable

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8c

Briefly explain why security authorization is not
required

Not needed, OMB.

10

Describe in further detail any changes to the system
that have occurred since the last PIA.

This is a new request.

11 Describe the purpose of the system.

The purpose of this project is to establish an up-to-date
reference database of anthropometric information about law
enforcement officers (LEOs) in the United States. The
information will be used to redesign LEO cruiser cabs and
personal protective gear (such as body armors).

Two parts of personal information will be collected for the
study. The first part is biographical information. The
biographical information includes sex, ethnicity, race, birth day,
Describe the type of information the system will
occupation, year of service at the current occupation, exam
collect, maintain (store), or share. (Subsequent
location, exam date, self-reported body height, and self12
questions will identify if this information is PII and ask reported body weight (see Attachment E: Biographical
about the specific data elements.)
Information). First and last name are also collected the second
part of information is anthropometric information. In addition,
participants who decide to participate in the data collection for
the study will be required to sign an Informed Consent Form.

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The information is collected to determine the eligibility of
individuals for the study, and to assure that the participants by
racial/ethnic group, sex, regions, and age match the proposed
sampling plan (see SSB: Collection of Information Employing
Statistical Methods). The anthropometric information includes
various body measurements (see Attachment G: Data Sheet), fit
of current vehicle and protective gear (see Attachment H:
Assessment of Challenges in Vehicle and with Body Armor),
and scans of participants (see Attachment I: 2-dimensional
hand scan and 3-dimensional body scans). The information is
collected to enhance design guidelines for LEO vehicle
configuration and personal protective equipment (PPE) for
reducing LEO work-related fatalities and injuries. Participants
do not need to reveal their names, except for signing a consent
form.

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

All participant data and personal identifiers in the study will be
managed in accordance with the Privacy Act and the NIOSH
IRB informed consent procedures. All forms and computer data
will be coded with a randomly assigned number to ensure
privacy. The link between the identifiers (in the consent form)
and the assigned random numbers will be kept in the NIOSH
Anthropometry Lab (Room 1502; an access-controlled room) in
a locked cabinet. The consent forms and the “key” of random
number assignments will be destroyed 6 years after the study
is completed. At the data collection sites, locked cabinets will
be available for securing this information. Once the
information is sent back to NIOSH, it will be kept in the NIOSH
Anthropometry Lab (Room 1502), which will be locked and has
key access only by the project officer, the anthropometry lab
manager, Division of Safety Research (DSR) management, and
NIOSH security personnel.
The results of the study in a summary format will be
disseminated to police vehicle manufacturers, manufacturers
of law enforcement officer (LEO) safety equipment, and state
police organizations. Additional dissemination of results will be
reported in peer-reviewed journals and other transportation
safety forums. All data shared will have no identifier (i.e., no
name, birth date, or identifiable face characters).

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

Yes
No

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15

Indicate the type of PII that the system will collect or
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
sex, ethnicity, race, exam
location, exam date
fit of current vehicle and
protective gear
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 Law Enforcement Officers

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)

500-4,999
Subject's name is collected on the consent form by their
signature and is only used for that purpose. Subject's sex,
ethnicity, race, birth day, occupation, year of service at the
current occupation, and exam location, are collected to ensure
the data sampling is representative of the law enforcement
officer population.
Exam date, self-reported body height, and self-reported body
weight, various body measurements, fit of current vehicle and
protective gear, 2-dimensional hand scans, and 3-dimensional
body scans are collected for research to enhance design
guidelines for LEO vehicle configuration and personal
protective equipment (PPE) for reducing LEO work-related
fatalities and injuries.

20 Describe the function of the SSN.

Not Used

20a Cite the legal authority to use the SSN.

SSN Not Used

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The National Institute for Occupational Safety and Health
(NIOSH) of the Centers for Disease Control and Prevention
(CDC), an agency of the Department of Health and Human
Identify legal authorities governing information use Services, is authorized to collect this information, under
21
and disclosure specific to the system and program.
provisions of the Public Service Act, Section 301 (42 U.S.C. 241);
Occupational Safety and Health Act, Section 20 (29 U.S.C. 669);
and the Federal Mine Safety and Health Act of 1977, Section
501 (30 U.S.C. 95)."
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.

SORN 09-20-0159, Records of Subjects in Certific

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?

OMB approval is in process
Yes
No

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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

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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.

Participants who decide to participate in the data collection for
the study will be required to sign an Informed Consent Form.
Participants do not need to reveal their names, except for
signing the consent form. Two parts of personal information
will be collected for the study. The first part is biographical
information (sex, ethnicity, race, birth day, occupation, year of
service at the current occupation, exam location, exam date,
self-reported body height, and self-reported body weight; see
Attachment E: Biographical Information). The information is
collected to determine the eligibility of individuals for the
study, and to assure that the participants by racial/ethnic
group, sex, regions, and age match the proposed sampling
plan; see SSB: Collection of Information Employing Statistical
Methods). The second part of information is anthropometric
information (various body measurements - see Attachment G:
Data Sheet; fit of current vehicle and protective gear – see
Attachment H: Assessment of Challenges in Vehicle and with
Body Armor; and scans of participants – see Attachment I: 2dimensional hand scan and 3-dimensional body scans). The
information is collected to enhance design guidelines for LEO
vehicle configuration and personal protective equipment (PPE)
for reducing LEO work-related fatalities and injuries.
NIOSH is authorized to collect your personal information and
will protect it to the extent allowed by law. There are
conditions under the Privacy Act where your information may
be released to collaborators or contractors, health departments
or disease registries, to the Departments of Justice or Labor, or
to Congressional offices.
The National Institute for Occupational Safety and Health
(NIOSH) of the Centers for Disease Control and Prevention
(CDC), an agency of the Department of Health and Human
Services, is authorized to collect this information, under
provisions of the Public Service Act, Section 301 (42 U.S.C. 241);
Occupational Safety and Health Act, Section 20 (29 U.S.C. 669);
and the Federal Mine Safety and Health Act of 1977, Section
501 (30 U.S.C. 95)."
System of Records Notice (SORN) Name and Number:
Anthropometric Information on Law Enforcement Officers,
SORN 09-20-0159; Federal Register Citation: Volume 82, Page
14000, 03/16/2017.

26

Is the submission of PII by individuals voluntary or
mandatory?

Voluntary
Mandatory

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NIOSH IRB approved consent form states, "Your participation is
voluntary and you may withdraw your consent and your
participation in this study at any time without penalty or loss of
Describe the method for individuals to opt-out of the benefits to which you are otherwise entitled.
collection or use of their PII. If there is no option to
27
You must be at least 18 years of age and be an employed
object to the information collection, provide a
police officer. Women who are pregnant and therefore not
reason.
actively patrolling will be excluded as their body dimension
measurements at this stage would not reflect their nonpregnancy condition. Please let us know if you are in this
status."
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
The data is collected in person; no contact information of
28 and/or data uses have changed since the notice at
individual is available. Major changes to the data system is
the time of original collection). Alternatively, describe unlikely.
why they cannot be notified or have their consent
obtained.
The overall results of the study will be documented in a journal
article or a NIOSH research report. No individual results or facial
Describe the process in place to resolve an
identifications of individuals will be published. For questions
individual's concerns when they believe their PII has about the research study, contact the principal investigator, Dr.
29 been inappropriately obtained, used, or disclosed, or Hongwei Hsiao at [email protected] or 304-285- 5910. For
that the PII is inaccurate. If no process exists, explain questions about your rights, your privacy, or harm to you,
why not.
contact the Institutional Research Board Chair at [email protected],
or 513-533-8591.

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.

Anthropometric data entry and editing software that identifies
possible erroneous values will be used while the survey
participant is present, so remeasures can be taken if necessary.
It is a two-step editing process. In the first step an entered
value is immediately checked against population minima and
maxima. This identifies typing errors, such as too many or too
few digits. It can also flag a dimension that was measured out
of sequence. In the second step, the measured values are
checked against regression-predicted values for that particular
participant. It is a finer check, and can identify errors such as
reversed digits.
Users
Administrators

31

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

Developers
Contractors
Others

Project officer and anthropometry lab
manager are the only ones with the

Describe the procedures in place to determine which
Project officer and anthropometry lab manager are the only
32 system users (administrators, developers,
ones with the random subject number assignments to the PII.
contractors, etc.) may access PII.

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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.

All forms and computer data will be coded with a randomly
assigned number to ensure privacy. The link between the
identifiers (in the consent form) and the assigned random
numbers will be kept in the NIOSH Anthropometry Lab (Room
1502; an access-controlled room) in a locked cabinet. The
consent forms and the “key” of random number assignments
will be destroyed 6 years after the study is completed. The link
will not be stored electronically with other data, so to allow
those with 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.

Project officer and anthropometry lab manager are the only
ones with the random subject number assignments to the PII.
Both of them have had training on human participant safety
and privacy training certificates from the NIOSH Institute
Review Board.

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

Human participant safety and privacy training by the NIOSH
Institute Review Board. CDC SEV # 5300 and #8906.

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.

All forms and computer data will be coded with a randomly
assigned number to ensure privacy. The link between the
identifiers (in the consent form) and the assigned random
numbers will be kept in the NIOSH Anthropometry Lab (Room
1502; an access-controlled room) in a locked cabinet. The
consent forms and the “key” of random number assignments
will be destroyed 6 years after the study is completed.

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

At the data collection sites, locked cabinets will be available for
securing this information. Once the information is sent back to
NIOSH, it will be kept in the NIOSH Anthropometry Lab (Room
1502), which will be locked and has key access only by the
project officer, the anthropometry lab manager, Division of
Safety Research (DSR) management, and NIOSH security
personnel. The project officer and the anthropometry lab
manager will be the only persons with access to the random
subject number assignments that link to the consent form.
They will be responsible for the secured transfer of custody of
the data to a different project officer in the event of a change
in job assignment.

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

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Reviewer Questions
2

Answer

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

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

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Reviewer Questions

Answer

Reviewer
Notes

General Comments

OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by
Beverly E. Walker -S
Date: 2018.05.08
12:51:24 -04'00'

HHS Senior
Agency Official
for Privacy

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