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Privacy Impact Assessment Form
v 1.21
Status

Form Number

0920-17BAN

Question

4/3/2018

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

0920-17BAN

2a Name:

Form Date

Strengthening United States Response to Resistant Gonorrhea (
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.

Initiation
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

Team Lead

POC Name

Robert D. Kirkcaldy

POC Organization NCHHSTP/DSTDP/ESB
POC Email

[email protected]

POC Phone

(404) 639-8659
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

This is an information collection.

10

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

N/A

11 Describe the purpose of the system.

The "Strengthening United States Response to Resistant
Gonorrhea (SURRG)" collection will enhance US state and local
public health surveillance and program infrastructure, build
capacity to support rapid detection and public health response
to antibiotic-resistant gonorrhea, and advance the
understanding of epidemiological factors contributing to
antibiotic-resistant gonorrhea.

SURRG awardees routinely collect PII for the purpose of
monitoring persons seeking STD clinic services, surveillance,
and contacting individuals with gonorrhea to ensure successful
treatment and conduct partner services. The information being
Describe the type of information the system will
collected will include: date of birth, gender, race/ethnicity, HIV
collect, maintain (store), or share. (Subsequent
status, sexual behavior, military status, education level,
12
questions will identify if this information is PII and ask employment status, insurance status and type, and medical
about the specific data elements.)
information, such as frequency of STD testing.
A unique non-identifiable project number is assigned to each
case. The key to link data will only be available at the local level.

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The purpose of SURRG is to improve national capacity to
detect, monitor, and respond to emerging antibiotic-resistant
gonorrhea. SURRG will also provide a robust evidence base for
directing public health action.

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

Nine funded jurisdictions will participate. Healthcare providers
at ~27 participating clinics (sexually transmitted disease (STD)
clinics affiliated with a single public health department (HD) or
other participating non-STD clinic sites) will collect specimens
for N. gonorrhoeae culture testing from men and women.
Cultured bacteria (called “isolates”) will undergo antibiotic
susceptibility testing within several days at the local public
health laboratory. Lab identification of resistance will be
rapidly communicated to a designated local HD staff member;
an outbreak investigation will be initiated. Local HD staff will
interview the person from whom the resistant isolate was
collected to ascertain additional epidemiological data and
information about recent contacts, and will be re-tested to
ensure they were cured of the infection. Recent contacts will
be interviewed and tested by local HD staff. The participating
HDs will collect and transmit to CDC demographic, clinical, and
lab data about persons tested for and diagnosed with
gonorrhea.
The project will utilize 3 distinct strategies to collect the
required information. (1) Facility-based data which will be
abstracted by local HD staff in a standardized way from
existing electronic medical records for patient visits to
participating STD clinics or partnering non-STD clinic sites
during which gonorrhea testing occurred. (2) Results of local
antibiotic-susceptibility testing of N. gonorrhoeae will be
transmitted to the local HD and relevant clinical site. (3) The
Persons found to be infected with gonococcal infections with
reduced antibiotic susceptibility or other gonorrhea infections
of public health significance will be interviewed by HD staff as
part of a field investigation to ascertain epidemiological data
and to identify recent contacts. Consistent with a public health
cluster investigation approach, recent contacts of the patient
who may have been exposed to gonorrhea will be interviewed
(using a standardized interview, including ascertainment of
recent contacts) by HD staff and tested for gonorrhea. The
estimated sample size will be 360 completed interviews.

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

Social media identifiers
(see Q12)

STD Surveillance identifiers

Other...

Other...

Other...

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?

19

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

500-4,999
(1) To allow local public health officials (disease investigation
specialists) to contact persons with gonorrhea and their
contacts (as per routine STD public health practice).

(2) To allow local public health officials to connect STD clinic
data, field investigation data, and laboratory data to ensure
streamlined and efficient access to actionable data during
rapid field investigations. This is currently done as part of
routine public health practice/STD control.
(3) To allow local public health officials to use data collected
during surveillance or during routine medical care at STD
clinics to complete some field investigation, thus reducing the
burden on survey participants by asking redundant questions.

20 Describe the function of the SSN.

N/A. SSNs are not collected

20a Cite the legal authority to use the SSN.

N/A. SSNs are not collected.

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Public Health Service Act, Section 301, "Research and
Identify legal authorities governing information use Investigation," (42 U.S.C. 241); and Sections 304, 306 and 308(d)
21
which discuss authority to maintain data and provide
and disclosure specific to the system and program.
assurances of confidentiality for health research and related
activities (42 U.S.C. 242 b, k, and m(d)).
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?

This is a new Information Collection Request.
Yes
No
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

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Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
24b Matching Agreement, Memorandum of
Not applicable
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

Not applicable
Personal information is routinely collected during the course of
clinical healthcare encounters. Personal information pertaining
to reportable/notifiable diseases (such as gonorrhea) and
contacts of persons with gonorrhea is also legally allowed to
be collected by local and state health departments as part of
surveillance and public health activities and does not require
consent.
Voluntary

Is the submission of PII by individuals voluntary or
mandatory?

Mandatory

Describe the method for individuals to opt-out of the
Opting out of collection of PII would be determined by
collection or use of their PII. If there is no option to
27
healthcare setting policy and local or state statutes regarding
object to the information collection, provide a
collection of data on reportable diseases.
reason.
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.
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.
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.

PII will only be stored and maintained within data systems of
local and state health departments. Local and state statutes
will determine the process for notifying individuals when
major changes to local or state data systems occur. Healthcare
providers who store PII will have determined necessary
policies.
These processes are under the domain of local and state health
departments and clinical providers, and may vary by
jurisdiction.
These processes are under the domain of local and state health
departments and clinical providers, and may vary by
jurisdiction.
Users

Local and/or state health department
officials who are responsible for

Administrators
31

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

Developers
Contractors
Others

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Only local and/or state health department officials who are
responsible for collecting, managing, using, and analyzing the
Describe the procedures in place to determine which data for surveillance and disease control activities will have
32 system users (administrators, developers,
access to data. States and independently funded project areas
contractors, etc.) may access PII.
which receive STD prevention funding must attest annually
that they uphold NCHHSTP Data Confidentiality and Security
Standards.

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.

Only local and/or state health department officials who are
responsible for collecting, managing, using, and analyzing the
data for surveillance and disease control activities will have
access to data. States and independently funded project areas
which receive STD prevention funding must attest annually
that they uphold NCHHSTP Data Confidentiality and Security
Standards.

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.

States and independently funded project areas which receive
STD prevention funding must attest annually that they uphold
NCHHSTP Data Confidentiality and Security Standards and that
those with access to the data have received sufficient training.

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

Details of training is under the auspices of each state and
project area.

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.

Yes
No
CDC uses the CDC Records Control Schedule for determining
retention and destruction of PII, specifically, section 04-4-40
Surveillance Report of STD Activity, which prescribes that
records be retained and destroyed when no longer needed for
administrative or research purposes or when 30 years old,
whichever comes first.
Importantly, CDC will not receive or store PII. Local and state
administrative, technical, and physical controls are determined
by each local and state health department and government. As
grantees of federal STD Prevention Funding, state and project
areas must operate in accordance with current NCHHSTP
Confidentiality and Security Guidelines.

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

CDC data will be stored on an ITSO supported server housed in
the Application Hosting Branch (AHB). This facility is protected
by Guards at the front gate entrance to the campus, additional
protections include Personal Identification Verification (PIV)
card access to the building and rooms where the servers are
located. Guards are also located inside the campus and
buildings to control ingress and egress. Access to the server is
controlled using individual access controls and only authorized
users will have access to the data.

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.

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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

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

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Reviewer Questions

Answer

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
Date: 2018.06.14
17:03:42 -04'00'

HHS Senior
Agency Official
for Privacy

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