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Privacy Impact Assessment Form
v 1.21
Status

Form Number

0840

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

OMB #0920-0840

2a Name:

02/19/20

Usability Testing to Inform Development of the CDC Division of
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

Health Communication Specialist

POC Name

Tiffani Phelps, MPH

POC Organization Division of STD Prevention
POC Email

[email protected]

POC Phone

404-639-4885
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 applicable

10

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

New Information Collection

11 Describe the purpose of the system.

The purpose of this qualitative evaluation information
collection will explore the usability of the current CDC DSTDP
website. Usability refers to how easily users are able to engage
with the website. This evaluation will provide information on
the ability of participants to complete specified tasks
successfully and easily; participants satisfaction with the
website, its organization, and its content; and, participants
preferences and needs from the website. The information
collected will be combined with the usability tester’s
observations on the users’ experiences and will be immediately
useful to the CDC DSTDP team in revising the website.
The vendor is expected to screen 32 people to achieve a total
participant group of 18 adults. Interviews will be conducted by
evaluation team with 6 people from each subgroup. Since
lower education level likely affects health literacy in general
and could impact the user experience of CDC DSTDP’s website,
half of those recruited will have an education level of high
school or less and half will have some college or more.

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 The evaluation team will collect PII, such as phone numbers,
about the specific data elements.)
email addresses, and names of all potential participants for
recruitment and interview purposes only. They also will collect
race/ethnicity and geographic location as part of the screening
process. This data will not be used beyond the screening
portion of the project. CDC will not have access to any data or
engage in the direct collection of information. No PII will be
transmitted to the CDC.

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

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

The the goals of this new information collection is to conduct
formative qualitative communication evaluation to: 1) Evaluate
user needs and preferences for the CDC Division of Sexually
Transmitted Disease Prevention’s (DSTDP) website; 2)
Determine how well the current information architecture maps
to how users think about the content; and, 3) Evaluate how
easily users can navigate the site and find what they are
looking for.
The evaluation team will collect PII, such as phone numbers,
email addresses, and names of all potential participants for
recruitment and interview purposes only. They also will collect
race/ethnicity and geographic location as part of the screening
process. This data will not be used beyond the screening
portion of the project. CDC will not have access to any data or
engage in the direct collection of information. No PII will be
transmitted to the CDC.
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

Other...

race/ethnicity

Other...

geographic location

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)

<100
PII such as phone numbers, email addresses, used for
recruitment and interview purposes only.
The secondary use of the PII, name and email address, is used
to pay the $30 incentive to participants and to notify
participants of any study changes.

20 Describe the function of the SSN.

not applicable

20a Cite the legal authority to use the SSN.

not applicable

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

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

Yes
No

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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 09-20-0160, "Records of Subjects in Health

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.

OMB #0920-084. A separate CDC identifier will be assigned by
the CDC ICRO following review.
Yes

24 Is the PII shared with other organizations?

No
Within HHS
Other Federal
Agency/Agencies
State or Local
Agency/Agencies

Identify with whom the PII is shared or disclosed and
24a
for what purpose.

Private Sector
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

Not applicable

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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.

26

At the beginning of the study eligible participants will be asked
to review and electronically sign a study consent form that
informs participants that personal identifying information will
be collected and every effort will be made to keep this
information confidential. The consent form will include an
explanation of the study, risks and benefits of participation,
duration of participation, contact information for individuals
who can answer questions about the research study regarding
participant rights and protections, the voluntary nature of
participation, and the right to withdraw without penalty.
Participant are provided with information to contact study staff
if clarification is needed regarding consent processes.
Voluntary

Is the submission of PII by individuals voluntary or
mandatory?

Mandatory

Describe the method for individuals to opt-out of the
Participants can opt out of all PII questions that are not
collection or use of their PII. If there is no option to
27
eligibility related. Also, participants can opt out of participating
object to the information collection, provide a
in the study altogether or withdraw from the study at any time.
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.

All participants will be notified by the study team if any
changes are made to the collection by telephone and or email.

Study participants will be provided contact information and
instructions of how to make contact if they have any questions
about their rights as a participant or concerns that their PII may
have been inappropriately obtained, used, or disclosed:
Participants will be able to update PII at each interval of study
participation when filling out surveys for data collection
purposes.
Users
Administrators

31

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

Developers
Contractors

Study team will have access to PII to
contact study participants and

Others
Study staff accessing the system will be limited by which PII
Describe the procedures in place to determine which data is necessary to perform the duties of their position. Users
also are limited to a reporting-only role, allowing for study
32 system users (administrators, developers,
oversight through real-time aggregate reporting, but no access
contractors, etc.) may access PII.
to protected health information (PHI). The Centers for Disease
Control and Prevention (CDC) lacks access to these data.

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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.

Access to Sensitive PII will be restricted to individuals trained in
human subject protections. PII is collected for a specific and
identifiable purpose with access restricted to specific job tasks
and individuals who perform those tasks.
Assigned user permissions will be determined by their roles to
perform different actions and need to view PII.

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.

All study staff will be trained on relevant study procedures
prior to interacting with participants involved in study
activities.

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

Researchers and study staff will participate in internal training
on study instruments, procedures, and reporting regulations,
which includes privacy awareness and confidentiality training.

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
Records are retained and disposed of in accordance with the
CDC Records Control Schedule 04-4-22 Family of HIV Surveys,
Division of HIV/AIDS Prevention/Surveillance and
Epidemiology, (N1-442-02-3-4, Item 1) and Division of HIV/
AIDS Prevention/Surveillance and Epidemiology, (N1-442-02-3,
Item 1). Record copy of study reports are maintained in agency
records from two to three years in accordance with retention
schedules. Source documents for computer are disposed of
when no longer needed by program officials. Personal
identifiers may be deleted from records when no longer
needed in the study as determined by the system manager,
and as provided in the signed consent form, as appropriate.
Disposal methods include erasing computer disks or tapes,
burning or shredding paper materials or transferring records to
the Federal Records Center when no longer needed for
evaluation and analysis. Cut off closed grant, contract, or
cooperative agreement files at the end of the calendar year in
which the project ends or a final report is written and destroy
six years after cut off.

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Physical
All printed records will be securely stored in locked file
cabinets within locked offices and monitored during access. No
names or other identifying information appear on data
documents or in data files, as the re-contact information will be
stored separately. Only designated staff will have access to the
data.

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

Technical
PII is stored in a database that provides staff with the minimum
amount of data needed to perform tasks associated with their
position. The application securely maintains participant
information behind a firewall rendered over a Secure Sockets
Layer (SSL) certificate for administrator-only access. All
passwords are stored encrypted within the database, which
also uses database level encryption to prevent information
copying from one database to another. Web application also
uses an automatic logout feature after a certain period of
inactivity.
Administrative
All respondents will receive unique identification nonidentifiable codes, which will be stored separately from PII on a
password protected computer. These codes will be used as the
de-identified data set that will later be shared with CDC. CDC
does not have access to the database. All staff collecting data
will participate in a training that will review protections for
privacy and confidentiality of all data, including PII. Only
Principal Investigators may handle requests to examine data
collected during this study.

39 Identify the publicly-available URL:

https://www.cdc.gov/std/default.htm

40 Does the website have a posted privacy notice?

Yes
No

41

Does the website use web measurement and
customization technology?

Yes

42

Does the website have any information or pages
directed at children under the age of thirteen?

Yes

43

Does the website contain links to non- federal
government websites external to HHS?

Yes

Is a disclaimer notice provided to users that follow
43a external links to websites not owned or operated by
HHS?

Yes

No

No

No
No

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

Answer

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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

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2020.04.01
for Privacy
09:49:30 -04'00'

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