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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-97368

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-4801444-000891

2a Name:

3/14/2018 12:44:22 PM

Traumatic Brain Injury Disparities in Rural Areas (TBIDRA)
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.

Development
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)?

8b Planned Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Epidemiologist

POC Name

Bethany West

POC Organization ONDIEH/NCIPC/DUIP
POC Email

[email protected]

POC Phone

770.488.0602
New
Existing
Yes
No
August 10, 2018
Not Applicable

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11 Describe the purpose of the system.

Traumatic Brain Injury Disparities in Rural Areas (TBIDRA)
enables CDC to identify challenges that rural health care
providers face in diagnosing and managing Traumatic Brain
Injury (TBI) across the severity spectrum. It also facilitates the
identification of innovative solutions to address gaps in
services to improve clinical care and TBI outcomes in rural
communities.

TBIDRA collects and maintains survey data, names, e-mail
addresses, mailing addresses, phone numbers, and
demographic data from physicians, physician assistants, and
nurse practitioners living in both rural and urban areas. No
personal or health information will be collected or maintained.
Describe the type of information the system will
UserID, Pin and Password associated with respondents are
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask used to identify the individual as a valid respondent to the
contractor's survey instrument; all of which will be stored until
about the specific data elements.)
the end of the contract. Users accessing the system do not
require a user id/password; validation occurs via Active
Directory.
User access is not controlled via
The Traumatic Brain Injury Disparities in Rural Areas (TBIDRA) is
a system whose purpose is to collect data that will serve to aid
CDC in identifying the challenges that rural health care
providers face in diagnosing and managing TBI across the
severity spectrum and beginning to identify innovative
solutions to address gaps in services to improve clinical care
and TBI outcomes in rural communities.

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

The information system will collect and maintain survey data,
names, e-mail address, mailing address, phone number, and
demographic data from physicians, physician assistants, and
nurse practitioners living in both rural and urban areas. No
personal health information will be collected or maintained.
The data will be collected orally via focus groups as well as
through a one-time web survey. Information will be
documented and saved on the Contractor's internal secured
file server, as well as in the web server databases. A UserID, Pin
& Password used to identify the individual as a valid
respondent to the Contractor survey instrument. All this
information will be stored temporarily until the end of the
contract.

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
Respondent user ID/Password

Employees
Public Citizens
16

Business Partners/Contacts (Federal, state, local agencies)

Indicate the categories of individuals about whom PII
is collected, maintained or shared.

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)

100-499
The PII is used primarily for contact and follow-up.
N/A

20 Describe the function of the SSN.

N/A

20a Cite the legal authority to use the SSN.

N/A

21

Identify legal authorities governing information use Public Health Service Act, Section 301, "Research and
and disclosure specific to the system and program.
Investigation" (42 U.S.C. 241).

22

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

Yes
No

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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?
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

Is the submission of PII by individuals voluntary or
mandatory?

Describe the method for individuals to opt-out of the
collection or use of their PII. If there is no option to
27
object to the information collection, provide a
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.

The OMB information collection approval number is 0920-1218
and the expiration date 02/28/2021.
Yes
No
A disclosure notification will be part of the script read to
respondents on survey site to obtain consent (for web survey)
and the process for focus groups and email communication to
schedule participation.
Voluntary
Mandatory
Individuals can opt-out of the study. During the introductory
script individuals will be advised that they can at any time optout of the study or refuse to answer any questions they do not
wish to answer.

The Contractor contacts the participants via email and phone
numbers on record to notify and obtain consent when major
changes occur to the system.

Individuals with concerns about inappropriate attainment, use,
or disclosure as well as inaccuracy of their PII may report their
concerns to the Contractor's Institutional Review Board.

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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.

Data collection will occur one-time. These methods will serve
as the primary manner in which the data is reviewed for
integrity, availability, accuracy, and relevancy.
Users
Administrators

31

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

Developers

Contractors

To conduct interviews or manage the
data collection process.
Administrators (contractors)
Administrators have full rights to

Others
Contractor uses the concept of role-based access control
(RBAC) to give the appropriate permissions associated with
each user role. RBAC uses the security principle of least
privilege which gives the user the precise amount of privilege
that is necessary to perform their job.

Describe the procedures in place to determine which
32 system users (administrators, developers,
Contractor administrators have full access to any files on the
contractors, etc.) may access PII.
server once approval to gain access is granted.

The developers do not require access to PII because they are
needed to validate and test the application's functionality. The
users do not require access to PII because they are there to
give the survey to respondents and manage data collection.
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.

The least privilege model will be used to allow those with
access to PII to be able to access the minimum amount of PII
needed to perform their job. Users must request access to
specific files needed and that is the only access they are
permitted. No one will be granted more access than is
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.

All personnel having system access are required to take Privacy
and IT Security Awareness training upon hire and annually
thereafter. This training has been reviewed and is compatible
with CDC requirements to make them aware of their
responsibilities for protecting the information being collected
and maintained.

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

All system users are required to complete annual training
requirements that consist of Ethics and Compliance training,
security awareness course and sign the acknowledgment of
the CDC Rules of Behavior which has been reviewed and is
compatible with CDC requirements.

Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?

Yes
No

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Describe the process and guidelines in place with
37 regard to the retention and destruction of PII. Cite
specific records retention schedules.

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

Records are retained and disposed of in accordance with the
CDC Records Control Schedule (N1-442-09-1) and in
accordance with contractual agreement. Record copy of study
reports are maintained in agency 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
tapes, burning or shredding paper materials or transferring
records to the Federal Records Center when no longer needed
for evaluation and analysis. Records are retained for 20 years;
for longer periods if further study is needed.
Administrative controls include a system security plan,
contingency plan, regular back up of files and storage of
backups off site, role-based security awareness training, least
privilege access enforced through Active Directory groups,
separate user and privileged accounts for administrators,
policies and procedures in place for retention and destruction
of PII, and a corporate incident response team and incident
response plans.
Technical controls include identification and authentication
using unique user IDs, passwords, and smart cards, use of
firewalls and intrusion detection/prevention systems, virus
scanning software on all computers, and a security information
and event management (SIEM) solution.
Physical controls include guards, identification badges, key
cards, and closed circuit TV.

39 Identify the publicly-available URL:
40 Does the website have a posted privacy notice?

This system is still in development and the publicly-available
URL is not available yet.
Yes
No

40a

Is the privacy policy available in a machine-readable
format?

Yes

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

No
No

No

No

General Comments

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OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by
Beverly E. Walker -S
Date: 2018.08.09 17:53:19
-04'00'

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