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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:

09/27/18

Communities Organized for the Prevention of Arboviruses (COP
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.

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

Health Scientist

POC Name

Stephen H (Steve) Waterman

POC Organization NCEZID/DB
POC Email

[email protected]

POC Phone

787.706.2465
New
Existing
Yes
No

Sep 28, 2018
Not Applicable

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8c

Briefly explain why security authorization is not
required

10

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

None
The National Center for Emerging and Zoonotic Infectious
Diseases (NCEZID)-Division of Vector Borne Diseases (DVBD) Dengue Branch (DB) is developing the Communities Organized
for the Prevention of Arboviruses (COPA) system to collect,
manage and analyze data related to the knowledge, attitudes
and practices from communities potentially hosting viral
diseases transmitted to humans by infected mosquitoes i.e.,
Dengue, West Nile, chikungunya, Yellow Fever, and Zika and
assist in the arboviral prevention and control.

11 Describe the purpose of the system.

The objective of COPA is to collect data on what actions an
individual will take once bitten by mosquitoes, to demonstrate
and ability to recognize and eliminate breeding containers and
to educate residents about Dengue mosquito and arboviral
prevention and control within the community. Primary focus is
to communicate prevention and control. The goal is to ensure
that these changes will ultimately translate into a significant
decrease in disease risk and transmission and to recognize it
could influence people’s ability to get early medical treatment
because mosquito bites are not considered a threat to life.
Data is collected from participants of randomly selected
households in communities potentially hosting mosquito
borne viral diseases. Heads of household will give general
information related to the household and participating
individuals will offer information related to their personal
mosquito bite prevention behaviors.
COPA data are entomological surveys conducted to measure
response and action in population areas where mosquitoes
could potentially transmit viral disease infections to humans
i.e., Dengue, West Nile, Chikungunya, Yellow Fever, and Zika.

Describe the type of information the system will
Data will be collected from randomly selected households with
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask individuals supplying information related to their mosquito
bite prevention behaviors, whether or not they know about
about the specific data elements.)
Dengue, how it is spread, and if they can identify breeding
sites. The system will collect Name, DOB, Phone Numbers, Email/Physical Address, GPS coordination, and Dwelling type.
The user access to CDC is using user ID and Password to upload
data.

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COPA is a Tablet-based EpiInfo survey tool, a statistical
software for epidemiology developed by the CDC. The
objective of COPA is to collect data on what actions an
individual will take once bitten by mosquitoes or demonstrate
ability to recognize and eliminate breeding containers and
educating residents about dengue mosquito and arboviral
prevention and control by community residents.

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

Data will be analyzed by Dengue Branch epidemiologists and
study personnel. CDC Dengue Branch will be the steward/
owner of the data processed by this system. The data will be
used by epidemiologists and study personnel to understand
mosquito prevention behaviors in the community study and
evaluate future interventions for the prevention of arboviral
diseases.
Data will be collected from randomly selected households with
individuals supplying information related to their mosquito
bite prevention behaviors, whether or not they know about
dengue, how it is spread, and if they can identify breeding
sites. The system will collect Name, DOB, Phone Numbers, Email/Physical Address, GPS coordination, and Dwelling type.
The user access to CDC is using user ID and Password to upload
data.
Yes

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

15

Indicate the type of PII that the system will collect or
maintain.

No
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

HHS User Credential
Information

GPS coordinates
Dwelling type

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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?

100-499
General Public: PII is used for mosquito mitigation behavior
analysis.
HHS User Credentials are used to identify the CDC employee
conducting the collection of data.

19

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

None

20 Describe the function of the SSN.

Not Applicable

20a Cite the legal authority to use the SSN.

Not Applicable

21

Identify legal authorities governing information use
Public Health Service Act
and disclosure specific to the system and program.

22

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

Yes
No
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

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23a

Identify the OMB information collection approval
number and expiration date.

In Progress.
Yes

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

No
CDC requires non-governmental participants in the COPA
survey to give consent with the research or public health event
by capturing a certified electronic signature from each
participant in the research protocol or study beforehand.
Individuals participating in COPA survey grant consent
through the COPA Consent Form.
Voluntary

Is the submission of PII by individuals voluntary or
mandatory?

Mandatory

Individuals may choose not to participate by refusing to sign
Describe the method for individuals to opt-out of the the consent form.
collection or use of their PII. If there is no option to
27
Collection of employees Non-Sensitive Internal CDC Business
object to the information collection, provide a
Contact Information related contact information is for user
reason.
identification with assigned responsibility in order to perform
specific functions of their employment.
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 information is collected using the Consent Forms. Any
28 and/or data uses have changed since the notice at
major changes would be explained in those forms thereby
the time of original collection). Alternatively, describe giving the appropriate notice.
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.

31

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

The CDC’s DVBD COPA surveys provide individuals with a
Consent Form based on purpose of collected information. The
Consent Form lists Points of Contact for responding to an
individual’s concern on contesting accuracy of information
collected and how to correct their submitted information. The
CDC will review concerns and respond to resolve inquiry of the
individual.
The system administrator performs database monitoring and
maintenance when new data is entered into the system or
changes are requested by the users.
Security controls are reviewed during the annual security selfassessments and recertification process.
Users

Users (Investigators) collecting the PII
and those performing analysis on the

Administrators

Oversee users and evaluate findings.

Developers
Contractors
Others

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System Administrators in coordination with Business Steward
will assign designated collection survey teams for read/write to
data fields and Subject Matter Experts for role based
transactional user’s access to analyze collective input. For
Describe the procedures in place to determine which example, collected data will be analyzed by Dengue Branch
32 system users (administrators, developers,
epidemiologists and study personnel for analytical assessment
contractors, etc.) may access PII.
based on specific need to know.

Least privilege, Role Based Access methods are used to allow
those with access to PII to only access the minimum amount of
information necessary to perform their job. The system
administrator is responsible for setting up the user access to
the system based on the CDC user ID and the permissions
assigned to it.
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 HHS credentialed employee PII data is identified as nonSensitive Internal Business information (Identified by name and
CDC issued UserID) and limited to authorized Administrators
and Subject Matter Experts.
Role-based - Access to PII is strictly enforced by setting up user
profile. Individuals can see selected functions and information
based on their user profile. This applies to geographical
location, system module and role.

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 CDC personnel are required to complete annual Security
and Privacy Awareness Training.

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

Users with significant security and privacy responsibilities are
provided additional CDC and system specific Role-Based
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
The records are maintained in accordance with General
Records Schedule (GRS) 20.6

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Administrative controls: Completion of training requirements;
risk analyses performed annually; branch management
reviewing access requests and granting minimal amount of
access.
Describe, briefly but with specificity, how the PII will
38 be secured in the system using administrative,
technical, and physical controls.

Technical controls: Users are authenticated and data secured
using operating system and server security, administered by
the local system administrator. PII data is encrypted at rest and
in transits with access restricted to specific authorized users as
required by HHS and CDC policy.
Physical controls: Facility access controls; server protected in a
guarded building.

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
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

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Reviewer Questions
8

Answer

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

Reviewer
Notes

General Comments

OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by
Beverly E. Walker -S
Date: 2018.11.21
14:34:59 -05'00'

HHS Senior
Agency Official
for Privacy

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