Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

0920-0571

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

TBD

2a Name:

08/20/18

Minimum Data Elements (MDEs) for the National Breast and Cer
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)?

8b Planned Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Health Scientist

POC Name

Dara Schlueter

POC Organization NCCDPHP/DCPC
POC Email

[email protected]

POC Phone

404-498-1782
New
Existing
Yes
No

tbd
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.

11 Describe the purpose of the system.

N/A, there was no prior PIA.
CDC will collect "Minimum Data Elements" (MDEs) from the 70
grantees participating in the CDC-funded National Breast and
Cervical Cancer Early Detection Program (NBCCEDP). The
MDEs are patient-level data on the delivery of screening and
diagnostic clinical services through the program. Information
will be used by CDC to monitor and evaluate the NBCCEDP,
provide feedback to grantees for program improvement,
provide summary data to stakeholders on outcomes, and
inform program planning.

The MDEs include seven categories of elements:
1. Patient demographics (race/ethnicity, date of birth (to
calculate age), location codes of residence)
Describe the type of information the system will
2. Breast cancer screening
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask 3. Cervical cancer screening
4. Breast and cervical cancer diagnoses
about the specific data elements.)
5. Breast and cervical cancer treatment
6. Timeliness of services
7. Patient navigation

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

Grantees report aggregate cancer screening and diagnostic
follow-up data. Data elements are limited to those needed to
adequately monitor program performance in screening and
timely links to treatment for the populations served by
NBCCEDP. Analysis of the data is conducted to assess how well
the program is meeting its goals. CDC uses this information for
decision-making in program management. Grantee
respondents receive customized feedback from CDC. Program
summary information and NBCCEDP aggregate results (e.g.,
performance ranges) will be shared across programs for
grantees to compare performance to the NBCCEDP as a whole.
CDC will periodically prepare reports on aggregated data for
Congress and publication. Individual-level data will not be
reported.
The dataset will not be shared.

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

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
City, State, and/or Zip Code
Race/ethnicity

Other...

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)

1,000,000 or more
Date of birth is used to calculate age to allow CDC to stratify
analyses by age.
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
Breast and Cervical Cancer Mortality Prevention Act of 1990
and disclosure specific to the system and program.

22

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

Yes
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

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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?

0920-0571, expires 12/31/2018
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

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

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?

There is no process. Prior notice is impossible because it is
unknown who will participate prior to their actual
participation.
Voluntary
Mandatory

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Describe the method for individuals to opt-out of the
Participation in screening and follow-up, and providing
collection or use of their PII. If there is no option to
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information to do so, is voluntary. Those who wish to opt out
object to the information collection, provide a
may do so.
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.

There is no process. Individuals cannot be notified because
CDC does not have individuals' contact information.

There is no process. CDC would be unable to address such
concerns because it is unable to identify individual participants
from the data received.
Patient-level data are de-identified before submission to CDC
except for date of birth. Therefore, periodic reviews are not
warranted.
Users
Administrators

31

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

Developers
Contractors

project staff who perform data
collection and compilation.

Others
Describe the procedures in place to determine which
Access to PII is limited to the contractor's project staff with
32 system users (administrators, developers,
authorization based on their role.
contractors, etc.) may access PII.
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.
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.
Describe training system users receive (above and
35 beyond general security and privacy awareness
training).
Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?

The contractor defines access to PII based on the need to
convert date of birth to age.

All of the contractor's project staff are required to sign a
confidentiality agreement before being given access.

None.
Yes
No

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Data will be destroyed within 3 years after the end of the
funding cycle (2022). This applies to CDC and CDC's contractor.
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.

Disposition authority: general records schedule is DAAGRS-2013-0002-0008 ("Disposition instructions: Temporary.
Destroy 3 years after project activity or transaction is
completed or superseded but longer retention is authorized if
needed for business use. ").
Administrative: Periodic review and update of the contractor's
security processes is conducted to identify any needed
changes. The contractual agreement includes non-disclosure
terms.
Technical: Contractor's server is password-protected. Once
information has been compiled by the contractor and
delivered to CDC via courier, all data are maintained for
restricted access on CDC's secure server with access permission
granted by the CDC NBCCEDP data manager.
Physical: The contractor's server is housed in a secure facility
with restricted access. Any storage media containing data are
stored under lock and key. CDC's server is housed in a secure
facility.

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

Question 8C: Unacceptable response, revise and provide necessary information, if this is an
existing system please provide, including ATO, clarify why this is being viewed as 2 different
Reviewer processes?
Notes Question 12: Please revise and specify what demographics specifically are collected-see
handbook for guidance
Question 13: Please revise, based on info spelled out in Q. 12 and clarify accordingly per HHS
guidance
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

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Reviewer Questions
5

Answer
Yes

Is this a candidate for PII minimization?

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

Reviewer
Notes

General Comments

OPDIV Senior Official
for Privacy Signature

The issues noted in the Reviewer's note were corrected prior to the acceptance/approval of this PIA

Beverly E.
Walker -S

Digitally signed by
Beverly E. Walker -S
Date: 2018.08.21
16:38:04 -04'00'

HHS Senior
Agency Official
for Privacy

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