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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:

NA

2a Name:

09/12/18

Using social media for recruitment in cancer prevention and con
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

Epidemiologist

POC Name

Juan Rodriguez

POC Organization Division of Cancer Prevention and
POC Email

[email protected]

POC Phone

770-488-3086
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
This is a one-time data collection using web-based surveys of
adults recruited via targeted social media and web ads using
Facebook, Twitter, and Google. The goal of the study is to
assess the feasibility of conducting survey-based research on
cancer prevention and control using these modes for subject
recruitment. Target populations for these surveys include the
general population (for cancer screening), cancer survivors,
and those at high risk for cancer. If feasible, finding specialized
populations for cancer prevention and control research using
social media is likely to yield a higher sample size and be more
cost-effective than other methods of subject recruitment such
as relying on finding these persons in the general population
or within a managed care organization. Data will be collected
by a contractor to CDC.
The bulk of the information collected in the system will be
responses to survey questions related to demographics (race,
state, zip code), health, well being, and health behaviors. In
addition, survey questions will also address cancer screening,
cancer survivorship, and genetic counseling and testing for
cancer risk.

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 PII (name and email address) will be collected in order to
about the specific data elements.)
deliver survey incentives and invite participants to participate
in a follow-up survey. IP addresses will only be used to ensure
that the same respondent is not taking the survey multiple
times. Zip code will be used to create survey weights, but will
not be analyzed individually or delivered to CDC by the
contractor.

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 data will be analyzed to assess the feasibility of this mode
of recruitment for research. Specifically, statistical analyses will
be conducted on the aggregated data to assess the extent of
sampling bias associated with surveys using social media
platforms as sampling frames and the ability to use weights or
other statistical methods to correct for potential biases.
Demographic information will enable construction of statistical
weights and comparison of findings with surveys of nationally
representative populations.
The individually identifiable information will only reside at the
contractor site and never be delivered or shared with CDC.
Participant e-mail addresses, and IP addresses will be deleted
by the contractor at the end of the data collection period.
Respondent names and mailing addresses will be deleted once
all survey incentives have been mailed. Respondent zip code
will be used to create statistical weights and will be deleted
once the weight variable is finalized. All PII collected will be
deleted by the contractor and never sent to 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

IP address

City, State, and/or Zip Code

Other...

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)

500-4,999
Participant name and email address will only be used to deliver
survey incentives and remind participants to complete their
survey or invite them to participate in a follow-up survey.
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
Investigation," (42 U.S.C. 241); sections 304, 306 and 308(d);
and disclosure specific to the system and program.
(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.

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?

We are currently seeking OMB approval and do not yet have an
approval number nor expiration date.
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)).

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Describe the procedures for accounting for
24c
disclosures

The contractor will house PII in a separate database as the
survey responses and only certain staff know will have access
to the PII data.

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.

Individuals will be notified through a consent form that will
appear as the first page of the web survey. Only those who
consent to participate will have information collected.

26

Voluntary

Is the submission of PII by individuals voluntary or
mandatory?

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.

An individual does not have to complete the survey. The
consent form will let the potential respondent know what kind
of data is being collected and they have the option to decline
participation.

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.

If a potential respondent clicks on an advertisement for our
study from a social media website or search engine, they will
be taken to a landing page for the study. This landing page
contains a consent form that explains our study, the kind of
information being collection, and their rights as a research
participant. The individual then has to click to consent to
continue to one of the study surveys. If they do not consent,
they will not be able to participate in the study and no data will
be collected on them.

All participants who consent to participation will be given two
toll-free phone numbers. The first toll-free number will be
provided by the contractor and should be used by participants
for assistance with technical issues associated with the web
survey or receiving the study incentive. The second toll-free
Describe the process in place to resolve an
individual's concerns when they believe their PII has number, will connect participants with the study Principal
29 been inappropriately obtained, used, or disclosed, or Investigator (Juan Rodriguez) in the Division of Cancer
that the PII is inaccurate. If no process exists, explain Prevention and Control at CDC. This number should be used
for questions or comments associated with the survey content,
why not.
or questions and concerns about consent. Concerns about
accuracy of PII will be handled by the tell-free number
provided by the contractor. Concerns about inappropriate use
or disclosure of PII will be handled by the PI at CDC.
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 because this is a one-time data collection
and PII will be destroyed after being used to deliver incentives
and verify no surveys were duplicative.
Users
Administrators

31

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

Developers
Contractors

The contractor will be responsible for
delivering incentives and verifying

Others

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Describe the procedures in place to determine which CDC's contractor implements access on the least privilege
32 system users (administrators, developers,
method. Only people whose jobs require access to the data
contractors, etc.) may access PII.
are granted the appropriate level of access.

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?

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

Staff with access to PII was limited to only study team members
and the data files with PII are being saved in secure locations.
Only the sampling statistician who is designing survey weights
will have access to geographical information. They will not
have the ability to link the PII with survey responses to protect
identities. IP addresses will only be accessible by those who are
ensuring fraudulent data entry. Name, address, and e-mail
address will only be accessible by staff who are mailing
incentives or sending out reminders about survey
participation.
All contractor employees are required to take Privacy
Awareness and IT Security Awareness training, as well as Ethics
and Compliance training.

N/A
Yes
No
Participant e-mail addresses, and IP addresses will be deleted
by the contractor at the end of the data collection period.
Respondent names and mailing addresses will be deleted once
all survey incentives have been mailed. Respondent zip code
will be used to create statistical weights and will be deleted
once the weight variable is finalized. All PII will be deleted
before data delivery to CDC. CDC will not receive PII.
The PII will be kept in a separate system with limited access.
Administrative: Personnel Screening, audits, access
agreements, sanctions, Risk Assessment, Planning, System and
Services acquisition, security assessments

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

Technical: Identification and Authentication – use of Active
Directory groups, Access Control processes utilizing Active
Directory for permissions\electronic signature, Least privilege
access, encryption, Audit and accountability, System and
Communication
Physical: Personnel Security (Guards, key cards, locked Data
Center, Cameras), Physical and Environmental Protection (Fire\
Water\Uninterruptable Power Supply (UPS), Contingency Plan,
Configuration Management –use of baselines (Center for
Internet Security (CIS) settings\Federal Desktop Core
Configuration (FDCC), Maintenance – vulnerability scanning
\remediation, Media Protection – encrypted tapes, Awareness
and Training of staff

39 Identify the publicly-available URL:

http://www.voxco.com/ will be used for the online surveys.

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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
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

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Reviewer Questions

Answer

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

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2018.11.06
for Privacy
14:07:06 -05'00'

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