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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:

01/28/19

Canine Leptospirosis Surveillance in Puerto Rico
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

Epidemiologist

POC Name

Aileen Artus

POC Organization NCEZID/DHCPP/BSPB
POC Email

[email protected]

POC Phone

404.639.3474
New
Existing
Yes
No

05/01/2019
Not Applicable

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8c

9

Briefly explain why security authorization is not
required

Indicate the following reason(s) for updating this PIA.
Choose from the following options.

Not applicable.
PIA Validation (PIA
Refresh/Annual Review)
Anonymous to NonAnonymous
New Public Access
Internal Flow or Collection

Significant System
Management Change
Alteration in Character of
Data
New Interagency Uses
Conversion

Commercial Sources
Other...
10

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

Not applicable.

11 Describe the purpose of the system.

The purpose of this information collection is to determine the
incidence and distribution of canine leptospirosis in Puerto
Rico; assess risk factors that lead to infection; characterize
circulating Leptospira serovars and species; assess applicability
of vaccines currently in use based on serovar determination;
and assess potential rodent, livestock and wildlife reservoirs of
leptospirosis based on infecting serovars found in dogs.

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
about the specific data elements.)

The dog owner's name and mailing address and the
information on the veterinary office , name of the facility,
address, phone number, and doctor's name are collected as
part of the study. Additionally, data elements concerning the
dogs health and environmental factors are collected.
Whenever possible, Centers for Disease Control and Prevention
(CDC) Bacterial and Special Pathogens Branch (BSPB) staff will
employ electronic technology to collect and process data in
order to reduce respondent burden, and aid in data processing
and reporting efficiency.

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

Due to the nature of data collection and resources available at
the sites, most of the collection will be conducted using paper
forms. Veterinarians and their staff may find it easier to
complete a paper copy of the data collection forms when
abstracting information from medical records or while
interviewing the owner for risk factors and symptoms. Some
sites may have limited resources and lack a computer, fax
machine, or Internet service. As such, they have the option of
sending completed forms by fax or email, or by mail when
sending specimen shipments to study coordinators at CDC or
the Puerto Rico Department of Health (PRDH). Data will be
entered into an electronic database at CDC to make data
management and analysis more efficient.
The system only has CDC users who are authenticated via
Active Directory which has a separate PIA.

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

Other...

Other...

Other...

Other...

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)

100-499
The primary purpose of the PII is to provide study supplies to
pet owners so they can complete the questionnaire and send
back specimens.
The secondary use of PII is to track the location of incidents by
keeping track of the veterinary facility where dogs are treated.

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
Section 301, 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

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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.

09-20-0136 Epidemiologic Studies and Surveillan

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?

0920-1170 Exp. 3/31/2019
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

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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

The dog owners are asked to sign the Owner Consent Form
prior to obtaining blood and urine samples from the dog. The
consent form explains how the information will be collected
and protected.
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
Individuals can opt out by not signing the consent form and
27
object to the information collection, provide a
not allowing CDC or PRDH to collect samples from their dog.
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.

The Principal Investigator for this study can use the
information in the system to notify and obtain consent from
the individuals whose PII is in the system.

Individuals can contact the individual listed on the SORN,
09-20-0136, “Epidemiologic Studies and Surveillance of Disease
Problems.”, if they believe their PII has been inappropriately
obtained, used or disclosed, or that the PII is inaccurate.
The conduct of this study requires that a shipment of supplies
be made each quarter for a year to complete the study. This
logistical effort will allow the Principal Investigator to ensure
the data integrity, availability, accuracy, and relevancy.
Users

Only study staff will have access to the
PII in order to ship supplies to study

Administrators
31

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

Developers
Contractors
Others

For Electronic Access: The program first evaluates whether the
individual has a need for access to the system. If the
individual's manager determines that access to the system is
required for the individual to perform their regular duties, they
Describe the procedures in place to determine which will make a request to the system administrator who will
establish an account for the user to access the system.
32 system users (administrators, developers,
contractors, etc.) may access PII.
For Physical Access: The program first evaluates whether the
individual has a need for access to the system. If the
individual's manager determines that access to the system is
required for the individual to perform their regular duties, they
will be given access to the PII to perform those duties.

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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.

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 CDC user id and assigned permissions.

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.

Users are required to take CDC Security and Privacy Awareness
Training annually.

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

Users with significant security responsibilities also are required
to take CDC or HHS Role-Based Training annually.

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 maintained and destroyed according to CDC
General Records Schedule (GRS) 20.6. Records are maintained
in agency for five years. Disposal methods include shredding
paper materials or transferring records to the Federal Records
Center when no longer needed for evaluation and analysis.
Records are destroyed by paper shredding process when five
years old unless needed for further study. Stool samples will be
destroyed when five years old unless needed for further study.
Administrative: Access to the application is approved by the
individual's supervisor indicating that the user has a need to
know the information on the system.

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

Technical: CDC user id is encrypted while stored in the system.
Physical: The server is protected by gate guards; and individual
user credentials are required for each nonpublic access point.
Closed circuit TV is also used by security guards to limit access
to authorized individuals.

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

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Reviewer Questions

Answer

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

Reviewer
Notes
12

Were any changes made to the system because of the completion of this PIA?

Yes
No

Reviewer
Notes

General Comments

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OPDIV Senior Official
for Privacy Signature

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2019.02.13
for Privacy
11:00:55 -05'00'

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