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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-27829

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-6028314-852030

2a Name:

9/20/2016 9:28:38 AM

School Associated Violent Deaths Surveillance System (SAVDSS)
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.

Implementation
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

Business Steward

POC Name

Leroy Frazier

POC Organization CDC/ONDIEH/NCIPC
POC Email

[email protected]

POC Phone

770.488.1507
New
Existing
Yes
No
October 7, 2016
Not Applicable

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11 Describe the purpose of the system.

A school-associated violent death is defined as a homicide,
suicide, or legal intervention in which the fatal injury occurred
1) on the campus of a functioning public or private elementary
or secondary school in the United States, 2) while the victim
was on the way to or from regular sessions at such a school, or
3) while the victim was attending or traveling to or from an
official school-sponsored event. Cases will include deaths of
students as well as non-students (e.g., faculty, school staff,
family members, or community residents).
The School Associated Violent Deaths Surveillance System
(SAVD-SS) will draw cases from the entire United States in an
attempt to capture all cases of school-associated violent
deaths that have occurred. SAVD-SS uses the collected data to
describe the epidemiology of school-associated violent deaths,
identify common features of these deaths, estimate the
frequency and rate of school-associated violent deaths in the
United States, and identify potential risk factors for these
deaths.

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.)

SAVD-SS will collect victim names, date of death, date of birth,
manner and cause of death, location of death, circumstances
surrounding the death (e.g., mental health problems, crises
experienced by the victim).

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A school-associated violent death is defined as a homicide,
suicide, or legal intervention in which the fatal injury occurred
1) on the campus of a functioning public or private elementary
or secondary school in the United States, 2) while the victim
was on the way to or from regular sessions at such a school, or
3) while the victim was attending or traveling to or from an
official school-sponsored event. Cases will include deaths of
students as well as non-students (e.g., faculty, school staff,
family members, or community residents).

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

SAVD-SS will draw cases from the entire United States in an
attempt to capture all cases of school-associated violent
deaths that have occurred. Cases will be identified by CDC
staff through a systematic search of computerized newspaper
and broadcast media databases (e.g., Lexis-Nexis). To confirm
the facts of each event, a brief interview will then be
conducted with at least one law-enforcement officer familiar
with the event (i.e., a police officer, police chief, or district
attorney). For each confirmed case additional data will be
obtained from three official sources: 1) law enforcement
investigative reports; 2) structured telephone interviews with
investigating law enforcement officials; and 3) structured
telephone interviews with school officials (i.e., school principal,
superintendent, school counselor, school teacher, or school
support staff) who are familiar with the case in question. These
sources will provide detailed information regarding victims,
alleged offenders, the school associated with each death, and
the circumstances of the fatal injuries.
SAVD-SS uses the collected data to describe the epidemiology
of school-associated violent deaths, identify common features
of these deaths, estimate the frequency and rate of schoolassociated violent deaths in the United States, and identify the
potential risk factors for these deaths. The type of information
collected are the victim names, date of death, date of birth,
manner and cause of death, location of death, circumstances
surrounding the death (e.g., mental health problems, crises
experienced by the victim).

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

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 Deceased public citizens

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
The primary purpose for which PII is used is confirmation of
facts related to cases.

The secondary uses for which PII will be used are: (1) to
describe the epidemiology of school-associated violent deaths;
(2) to identify common features of these deaths; (3) to estimate
the frequency and rate of school-associated violent death in
the United States; and (4) to identify potential risk factors for
these deaths.

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)

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22

Yes

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

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
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?

0920-0604 Exp: 05-31-2019
Yes
No
There is no process in place to notify individuals that their
personal information will be collected because they are
deceased.
Voluntary
Mandatory

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

There is no process in place to notify and obtain consent
from individuals whose PII is in the system because individuals
are deceased.

Only PII on deceased individuals is collected.

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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.

31

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

The Database administrator and technical steward will
periodically review the PII contained in the system against the
spreadsheets/database from which the data is extracted to
ensure the data's integrity, availability, accuracy and relevancy.
Users

Initially necessary for case finding and
case confirmation tasks

Administrators

Necessary for tasks associated with all
core study data collection
management processes

Developers
Contractors
Others

Describe the procedures in place to determine which
Role Based Access Control (RBAC) is used to determine who
32 system users (administrators, developers,
has access to PII.
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.

The least privilege model is used to allow those with access to
PII to be able to access the minimum amount of PII needed to
perform their job.
All users are provided mandatory security and privacy
awareness training annually.

Users are also provided a separate HIPAA specific training.

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?

Policies and rules regarding the treatment and handling of
such information are reviewed annually and education
regarding them is provided as needed (e.g., when new staff are
added to the study or new rules regarding sensitive
implementation are implemented by CDC or HHS). This
training instills awareness regarding such policies, the
penalties for noncompliance, and the nature of the
administrative, technical, and physical safeguards that have
been implemented to insure the security and confidentiality of
the study's records, and to protect against any potential
threats or hazards to their security or integrity. During these
trainings, staff are also required to sign security pledges and
non-disclosure agreements acknowledging their agreement to
uphold the aforementioned responsibilities and to adhere to
the study's guiding policies and guidelines for data collection
and management.
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.

Records are retained and disposed of in accordance with the
CDC Records Control Schedule N1-442-09-1. As such, record
copies of study reports are maintained in the 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.
Over the course of the study, the data will be reported in the
aggregate, such that no individual case can be identified from
the reports. Once data collection is deemed complete, all
records bearing identities of the victim, alleged offenders,
informants, schools and communities will be destroyed.

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

During the study, data will be secured through the use of
technical, physical, and administrative controls. Hard copies of
data (i.e., law enforcement investigative reports and interviews
with school and law enforcement personnel) will be kept
under lock and key in the Division of Violence Prevention (DVP)
secured offices. These offices are located in a secured facility
that can be accessed only by presenting the appropriate
credentials (i.e., guards, identification badges, Key cards, and
smart cards). The building housing the Division of Violence
Prevention (DVP) offices can only be accessed using a key card
that has been previously authorized by CDC security.
Digital data will be stored and backed up nightly on-site. Data
is secured using technical controls (i.e., two-factor user
identification and authentication, passwords, vulnerability
scanning, and firewalls ) that only allow access by authorized
individuals. The access list is audited annually and as needed
(e.g., when a staff member leaves the study).

General Comments

OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by Beverly E. Walker -S
DN: c=US, o=U.S. Government,
ou=HHS, ou=CDC, ou=People,
0.9.2342.19200300.100.1.1=10014403
43, cn=Beverly E. Walker -S
Date: 2016.11.08 13:44:47 -05'00'

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