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Privacy Impact Assessment Form
v 1.21
Status

Form Number

0920-19AUK

Question

11/21/2019

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

0920-19AUK

2a Name:

Form Date

Promoting Adolescent Health through School-Based HIV Preven
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)?

No
Yes
No
Agency
Contractor
POC Title

Health Scientist

POC Name

Diane Orenstein

POC Organization CDC, NCHHSTP, DASH
POC Email

[email protected]

POC Phone

770.488.8003
New
Existing
Yes
No

8b Planned Date of Security Authorization
Not Applicable

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8c

Briefly explain why security authorization is not
required

Because this not a system.

10

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

n/a

11 Describe the purpose of the system.

In September 2018, the Division of Adolescent and School
Health (DASH) funded 25 Local Education Agencies (LEAs)
under Promoting Adolescent Health through School-Based HIV
Prevention (PS18-1807). PS18-1807 supports a multicomponent, multi-level effort to support youth reaching
adulthood in the healthiest possible way. DASH is developing
the Program Evaluation and Reporting System (PERS), a
program evaluation and monitoring system for LEAs to report
process and outcome measures. PERS will collect data about
LEAs and their priority schools related to three strategies,
Sexual Health Education (SHE), Sexual Health Services (SHS),
and Safe and Supportive Environments (SSE).
LEAs will enter process and outcome data into the PERS system
semi-annually, using a set of three questionnaires. The
questionnaires ask for programmatic information about the
LEAs and their priority schools. Data collection involves
collecting programmatic reporting data from the project
manager at each of the funded NOFO 1807 Local Education
Agencies (LEAs). LEAs are the school districts funded to
implement this programmatic initiative.

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 data that is collected from the program managers does not
involve the collection of sensitive, or personal information.
Although the name and work email address of the program
managers at each LEA entering, viewing, and submitting data
stored for each responding organization, the system only
collects programmatic data about LEAs and priority schools.
CDC will maintain information in secure electronic files that will
only be accessible to authorized members of the team.
Electronic files will be stored on secure network servers, and
access will be restricted to approved team members identified
by user ID and password.

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Data entry into PERS is structured as a series of questionnaires
which are answered by each LEA for their own work and the
work of their priority schools. In addition, LEAs can upload
relevant curriculum documents into the system. LEAs will have
the option for multiple staff members have log-ins. To facilitate
the data collection process for LEAs, copies of the
questionnaires in PDF format are available for download from
PERS.
Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

The data that is collected from the program managers does not
involve the collection of sensitive, or personal information.
Although the name and work email address of the program
managers at each LEA entering, viewing, and submitting data
stored for each responding organization, the system only
collects programmatic data about LEAs and priority schools.
CDC will maintain information in secure electronic files that will
only be accessible to authorized members of the team.
Electronic files will be stored on secure network servers, and
access will be restricted to approved team members identified
by user ID and password.
Yes

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

Indicate the type of PII that the system will collect or
15
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

Other...

Business E-Mail Address

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?

100-499

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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)

Names and email addresses are used to link PERS users to their
LEA and to determine which forms they have access to in the
system. Professional Email addresses are used as the user login.
none

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 Sections 301(a) and 317(k)(2) of the Public Health Service Act
and disclosure specific to the system and program.
[42 U.S.C. Sections 241 and 247(k)(2)], as amended

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.

09-90-1901 HHS Correspondence, Customer Serv

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?

Yes
No

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Within HHS

24a

Other Federal
Agency/Agencies
State or Local
Agency/Agencies

Identify with whom the PII is shared or disclosed and
for what purpose.

Private Sector
DASH website includes the names of the following:
all our funded LEAs from PS18-NOFO1807 and
all project managers for each LEA.
Describe any agreements in place that authorizes the Anyone can google “local education agencies within a
information sharing or disclosure (e.g. Computer
specified state” and all of the school districts will appear.
24b Matching Agreement, Memorandum of
Any person can then see all of the departments within the
Understanding (MOU), or Information Sharing
specific LEA, e.g. school instruction & curricula, funded
Agreement (ISA)).
projects, etc.
Once a department or program is opened, a person can then
go to “directory” and see a list of names and emails for all
persons on staff.
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?

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.
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.

N/A
Individuals are asked to register in the system using their
name, professional email address, and LEA name.
Voluntary
Mandatory
Individuals can opt-out of providing their name or email
address, however, they will not be able to access the system.
The system must be able to identify the user via email address
and the user must be linked to their LEA for data collection and
analysis.

In the event that a major change occurs, individuals will be
notified via email.

No process exists as we will only collecting individuals names
and their professional email address.
The contract will review the list of registered users at various
points in the project to ensure that only active users' PII is
stored in the system.

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Users

31

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

Administrators

System maintenance

Developers

System development and
maintenance
Direct Contractor need access for
system maintenance and data analysis

Contractors
Others

Administrators, developers, and contractors that are
Describe the procedures in place to determine which responsible for maintaining and developing the system and
conducting data analysis will have a "Systems/Database
32 system users (administrators, developers,
Administrator" user-type which will allow them to access the
contractors, etc.) may access PII.
User Names and Email addresses. Other PERS users will only
have access to their own user name, email, and data.
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.

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

Those with access to PII need to be able to confirm the users'
names, email addresses, and corresponding funded agency.
All CDC employees and contractors must complete the Records
Management and Security Awareness training. In addition, IT
Administrators must take the Information Security for IT
Administrators course.

none
Yes
No
Records are retained and disposed of in accordance with the
CDC Records Control Schedule 04-4-22 Family of HIV Surveys,
Division of HIV/AIDS Prevention/Surveillance and
Epidemiology.
Administrative controls: The information collection involves
use of web-based data collection methods. The website does
use cookies, and access to the web-based questionnaire, which
is password-protected and given only to the staff of the CDC/
DASH-funded LEAs who will complete the questionnaires.
Once the contractor is notified that business partners no
longer are participating, an Administrator will delete the
individuals' contact information from the list of users.
Technical controls: CDC will maintain information in secure
electronic files that will only be accessible to authorized
members of the team. Electronic files will be stored on secure
network servers, and access will be restricted to approved
team members identified by user ID and password.
Physical controls include security guards, identification badges,
key cards, and closed circuit TV.

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Reviewer Questions

Answer

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
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

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Reviewer Questions

Answer

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: 2019.11.22
for Privacy
10:49:38 -05'00'

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