Pia

PRIVACY IMPACT ASSESSMENT (PIA)
PRESCRIBING AUTHORITY: DoD Instruction 5400.16, "DoD Privacy Impact Assessment (PIA) Guidance". Complete this form for Department of Defense
(DoD) information systems or electronic collections of information (referred to as an "electronic collection" for the purpose of this form) that collect, maintain, use,
and/or disseminate personally identifiable information (PII) about members of the public, Federal employees, contractors, or foreign nationals employed at U.S.
military facilities internationally. In the case where no PII is collected, the PIA will serve as a conclusive determination that privacy requirements do not apply to
system.
1. DOD INFORMATION SYSTEM/ELECTRONIC COLLECTION NAME:

Naval Education and Training Future Officer and Citizenship User System (NETFOCUS)
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

Department of the Navy
Naval Education and Training Command (NETC)
SECTION 1: PII DESCRIPTION SUMMARY (FOR PUBLIC RELEASE)
a. The PII is: (Check one. Note: foreign nationals are included in general public.)
From members of the general public

From Federal employees and/or Federal contractors

From both members of the general public and Federal employees and/or
Federal contractors

Not Collected (if checked proceed to Section 4)

b. The PII is in a: (Check one)
New DoD Information System

New Electronic Collection

Existing DoD Information System

Existing Electronic Collection

Significantly Modified DoD Information System
c. Describe the purpose of this DoD information system or electronic collection and describe the types of personal information about individuals
collected in the system.

Naval Education & Training Future Officer and Citizenship User System (NETFOCUS) serves as the authoritative data source for the Naval
Reserve Officer Training Corp (NROTC) and the Naval Junior Reserve Officer Training Corp (NJROTC) programs and provides automated
support for the management and administrative functions for Naval Service Training Command (NSTC), Great lakes, Officer Development
(OD) and Citizenship Development (CD) programs.
Personal information collected: Name, SSN (Full and truncated), citizenship, gender, race/ethnicity, birth date, personal cell telephone
number, personal email address, mailing/home address, security clearance, marital status, financial information, military records, education
information.
d. Why is the PII collected and/or what is the intended use of the PII? (e.g., verification, identification, authentication, data matching, mission-related use,
administrative use)

PII is initially collected from NROTC and Seaman to Admiral - 21st Century (STA-21) program applicants. Prospective candidates apply
via web applications. NROTC candidates apply for the scholarship program via automated web site, where the candidate is issued a user
name and a Federal Information Security Management Act (FISMA)-compliant password. STA-21 scholarship candidates are required to
have common-access-card (CAC)/PIN. In each instance, the applicant can enter or view only his/her own data.
Non-candidate user access is managed by authorized administrators within NSTC OD and CD departments. Access is role-based and issued
on a need-to-know basis. Access controls and privacy safeguards are in-compliance with DON and DoD policy and guidance.
e. Do individuals have the opportunity to object to the collection of their PII?

Yes

No

(1) If "Yes," describe the method by which individuals can object to the collection of PII.
(2) If "No," state the reason why individuals cannot object to the collection of PII.

Failure to provide required information would affect the applicant's submission and chance for acceptance.
f. Do individuals have the opportunity to consent to the specific uses of their PII?

Yes

No

(1) If "Yes," describe the method by which individuals can give or withhold their consent.
(2) If "No," state the reason why individuals cannot give or withhold their consent.

Once the individual provides their PII, consent is assumed.

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 1 of 10

g. When an individual is asked to provide PII, a Privacy Act Statement (PAS) and/or a Privacy Advisory must be provided. (Check as appropriate and
provide the actual wording.)
Privacy Act Statement

Privacy Advisory

Not Applicable

Privacy Advisory:
We will not obtain personally identifying information about you when you visit our site unless you choose to provide such information to us.
If you choose to send an email to the site webmaster or submit an on line feedback form, any contact information that you provide will be
solely used to respond to your request and not stored. Please do not provide your full social security (SSN) number to anyone and do not
send SSNs or other Privacy Act information via email - that is risky and subject to interception and possible fraudulent use.
NETFOCUS Gateway Consent Banner:
You are accessing a U.S. Government (USG) Information System (IS) that is provided for USG-authorized use only.
By using this IS (which includes any device attached to this IS), you consent to the following conditions:
• The USG routinely intercepts and monitors communications on this IS for purposes including, but not limited to, penetration testing,
Communications Security (COMSEC) monitoring, network operations and defense, personnel misconduct (PM), law enforcement (LE), and
counterintelligence (CI) investigations.
• At any time, the USG may inspect and seize data stored on this IS.
• Communications using, or data stored on, this IS are not private, are subject to routine monitoring, interception, and search, and may be
disclosed or used for any USG-authorized purpose.
• This IS includes security measures (e.g., authentication and access controls) to protect USG interests - not for your personal benefit or
privacy.
• Notwithstanding the above, using this IS does not constitute consent to PM, LE or CI investigative searching or monitoring of the content
of privileged communications, or work product, related to personal representation or services by attorneys, psychotherapists, or clergy, and
their assistants. Such communications and work product are private and confidential.
Agree or Disagree
For Official Use Only - Privacy Act Protected

h. With whom will the PII be shared through data exchange, both within your DoD Component and outside your Component? (Check all that apply)

*Officer Personnel Information System (OPINS)--(outbound
only) – SSN, Name, DOB, Citizenship, Place of Birth, Legal
Residence
*Naval Personnel Command (NPC) PERS-4, PERS-802
*United States Naval Academy (USNA)
Specify.
*Fund Administration and Standardized Document
Automation System (FASTDATA)
Standard Accounting, Budgeting and Reporting System
(SABRS)
*Navy Exchange Command (NEXCOM)
Defense Finance and Accounting Service (DFAS)-(Outbound only) – SSN, Name, Account number, RTN,
Account type, Marital Status, Number of Dependents, Legal
Residence.
Specify.
*Department of Defense Medical Exam Review Board
(DoDMERB)--(Inbound and outbound) – SSN, Name, Date
of Birth, Physical Status, Medical Reason code.
*Defense Mapping Agency (DMA)

Within the DoD Component

Other DoD Components

Other Federal Agencies

Specify.

State and Local Agencies

Specify.

Contractor (Name of contractor and describe the language in
the contract that safeguards PII. Include whether FAR privacy
clauses, i.e., 52.224-1, Privacy Act Notification, 52.224-2,
Privacy Act, and FAR 39.105 are included in the contract.)

Specify.

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 2 of 10

Other (e.g., commercial providers, colleges).

Specify.

*College Board SAT/ACT - Standardized Tests for College
Admissions

i. Source of the PII collected is: (Check all that apply and list all information systems if applicable)
Individuals

Databases

Existing DoD Information Systems

Commercial Systems

Other Federal Information Systems

Individual:
1. NROTC Scholarship Applicants enter the initial data themselves. The majority of applicants are high school seniors or recent high
school graduates.
2. STA-21 Program Applicants also provide the same type of information as NROTC Scholarship applicants. The difference is that
STA-21 applicants are active duty enlisted personnel.
3. Throughout a NROTC Midshipman's (MIDN) college career, academic and other program performance information such as PFT data is
entered by authorized NROTC Unit staff personnel.
4. The initial record for NJROTC Cadet is manually entered by an authorized user, i.e. the Senior Naval Science Instructor (SNSI) in
charge of the local NJROTC unit at the the High School.
5. Department of Defense Medical Exam Review Board (DODMERB). DODMERB provides NETFOCUS with qualification information
which is loaded into NETFOCUS.
6. United States Naval Academy (USNA) sends NETFOCUS USNA applicant statistics which are loaded into NETFOCUS.
j. How will the information be collected? (Check all that apply and list all Official Form Numbers if applicable)
E-mail

Official Form (Enter Form Number(s) in the box below)

Face-to-Face Contact

Paper

Fax

Telephone Interview

Information Sharing - System to System

Website/E-Form

Other (If Other, enter the information in the box below)

k. Does this DoD Information system or electronic collection require a Privacy Act System of Records Notice (SORN)?
A Privacy Act SORN is required if the information system or electronic collection contains information about U.S. citizens or lawful permanent U.S. residents that
is retrieved by name or other unique identifier. PIA and Privacy Act SORN information must be consistent.
Yes

No

If "Yes," enter SORN System Identifier

N01131-1, N01533-2, NM01500-2

SORN Identifier, not the Federal Register (FR) Citation. Consult the DoD Component Privacy Office for additional information or http://dpcld.defense.gov/
Privacy/SORNs/
or
If a SORN has not yet been published in the Federal Register, enter date of submission for approval to Defense Privacy, Civil Liberties, and Transparency
Division (DPCLTD). Consult the DoD Component Privacy Office for this date
If "No," explain why the SORN is not required in accordance with DoD Regulation 5400.11-R: Department of Defense Privacy Program.

l. What is the National Archives and Records Administration (NARA) approved, pending or general records schedule (GRS) disposition authority for
the system or for the records maintained in the system?
(1) NARA Job Number or General Records Schedule Authority.

DAA-NU-2015-0001-000

(2) If pending, provide the date the SF-115 was submitted to NARA.

(3) Retention Instructions.

New Navy Disposition schedule 1000-7 replaces SSIC 1500.1. Permanent Record. Transfer to FRC when no longer required for research or
reference. Transfer to NARA when 25 years old. New NARA Schedule is: DAA-NU-2015-0001-0007

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 3 of 10

m. What is the authority to collect information? A Federal law or Executive Order must authorize the collection and maintenance of a system of
records. For PII not collected or maintained in a system of records, the collection or maintenance of the PII must be necessary to discharge the
requirements of a statue or Executive Order.
(1) If this system has a Privacy Act SORN, the authorities in this PIA and the existing Privacy Act SORN should be similar.
(2) If a SORN does not apply, cite the authority for this DoD information system or electronic collection to collect, use, maintain and/or disseminate PII.
(If multiple authorities are cited, provide all that apply).
(a) Cite the specific provisions of the statute and/or EO that authorizes the operation of the system and the collection of PII.
(b) If direct statutory authority or an Executive Order does not exist, indirect statutory authority may be cited if the authority requires the
operation or administration of a program, the execution of which will require the collection and maintenance of a system of records.
(c) If direct or indirect authority does not exist, DoD Components can use their general statutory grants of authority (“internal housekeeping”) as
the primary authority. The requirement, directive, or instruction implementing the statute within the DoD Component must be identified.

SORN N01131-1, Officer Selection and Appointment System (June 14, 2006, 71 FR 34328),
SORN NM01500-2 Department of the Navy Education and Training Records (Novemeber 22, 2010 75FR71083)
SORN N01533-2 Navy Junior Reserve Officer Training Corps Payment Reimbursement System (July 20, 2009, 74 FR 35171)
5 U.S.C. 301, Departmental Regulations, 10 U.S.C. Sections governing authority to appoint officers; 10 U.S.C. 591, 600, 716, 2107, 2122,
5579, 5600; Merchant Marine Act of 1939 (as amended); and E.O.s 9397, 10450, and 11652.
The enactment of Public Law 88-647 and codification in Title 10, U.S.C., Sec. 2031, authorized the military service secretaries to
commission Junior reserve Officers' Training Corps (NJROTC) programs. Title 10, U.S.C.. Sec. 2031 is the statutory basis for the NJROTC
program.
n. Does this DoD information system or electronic collection have an active and approved Office of Management and Budget (OMB) Control
Number?
Contact the Component Information Management Control Officer or DoD Clearance Officer for this information. This number indicates OMB approval to
collect data from 10 or more members of the public in a 12-month period regardless of form or format.
Yes

No

Pending

(1) If "Yes," list all applicable OMB Control Numbers, collection titles, and expiration dates.
(2) If "No," explain why OMB approval is not required in accordance with DoD Manual 8910.01, Volume 2, " DoD Information Collections Manual:
Procedures for DoD Public Information Collections.”
(3) If "Pending," provide the date for the 60 and/or 30 day notice and the Federal Register citation.

0703-0026 EXPIRATION DATE: 12/31/2019 ICR REFERENCE NUMBER: 201611-0703-001

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 4 of 10

SECTION 2: PII RISK REVIEW
a. What PII will be collected (a data element alone or in combination that can uniquely identify an individual)? (Check all that apply)
Biometrics

Birth Date

Child Information

Citizenship

Disability Information

DoD ID Number

Driver's License

Education Information

Emergency Contact

Employment Information

Financial Information

Gender/Gender Identification

Home/Cell Phone

Law Enforcement Information

Legal Status

Mailing/Home Address

Marital Status

Medical Information

Military Records

Mother's Middle/Maiden Name

Name(s)

Official Duty Address

Official Duty Telephone Phone

Other ID Number

Passport Information

Personal E-mail Address

Photo

Place of Birth

Position/Title

Race/Ethnicity

Rank/Grade

Protected Health Information (PHI)1
Religious Preference

Records

Security Information

Work E-mail Address

If Other, enter the information in the box below

Social Security Number (SSN) (Full or in any
form)

Financial information: account number, RTN, Account Type
Military Information: PRD -- Projection Rotation Date; EAOS -- End of Obligated
Service; PFT data -- Pass/Fail status and overall score
Education Information:
ACT scores – Name, Date of Birth, Home of Record, Score, test type, test date
SAT Scores – Name, SSN, Address, Date of Birth, test date, test scores
High School transcripts – Overall GPA
If the SSN is collected, complete the following questions.
(DoD Instruction 1000.30 states that all DoD personnel shall reduce or eliminate the use of SSNs wherever possible. SSNs shall not be used in spreadsheets,
hard copy lists, electronic reports, or collected in surveys unless they meet one or more of the acceptable use criteria.)
(1) Is there a current (dated within two (2) years) DPCLTD approved SSN Justification on Memo in place?
Yes

No

If "Yes," provide the signatory and date approval. If “No,” explain why there is no SSN Justification Memo.

Signed by (18 Apr 2017) Robyn W. Baker, CIO/N6, Naval Education and Training Command (NETC)

(2) Describe the approved acceptable use in accordance with DoD Instruction 1000.30 “Reduction of Social Security Number (SSN) Use within DoD”.

Computer Matching: NETFOCUS uses SSN to uniquely identify NROTC scholarship applicants who have never been, or may never be
issued an DoD ID Number. Legacy System: Interface partners may not be able to complete a timely transition from using SSN as a unique
person identifier. For those systems, it may be necessary to continue to exchange data based on the SSN, even though an alternate identifier
exists in NETFOCUS.
(3) Describe the mitigation efforts to reduce the use including visibility and printing of SSN in accordance with DoD Instructoin 1000.30, “Reduction of
Social Security Number (SSN) Use within DoD”.

NETFOCUS interfaces with the Department of Defense Medical Examination Review Board (DoDMERB) to medically qualify selectees.
The DoD ID Number is issued to individuals as a result of the DoDMERB medical qualification process. The nightly NETFOCUS-DEERS
web service interface acquires and stores the DoD ID Number. This process has allowed a significant reduction of SSN use throughout
NETFOCUS to be implemented.
(4) Has a plan to eliminate the use of the SSN or mitigate its use and or visibility been identified in the approved SSN Justification request?
If "Yes," provide the unique identifier and when can it be eliminated?
If "No," explain.
Yes

No

NETFOCUS has completed an effort to reduce SSN usage by utilizing the DoD ID Number as the unique identifier where possible. With
that said, until an alternate methodology can be implemented to synchronize U/I's with interfacing DoN and DoD systems, such as Officer
Personnel Information System (OPINS) and Defense Joint Military Pay System-Reserve Component (DJMS-RC), NETFOCUS must
continue collecting the SSN.
DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 5 of 10

b. What is the PII confidentiality impact level2?

1

Low

Moderate

High

The definition of PHI involves evaluating conditions listed in the HIPAA. Consult with General Counsel to make this determination.

2

Guidance on determining the PII confidentiality impact level, see Section 2.5 “Categorization of PII Using NIST SP 800-122.” Use the identified PII confidentiality impact level to apply the appropriate Privacy Overlay
low, moderate, or high. This activity may be conducted as part of the categorization exercise that occurs under the Risk Management Framework (RMF). Note that categorization under the RMF is typically
conducted using the information types described in NIST Special Publication (SP) 800-60, which are not as granular as the PII data elements listed in the PIA table. Determining the PII confidentiality impact level is
most effective when done in collaboration with the Information Owner, Information System Owner, Information System Security Manager, and representatives from the security and privacy organizations, such as the
Information System Security Officer (ISSO) and Senior Component Official for Privacy (SCOP) or designees.

c. How will the PII be secured?
(1) Physical Controls. (Check all that apply)
Cipher Locks

Closed Circuit TV (CCTV)

Combination Locks

Identification Badges

Key Cards

Safes

Security Guards

If Other, enter the information in the box below

(2) Administrative Controls. (Check all that apply)
Backups Secured Off-site
Encryption of Backups
Methods to Ensure Only Authorized Personnel Access to PII
Periodic Security Audits
Regular Monitoring of Users' Security Practices
If Other, enter the information in the box below

(3) Technical Controls. (Check all that apply)
Biometrics

Command Access Card (CAC)

DoD Public Key Infrastructure Certificates

Encryption of Data at Rest

Encryption of Data in Transit

External Certificate Authority Certificates

Firewall

Intrusion Detection System (IDS)

Least Privilege Access

Role-Based Access Controls

Used Only for Privileged (Elevated Roles)

User Identification and Password

Virtual Private Network (VPN)

If Other, enter the information in the box below

d. What additional measures/safeguards have been put in place to address privacy risks for this information system or electronic collection?

User accounts are flagged at 30 days of non-use, disabled after 45 days of non-use and deleted after 60 days.

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 6 of 10

SECTION 3: RELATED COMPLIANCE INFORMATION
a. Is this DoD Information System registered in the DoD IT Portfolio Repository (DITPR) or the DoD Secret Internet Protocol Router Network
(SIPRNET) Information Technology (IT) Registry or Risk Management Framework (RMF) tool 3?
Yes, DITPR

DITPR System Identification Number

Yes, SIPRNET

SIPRNET Identification Number

Yes, RMF tool

RMF tool Identification Number

DITPR ID: 1496
242

No
If “No,” explain.

DITPR DON ID: 20813
b. DoD information systems require assessment and authorization under the DoD Instruction 8510.01, “Risk Management Framework for DoD
Information Technology”.
Indicate the assessment and authorization status:
Authorization to Operate (ATO)

Date Granted:

ATO with Conditions

Date Granted:

Denial of Authorization to Operate (DATO)

Date Granted:

Interim Authorization to Test (IATT)

Date Granted:

(1) If an assessment and authorization is pending, indicate the type and projected date of completion.

IATO:
Granted: 2018-02-05
Expires: 2018-05-31
(2) If an assessment and authorization is not using RMF, indicate the projected transition date.

c. Does this DoD information system have an IT investment Unique Investment Identifier (UII), required by Office of Management and Budget (OMB)
Circular A-11?
Yes
If "Yes," Enter UII

No

007-000001247

DD FORM 2930, JUN 2017

If unsure, consult the component IT Budget Point of Contact to obtain the UII

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 7 of 10