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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-81890

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-6552278-630311

2a Name:

8/12/2019 8:18:51 AM

Evaluation of National Diabetes Prevention Program
Effectiveness (ENDPPE)
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.

Planning
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

Health Scientist

POC Name

Krista Proia

POC Organization DDT
POC Email

[email protected]

POC Phone

404-498-0961
New
Existing
Yes
No
November 6, 2019
Not Applicable

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11 Describe the purpose of the system.

The purpose of the system is to facilitate a Landscape
Assessment Survey to increase enrollment in CDC's National
PII Maintained: Business contact information, including name,
email address and mailing address of CDC-recognized
organizations offering lifestyle change programs.
Non-PII Maintained:
Lifestyle change program characteristics (community-level,
program-level, and introductory-session level);
Perceived barriers and facilitators to enrolling in the National
DPP lifestyle change program;
First-session attendance as well as registration in the lifestyle
change program among introductory session participants; and
Indicators of intervention fidelity among sites.

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.)
External users receive a uniquely assigned weblink to access
the survey and credential are permanently store until the end
of the project. For survey respondents that did not complete
an online survey, they are to complete a paper-based and
submitted/uploaded the surveys via Secure File Transfer
Protocol (SFTP) using User ID and Password.

Internal user is utilizing Active Directory (user id/password) to
authenticate; credentials are permanently stored until the
project ends. Active Directory is a separate system with its
own PIA.
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 system will be used to conduct a Landscape Assessment
survey of CDC-recognized organizations providing National
Diabetes Prevention Program's Lifestyle Change Programs
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
User Id and password

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
PII (business contact information) will be used only for
contacting study participants to engage in data collection
efforts at their respective organization's National DPP Lifestyle
Change Program.
PII will be used for a paper based survey outside this system.

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)

22

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

Yes
No

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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?

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.

TBD
Yes
No
No process is in place because PII is being collected from
organizations about staff at their associated class locations
(other organizations) that are the points of contact. As the
appointed points of contact, it is not necessary to notify them
that their information is being shared by their parent
organization.
Voluntary
Mandatory
There is no method for individuals to opt out of the use of their
PII. PII is provided by a CDC-recognized organization and
necessary as a point of contact to interact with CDC. If the POC
does not want to provide his or her data, the organization
cannot participate in the study.

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
No process in place. CDC announces major changes to the data
28 and/or data uses have changed since the notice at
the time of original collection). Alternatively, describe collection through Federal Register Notices.
why they cannot be notified or have their consent
obtained.

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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 resolve an individual's concerns
when they believe their PII has been inappropriately obtained,
used or disclosed, or that the PII is inaccurate, because the PII is
being obtained from the CDC-recognized organization to
which the individual is associated or is employed.

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.

Periodic reviews are not necessary as this is a one point in time
assessment.
Users

data entry

Administrators
31

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

Developers
Contractors

Indirect contractor: Statistical analysis
and reporting.

Others
Describe the procedures in place to determine which The National DPP Introductory Session Project leader (at CDC)
32 system users (administrators, developers,
is responsible for ensuring that personnel have controlled
contractors, etc.) may access PII.
access only to what is relevant to their specific work on the

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.

Role-based access controls are in place to ensure the concept
of “least privilege” is implemented. Based on the technical
director and project director’s assessment of each team
member, the network administrator creates and implements
network access groups. The access groups include managers,
system staff, data analyst, web developer, database
administrator, statisticians working on data validation,
processing, visualization etc. Each individual assigned to work
on the project is assigned to a group associated with their role.
Access rights are then derived from that role.
The project network directory structure is organized such that
access to each sub folder is restricted to one or more network
access groups, effectively ensuring that an individual’s access
to data containing PII is restricted only to network areas
pertaining to tasks the individual is required to perform.

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 indirect contractors that process these data files are
trained in standards and procedures to maintain the security
and confidentiality of PII. Audits are conducted throughout
the year to ensure adherence to these standards.

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

None

Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?

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, stored, and disposed of in accordance
with CDC’s Records Control Schedule for Scientific and
Research Project Records (N1-442-09-01). PII will be removed
before records are archived. Contractors will destroy all records
no later than five years after the end of the project.
Administrative Controls: Administrative controls include a
security plan, contingency plan, file back-up, least privilege,
and training. Access reports are reviewed on a monthly basis.

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

Technical Controls: PII data is encrypted and stored in a secure
database. Technical controls are in place to manage user
identity, identity proofing, authentication and authorization.
Physical Controls: Physical controls include ID Badges and Key
Cards. The system is in a location protected by security guards,
gates, and surveillance at the entry point to each facility.
Access to the buildings is limited to authorized personnel.

General Comments

OPDIV Senior Official
for Privacy Signature

signed by Jarell
Jarell Oshodi Digitally
Oshodi -S
Date: 2019.08.26 16:07:48
-S
-04'00'

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