Privacy Impact Assessment

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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:

04/17/2019

Chronic Disease Management Information System (CDMIS)
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.

Operations and Maintenance
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)?

8a Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Information System Security Offic

POC Name

Cindy Allen

POC Organization CDC
POC Email

[email protected]

POC Phone

770-488-5388
New
Existing
Yes
No

Jul 31, 2019

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9

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

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
Documenting business contact as PII
10

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

11 Describe the purpose of the system.

None.
The Chronic Disease Management Information System (CDMIS)
is a post award grants management web-based tool that
allows CDC's National Center for Chronic Disease Prevention
and Health Promotion (NCCDPHP) program staff and award
recipients to monitor, track, and enhance performance and
transparency on strategies, activities, and outcomes across
multiple years.
The data is used to document and report on activities of the
Notice of Funding Opportunity (NOFOs) recipients.

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The Chronic Disease Management Information System collects
and stores information so that CDC staff and awardees can
conduct data analysis of strategies, activities, and outcomes
across multiple years after award closeout.
The data collected are used to document and report recipient
efforts through interim and annual reports by allowing states,
territories and large metropolitan areas to uniformly define,
collect, and report chronic disease data.
CDMIS is organized into different modules which are described
below:
1. Program Information - Funded partners enter program
contact information. CDC staff contacts are also stored in this
module
2. Resources -Funded partners enter names, position title,
email, telephone number, job descriptions, personnel status
Describe the type of information the system will
(active or inactive) and position status (filled or vacant) for
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask human resources associated with the program
about the specific data elements.)
3. Planning - Funded partners document standard and nonstandard data sources used to plan, evaluate, and implement
actions. This module allows storage and retrieval of relevant
documents over time such as state plans, evaluation plans,
burden reports, and logic models.
4. Action Plan - Funded partners build Action Plans (aka work
plans) using a standardized template. The template is
composed of Project Period Objectives, Annual Objectives,
Progress, Activities and Products. Information in the Action
Plan section is used to populate annual performance reports
5. Reports - Funded partners generate annual performance
reports using a step-by-step process.
6. Search Tab -The Search section allows CDC staff to search
across organizations for specific information of interest. Staff
only have access to the funded partners that they manage.
Award recipients only have access to their own data.

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The Chronic Disease Management Information System is used
by NCCDPHP and funding recipients (awardees) to document
and report recipient efforts through interim and annual
reports. The recipients support the development,
implementation and evaluation of chronic disease programs.
All recipients are required to report data to NCCDPHP using
CDMIS.
Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

The data collected are used to document and report recipient
efforts through interim and annual reports by allowing states,
territories and large metropolitan areas to uniformly define,
collect, and report chronic disease data.
The data collected, processed, and stored by CDMIS include
contact and supporting information of recipients including
names, position title, email, telephone number, job
descriptions, personnel status (active or inactive) and position
status (filled or vacant) for human resources associated with
the program. CDMIS also contains plans and reports for
program implementation and evaluation.
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...

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?

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)

User name and password are used to control access.
Name and email address are used for CDC to communicate
with recipients.
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
Section 301 of the Public Health Service Act [42 U.S.C. 241]
and disclosure specific to the system and program.

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.

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?

OMB# 0920-0739, Exp: 09/30/2019
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
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

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

CDC sends all award recipients a Notice of Funding Award
letter that outlines the requirements of the award. Those
requirements include providing CDC with contact information
of staff involved in the project. This is a condition of the award.
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
No method in place. Individuals must provide contact
27
object to the information collection, provide a
information as a condition of the CDC funding.
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.

CDC will notify the users of upcoming changes through email.
CDC also provides release notes to the users that outline
changes to the system.

A user can notify their CDC project officer to resolve any
concerns. The CDC project officer will notify the CDMIS help
desk at [email protected] to investigate and resolve any issues.
The contact information and system access is reviewed
annually by the CDC Project Officer for accuracy and relevancy.
Users
Administrators

31

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

State users have access to the PII of
users within their state; CDC users (aka
Admins (contractors) can access PII to
provide technical support.

Developers
Contractors

Admins (contractors) can access PII to
provide technical support.

Others

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The NCCDPHP program administrator of the funding award
identifies which CDC Project Officer will work with a recipient.
The project officers are only given access within CDMIS to the
Describe the procedures in place to determine which recipients/awardees they are assigned to oversee.
32 system users (administrators, developers,
contractors, etc.) may access PII.
The CDC Project Officers work with the awardees in each state
to determine who should have access to CDMIS within the
state. The recipients only have access to information within
their state.
Role-based access controls are in place to ensure the concept
of “least privilege” is implemented. 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. Users are
given access to the least amount of information necessary to
complete their duties.
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.

Roles include:
CDC user (program staff, project officer)
CDC program administrator (access across a module, manage
users)
CDC system administrator (provides technical support to CDC
and recipient users)
Recipient user (limited access based on state and program
activities)

CDC users complete annual security and privacy awareness
training.
Recipient staff do not receive training from CDC.

None
Yes
No
PII is not retained after the award activities have ended. The PII
is destroyed when user accounts are removed. All PII will be
destroyed when CDMIS is no longer operational.
Federal records are retained, stored, and disposed of in
accordance with CDC’s Scientific and Research Project Records
Control Schedule (N1-442-09-01). PII is not retained. CDC will
follow the National Archives Disposal of Records (44 USC
Chapter33) guidance once retention has ended.

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Administrative Controls:
Access to PII is role-based and limited to authorized staff only.
Audits are conducted annually of PII to ensure appropriate
access. A security assessment of the system is conducted
annually. Administrative controls include a security plan,
contingency plan, file back-up, least privilege access, and
training.
Describe, briefly but with specificity, how the PII will
38 be secured in the system using administrative,
technical, and physical controls.

Technical Controls:
All data is encrypted in transit. Access controls (user id and
password) are in place to restrict access to only authorized
users. Continuous monitoring is in place to detect security
threats.
Physical Controls:
CDC’s servers are located in a secure facility with multiple
layers of restricted access. Physical controls include ID Badges,
Key Cards, and Closed Circuit TV (CCTV). The system is in a data
center protected by guards, gates, and surveillance at the entry
point to the facility. Access to the data center is limited to
authorized personnel.

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

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Reviewer Questions

Answer

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

OPDIV Senior Official
for Privacy Signature

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2019.07.19
for Privacy
15:15:48 -04'00'

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