Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-80035

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-2613524-286155

2a Name:

3/22/2017 7:24:48 AM

Import Permit Select Agent System (IPSAS)
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.

Development
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

Vicky Jackson

POC Organization PHPR/DSAT
POC Email

[email protected]

POC Phone

770-488-2708
New
Existing
Yes
No
April 5, 2017
Not Applicable

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Public Law 107-188 requires maintenance of a national
database of entities that are registered for possession of Select
Agents and Toxins, laboratory compliance with national safety
guidelines, security measures including controlled access to
Select Agents and Toxins, security screening of entities and
personnel, and criminal/civil penalties for inappropriate use of
Select Agents & Toxins.
11 Describe the purpose of the system.

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 Import Permit Select Agent System (IPSAS) is a joint CDC
and USDA Agriculture Select Agent Services (AgSAS) system is
designed to control, protect, and store the use, possession and
transfer of Select Agents and Toxins. IPSAS maintains
information regarding an entity’s Select Agent registration. It
will replace the current NSAP Information System once it is
retired.

IPSAS maintains information regarding an entity’s Select Agent
registration: facility information; a list of select agents or toxins
to be possessed, used, or transferred by the entity; a list of
individual(s) who will have access to select agents and toxins;
characterization of the select agents and toxins; and additional
laboratory information.
Part of the overall public health mission of the Centers for
Disease Control and Prevention (CDC) is to prevent the
introduction, transmission and spread of communicable
diseases from foreign countries into the United States. is a joint
CDC and USDA Agriculture Select Agent Services (AgSAS)
system is designed to control, protect, and store the use,
possession and transfer of Select Agents and Toxins.

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

IPSAS is a Project Matrix, Surveillance, and Resource
Management Information System for the management and
processing of Import Permit (IP) and Select Agent (SA)
information. It provides the Select Agent program with the
document and records management support in compliance
with National Archives and Records Administration (NARA)
standards. It also provides for a secure national database and
processing environment, to include data entry, scanning and
complex reporting capability in support of national incident
response or appropriate law enforcement queries.
IPSAS maintains information regarding an entity’s (i.e.,
institution or organization) Select Agent registration: facility
information; a list of select agents or toxins to be possessed,
used, or transferred by the entity; a list of individual(s) who will
have access to select agents and toxins; characterization of the
select agents and toxins; and additional laboratory
information.

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
DOJ Number

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
The PII is used to assist in identifying an individual for FBI to
conduct background check.
N/A

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 Security and Bioterrorism Preparedness and
Response Act of 2002 and The Agricultural Bioterrorism
and disclosure specific to the system and program.
Protection Act of 2002 (Pub. L. 107-188).

22

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

Yes
No

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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.

09-20-0170 National Select Agent Registry
(NSAR)/Select Agent Transfer and Entity
Registration Information System (SATERIS), HHS/

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.

OMB NO. 0579-0213 (APHIS OMB Number) exp 12/31/2018
OMB NO. 0920-0576 (CDC OMB NUMBER) exp 12/31/2018
Yes

24 Is the PII shared with other organizations?

No
Within HHS
Other Federal
Agency/Agencies

24a

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

APHIS and CJIS for compliance with federal mandates.
State or Local
Agency/Agencies
Private Sector

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Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
Interconnection Security Agreement, between USDA/APHIS
24b Matching Agreement, Memorandum of
and HHS/CDC.
Understanding (MOU), or Information Sharing
MOU Among CDC, APHIS, and CJIS
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

Is the submission of PII by individuals voluntary or
mandatory?

Disclosure of any IPSAS records is processed through
managerial written/approved procedures. Requests for
disclosures are processed and maintained using a SharePoint
WorkFlow. An accounting of disclosures is produced by a
review of signed transmittal documents.
The application instructions to USDA/CDC Form 1, Application
for Registration for Possession, Use, and Transfer of Select
Agents and Toxins, advises that the application will capture
information regarding the entity and the Responsible Official
(RO), Alternate Responsible Official (ARO), and Owner/
Controller (if applicable). The instructions also indicate what
information is needed with regard to these individuals as well
as the information that will be required regarding individuals
who will have access to the select agents and toxins.
Voluntary
Mandatory

Submission of PII is mandatory. A Security Assessment is
Describe the method for individuals to opt-out of the required for those individuals identified as a Responsible
Official (RO), Alternative Responsible Official (ARO), owners of
collection or use of their PII. If there is no option to
27
non-governmental entities, and individuals who want to have
object to the information collection, provide a
access to select agents or toxins. Access to the system may be
reason.
denied if there is insufficient information to conduct a Security
Risk Assessment.
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
Notification of any major changes to the system are posted on
28 and/or data uses have changed since the notice at
the time of original collection). Alternatively, describe the Select Agents Web Site as "Select Agent (SA) Grams."
why they cannot be notified or have their consent
obtained.
The process to be followed in the event an individual has
concerns regarding the use/accuracy/disclosure of his/her PII is
as follows: The user may contact the Business Steward in
Describe the process in place to resolve an
writing via the address indicated in the SORN. Individuals must
individual's concerns when they believe their PII has reasonably identify the record and specify the information
29 been inappropriately obtained, used, or disclosed, or being contested, the corrective action sought, and the reasons
that the PII is inaccurate. If no process exists, explain for requesting the correction, along with supporting
why not.
information to show how the record is inaccurate, incomplete,
untimely, or irrelevant.

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.

There is an established daily quality control check of IPSAS. in
addition the individual’s information is rechecked when the
person’s access is renewed or information regarding the
individual changes.

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Users

For initial data entry

Administrators
31

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

Developers

To perform Production Operational
and Maintenance functions to fix bugs
and update logic

Contractors
Others
Describe the procedures in place to determine which
Role-Based Access (RBAC) is used to determine who may
32 system users (administrators, developers,
access the system and its 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.

The least privilege model is used to allow those with
access to PII to only access the minimum amount of
information necessary to perform one's 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.

All individuals are required to show a certificate of completion
for mandatory Security and Privacy Awareness Training.

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

System stewards (Business, Security & DAA) must undergo
additional Role Based Training. Users must be verified by the
DSAT process and sign the IPSAS Rules of Behavior.

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.

Yes
No
Data will be maintained in accordance with a National Archives
Records Agency (NARA) compliant Records File Retention and
Destruction Plan. The CDC Records Control Schedule (B-321),
the Division of Select Agents and Toxins (DSAT) Records
Retention Schedule N1-442-06-01. The PII will be retained for
the life of the system.
IPSAS stores data in a series of password protected databases
hosted in secure environments on encrypted networks.
Additional administrative controls are in place to protect the
PII with Rules of Behavior, Policies and Procedures including
mandatory Security and Privacy Awareness Training.

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

Technical controls are in place with ITSO and OCISO. Logical
access barriers include Access Control Lists (ACLs), Active
Directory (AD) groups, Firewalls and Intrusion Detection
System (IDS).
Physical controls are in place through OSSAM including
Guards, SmartCard (PIV) access cards for locks, and Closed
Circuit Television (CCTV).

39 Identify the publicly-available URL:

TBD

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Yes

40 Does the website have a posted privacy notice?

No

40a

Is the privacy policy available in a machine-readable
format?

Yes

41

Does the website use web measurement and
customization technology?

Yes

No
No
Technologies

Yes

Web beacons

No
Yes

Web bugs
Select the type of website measurement and
41a customization technologies is in use and if it is used
to collect PII. (Select all that apply)

No

Session Cookies
Persistent Cookies

No
Yes
No
No

42

Does the website have any information or pages
directed at children under the age of thirteen?

Yes

43

Does the website contain links to non- federal
government websites external to HHS?

Yes

OPDIV Senior Official
for Privacy Signature

Yes

Yes

Other...

General Comments

Collects PII?

No

No

At the time of this PIA review, the website has not been fully developed; therefore, Questions 39-43
cannot be validated. A POA&M is being requested from the responsible program so that the related
weaknesses can be monitored through mitigation.

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: 2017.04.26 08:23:48 -04'00'

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