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Privacy Impact Assessment Form
v 1.21
Status

Form Number

Form Date

Question
1

OPDIV:

2

PIA Unique Identifier:

2a Name:

Answer
CDC/DDPHSS/CSELS

Epi Info Secure Web Survey - PRA
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

IT Project Manager

POC Name

Leslyn McNabb

POC Organization CDC/OPHSS/CSELS
POC Email

[email protected]

POC Phone

404-498-2286
New
Existing
Yes
No

Jun 30, 2020

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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
Other...
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 Epi Info Secure Web Survey system (EISWS) allows CDC
users with authorized access to the Epi Info system to create,
distribute, and receive completed online surveys to gather
information for analysis. The surveys can be distributed to the
targeted audience using emails or any other electronic form.
Each survey is accessed using the URL that is unique to a given
survey. An epidemiologist will be able to download the survey
responses from web and analyze the survey data any time
during the period the survey is open or after the survey has
closed using Epi Info desktop application.
CDC programs use The Epi Info Secure Web Survey system
(EISWS) to collect public health data for epidemiologic
investigations and research studies. The system will collect
data that enables epidemiologists to conduct outbreak
investigations, track cases, perform contact tracing, evaluate
public health interventions, and collect information on
attitudes and behaviors that impact public health outcomes.
Programs that use this system must sign an agreement after
reading the Rules of Behavior (RoB) document that explicitly
indicates the terms and usage of the system and what
information can be collected. The data collected may vary
dependent upon the unique variables needed by individual
research studies. However, any data collected must fall within
the parameters of the RoB, and as such is limited to:

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 Name, Date of Birth or Age, Sex, Mailing Address, Physical
about the specific data elements.)
Address, Physical locations traveled, Email Address, Phone
Number, Photographic Identifiers, Employment Status,
Occupation, Disease Status, Disease Signs and Symptoms,
unique identifier, and Behavior Information that impacts Public
Health.
Social Security Numbers (SSN) are not allowed to be collected
by EISWS. Data from this system is not shared with any other
system(s).
External users (survey respondents): No user credentials
collected or required. Users navigate directly to survey with a
system generated unique URL. Users do not authenticate in
any way. Internal users are authenticated through Active
Directory (AD). AD is a separate system with its own PIA.

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EISWS is a unique system that allows for the creation of a
survey by a CDC user based on the need to conduct an
epidemiologic investigation. The survey designer (CDC user)
may choose to collect PII as part of their survey. All data
(whether PII or not) will be stored inside the EISWS system.
EISWS does not share any of this data with any other system.
Data elements that can be collected in a survey include: Name,
Date of Birth or Age, Sex, Mailing Address, Physical Address,
Physical locations traveled, Email Address, Phone Number,
Photographic Identifiers, Employment Status, Occupation,
Disease Status, Disease Signs and Symptoms, and Behavior
Information that impacts Public Health.
A unique identifier will be used to keep track and link data to
individuals.

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

Social Security Numbers (SSN) are not allowed to be collected
by EISWS. Data from this system is not shared with any other
system(s). Survey respondents have the choice to not respond
to specific questions or the survey itself.
Examples of epidemiologic investigations that surveys can be
created for:
1. Collecting baseline data regarding prevalence and incidence
of infections on a specific disease in a given population.
2. Conduct community based evaluations of interventions.
3. Conduct surveys on attitudes and behaviors around specific
public health initiatives.
4. Conduct surveys on Flu vaccine knowledge, attitudes and
beliefs.
5. Conduct surveys about the level of knowledge and use of
personal protective equipment in a hazardous workplace
environment or among a particular occupation.
External users (survey respondents): No user credentials
collected or required. Users navigate directly to survey with a
system generated unique URL. Users do not authenticate in
any way.
Internal users: Authenticated through Active Directory (AD).
AD is a separate system with its own PIA.

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

Yes
No

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

Physical locations traveled

Disease Signs/Symptoms

Occupation

Behaviors

Sex; Unique Identifier

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)

50,000-99,999
PII is used to assess exposure risks, monitor outcomes and
interventions, monitor behaviors and their impact to public
health interventions.
Research and the assessment of policy and practice is the
secondary use for the PII.

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, 42 U.S. Code § 300u
and disclosure specific to the system and program.

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.

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.

None
Yes

24 Is the PII shared with other organizations?

No
Within HHS
Other Federal
Agency/Agencies
State or Local
Agency/Agencies

Identify with whom the PII is shared or disclosed and
24a
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
N/A
Understanding (MOU), or Information Sharing
Agreement (ISA)).
24c

Describe the procedures for accounting for
disclosures

N/A

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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

Epi Info Secure Web Survey employs the standard CDC
Disclaimer and Use Warning that is used across CDC systems. It
also states that users of the system *may* be asked to submit
personally identifiable information (PII).
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
Individuals may opt-out of the collection and use of their PII by
27
object to the information collection, provide a
not participating or entering PII into the survey.
reason.
Should major changes ever occur to the system, CDC will not
always have the capability to notify and obtain consent. The
dependency is on the particular questions on the survey and
Describe the process to notify and obtain consent
its purpose (PII questions pertaining to contact information are
from the individuals whose PII is in the system when not always asked). Surveys may not have any identifier other
major changes occur to the system (e.g., disclosure
than a random number so there would be no way to know who
28 and/or data uses have changed since the notice at
filled out the form because submissions would be anonymous.
the time of original collection). Alternatively, describe If data use changes during or after the program collected data,
why they cannot be notified or have their consent
and the survey collected contact information, then the
obtained.
program in question using Epi Info Secure Web Survey could
contact the users directly to obtain consent for those changes.
These terms are outlined in the system's Rules of Behavior
(ROB) document.
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.

The program contact that signed Epi Info's Rules of Behavior
(ROB) document, is also the person who creates and publishes
the surveys. The Rules of Behavior states that the program
agrees to provide an email contact address within the survey
for respondents to send questions or concerns. Thus, the
program who designed and deployed the survey would be
responsible for handling these concerns.
Epi Info Secure Web Survey system administrators require a
CDC user to sign the Rules of Behavior in order to use Epi Info
Secure Web Survey. Epi Info system administrators verbally go
over the Rules of Behavior with the CDC user who signed it.
The Rules of Behavior states that Epi Info Secure Web Survey
system administrators will, at a minimum, annually review the
surveys' PII for integrity, availability, accuracy and relevancy.
They also have the right to review the PII collected at any time,
if they suspect integrity, availability, accuracy, or relevancy has
been compromised.

Users
Administrators
31

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

Administrators need to set up the data
owner for the program in the system

Developers
Contractors
Others

The program data owner of the form
who has the key to publish the forms

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Epi Info program management assigns specific system
Describe the procedures in place to determine which administrators and developers, the authority to access, write,
update, and maintain EISWS. Epi Info management also
32 system users (administrators, developers,
maintains a Web Survey Terms of Access and Use document
contractors, etc.) may access PII.
that outlines how access is granted and outlines the publishing
process.
Access for internal CDC system administrators is determined
on a case-by-case basis by the EISWS program management.
Both privileged and non-privileged users’ access is governed
by the principle of Least-Privilege, which restricts their access
to the minimum functions and information essential to their
job functions. The enforcement of the least-privilege model is
controlled by the EISWS system; system administrators
(privileged users) and non-privileged users are added to the
EISWS security "Groups", and only members of those groups
get access to the minimal data required to perform their duties.
System administrators and developers (all of which are FTE) are
provided access to the system based on need to know (i.e.,
Active Directory) and audit controls are in place to track their
activity on the servers and within the consolidated database
environment. These individuals are responsible for supporting,
building, and maintaining the system itself and require full
access to the entire application.

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.

There are system controls in place that limit a user's access to
type, amount and categories of PII. Access to PII is first
restricted by physical access. A CDC user must first be on the
CDC network, they must have signed the Rules of Behavior
(ROB), and have been granted access to the system by a system
administrator and be provided an Organization Key in order to
design a survey (that may or may not contain PII). The survey
designer (CDC user) determines the amount of PII in their own
surveys.
Access to PII is further restricted through the process for
publishing a survey. Once a CDC user has created a survey and
would like to publish, they must use the Organization key to
publish. At the time of publish, the CDC user receives two
additional keys, a publisher key and a survey key. Only a
person with all three keys can make changes to the survey,
access the data collected in the survey, and perform analysis
on it.
The EISWS system is designed to only allow the survey creator/
designer to read/review/analyze the data that was collected
from the survey they created. Physical access controls are in
place as well as three encryption keys to ensure access to data
is limited to the single individual who created and then
published the survey. CDC users can not view or access
surveys or survey responses of other CDC users' surveys that
are also hosted by Epi Info Secure Web Survey.

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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 internal users of the system are required to complete the
security and privacy awareness training at least annually.

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

N/A

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 is retained and disposed of in accordance with the CDC
Records Control Schedule for EISWS: Per GRS 23.7 (), PII is
stored for 2 years to allow CDC access to the information when
requested. After two years, data is purged from the database.
Epi Info Secure Web Survey is a public facing application for
administering surveys and and in internal-only Application
Programming Interface (API) for accessing data:
Administrative Controls – Programs agree to Rules of Behavior
for PII data collection. Program will secure Office of
Management and Budget / Institutional Review Board (OMB/
IRB) approval for the data being collected as per CDC
requirement. Program will provide the form to Epi Info Secure
Web Survey administrator to review the form for PII elements
being collected prior to going live.

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

Technical Controls – Technical controls are in place to minimize
the possibility of unauthorized access, use, or dissemination of
the data in the system. The application also utilizes the CDC’s
infrastructure firewalls, virus protection and intrusion detection
systems for both the public facing site and intranet service.
Physical Controls - Epi Info resides on client's CDC workstations
that uses machine level encryption to encrypt data. EISWS
database Servers are housed in secure CDC enterprise data
centers that limit access to only authorized individuals part of
Epi Info technical team. Physical controls include the use of
human guards, identification badges, key cards, and ClosedCircuit Television (CCTV) in the server farm.

39 Identify the publicly-available URL:
40 Does the website have a posted privacy notice?

http://www.cdc.gov/EpiInfo
Yes
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

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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)

Collects PII?

No

Session Cookies
Persistent Cookies

Yes
No
Yes
No
Yes

Other...

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

Is a disclaimer notice provided to users that follow
43a external links to websites not owned or operated by
HHS?

Yes

No

No
No

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

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Reviewer Questions
6

Does the PIA accurately identify data retention procedures and records retention schedules?

Answer
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

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: 2020.06.15
for Privacy
08:34:14 -04'00'

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