Privacy Impact Assessment

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:

OMNI-CHANNEL
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

11/26/19

Department of the Navy
BUREAU OF NAVAL PERSONNEL (BUPERS)
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.

OMNI-CHANNEL will be used to record and index telephone conversations between customers and customer service representatives
(CSRs) in My Navy Career Center (MNCC) contact centers. Callers could be members of the military, family members, contractors or
members of the public. Callers may ask about their own official records, family members may ask about upcoming transfers, and members
of the public may call looking for individuals (for legal reasons).The inbound calls will be recorded in order to resolve misunderstandings or
misperceptions made during the customer-CSR interaction. This system will also facilitate the process of monitoring and evaluating the
recorded audio used by CSRs in order to provide training, collect data in support of the CSRs annual performance evaluation, and provide
information used for business process improvements.
Data that will be collected: either the SSN or DoD ID.
Data collected could be: Name, personal contact information (email, phone number and home address), rank, mother's maiden name and
financial 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 collected for identification and verification purposes.
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.

The interactive voice response (IVR) system, which front ends the call flow process, informs the caller that the conversation is being
recorded for quality evaluation purposes and explains to the customer that if they do not provide their DoD ID or SSN they cannot be
assisted on a personnel specific issue. At that point, the caller can hang-up or the call will be answered by a customer service representative
(CSR).
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.

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Once PII is provided by the individual, consent is implied.

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

MNCC OMNI-CHANNEL Privacy Act Statement – We are required by law to provide the following Privacy Act Notice to you. The
information requested is authorized for collection under Executive Order (E.O.) 9397, as amended, and System of Records Notice T5040.
The information collected is used to record and index telephone conversations between customers and customer service representatives
(CSRs) in My Navy Career Center (MNCC) contact centers. The inbound calls will be recorded in order to resolve misunderstandings or
misperceptions made during the customer-CSR interaction. This system will also facilitate the process of monitoring and evaluating the
recorded audio and computer screens used by CSRs in order to provide training, collect data in support of the CSRs annual performance
evaluation, and provide information used for business process improvements. In addition to the applicable standard Routine Uses associated
with SORN T5040, and DoD Instruction 1000.30 Legacy System Interface acceptable use, this information will be used by CSRs to access
your Privacy Act records for customer service purposes. Disclosure of requested information is voluntary, however failure to provide the
requested information may impact the CSRs ability to assist you.
More information on the PIA and SORN can be found at the following link:
http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/
h. With whom will the PII be shared through data exchange, both within your DoD Component and outside your Component? (Check all that apply)

MNCC employees and management on a need-to-know
basis. Investigatory agencies (e.g., Inspector General)

Within the DoD Component

Specify.

Other DoD Components

Specify.

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.)

The vendor is AT&T/TTEC. All seven FAR and DFAR
clauses have been added to the contract. All contract
Specify.
employees complete privacy training prior to having access
to PII.

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

Specify.

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

All PII is collected via telephone.
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.

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Yes

No

If "Yes," enter SORN System Identifier

T5040 (Working with DFAS to modify the

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-GRS-2017-0001-00

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

(3) Retention Instructions.

Records contained in OMNI-CHANNEL are scheduled under SSIC 2000-21 and are temporary. Destroy 1 year after resolved, or when no
longer needed for business use, whichever is appropriate.
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 T5040, Call Recording Application Records (March 24, 2009, 74 FR 12320), authorities:
5 USC Section 301, Departmental Regulations; EO 12862 (Customer Service); and EO 9397 Social Security Number (SSN) as amended.

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.

OMB package is in process at BUPERS and will be submitted by mid-December.

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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)

Military Records: Pay, Service Years, Time in Grade
Financial Information: Basic Allowance for Housing, Basic Allowance for Subsistence, advance travel pay, per diem
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.

BUPERS CIO; approved 07 NOV 2019

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

LEGACY SYSTEM INTERFACE

(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”.

The MNCC system is required to have the full SSN provided because of the need to interface with systems that do not contain the DoD ID.

(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

We adhere to the SSN reduction policy as stated in the mitigation efforts above; Section 2 a (3). Until such time corporate systems are
modernized to utilize the DoD ID, the SSN must continue to be used to ensure the correct official record
is matched to the individual requesting assistance. It would be unrealistic to identify a date this modification to our corporate systems will
occur.
2

b. What is the PII confidentiality impact level ?

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Low

Moderate

High

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1

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?

COLLECTION: OMNI-CHANNEL automatically and systemically collects PII by recording telephone conversations. The information is
retained on servers in secure facilities.
USE and PROCESSING: A limited number of personnel on a need-to-know basis have been approved through the National Agency Check
with Law and Credit (NACLC) and System Authorization Access Request (SAAR) processes to access the OMNI-CHANNEL system.
RETENTION and DESTRUCTION: The records are destroyed in accordance with SECNAV M-5210 Change 1, Department of the Navy
Records Management Program Manual and SECNAVINST 5210.8F Department of the Navy Records Management Program.

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