Privacy Impact Assessment - NDU NEIS

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:

National Defense University (NDU) Enterprise Information System (NEIS)
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

08/24/20

National Defense University

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.

This data is critical to generate official transcripts for students, Program for Accreditation of Joint Education (PAJE) reports, and Middle
States accreditation reports. It is also used to facilitate travel and logistics for foreign nationals who attend the university and their families,
as well as HR actions for all University personnel military students. A combination of military, civilian, and/or contract personnel access
different combinations of this data in several IT systems. The types of personal information include an individual’s name, address, date of
birth, phone numbers, e-mail addresses, citizenship, race, sex, age, marital status, spouse information, education and academic data,
information pertaining to employment, attributes pertaining to US and Foreign military, civilian, and inter-agency personnel records related
to student course enrollments and final grades, Social Security Number (SSN), DoD Identification number, passport number, country of
origin, disability and limited medical information, student identification number, grade/rank, branch of service or civilian agency, years of
Federal service, security clearance granted and date, biographical data (agency/Service, military operations, assignments, Joint Professional
Military Education (JPME) Level, degrees granted, gender, disability, Date of Rank (DOR), Basic Active Service Date (BASD), Joint
Service experience, command experience), and financial information (account number and routing number).
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)

The PII collected is used to verify, identify, match records, and authenticate authorized users. The data is used to generate student
transcripts and related reports.
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.

Individuals can object in writing, with a memo provided in Appendix A of NDU Governance and Privacy Program Policy and Procedures.
Individuals also read the Privacy Act Statement before submitting PII.
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.

Individuals can object in writing. Individuals also read the Privacy Act Statement before they submit PII.

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.)

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 1 of 8

Privacy Act Statement

Privacy Advisory

Not Applicable

PRIVACY ACT STATEMENT
AUTHORITY: 10 U.S.C. 2165, National Defense University; 10 U.S.C. 2163 Degree Granting Authority for National Defense University
and E.O. 9397, as amended (SSN).
PURPOSE: The data provided will be used to update your National Defense University (NDU) record. NDU data are used to authenticate
and identify NDU personnel and students; track academic enrollment, assignments, progress, and assessments; track personnel records and
actions; create academic transcripts and related reports; facilitate award of degrees and credentials; conduct analysis for regional and DoD
academic accreditations; and create reports for University leadership to aid in the development of effective curricula, facilitate academic
completion requirements.
ROUTINE USES: Data are shared with other Federal/State agencies and contractors for the purpose of communicating educational
credentials and accrediting University programs.
DISCLOSURE: Voluntary. However, if data in NDU systems are not up-to-date, your NDU entitlements/privileges and the ability of NDU
systems to identify you as an NDU-affiliated person could be delayed or inaccurate. The production of accurate academic transcripts may not
be possible. Home addresses will be used for mustering in the event of an officially declared manmade or natural disaster (DoDI 3001.02)
and for notification of a Privacy compromise, loss or stolen (breached) personally identifiable information (PII). If addresses are not correct
these two requirements will not be performed with accuracy as to your location.
h. With whom will the PII be shared through data exchange, both within your DoD Component and outside your Component? (Check all that apply)
Within the DoD Component

Specify.

Other DoD Components

Specify.

JDIRs, JS DOM, JS JAG Office

Military Service Branch Admin/Ops Offices/Military
Colleges, Universities and Academies, and Military JAG
Offices
Non-DoD Federal Agencies, Federal Law Enforcement
Specify.
Agencies, Congress, and Federal Courts
State and Local Government Agencies, State and Local
Specify. Courts, State and Local Law Enforcement Agencies, State
and Local IG Offices

Other Federal Agencies

State and Local Agencies

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.)

Specify.

Intellipeak Solutions, & OSC Edge

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

Specify.

Former Students/Alumni, Public and Private Domestic and
Foreign Universities, Colleges, and Academies

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

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)?

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 2 of 8

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
or other unique identifier. PIA and Privacy Act SORN information must be consistent.
Yesby name No
If "Yes," enter SORN System Identifier

DNDU01

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-0218-2019-0002

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

(3) Retention Instructions.

The Archivist of the United States approved the Joint Chiefs of Staff Academic Affairs Records schedule on 22 JUN 2020,
DAA-0218-2019-0002.
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.

10 U.S.C. 2165, National Defense University; 10 U.S.C. 2163 Degree Granting Authority for National Defense University and E.O. 9397, as
amended (SSN).
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 control number request is pending. NDU is not yet in receipt of the 60 and/or 30 day notice.

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 3 of 8

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)

Branch of Service and Agency

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.

Ms. Cindy Allard, Chief , Defense Privacy, Civil Liberties, and Transparency Division – 2019/06/28

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

The SSN that is collected for the NDU SMS and student and employee data files is used to verify an individual’s identity for the purpose of
accurate academic records and transcripts. The SSN is also used by NDU Security to perform background checks and to issue Common
Access Cards (CACs) These requirements are consistent with the guidance for acceptable uses of the SSN as specified in DoDI 1000.30
(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”.

NDU is currently in the process to procure a new Student Information System which is planned to accomplish the centralization of not just
SSN but all student PII. From there the reduction of SSN use is planned as alternatives such as a Student ID are explored.
(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

NDU plans to develop an SSN elimination/mitigation strategy in concert with adoption of its new Student Information System, which is not
yet procured.
b. What is the PII confidentiality impact level2?

1

Low

Moderate

High

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.

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 4 of 8

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

Other- Locked offices, desks, and filing cabinets.

(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

Training users on best practices

(3) Technical Controls. (Check all that apply)
Biometrics

Common 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?

Mitigation: The following controls are used to mitigate the risks:
a. Access Controls. Access controls consist of privileges, password control, discretionary access control. Access only occurs through
Government Furnished Equipment (GFE) with direct or VPN connections. Users are granted only those privileges that are necessary for
their job requirements. The roles also determine which menu items are enabled for the user.
b. Confidentiality. To protect confidentiality of data the following security measures have been put into place: Data at rest is encrypted
using transparent data encryption; PII is encrypted using AES_256.
c. Integrity. To ensure that data has not been altered or destroyed in an unauthorized manner, the following security measures are in place:
Only personnel granted elevated privileges are authorized to change data; Security permissions are set on data files and folders to restrict
access to authorized personnel only; In the event of a system restore, data and log files are validated to ensure that they have not been
altered or tampered with.
d. Audits by authorized personnel with access and a need to know. This includes review and examination of records, activities, and system
parameters, to assess the adequacy of maintaining, managing and controlling events that may degrade the security posture of the NEIS.
e. Training. Security training is provided on a continuous basis to keep users alert of security requirements. Personnel are expected to attend
annual security briefings and training as defined by the organization. Visual effects are used as constant reminders to ensure users always
remain aware of their responsibilities.
f. Physical Security. The Network Operation Center (NOC) is a secure facility where there is restricted access, controlled by badge readers
and only accessible by authorized personnel.

DD FORM 2930, JUN 2017

PREVIOUS EDITION IS OBSOLETE.

AEM Designer

Page 5 of 8