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:

SOS IMCOM - INSTALLATION MANAGEMENT COMMAND SURVIVOR OUTREACH SERVICE SYSTEM
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

09/09/20

United States Army
Headquarters Installation Management Command, G9
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.

The purpose of the information system is to collect surviving member information when seeking program assistance for Fallen Soldiers
benefits. This module is utilized by Active Duty Army, Army Reserve, National Guard survivor outreach service program personnel for
client intake. The information system also has the capability to generate analytical reports which are provided to higher headquarters as
needed.

The types of personal information collected in the system are name, birth date, home cell phone, home mailing address and personal email
address, Military Status, Service branch, vehicle decal number, alternate phone number, Defense Casualty Information Processing System
(DCIPS) ID.
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 SOS module is the initial survivor information collection point when seeking program assistance for benefits.
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.

Survivor information is not required, however failure to provide the requested information may impede personnel from being able to assist
individuals effectively.
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.

Survivor information is not required, however failure to provide the requested information may impede personnel from being able to assist
individuals effectively.
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

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Privacy Advisory

Not Applicable

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PRIVACY ACT STATEMENT
AUTHORITY: 10 U.S.C. 1475, Death gratuity: death of members on active duty or inactive duty training and of certain other persons; 10
U.S.C. 7013, Secretary of the Army; Army Regulation 608-1, Army Community Service, DoDI 1300.18, Department of Defense (DoD)
Personnel Casualty Matters, Policies, and Procedures; Army Regulation (AR) 638-8, Army Casualty Program; AR 638-2, Army Mortuary
Affairs Program.
PURPOSE: The purpose of the information system is to collect surviving member information when seeking program assistance for Fallen
Soldiers benefits. This module is utilized by Active Duty Army, Army Reserve, National Guard survivor outreach service program personnel
for client intake. The information system also has the capability to generate analytical reports which are provided to higher headquarters as
needed.
ROUTINE USES: In addition to those disclosures generally permitted under 5 U.S.C. 552a(b) of the Privacy Act, these records or
information contained therein may specifically be disclosed outside the DoD as a routine use pursuant to 5 U.S.C. 552a(b)(3).
DISCLOSURE : Voluntary. However, failure to provide the requested information may impede Army Community Service personnel from
being able to assist individuals effectively.
h. With whom will the PII be shared through data exchange, both within your DoD Component and outside your Component? (Check all that apply)

USA Garrisons, Army Reserve, National Guard

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.)

GTRI - The CONTRACTOR: shall not electronically
process any personal information in any way that does not
comply with applicable privacy policies, including but not
limited to, adhering to the Department of Army regulation
requirements in handling, processing, and protecting
Personally Identifiable Information (PII).
(1)The CONTRACTOR shall follow the same regulatory
policies, procedures, and guidance as a Government agency
to include, Privacy Act of 1974 (5USC 552a), DoD5400.11R, and 32 CFR Part 505.
(2)As directed by the Agency’s Program Manager, the
contractor shall incorporate by this contract the
administrative, technical, and physical safeguards as
required by the Privacy Impact Assessment to protect any
Specify. and all Government data as well as assessing these
safeguards throughout the life cycle of this contract. Further,
if there is a change/new use/application of new technologies
that creates new privacy risks the contractor shall notify the
Program manager and establish additional appropriate
safeguards of PII to this system to ensure that all data
required under this contract is protected. The Contractor
shall also ensure the confidentiality, integrity, and
availability of Government data in compliance with all
applicable laws and regulations, including data breach
reporting and response requirements, in accordance with
DFARS Subpart224.1 (Protection of Individual Privacy),
which incorporates by reference DoDD5400.11, "DoD
Privacy Program," May 8, 2007, and DoD 5400.11-R, "DoD
Privacy Program," May 14, 2007.

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

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Other Federal Information Systems

Manual input of information from DCIPS, no cross functional system interface or electronic transfer with DCIPS.
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)

Defense Casualty Information Processing System (DCIPS) information transfer.
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.
Yes

No

If "Yes," enter SORN System Identifier

SORN pending submission

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-2017-0002-0002

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

(3) Retention Instructions.

Temporary, Destroy when superseded, obsolete, or when customer requests the agency to remove the records.
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. 1475, Death gratuity: death of members on active duty or inactive duty training and of certain other persons; 10 U.S.C. 7013,
Secretary of the Army; Army Regulation 608-1, Army Community Service, DoDI 1300.18, Department of Defense (DoD) Personnel
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Casualty Matters, Policies, and Procedures; Army Regulation (AR) 638-8, Army Casualty Program; AR 638-2, Army Mortuary Affairs
Program.
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.

Submission pending review and request from RMDA.

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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 Status, Service branch, vehicle decal number, alternate phone number, DCIPS ID, simple financial service provided.

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.

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

(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”.

(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

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.

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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

Hosted by Amazon Web Service GovCloud.

(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

Hosted by Amazon Web Service GovCloud.

(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

An enterprise single sign-on service and brokering agent will be used for user access to the system.

d. What additional measures/safeguards have been put in place to address privacy risks for this information system or electronic collection?

Hosting environment is a Federal Risk and Authorization Management Program (FedRAMP) approved Government Cloud and is remotely
managed by contract support representatives.

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