NACS 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:

Navy Access Control System (NACS)
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

Department of the Navy

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 requirement for NACS is to provide automated entrance into a naval installation based on two
factor authentication leveraging existing authoritative identification sources such as CAC and Teslin cards.
The NACS system collects this information from these cards through proximity sensors and/or barcode.

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 purpose of this electronic collection is to authorize Department of the Navy civilian, military, and
contractor personnel entrance onto the naval installation. NACS compares CAC and Teslin holder PII
information on Federal personnel and Federal contractors from the authoritative data source Defense
Enrollment Eligibility Report System (DEERS) database and the Department of Navy Total Workforce
Management System (TWMS) via Socket Layer (SSL) as defined in the Enabler System Security
Authorization Agreement (SSAA). This provides NACS with the ability to interactively check for
authentication, permissions and privileges before any benefit, service or privilege is provided.
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 have the opportunity to object to the collection of their PII by following the procedures outlined in
the System of Record Notice (SORN) NM05512-2 and by refusing to provide the requested PII information
as disclosure is voluntary; however, failure to provide the information may result in refusal to grant access to
DoD installations.
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 give or withhold their consent to the specific uses of their PII following the procedures
outlined in the System of record Notice (SORN) NMOS000-2 and NM05512-2 or by refusing to provide the
requested information. Disclosure of PII is voluntary; however, failure to provide the information may result in
refusal to grant access to DoD installations.
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.)

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Privacy Act Statement

Privacy Advisory

Not Applicable

No information is provided to the user when requesting PII data. The PII data is resident on the CAC
and Teslin card. This information is pulled and verified against the DOD DMDC database for
authentication and to allow authorization to enter the Navy base. The system receiving data is fully
automated and reads the DOD CAC through the contact-less chip on the CAC as well as bar code on
the back of the CAC as a backup or for those individuals that hold Teslin dependent, retired or other
federal cards that are able to be authenticated by the DOD DMDC database.
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.

USN

Other DoD Components

Specify.

USMC, USAF, USA, CG

Other Federal Agencies

Specify.

DLA, PFPA

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.)

Specify.

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

Navy, Marines, Public Safety Anti-Terrorism Force Protection, Naval Criminal
Investigative Service (NCIS), Air Force Army, BIMA and other DOD
Components as needed.
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)

No information is provided to the user when requesting PII data. The PII data is resident on the CAC
and Teslin card. This information is pulled and verified against the DOD DMDC database for
authentication and to allow authorization to enter the Navy base. The system receiving data is fully
automated and reads the DOD CAC through the contact-less chip on the CAC as well as bar code on
the back of the CAC as a backup or for those individuals that hold Teslin dependent, retired or other
federal cards that are able to be authenticated by the DOD DMDC database.
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 NM05512-2

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

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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.

NA

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

(3) Retention Instructions.

It does not appear that the system stores any records as it is connected to other systems. NPACS is connected to other systems to include
DoDIN, Physical Security Access Control Enterprise Architecture (PSAC-EA) for Authentication, log management and enterprise services,
Public Services Network (PSNET) for transport, and Commander Navy Installation Command (CNIC) Cyber Security Operations Center
(C2SOC) who is responsible for monitoring technologies such as monthly ACAS Scans via VRAM for verification of applied patches and
m. What
is the authority to collect information? A Federal law or Executive Order must authorize the collection and maintenance of a system of
HBSS
services.
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.

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.

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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)

Types of Personal Information: Name, DoD ID Number, Biometrics, FACS-N, License Plate Picture, Video.
When a system user presses the intercom button at a gate to request assistance, the image of their face is
transmitted to the Regional Dispatch Center that is assisting them. So, the facial image is the biometric PII
element and also the video PII element collected here.
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?

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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

Data collection and data flow is encrypted. Only those persons with the appropriate access, accounts and privileges
can view the PII in the system. The risks are as follows:
(a) Since the NACS system operates on the Navy's Public Safety Network (PSNet) which is a closed network there is a
risk that security controls could be disabled for maintenance and other purposes. The risk would be that the security
controls would not be reset.
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(b) All systems are vulnerable to "insider threats". The NACS managers are vigilant to this threat by limiting system
access to those individuals who have a defined need to access the information. There are defined criteria to identify
who should have access to NACS. These individuals have gone through extensive background and employment
investigations.
(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?

Safeguards:
Encryption. Encryption is done with the National Institute of Standards and Technology (NIST) approved algorithms. NACS enforces a
two-factor authentication (CAC + CAC Pin) for all kinds of access and transactions. NACS employs industry standard techniques to protect
the control points within the system. In general, everything is protected with public/private or symmetric key concepts. Data and
communications are encrypted. Additionally, NACS uses a standard suite of hardware encrypted key techniques to ensure the devices
talking to each other on the network are authentic. The use of secure network services is also utilized for communications such as HTTPS
and LDAP. The servers communicate with each other via the PSNet and authenticate between themselves using cryptographic certificates.
The information processed by the system is Sensitive Unclassified. Standard DOD security safeguards for
logging will be supported. This includes PSNet requirements, standard user name and password (3 attempts) and autilizing the CAC for
communications for compliance with Open SSL FIPS 140-2 validation.

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