ACAS Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

TBD

2a Name:

07/13/20

ATSDR Communication Activities Survey (ACAS)
General Support System (GSS)
Major Application

3

The subject of this PIA is which of the following?

Minor Application (stand-alone)
Minor Application (child)
Electronic Information Collection
Unknown

3a

Identify the Enterprise Performance Lifecycle Phase
of the system.

Development
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)?

No
Yes
No
Agency
Contractor
POC Title

Communication/Program Evaluat

POC Name

Matt Sones

POC Organization ATSDR DCHI
POC Email

[email protected]

POC Phone

770-488-0731
New
Existing
Yes
No

8b Planned Date of Security Authorization
Not Applicable

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8c

Briefly explain why security authorization is not
required

This study uses multiple CDC authorized systems for data
collection, processing, and storage.

10

Describe in further detail any changes to the system
that have occurred since the last PIA.

N/A

11 Describe the purpose of the system.

The purpose of the study is to gather information from
communities in proximity to hazardous waste so that ATSDR
can effectively implement programs that address the
communities' concerns.
The study will collect, maintain, or share the following types of
information:

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
about the specific data elements.)

Contact (email address, phone number)
Demographic (whether community member or agency
stakeholder)
Surveys (customer satisfaction)
CDC users will authenticate using Active Directory, a CDC
authorized system. No other users will be authenticated.
Communities in proximity to hazardous waste sites are
concerned that they are being exposed to hazardous
substances being released into the environment. This study
will conduct surveys that help ATSDR to better address
community concerns.
Contact information such as email address and telephone
numbers will be used to send online or telephone surveys to
members of the community who indicated they would like to
take part in providing customer feedback.
Demographic information will be used to distinguish
responses from two types of customers (community or state/
local agency)

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

Survey responses will be used to assess the effectiveness of
ATSDR's communication methods with the public and to make
improvements in customer service.
ATSDR will not share the contact information. ATSDR will
delete the email address from the database as soon as the
online response to the ACAS is received. ATSDR will not store
telephone numbers during the SMS Text Survey polling.
Deidentified survey results will be shared internally with ATSDR
leadership and staff across the agency and disseminated
externally to stakeholders and partners through annual reports
and budget performance narratives that will be posted via the
internet.
The data will be stratified by demographic categories
(community member or agency stakeholder) so that ATSDR
can improve and provide customer-specific communications.
CDC users will authenticate using Active Directory, a CDC
authorized system. No other users will be authenticated.

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Yes

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

No

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

Other...

Demographic

Other...

Other...

Other...

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)

500-4,999
The primary purpose of the PII is for sending participants a link
to the customer service survey(s).
There is no secondary purpose for the PII in the system.

20 Describe the function of the SSN.

N/A

20a Cite the legal authority to use the SSN.

N/A

Comprehensive Environmental Response, Compensation, and
Identify legal authorities governing information use Liability Act of 1980’’ as amended by ‘‘Superfund Amendments
21
and Reauthorization Act of 1986’’ (42 U.S.C. 9601, 9604); and
and disclosure specific to the system and program.
the ‘Resource Conservation and Recovery Act of 1976’’ as
amended in 1984 (42 U.S.C. 6901).
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.

24 Is the PII shared with other organizations?

OMB Control No. 0923-0055; exp. date 06/30/2020; we are
submitting a reinstatement ICR to OMB to reactivate this
number.
Yes
No
Within HHS

Identify with whom the PII is shared or disclosed and
24a
for what purpose.

Other Federal
Agency/Agencies
State or Local
Agency/Agencies
Private Sector

Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
There are no agreements in place that authorize the
24b Matching Agreement, Memorandum of
information sharing or disclosure.
Understanding (MOU), or Information Sharing
Agreement (ISA)).
24c

Describe the procedures for accounting for
disclosures

It is not envisioned that disclosures will be necessary.
However, if a disclosure is needed, they will be accounted for in
a spreadsheet that is maintained by the study point of contact.

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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

The sign in sheet at community meetings informs the
participants that PII is being collected and what their personal
information will be used for.
Voluntary

Is the submission of PII by individuals voluntary or
mandatory?

Mandatory

Describe the method for individuals to opt-out of the
Individuals may opt out of the collection or use of their PII by
collection or use of their PII. If there is no option to
27
not completing a survey and/or by not providing contact
object to the information collection, provide a
information at the community meetings.
reason.
Describe the process to notify and obtain consent
from the individuals whose PII is in the system when
major changes occur to the system (e.g., disclosure
28 and/or data uses have changed since the notice at
the time of original collection). Alternatively, describe
why they cannot be notified or have their consent
obtained.

ATSDR will delete the email address from the database as soon
as the online response to the ACAS is received. ATSDR utilize
but will not collect or store telephone numbers during the SMS
Text Survey polling. No further contact with meeting attendees
will be possible that this point.

Individuals, who believe their PII has been inappropriately
obtained, used, or disclosed, or that the PII is inaccurate,
should contact the point of contact (POC) as identified in the
sign-in sheet. They will be directed to identify the record and
Describe the process in place to resolve an
specify the information being contested, the corrective action
individual's concerns when they believe their PII has sought, and the reasons for requesting the correction, along
29 been inappropriately obtained, used, or disclosed, or with supporting information to show how the record is
that the PII is inaccurate. If no process exists, explain inaccurate, incomplete, untimely, or irrelevant. The POC will
why not.
make a determination as to the next steps that should be taken
to address the individual's concerns. If an incident has
occurred, the PI will report the potential incident to the Centers
for Disease Control and Prevention (CDC) Security Incident
Response Team and Privacy Officer.
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.

There is no process in place for periodic reviews of the PII
contained in the system. ATSDR will delete the email address
from the database as soon as the online response to the ACAS
is received. ATSDR utilize but will not collect or store telephone
numbers during the SMS Text Survey polling.
Users

Users will need to have access to PII in
order to send links to surveys to

Administrators
31

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

Developers
Contractors
Others

Describe the procedures in place to determine which The POC will determine the level of access for each user
32 system users (administrators, developers,
depending on their role in the study. The study POC will give
contractors, etc.) may access PII.
access to new users.
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.

Only ATSDR project staff will have access to PII during online
data collection. PII will be deleted as soon as the online survey
results are received.

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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.

Study staff will complete CDC's annual security awareness
training and sign associated rules of behavior.

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

The users will not receive additional training.

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
The study uses the CDC/ATSDR Minor Research Records record
control schedule in regard to the retention and destruction of
PII. The schedule states that the records should be maintained
"at least six years, but no longer than ten years, after the
retirement of the system—depending upon program need for
scientific, legal, or business reference—then delete/destroy".
The PII in the system is secured using a layered approach with
appropriate administrative, technical, and physical controls,
being implemented.

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

The administrative controls educate system users of their
responsibility to protect PII and legally bind them to do so.
These controls include signed rules of behavior , nondisclosure agreements, CDC privacy and security awareness
training, and records management training. Records are
maintained according to CDC record control policies and
procedures.
The technical controls, implemented by the system, act to
either allow access to system PII data only to approved users or
to make PII data unreadable outside of the system. These
controls include encryption, authentication, firewalls, intrusion
detection systems, and anti-malware systems.
The physical controls, implemented by the system, restrict
access to CDC buildings and areas housing computers used by
this system. These controls include guards, identification
badges, key cards, locked doors, cipher locks, fences, alarms
and closed circuit TV.

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

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Reviewer Questions
2

Answer

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
6

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

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

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Reviewer Questions

Answer

Reviewer
Notes

General Comments

OPDIV Senior Official
for Privacy Signature

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2020.08.04
for Privacy
11:35:15 -04'00'

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