Privacy Narrative

Information Collection Request - Privacy Narrative
Oral Health Basic Screening Survey for Children
Title: ______________________________________________________________________________________
Mei Lin, Epidemiologist, Division of Oral Health, NCCDPHP
Point of Contact: _____________________________________________________________________________

The oral health Basic Screening Survey for children (BSS) is a state-tailored survey administered by individual
states. There are two levels (child and state levels) of data collection. States use paper or electronic (e.g., Epi
Info or MS Access) forms to collect child-level oral health screening data from a state-representative sample of
students in grades K-3 or Head Start enrollees. There is no plan at this time to introduce a standard, web-based
screening form. States are invited to email state-aggregated screening data only to CDC's partner -- the
Association of State and Territorial Dental Directors (ASTDD). ASTDD reviews and verifies the data and emails
the data to CDC for publication on the CDC's Oral Health Data (OHD) website. Consents and invitations to
participate in the data collection are located in attachments 2d, 2e and 2h.
The NCCDPHP Privacy Officer has reviewed this submission and determined that the Privacy Act does not
apply. The data is not collected thru a CDC sponsored Information technology (IT) system. States collect
child-level screening data that may include certain PII (e.g., child's date of birth [DOB], state student ID [SSID])
using the screening form (Attachment 2f) in paper or data entry tools such as Epi Info or MS Access. Data
collection is not through a web-based data collection system.
Collection of child-level and state-level aggregated data requires privacy protection.
Child-level data
The child's name is necessary to compile a roster of students to screen to verify the unique, randomly
generated school or state Department of Education (DOE) SSID; to verify consent and ensure that screening is
provided to the correct child with consent; to provide screening results to parents or caretakers; and to
provide information to the school for follow-up if urgent dental care needs are found. The child's name is not
onto the screening form (Attachment 2f).
Once the screening is completed, the screening results (Attachment 2g) are placed in a sealed security
envelope with the child's name on it taken onsite from the class roster and given to the teacher for distribution
to the child to take home to the parent/caretaker. Only if the child is in need of urgent care, the screener
informs the school contact to ensure follow-up.
✔ Yes
Does
ICR collect
requestthe
anychild's
PII? DOB
No age,
If yes,
Somethis
states
to calculate
but describe:
only their_____________________________________
age is retained in the analysis file.

Does
ICRobtain
include
a form that
requires a Privacy
Act are
Statement?
Yes ✔the
Noschool to include SSID on
Statesthis
that
child-level
demographics
from DOE
instructed to inform
the class
SSID aisPIA?
entered onYes
the screening
form onIf the
day at
the
schoolexist?
and is thenYes
used at No
✔ No
Does
this roster.
ICR require
yes,screening
does a signed
PIA
already
DOE through its secured data system to link the screening data with DOE demographic data. Before sending
the linked dataset to the state oral health program, DOE remove SSID from the dataset once the linkage is
complete.

C/I/O Approval

Screeners are instructed to mail all the paper consent forms, any paper instruments, and any other
documentation
from
screening via USPS or other state
agency designated
secure delivery
Associate
Director
for the
Science
Information
Systems Security
Officer system to the
state health departmentDigitally
designated
contact,
and to return or destroy the class roster.
signed
by Rachel
Digitally signed by

Cynthia
Rachel
Kaufmann -S
Cynthia Allen -S
The protocol specifies that
along
with training in clinical observation, screeners also
be2021.01.04
trained in privacy
Date:
2020.12.17
Date:
Kaufmann
-S
Allen
-S
protection and their roles13:17:51
in protecting
system.
-05'00'children's privacy and utilizing the data entry
14:25:01
-05'00'

Comments:
The protocol instructs states to use a password-protected platform, transmit data securely and use encrypted
files when handling PII. The system should be monitored by the state agency or security office and accessible
only by authorized program personnel and IT administrators trained in data privacy protection and security.
State programs are also instructed to store all paper forms in locked cabinets accessible only by program
personnel. The consent form contains information on privacy protections (see Attachment 2e).
BSS instructs states to develop a data management plan (DMP) that includes information on methods to assure