Nceh Cbls Pia

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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-29684

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-1557750-345723

2a Name:

3/15/2018 9:02:01 AM

Childhood Blood-Lead Surveillance System (CBLS)
General Support System (GSS)
Major Application

3

Minor Application (stand-alone)

The subject of this PIA is which of the following?

Minor Application (child)
Electronic Information Collection
Unknown

3a

Identify the Enterprise Performance Lifecycle Phase
of the system.

Operations and Maintenance
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)?

8a Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Business Owner

POC Name

David Wright

POC Organization NCEH
POC Email

[email protected]

POC Phone

770-488-4715
New
Existing
Yes
No

Sep 19, 2018

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11 Describe the purpose of the system.
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.)
Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.
14 Does the system collect, maintain, use or share PII?

15

Childhood Blood-Lead Poisoning Surveillance (CBLS) system is
a surveillance and analysis system used to maintain and report
The system maintains laboratory blood lead testing
information (child_id, address_id, test result, submission year,
submission quarter) for children exposed to lead. Each State
collects the information, and CDC receives demographic
Lead exposure has been linked to a number of health effects
and even relatively low blood lead levels can have a negative
and long lasting effect on the cognitive skills, behavior, and
Yes
No

Indicate the type of PII that the system will collect or
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
Race
City, State, and zip code
Gender
Ethnicity
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)

20 Describe the function of the SSN.

1,000,000 or more
The PII is primarily used for childhood blood lead surveillance
and analysis.
A secondary use for the PII is research and training.
N/A

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20a Cite the legal authority to use the SSN.

N/A

Public Health Service Act, section 301, "Research and
Identify legal authorities governing information use Investigation, " (42 U.S.C. 241); and Sections 304, 306, and
21
308(d) which discuss authority to maintain data and provide
and disclosure specific to the system and program.
assurances of confidentiality for health research and related
activities (42 U.S.C. 242 b, k, and m(d)).
22

Are records on the system retrieved by one or more
PII data elements?

Yes
No
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?
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

Is the submission of PII by individuals voluntary or
mandatory?

Describe the method for individuals to opt-out of the
collection or use of their PII. If there is no option to
27
object to the information collection, provide a
reason.

Yes
No
There is no prior notice given by CDC because CDC does not
collect the data directly from the individuals. Data is collected
and submitted to CDC by State and Local public health
agencies.
Voluntary
Mandatory
Individuals have no means of opt-out. in most jurisdictions
where CBLS data is initially collected all blood lead test
laboratory records must be reported to the state or local public
health authority. States remove major identifying information
from patient records and submit to CDC for aggregation,
analysis and reporting.

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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.

CDC does not have a process to notify and obtain consent
from individuals in the event of a significant system change.
The reason for this is that CDC is not provided names nor any
contact information by the state/local public health authorities.

Describe the process in place to resolve an
individual's concerns when they believe their PII has
29 been inappropriately obtained, used, or disclosed, or
that the PII is inaccurate. If no process exists, explain
why not.

It is not necessary to implement this process since the deidentified data released or reported by CDC is not unique to
the individual but is only reported in aggregates. CDC is not
provided names nor any contact information by the state/local
public health authorities; all data is collected and submitted to
CDC by State and Local public health agencies.
CBLS does not contain PII in the system. All child blood lead
data is de-identified from state and local agencies prior to
submission to CDC.

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.

CBLS data is cleansed quarterly for data integrity, accuracy and
relevancy. The data is reviewed for accuracy, file duplication
and all fields are reviewed for relevancy and consistency. This
file is provided to the data manager for validation. The Data
Manager transfers the data via secure FTP to an encrypted
shared drive for validation & processing into the encrypted
CBLS database. If changes or updates to the data files are
required those changes are completed based on the validation
process. The cleaned and validated file is now the official file.
Users
Administrators

31

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

Full access for data management and
maintenance

Developers
Contractors
Others

Describe the procedures in place to determine which Per a role-based access model, access to PII in the Childhood
32 system users (administrators, developers,
Blood Lead Surveillance (CBLS) system is determined by the
contractors, etc.) may access PII.
Business Steward. Administrators, Data Managers, and Project

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.

The least privilege model is applied to access PII. Least
privilege provides the user with only those privileges which are
essential to perform their intended job function. Managers can
only access PII after having the managerial group permission
associated to their account by the system Business Steward.
Examples of controls that are employed are: Read/Write
permissions that are controlled by user roles and privileges;
Windows authentication; and Active Directory controls for
administrative access and audit logs.

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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.

All system administrators must undergo annual Security and
Privacy Awareness training (SAT).

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

All system administrators have extensive training and
experience maintaining database management systems and
best practices related to public health surveillance and
reporting systems.

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.

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

Yes
No
Records are retained and disposed of in accordance with the
CDC Records Control Schedule B321 and B371. Record copy of
study reports are maintained in agency from two to three years
in accordance with retention schedules. Source documents for
computer are disposed of when no longer needed by program
officials. Personal identifiers may be deleted from records
when no longer needed in the study as determined by the
system manager, and as provided in the signed consent form,
as appropriate. Disposal methods include erasing computer
tapes, burning or shredding paper materials or transferring
records to the Federal Records Center when no longer needed
for evaluation and analysis. Records are retained for 20 years;
for longer periods if further study is needed.
Administrative: The HHS Rules of Behavior govern the data
protection, integrity and general use of the system and data
rights. Only users with proper role based access privileges
(Centers for Disease Control / National Centers for
Environmental Health / Lead Poisoning Prevention Branch
(CDC/NCEH/LPPB) staff have Active Directory (AD) rights to
access the network and only approved individuals (Data
manager, data stewards, and system users) have privileges to
access data directly. CDC approved credentials are used to
access the system, based on the principles of least privilege
Technical: Active Directory, Windows Authentication, Audit
Logs
Physical: Production and test servers are stored in a server
room secured by the CDC. Access tools are in place to secure
entry into CDC buildings (Guards, ID Badges, Key Card, and
Closed Circuit TV).

General Comments

OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by
Beverly E. Walker -S
Date: 2018.09.19 14:59:13
-04'00'

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