Draft 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:

Personnel Investigations Processing System (PIPS)
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

DoD Business Enterprise
DCSA
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 Personnel Investigations Processing System (PIPS) supports personnel vetting missions and is the case processing system for
background investigations conducted by DCSA. This processing includes: ingest of security questionnaire information on subjects of
investigation, either electronically via the Electronic Questionnaires for Investigations Processing (e-QIP) or via manual data entry;
automated scheduling of National Agency Checks at the Federal Bureau of Investigation (FBI), Department of Defense Central Index of
Investigations (DCII), national credit bureaus, etc.; scheduling and transmitting investigation requests to multiple investigative service
providers; receiving reports of investigation from other investigative service providers; scheduling investigative inquiries to various sources
(e.g., law, education, employment, etc.); closing investigations automatically; transmitting results electronically to customer agencies; and
tracking all stages and pieces of each investigation. From the data in PIPS, DCSA produces a large variety of statistics and specific
management information reports, used within the agency and its customer agencies to track investigations. Adjudication, security clearance,
and credential data is also stored in PIPS.
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)

PII is collected and used for personnel vetting missions, such as the conduct of personnel background investigations; suitability, fitness, and
security clearance determinations; physical and logical access determinations; continuous evaluation; etc.
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.

The individuals were notified of the routine use previously at the point of collection via the e-QIP system, and again at the beginning of an in
person interview. The investigator provides notice and consent details verbally.

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 are notified at the point of collection, at the beginning of an in person interview, and on various consent forms. They are
informed that providing information is voluntary but that if they do not consent to the collection of the required information, it may affect the
completion of their background investigation. They do not have the ability, once they have agreed to the background investigation, to
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consent to some uses of their information and decline to consent to other uses. The exception to this is the SF86 Medical Release
authorization, which is valid for 1 year from the date signed but can be revoked at any time by writing to the individual's health care
provider/entity, except to the extent that action has already been taken based on the authorization.
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

Privacy Advisory

Not Applicable

Individuals are not provided with notice specifically about PIPS. The Privacy Act advisement, provided on the SF forms and at the
beginning of personal interviews, informs the individual on the uses of the information. While that advisement does not explain the system
specifically, it does provide information concerning how their information will be used. In addition, notification specifically about this
system is provided through publication of this PIA.

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.

FTS, e-QIP, OPIS, DMRS, NFW, FWS, Arc-Nlets

Other DoD Components

Specify.

DMDC (JPAS)

External Agency Partners including FBI, State Department,
USCIS, FINCEN, etc. who provide records in support of the
Specify.
PV mission; as well as sharing PII as necessary with the
Suitability and Security Executive Agents.
PII is shared with state and local agencies (such as law
Specify. enforcement agencies) when we conduct LAWE checks,
state BAR checks, etc.

Other Federal Agencies

State and Local Agencies

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.

PII is only shared with contracted entities and their
respective personnel who have been properly vetted.

Other (e.g., commercial providers, colleges).

Specify.

Credit bureas, education institiutions, Employment
verifuication services.

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

PIPS accepts the subject-entered data from e-QIP as well as data that may be manually entered by DCSA personnel/contractors, scopes
investigative leads, distributes work to field investigators, provides automated National Agency Checks (NAC) such as fingerprints
searches to the FBI, supports review of cases, closes cases, and delivers closed cases, as well as advance products to the agencies. PIPS
provides automated capability for agencies to upload adjudications, as well as clearance and credential data into CVS.
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)

System-to-System Information System: FTS, e-QIP, NFW, FWS, and ARC-Nlets.. OMB numbers for forms are noted in section 1.n below.
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

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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.

N1-478-08-002 and DAA-0446-2019-0004

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

(3) Retention Instructions.

The records in PIPS are subject to the retention schedules referenced above. Depending on the type of information and the action taken on
that information, various retention periods apply. Standard investigations with no issues are retained for 16 years from the closing of the
investigation; those with issues are retained for 25 years from the closing of the investigation. Files obtained from other agencies in the
course of an investigation are retained consistent with the agreement between the agency and DCSA. Additionally, information in PIPS is
retained for certain business need purposes, for a temporary time. Case processing data is temporarily retained for 2 years or less, depending
on the business need. FBI criminal history record information is temporarily retained in PIPS for 6 months after case closing; but retained
according to the retention schedule in OPIS. Credit reports are temporarily retained in PIPS for 7 days after case closing; but retained
according to the retention schedule in OPIS. If there is a credit report received on the individual, it is retained for 7 days after the case has
closed. If information received includes FBI case files on the individual it is stored in PIPS, and retained for 6 months after the case has
closed. Individual data, investigation and item events during the processing of the case are retained. SSN is necessary as they are used as
primary keys to request individual information from federal agencies and bureaus including the following commercial entities: Credit
Bureaus, Court and Law information, Periodical information from wire services, license information from license bureaus.
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. 137, Under Secretary of Defense for Intelligence; 10 U.S.C. 504, Persons Not Qualified; 10 U.S.C. 505, Regular components:
Qualifications, term, grade; Atomic Energy Act of 1954, 60 Stat. 755; Public Law 108-458, The Intelligence Reform and Terrorism
Prevention Act of 2004 (50 U.S.C. 401 note); Public Law 114-92, Section 1086, National Defense Authorization Act (NDAA) for Fiscal
Year (FY) 2016, Reform and Improvement of Personnel Security, Insider Threat Detection and Prevention, and Physical Security (10 U.S.C.
1564 note); Public Law 114-328, Section 951 (NDAA for FY2017), Enhanced Security Programs for Department Defense Personnel and
Innovation Initiatives (10 U.S.C. 1564 note); Public Law 115-91, Section 925, (NDAA for FY2018) Background and Security Investigations
for Department of Defense Personnel (10 U.S.C. 1564 note); 5 U.S.C. 9101, Access to Criminal History Records for National Security and
Other Purposes; Executive Order (E.O.) 13549, as amended, Classified National Security Information Program for State, Local, Tribal, and
Private Sector Entities; E.O. 12333, as amended, United States Intelligence Activities; E.O. 12829, as amended, National Industrial Security
Program; E.O. 10865, as amended, Safeguarding Classified Information Within Industry; E.O. 13467, as amended, Reforming Processes
Related to Suitability for Government Employment, Fitness for Contractor Employees, and Eligibility for Access to Classified National
Security Information; E.O. 12968, as amended, Access to Classified Information; E.O. 13470, Further Amendments to Executive Order
12333; E.O. 13488, as amended, Granting Reciprocity on Excepted Service and Federal Contractor Employee Fitness and Reinvestigating
Individuals in Positions of Public Trust; E.O. 13526, Classified National Security Information; E.O. 13741, Amending Executive Order
13467, To Establish the Roles and Responsibilities of the National Background Investigations Bureau and Related Matters; E.O. 13764,
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Amending the Civil Service Rules; DoD Manual 5200.02, Procedures for the DoD Personnel Security Program (PSP); DoD Instruction
(DoDI) 1400.25, Volume 731, DoD Civilian Personnel Management System: Suitability and Fitness Adjudication for Civilian Employees;
DoDI 5200.46, DoD Investigative and Adjudicative Guidance for Issuing the Common Access Card (CAC); Homeland Security Presidential
Directive (HSPD) 12: Policy for a Common Identification Standard for Federal Employees and Contractors; Federal Information Processing
Standard (FIPS) 201-2, Personal Identity Verification (PIV) of Federal Employees and Contractors; and E.O. 9397 (SSN), as amended.
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.

Form Number
SF-85
SF-85P
SF86
SF-87

Form Name
Questionnaire for Non-Sensitive Positions
Questionnaire for Public Trust Positions
Questionnaire for National Security Positions
Fingerprint Chart

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OMB Number Expiration Date
3206-0261
09/30/2021
3206-0258
12/31/2020
3206-0005
02/28/2023
3206-0150
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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)

Aliases used, Personal Conduct, other information requested on applicable forms and during the investigative process from investigation
sources.
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.

PIA itself provides justification.

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

Security Clearance Investigation or Verification: The initiation, conduct,adjudication, verification, quality assurance, and billing fund control
of background investigations and security clearances requires the use of the SSN. The SSN is the single identifier that links all of the aspects
of these investigations together. This use case is also linked to other Federal agencies that continue to use the SSN as a primary identifier.
(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

(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

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

Biometrics will be implemented in the new computer room.

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

Privacy Risk: There is a risk that the information obtained in the course of the investigation will be inaccurate, resulting in an adverse
decision for the individual being investigated.
Mitigation: This risk is mitigated by incorporating reviews by a team of case analysts who confirm that the information pertains to the
individual being investigated and corroborate the information using various sources.
Privacy Risk: There is a risk that information obtained from commercial sources and electronic records searches will be misinterpreted or
that relevant information may be overlooked, resulting in an adverse decision for the individual being investigated.
Mitigation: This risk is mitigated by training investigators regarding how to interpret the information they obtain in the course of the
investigation and by having processes in place to validate the information.
Privacy Risk: There is a risk that authorized users may inappropriately access and disclose the information in PIPS for an unauthorized
purpose.
Mitigation: This risk is mitigated by assigning specific cases and roles. They can then only see the cases assigned to them, based upon their
authorization and privilege. In addition, there are also built in audit logs to monitor disclosures and determine who had access during this
time. These logs are checked regularly to ensure that the system was is accessed appropriately.
Privacy Risk: There is a risk of loss or compromise of sensitive information collected through the background investigation process.
Mitigation: This risk is mitigated through the use of multiple layers of physical and IT protection used to safeguard the data. In addition,
physical security on the premises ensures that only authorized individuals have access to the building and layered firewalls and data
encryption methods ensure it can only be access by authorized individuals on the network.
Privacy Risk: There is a risk that information may be kept longer than is necessary to meet the business need for which it was collected.
Mitigation: This risk is mitigated by DCSA staff following the established retention schedule and documented guidance from NARA, which
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clearly defines retention requirements by record type and agency. The risk is also lessened by using the ROID application, a backend
application consisting of scheduled batch jobs that purge and minimize investigation data in accordance with internal business need
retentions as well as NARA-approved retention schedules.

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