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Privacy Impact Assessment Form
v 1.21
Status

Form Number

1A

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

TBD

2a Name:

02/02/21

Assessment of Chemical Exposures (ACE) Investigations
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.

Planning
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

Surveillance Team Lead

POC Name

Maureen Orr

POC Organization ATSDR
POC Email

[email protected]

POC Phone

404-567-3256
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

The information collection will use multiple CDC authorized
systems for data collection, analysis, 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 ACE toolkit has data collection instruments, EPi Info
databases and training materials that can be modified to
perform a rapid epidemiological assessment. The ACE toolkit is
used when an Epi AID is requested by state, regional, local, or
tribal health departments. An Epi Aid involves ATSDR and
other CDC staff including EIS officers. They are short intense
investigations to help the requesting agency to respond to
acute environmental incidents with multiple affected
individuals.

ACE will collect, maintain, and share the following types of
information:
Participant's Identification (name, date of birth, mailing
address, phone number, email address, social media accounts,
social security number [SSN], driver’s license number, state id
number, and housing unit latitude and longitude)
Participant's Emergency Contact (name, mailing address, email
Describe the type of information the system will
address, and phone number)
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask Demographic (sex, education level, race, employment status,
etc.)
about the specific data elements.)
Exposure (location during exposure, decontamination,
treatments, other people present, etc.)
Medical (history, clinical tests and imaging results, etc.)
Hospital Preparedness (surge, response, decontamination,
lessons learned, etc.)
Users will be authenticated by Active Directory (AD), an
authorized CDC system.

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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?

This data collection is to for rapid assessment after an acute
environmental incident on behalf of the requesting (state/local
or tribal) health agency. ATSDR will provide tools from its
toolkit, technical expertise, laboratory and mapping expertise,
and personnel support to requesting health agencies. Data
collection will be conducted in the days or weeks following an
acute environmental incident.
The ACE investigation will collect, maintain, and share the
following types of information: Participant's Identification,
Participant's Emergency Contact, Demographic, Exposure,
Medical, and Hospital Preparedness.
Participant's identification, participant's emergency contact,
demographic, and exposure information will be collected by
our investigation staff in conjunction with and on behalf of the
state or local health department trained volunteers.
Participants will be members of the public who are age 18 or
older. Information will be collected about individuals of all
ages with a minor’s data being provided by their parents or
guardians.
Hospital preparedness information is collected face to face by
assessment staff from responding hospital staff.
The participant’s identification and emergency contact
information is collected so that the states or health
departments can contact affected individuals and follow up
with them. The respondent Id is the link to the identifying
information, that is the item that will be used for analysis. It can
be used by the requesting agency to locate the individual, if
necessary.
Demographic information is collected to analyze the
populations that were affected by the exposure and identify
cohorts that may be followed and assessed for persistent
health effects resulting from the exposure.
Exposure and medical information is collected to characterize
exposure and acute health effects of the affected community
to inform health officials and the community.
Hospital preparedness information is collected in order to
assess the impact of the incidents on the health services used
and share lessons learned for use in hospital, local, and state
planning for environmental incidents.
After a field investigation ends, ATSDR will transfer all data to
the requesting health agency and delete all ATSDR copies of
this data. A signed non-disclosure agreement between ATSDR
and the requesting health agency will allow only deidentified
data to be transferred to ATSDR. ATSDR will not retain the link
between the respondent’s direct identity (e.g., name, date of
birth, address, phone number, email address) and the
respondent ID number.
Yes
No

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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...

Social media accounts

Other...

Other...

Other...

Employees
Public Citizens
16

Indicate the categories of individuals about whom PII
is collected, maintained or shared.

Business Partners/Contacts (Federal, state, local agencies)
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 the PII is used is to avoid duplication in
counting exposed people.
The secondary uses of PII is to follow up with people and
provide them with future services (medical services, testing,
etc.).

20 Describe the function of the SSN.

In a large scale environmental disaster, many people may have
similar names and DOB, the SSN will help to follow up with
them and avoid duplication in counting. SSN is not required;
other ID can be provided including drivers license or state ID.
We will only collect the number of SSN digits necessary for the
size of the incident. The SSN can also be used to help locate
people to provide them information or services they may need
as a result of the incident.

20a Cite the legal authority to use the SSN.

ATSDR is authorized to collect SSN under the ‘Comprehensive
Environmental Response, Compensation, and Liability Act of
1980’’ as amended by ‘‘Superfund Amendments and
Reauthorization Act of 1986’’ (42 U.S.C. 9601, 9604); and the
‘Resource Conservation and Recovery Act of 1976’’ as amended
in 1984 (42 U.S.C. 6901).

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ATSDR is authorized under the ‘Comprehensive Environmental
Response, Compensation, and Liability Act of 1980’’ as
Identify legal authorities governing information use amended by ‘‘Superfund Amendments and Reauthorization
21
and disclosure specific to the system and program.
Act of 1986’’ (42 U.S.C. 9601, 9604); and the ‘Resource
Conservation and Recovery Act of 1976’’ as amended in 1984
(42 U.S.C. 6901).
22

Yes

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

No
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.

ATSDR SORN 09-19-0001. Records of Persons Exp

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.

OMB Control No: 0923-0051 (Expiration Date: 02/28/2021)
Yes

24 Is the PII shared with other organizations?

No
Within HHS

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

Other Federal
Agency/Agencies
State or Local
The data including PII are given to th
Agency/Agencies
Private Sector

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Prior to initializing the ACE investigation the requesting agency
and the ATSDR/CDC ACE lead will sign a Assessment of
Chemical Exposures Technical Agreement which states that
the data belongs to the requesting agency and that ATSDR and
Describe any agreements in place that authorizes the CDC will protect it while it is in their possession but will not
information sharing or disclosure (e.g. Computer
retain it. The data will be given to the requesting health
24b Matching Agreement, Memorandum of
department at the investigation conclusion. and wiped form
Understanding (MOU), or Information Sharing
the CDC devices. Deidentified data may be provided to ATSDR
Agreement (ISA)).
by the requesting agency for analysis and publications. In this
case a data sharing agreement, using the official CDC template
will be executed. ATSDR will not share the data with any other
entities. An internal ATSDR/CDC ACE Data Sharing
Confidentiality Manual details these procedures.
Describe the procedures for accounting for
24c
disclosures

We do not anticipate any disclosures of information by us. As
we are collecting information on behalf of the requesting
health departments and returning it to them, they will be
responsible for accounting for any disclosures.

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.

The participant is given an informed consent to sign before
providing their information. This information collection is
governed by the Privacy Act which prohibits the disclosure of
information from a system of records absent of the written
consent of the subject individual, unless the disclosure is
pursuant to one of twelve statutory exceptions. The Act also
provides individuals with a means by which to seek access to
and amendment of their records and sets forth various agency
record-keeping requirements. Additionally, with people
granted the right to review what was documented with their
name, they are also able to find out if the "records have been
disclosed".and are also given the rights to make correction

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.

Voluntary
Mandatory
The participant can decide not to participate in the
investigation as explained by the informed consent. If we
abstract all the medical records from a participating hospital
we are doing this under the state health department's
authority that does not require informed consent.

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
The requesting health department maintains the data
28 and/or data uses have changed since the notice at
including the PII. They would have to obtain additional
the time of original collection). Alternatively, describe consent if needed.
why they cannot be notified or have their consent
obtained.

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Individuals should contact the requesting health agency who
maintains the PII. If the problem is with the data collection, the
requesting health agency should contact the lead ATSDR
investigator (varies by investigation type) to identify the record
Describe the process in place to resolve an
and specify the information being contested, the corrective
individual's concerns when they believe their PII has action sought, and the reasons for requesting the correction,
29 been inappropriately obtained, used, or disclosed, or along with supporting information to show how the record is
that the PII is inaccurate. If no process exists, explain inaccurate, incomplete, untimely, or irrelevant. If an incident
why not.
has occurred, the PI or data manager will report the potential
incident to the Centers for Disease Control and Prevention
(CDC) Security Incident Response Team and Privacy Officer. The
data manager will serve as the point of contact to resolve
concerns.
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.

ATSDR will only have access to PII for a limited time before it is
transferred to the requesting organization and deleted by
ATSDR. The health department who requested the
investigation will be regulated by their own rules for periodic
reviews of PII.
Users

PII will be entered into Epi Info, the
ATSDR/CDC staff collecting the data

Administrators
31

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

Developers
Contractors
Others

Only ATSDR or CDC staff who have read the internal ATSDR/
Describe the procedures in place to determine which CDC ACE Data Sharing Confidentiality Manual and who are
32 system users (administrators, developers,
either collecting or entering data as part of the Epi Aid are
contractors, etc.) may access PII.
allowed to see the PII.

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 staff collecting data will only have access to the records
they are collecting and not to the entire set of records. Records
will be transferred to the main storage device every night and
it will be stored under lock and key. At the end of the
investigation, before leaving the field, all data will be stripped
from the CDC/ ATSDR devices and will be further reimaged to
make sure the PII is deleted permanently.

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.

ATSDR and CDC staff will all go through annual security
awareness training. Additionally all staff will be required to
read the internal ATSDR/CDC ACE Data Sharing Confidentiality
Manual.

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

There is instructions on data security in the ACE training
manual and trainings. A training is conducted prior to the
investigation's staff entering the field to collect data that
covers data security and privacy .Additionally all staff will be
required to read the internal ATSDR/CDC ACE Data Sharing
Confidentiality Manual.

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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 PII is only kept until the data are entered, staff enter the
data nightly as it is collected so that is is all entered before they
leave the field, generally within 2 weeks. Then the data are
transfered securely to the requesting agency and removed
from the CDC/ATSDR devices permanently. If a data sharing
agreement is signed and ATSDR/CDC obtains deideintified
data for analysis and publications it will follow the
destruction and retention of PII under Records Control
Schedule CDC RG-0442, Scientific and Research Project
Records, Minor Research Records which states that "the
records should be maintained no longer than ten years after
after the completion of the study, 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.
Data will be on entered on laptps or mobile devices and
transferred to a main device at the end of each day of
collection. It will then be put under lock and key. People
entering data are instructed to lock there devices in a secure
place when not in use and make sure their screens are not
visible to others.

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
2

Does the PIA appropriately communicate the purpose of PII in the system and is the purpose
justified by appropriate legal authorities?

Yes
No

Reviewer
Notes

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Reviewer Questions
3

Do system owners demonstrate appropriate understanding of the impact of the PII in the
system and provide sufficient oversight to employees and contractors?

Answer
Yes
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

Reviewer
Notes

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General Comments

OPDIV Senior Official
for Privacy Signature

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2021.02.03
for Privacy
12:25:50 -05'00'

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