PIA Form

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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-32344

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-9190507-619324

2a Name:

12/20/2017 1:46:18 PM

Electronic Disease Notification (EDN)
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 Steward

POC Name

Todd Mercer

POC Organization CDC/OID/NCEZID/DGMQ
POC Email

[email protected]

POC Phone

404-639-4489
New
Existing
Yes
No

Apr 3, 2019

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Under the authority of the Immigration and Nationality Act
(INA), CDC has the regulatory responsibility to ensure that state
or local health officials at the U.S. resettlement destination of
each refugee are notified promptly of the refugee arrivals and
provided all applicable medical records. Each refugee or
immigrant who enters the United States must undergo a
medical examination in their country of origin. These legally
required medical examinations identify persons with
inadmissible conditions of public health significance before
they enter the United States.
11 Describe the purpose of the system.

The EDN system is a centralized electronic reporting system
that collects health information on all newly arriving refugees
and newly arriving immigrants with medical condition of
public health significance. Information in the EDN system is
used to notify state health departments in all 50 states and the
District of Columbia (DC) about these arrivals. The objectives of
EDN are to 1) provide timely and accurate medical notifications
to U.S. health departments of all newly arriving refugees and
immigrants with health conditions that might require followup; 2) monitor diseases of public health significance, such as
tuberculosis; and 3) provide data for evidence-based
recommendations to the U.S. and international public health
communities, as well as to federal partners.
The EDN system collects information about immigrants and
refugees including surname, given name, birth date, birth
place (city/country), sex, passport number, case or alien
number, present address of residence (city, postal code,
country), intended US address (city, state, postal code), medical
notes, email, weight, and hight. The panel physician
performing exam is also collected. Some of the information is
provided on paper forms and is manually entered into the EDN
system, and some is electronically transmitted into EDN.

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
The EDN system uses the CDC Smart cards and Active Directory
about the specific data elements.)
(AD) for internal user authentication and Secure Access
Management Services (SAMS) for external user authentication.
Both CDC AD and SAMS are separate systems with their own
PIA documents. User passwords are stored and maintained in
the CDC AD and SAMS systems, but not in the EDN system.
However, user IDs are stored in the EDN system permanently.
Active Directory is a separate system with its own PIA. SAMS is
a separate system with its own PIA.

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The EDN system networks CDC researchers, quarantine
stations, and state health departments that perform
surveillance for immigrants requiring medical treatment
follow-up upon entering the United States. The EDN
application provides federal and state public health officials
with data to evaluate the effectiveness of follow-up on
Tuberculosis (TB) cases, as well as the ability to record the
results of domestic follow up examination.

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

Following information about immigrants and refugees,
including their PII information, is collected in EDN system:
surname, given name, birth date, birth place (city/country), sex,
passport number, case or alien number, present address of
residence (city, postal code, country), intended US address
(city, state, postal code), medical notes, email, weight, and
hight. In addition, the panel physician performing exam is also
collected. The above information is collected under the
requirement of the authority of the Immigration and
Nationality Act to notify US health partners of US arrivals of all
refugees and immigrants with notifiable health conditions as
well as the overseas medical information.
EDN data is shared with State and Local Health Departments
for federally mandated follow-up persons’ arrival in their
jurisdiction.
The EDN system uses the CDC Smart cards and Active Directory
(AD) for internal user authentication and Secure Access
Management Services (SAMS) for external user authentication.
Both CDC AD and SAMS are separate systems with their own
PIA documents. User passwords are stored and maintained in
the CDC AD and SAMS systems, but not in the EDN system.
However, user IDs are stored in the EDN system permanently.
Active Directory is a separate system with its own PIA. SAMS is
a separate system with its own PIA.

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

Yes
No

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15

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
Birth country
Alien Number
Sex
Birth City
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 Aliens

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)

100,000-999,999
The primary purpose is for state and local health departments
to be able to follow up on migrants with medical conditions
that arrive to their jurisdiction.
N/A

20 Describe the function of the SSN.

N/A

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); sections 304, 306 and 308(d)
21
which discuss authority to grant assurances of confidentiality
and disclosure specific to the system and program.
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

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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.

09-20-0136 : Epidemiologic Studies and
Surveillance of Disease Problems. HHS/CDC.

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.

1405-0113 Expiration: 10/31/2020
Yes

24 Is the PII shared with other organizations?

No
Within HHS

24a

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

Other Federal
Agency/Agencies
State or Local
Agency/Agencies
State and Local Health Departments for fed
Private Sector

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Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
24b Matching Agreement, Memorandum of
N/A
Understanding (MOU), or Information Sharing
Agreement (ISA)).
24c

Describe the procedures for accounting for
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.

26

Is the submission of PII by individuals voluntary or
mandatory?

The EDN Helpdesk tracks for accounting for disclosures in an
Access database. There is also an organized email folder
system for requests that come in through the email box.
CDC does not collect the original data. PII and other personal
information are collected by the forms of the U.S. Department
of State in immigrant or refugee medical exams. Privacy Act
Notice on the form states how the information is going to be
used. Immigrants or refugees may decline to provide the PII
requested by the U.S. Department of State. In that event the
U.S. Department of State may delay or prevent the processing
of their case.
Voluntary
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.

Immigrants or refugees may decline to provide the PII
requested by the U.S. Department of State. In that event the
U.S. Department of State may delay or prevent the processing
of their case.

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.

The consent for original uses is obtained during the initial PII
collection. Repeated notification for changes would be
infeasible given the size of the dataset and the potential for
individuals moving from their location. The uses for the PII are
tied to regulatory activity around health related inadmissibility
or response to communicable disease and domestic
evaluation.

Describe the process in place to resolve an
individual's concerns when they believe their PII has Immigrants or refugees may notify CDC via point of contact or
29 been inappropriately obtained, used, or disclosed, or state/local health department if their PII is incorrect or
that the PII is inaccurate. If no process exists, explain inappropriately used.
why not.

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 are processes in place for program period reviews of PII
contained in the system to ensure the data's completeness,
integrity, availability, accuracy and relevancy. Refugee records
are reconciled monthly with records received from the
International Organization for Migration (IOM) via the
electronic interface. Records are reconciled routinely with
federal partners such as the Department of State (Consular
Affairs and the Bureau of Population, Refugees, and Migration)
to ensure completeness and data integrity. Sample records
from the daily notification of arrivals report received from
Customs and Border Protections (CBP) are cross referenced
with records that are in EDN.

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31

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

Users

Users require access to medical data
for manual data entry.

Administrators

Administrators require access to PII for
helpdesk support and user
management.

Developers

Developers require access to PII to
troubleshoot data issues and reset
entry records when required.

Contractors
Refuge and Tuberculosis (TB)
coordinators at US health department
require access to PII to ensure proper
medical follow up is performed and
Describe the procedures in place to determine which The Role-based access (RBAC) is used in EDN system. User
32 system users (administrators, developers,
identification process is through CDC Secure Access
contractors, etc.) may access PII.
Management Services (SAMS). After a user is approved to
Others

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 privileged model is utilized to allow those with access
to PII to only access the minimum amount of
information necessary to perform their job. EDN predefined
user groups and roles limit those with access to PII to only the
minimum amount of information necessary to perform their
job. Non-CDC users can only access their own jurisdiction data
based on their role and jurisdiction defined.

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.

Annual security and privacy awareness training.

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

All CDC personnel are required to acknowledge a Rules of
Behavior attesting to their understanding of the privacy
requirements.

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
Records are retained and disposed of in accordance with the
CDC Records Control Schedule. 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.
EDN system adheres to the CDC Records and Retention
schedule GRS 20.2 and 20.6

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Administrative Controls include Federal, HHS, and CDC specific
Privacy, Risk Assessment, and Incident Management Policies,
annual system privacy impact assessments; and mandatory
annual security & privacy awareness training.

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

Technical Controls include the Data Entry module can only be
accessed by CDC registered users that have CDC network
access using a smartcard. Health department users also need
to be registered EDN users and can only access the system via
the Secured Access Management System (SAMS) where they
go through a level III authentication. The system is backed up
on a nightly basis with copies of the files stored off site in a
secure fireproof safe. All users must be registered to have
access.
Physical Controls include access to the CDC Clifton Road
facility where the mainframe computer is located is controlled
by a cardkey system. The hard copy records are kept in locked
cabinets in locked rooms. Access to the data entry center is
only available to smartcard holders inside CDC facilities where
there is also physical CDC security.

General Comments

OPDIV Senior Official
for Privacy Signature

signed by Jarell
Jarell Oshodi Digitally
Oshodi -S
Date: 2019.04.03 16:18:06
-S
-04'00'

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