Att 11 PIA

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

0920-1182

Question

2/19/2021

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

0920-1182

2a Name:

Form Date

Formative Research to Develop HIV Social Marketing Campaign
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.

Initiation
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

Team Lead

POC Name

Euna M. August

POC Organization Centers for Disease Control and P
POC Email

[email protected]

POC Phone

(404) 639-8297
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

Not applicable

10

Describe in further detail any changes to the system
that have occurred since the last PIA.

Not applicable

11 Describe the purpose of the system.

The purpose of this information collection request is to
conduct formative research with healthcare providers in
support of “Let’s Stop HIV Together”, an HIV preventionfocused social marketing campaign funded by CDC. The
formative research will involve conducting semi-structured, indepth interviews (in-person or via video conference or
telephone) with healthcare providers who will also be asked to
complete a brief, web-based companion survey. The
information collected through the system will be used by CDC
to inform the development and/or revision of campaignrelated messages, concepts, and materials about HIV
prevention, testing, and care for healthcare providers.

CDC's contractor and/or a third-party vendor will recruit
participants for the interviews. Contractors are indirect. The
third-party vendor's systems will collect and store responses to
web-based survey questions. Responses will include
sociodemographic characteristics (e.g., race/ethnicity, gender,
age, etc.), clinical practice characteristics (e.g., practice type,
provider type, area of expertise, years in practice, patient
characteristics, etc.), information needs, use of electronic
Describe the type of information the system will
media, patient-provider communication, and HIV screening
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask practices.
about the specific data elements.)
In addition, the recruiters will collect personally-identifiable
information (PII) during the recruitment process, including
participants names, email and physical addresses, phone
numbers, and email addresses. Depending on the recruitment
needs for the round of data collection, services of a subcontractor (i.e., third party vendor) will be acquired to facilitate
identification of participants who meet our selection/inclusion
criteria. This may vary.

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The overall purpose of this data collection is to gather input
from healthcare providers on HIV-related topics to help inform
the development of the Let's Stop HIV Together
communication campaign. The primary data collection mode is
individual interviews which will be supplemented with
quantitative data gathered through a brief companion webbased survey. During recruitment, PII will be collected so that
recruiters can remind participants of upcoming interview
appointments. All PII will be kept in locked file cabinets or
secure online servers and will be destroyed after the interviews
are completed. No PII will be sent to CDC. Further, PII will not
be linked to survey or interview responses.
Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

For the companion survey, the survey vendor will email
participants a link to the voluntary, self-administered survey.
The surveys use Transport Layer Security (TLS version 1.2)
encryption for all transmitted data. Data at rest are also
encrypted, and data are isolated from other user's data. The
data are encrypted end-to-end and only the contractor can
decrypt the data. The information that will be collected,
maintained, and shared by the survey system is described in
#12. The survey does not involve collection of PII. The . PII will
only be collected by the contractor/sub-contractor for the
purpose of recruitment. These data will be stored and
encrypted and will only be used for the recruitment process.
Authentication is via username and password; PII will be
destroyed after the data collection process and will not be
transferred to CDC.
Yes

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

Indicate the type of PII that the system will collect or
15
maintain.

No
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...

Other...

Other...

Other...

Other...

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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)

500-4,999
To contact and remind participants of upcoming interview
appointments.
None

20 Describe the function of the SSN.

NA

20a Cite the legal authority to use the SSN.

NA

21

Identify legal authorities governing information use
NA
and disclosure specific to the system and program.

22

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

Yes
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.

Published:
Published:
In Progress

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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#: 0920-1182 Expired: May 31, 2020
This information collection is under review for reinstatement.
Once approved by the OMB, another expiration date will be
assigned three years from the approval date. OMB number will
not change.
Yes

24 Is the PII shared with other organizations?

No
Within HHS

24a

Other Federal
Agency/Agencies
State or Local
Agency/Agencies

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

Private Sector
Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
24b Matching Agreement, Memorandum of
none
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?

none
The recruiters are responsible for notifying individuals that
their PII will be collected and why it is necessary to do so.
Voluntary
Mandatory

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Describe the method for individuals to opt-out of the Participation is voluntary. Participants who opt out of
collection or use of their PII. If there is no option to
collection or use of PII, however, will be ineligible to
27
object to the information collection, provide a
participate.
reason.
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
NA - (a) No changes will be made to the system and (2) PII is
28 and/or data uses have changed since the notice at
the time of original collection). Alternatively, describe destroyed upon completion of interviews.
why they cannot be notified or have their consent
obtained.
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.

We do not anticipate that this will be an issue due to the nature
of the data collection. However, the consent form tells
individuals that they can contact the contractor's project
director and/or office of research protection (ORP) if they have
concerns. Contact information for these entities are provided
along with the contractor's hours of operation.

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.

No periodic reviews are planned.
Users
Administrators

31

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

Developers
Contractors

Contractors will have access to PII only
for the purpose of reminding

Others
Describe the procedures in place to determine which
32 system users (administrators, developers,
Only the contractor and/or the third party can access PII.
contractors, etc.) may access 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.

Only authorized users (i.e., recruitment staff) will have access to
PII. PII will be destroyed upon completion of the interviews.

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.

No more than 2 contractor staff will have access to data files
containing PII. These staff have received training from the
Collaborative Institutional Training Initiative (CITI) Program on
human subjects, including data privacy and research ethics.
Contractor staff are also required to complete an IT security
awareness training. Third-party vendor staff involved with the
study will be required to sign a privacy agreement prior to
recruitment. CDC staff will complete all required trainings on
human subjects and data privacy, including the Security and
Awareness Training.

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

NA

Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?

Yes
No

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Describe the process and guidelines in place with
37 regard to the retention and destruction of PII. Cite
specific records retention schedules.

The contractor and third-party vendor will destroy PII upon
interview completion. Online files will be deleted, and paper
records will be stored securely in a locked receptacle until
shredded. We will adhere to the records control schedules, as
defined within the CDC/ATSDR Records Control Schedule.
Administrative controls: All recruitment staff will be trained
prior to recruitment, which will entail procedures for collecting,
storing, and eventual destruction of PII. Additionally, thirdparty recruiters will be required to sign a confidentiality
agreement before they are permitted to work on the study.

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

Technical controls: Access to PII will be limited to recruitment
staff. PII will be locked in a file cabinet or stored on online
servers accessible only to staff who are approved to access the
information by the contractor’s project director. Survey data,
which does not include PII, will initially be stored by the survey
vendor. The data will be encrypted at rest and in transit, from
the participant to the survey vendor and from the survey
vendor to the contractor. Data are encrypted end-to-end and
only the contractor will have access to the data using a master
key. When data are transported to the contractor over TLS,
they are then saved to a network share drive behind a firewall
which only authorized users have access to.
Physical controls: Computers are password-protected, and
access to online servers is granted to staff permitted to work
on the project by the project director. Access to facilities is
restricted to contractor employees.

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

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

Yes

No

Reviewer
Notes
3

No

Reviewer
Notes
4

Does the PIA appropriately describe the PII quality and integrity of the data?

Yes
No

Reviewer
Notes

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Reviewer Questions
5

Is this a candidate for PII minimization?

Answer
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

General Comments

OPDIV Senior Official
for Privacy Signature

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2021.05.04
for Privacy
12:53:54 -04'00'

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