0704-0152_pia

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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:

DD 2475 - DoD Educational Loan Repayment Program Annual Application

2. DOD COMPONENT NAME:

Assistant Secretary of Defense - Reserve Affairs

3. PIA APPROVAL DATE:

09/07/21

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.

For the Military Service to pay a portion of a Service Member's student loan(s). The information provided will be reviewed by Military

Service personnel record custodians to verify that eligibility requirements are met. The form will be forwarded to the lender that is identified

for verification of the loan amount and status. The form is returned to the Service finance office to make the annual payment to the lender.

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)

Verification that Service Member eligibility requirements are met

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.

Disclosure of the requested information is voluntary

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.

By signing the form, the Service Member authorizes the release of the financial data by lender/holder to complete entries.

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

PRIVACY ACT STATEMENT

AUTHORITY: 10 U.S.C. 2171, Education Loan Repayment Program: Enlisted Members on Active Duty in Specified Military Specialties;

2173, Education Loan Repayment Program: Commissioned Officers in Specified Health Professions; 16301, Education Loan Repayment

Program: Members of Selected Reserve; 16302, Education Loan Repayment Program: Health Professions Officers Serving in Selected

Reserve with Wartime Critical Medical Skill Shortages; 16303, Loan Repayment Program: Chaplains Serving in the Selected Reserve, and

E.O. 9397, Social Security Number (SSN).

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PRINCIPAL PURPOSE(S): In completing this form, you are requesting your Military Service to pay a portion of your student loan(s). The

information you provide will be reviewed by Military Service personnel record custodians to verify that you meet eligibility requirements.

This form will then be forwarded to the lender that you identify for verification of the loan amount and status. The form is returned to the

Service finance office to make the annual payment to your lender. Collected information is covered by the Applicable Military Service

System of Records Notice (SORN) for the Official Military Personnel File or Military Records Jacket. These links can be found at: http://

dpclo.defense.gov/privacy/SORNs/component/DOD_Component_Notices.html.

ROUTINE USE(S): To the lender (Department of Education, U.S. Public Health Service, or other financial institution) you identify so that

the loan amount and status can be verified. The lender returns the completed form to your unit for additional processing. To the Internal

Revenue Service for the purpose of reporting taxable income, and to the credit reporting agencies to assist in the recovery of any improper

payments made toward delinquent debts owed by a beneficiary or former beneficiary. The DoD Blanket Routine Uses found at http://

privacy.defense.gov/blanket_uses.shtml may apply to this collection.

DISCLOSURE: Voluntary. However, if the requested information is not provided, DoD will not be able to verify the loan amount or status

and make the annual payment you are requesting. Your Social Security Number (SSN) is used to ensure accuracy of data involving the

specified individual applicant. If you do not provide your SSN, processing of your application may be delayed.

OFFICIAL MILITARY PERSONNEL FILES:

Air Force: http://dpclo.defense.gov/privacy/SORNs/component/airforce/F036_AF_PC_C.html

Army: http://dpclo.defense.gov/privacy/SORNs/component/army/A0600-8-104B_AHRC.html

Army National Guard: http://dpclo.defense.gov/privacy/SORNs/component/army/A0600-8-104b_NGB.html

Navy: http://dpclo.defense.gov/privacy/SORNs/component/navy/N01070-3.html

Marine Corps: http://dpclo.defense.gov/privacy/SORNs/component/usmc/M01070-6.html

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.

Services

Other DoD Components

Specify.

Other Federal Agencies

Specify.

DHS, US Coast Guard

State and Local Agencies

Specify.

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.

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

Specify.

Financial Lending Institutions

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

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)

DD Form 2475 - DoD Educational Loan Repayment Program (LRP) Annual Application

k. Does this DoD Information system or electronic collection require a Privacy Act System of Records Notice (SORN)?

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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

F0306 AF PC C; A0600 8 104B AHRC; A

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.

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

(3) Retention Instructions.

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.

AUTHORITY: 10 U.S.C. 2171, Education Loan Repayment Program: Enlisted Members on Active Duty in Specified Military Specialties;

2173, Education Loan Repayment Program: Commissioned Officers in Specified Health Professions; 16301, Education Loan Repayment

Program: Members of Selected Reserve; 16302, Education Loan Repayment Program: Health Professions Officers Serving in Selected

Reserve with Wartime Critical Medical Skill Shortages; 16303, Loan Repayment Program: Chaplains Serving in the Selected Reserve, and

E.O. 9397, Social Security Number (SSN).

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.

OMB No. 0704-0152

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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

Protected Health Information (PHI)

1

Race/Ethnicity

Rank/Grade

Religious Preference

Records

Security Information

Social Security Number (SSN) (Full or in any

form)

Work E-mail Address

If Other, enter the information in the box below

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.

Cindy L. Allard Chief, Defense Privacy, Civil Liberties, and Transparency Division, 25 MAY 18

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

ROUTINE USE(S): To the lender (Department of Education, U.S. Public Health Service, or other financial institution) you identify so that

the loan amount and status can be verified. The lender returns the completed form to your unit for additional processing. To the Internal

Revenue Service for the purpose of reporting taxable income, and to the credit reporting agencies to assist in the recovery of any improper

payments made toward delinquent debts owed by a beneficiary or former beneficiary. The DoD Blanket Routine Uses found at http://

privacy.defense.gov/blanket_uses.shtml may apply to this collection.

(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”.

Providing the SSN on the form is voluntary.

(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

Providing the SSN on the form is voluntary.

b. What is the PII confidentiality impact level

2

?

Low

Moderate

High

1

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

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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.

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

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