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:

National Industrial Security System (NISS)
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

05/27/20

If Other, enter the Component name in the box below.
Defense Counterintelligence and Security Agency (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.

NISS is DCSA's electronic repository of industrial security facility clearance information. NISS data is indexed and retrieved by the name or
Cage code associated with a NISP facility and provides users with a nationwide perspective on NISP facilities as well as facilities under
DCSA oversight in the DoD conventional Arms, Ammunition, and Explosives (AA&E) program. All industrial security personnel use NISS
to track industrial security facility clearances and actions in connection with any NISP or AA&E facility. For Key Management Personnel
(KMP) and for Culpable individuals involved in Security violations, NISS collects first, middle, and last name, SSN, date of birth, place of
birth (city, state, country), citizenship data, and personnel security clearance information.
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)

All industrial security personnel use NISS to track industrial security facility clearances and actions in connection with any NISP or AA&E
facility.
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.

Participation in the NISP is voluntary. During system account creation, users must assert that they have read the Privacy Act Statement in
order to submit their account request. The Privacy Act Statement outlines the Authorities, Purpose, Routine Use(s) and Disclosures for
specific uses of their PII within the system. If a user doesn't consent to the Privacy Act Statement, their account request will not be approved.
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.

During system account creation, users must assert they have read the Privacy Act Statement in order to submit their account request. The
Privacy Act Statement outlines the specific uses for their PII information within the NISS system.
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

Authority: E.O. 12829, National Industrial Security Program (NISP); DoD Manual 5220.22-M, National Industrial Security Program
Operating Manual; DoD Instruction 5220.22, National Industrial Security Program; and E.O. 9397 (SSN), as amended.
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Purpose: The National Industrial Security System (NISS) maintains and processes unclassified company and personal information necessary
to conduct the DCSA security oversight mission. It will provide the United States Government (USG) and Industry stakeholders with a datadriven, collaborative, capability to assess and mitigate the risk of the loss or compromise of classified information. DCSA is responsible for
an industrial base of more than 12,000 cleared facilities, 40,000 classified information systems, and 900,000 cleared industry personnel.
Routine Uses: In addition to those disclosures generally permitted under 5 U.S.C. 552a (b) of the Privacy Act of 1974, as amended, the
records contained herein may specifically be disclosed outside the DoD as a routine use pursuant to 5 U.S.C. 552(b)(1) as follows:
To DCSA personnel for the purpose of being issued an Internal NISS user account, those individuals will have access to Personal
Identification Data information.
To security and contracting personnel for other (non-DoD) Federal agencies, in connection with FCL Verification Requests, Facility
Security Officer (FSO) name and telephone number will be available for any cleared company. Special requests for additional information
may be made, and these requests will be coordinated and adjudicated in accordance with Agency standard procedures.
To security personnel working for cleared companies. Information in NISS regarding a particular cleared company will be available for
review by authorized security personnel working for that company. Authorized personnel working for cleared companies who are verifying
the facility clearances of other companies may obtain core facility information and FSO name and telephone number.
Disclosure: Voluntary; however, failure to provide all the data requested may result in our inability to maintain accurate historic facility
security information, may slow down the performance against classified contracts and provides an area of error in the maintenance of
transparency between Industry and Government stakeholders.
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.

Other DoD Components

Specify.

Other Federal Agencies

Specify.

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.

Authorized DCSA personnel may be issued an internal NISS
user account; those individuals will have access to all
Personal Identification Data (PID) Information. The primary
user is the Industrial Security Program (ISP) for maintaining
information of those facilities participating in the NISP.
Information provided to external users at a given facility
will include KMP List and name/telephone/email of those
persons associated with the facility. For general FCL
information requests for all external users, FSO name and
telephone number will be available for any valid company
searched.
Information provided to external users at a given facility
will include KMP List and name/telephone/email of those
persons associated with the facility. For general FCL
information requests for all external users, FSO name and
telephone number will be available for any valid company
searched.
To any criminal, civil, security, or regulatory authority
(whether Federal, State, territorial, local, or tribal) for the
purpose of providing background search information on
individuals for legally authorized purposes or individuals
seeking employment opportunities requiring background
checks.
The contractors developing this system will not be furnished
with PII. Contractors who will be the users of the system
will be provided notices regarding PII protections applicable
to all users.

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

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Information is provided by security personnel at the facility or located in JPAS/DISS while conducting a search.
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)

Other: In addition to the above, information can be collected via the NISS itself.
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

V10-01 - Submitted to DPCLTD March 11

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.

DAA-0446-2017-0001

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

(3) Retention Instructions.

Delete records/data when no longer needed.
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.

E.O. 12829, National Industrial Security Program (NISP); DoD Manual 5220.22-M, National Industrial Security Program Operating Manual;
DoD Instruction 5220.22, National Industrial Security Program; and E.O. 9397 (SSN), as amended.

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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 Control Number: 0704-0571. Expiration Date: 04/30/2021

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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)

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.

December 17, 2019
Cindy Allard; Chief, Defense Privacy, Civil Liberties, and Transportation Division

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

The Defense Privacy, Civil Liberties and Transparency Division (DPCLTD) has reviewed this request and has accepted your justification to
use the SSN for the purpose of (3) Security Clearance Investigation or Verification, to verify contractors’ eligibility for and ability to
maintain facility security clearances. Also, Acceptable Use (11) Legacy System Interface, was accepted. NISS interfaces with the Defense
Information System for Security (DISS) to create security violation incident reports.
(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”.

DCSA will store all personally identifiable information (PII) electronically which has physical controls. The records are maintained in a
controlled facility in servers located within the DCSA Data Center East. Access to the records is limited to person(s) responsible for
servicing the record in performance of their official duties and who are properly screened and cleared for need-to-know. Physical entry is
restricted by the use of Security Guards, Identification Badges, Key Cards, and Closed Circuit TV, and is only accessible to authorized
personnel. Paper records are contained and stored in regulation safes/filing cabinets which are located in a Sensitive Compartmented
Information Facility (SCIF) with limited access. Access to the NISS is restricted by User Identification, Intrusion Detection System,
Encryption, Firewall, External Certificate Authorities, DoD Public Key Infrastructure Certificates and Common Access Card and PIN. The
DCSA reviewed all of the safeguards established for the system to ensure they are compliant with The Department of Defense (DoD)
requirements and are appropriate to the sensitivity of the information stored within the system, including the use of SSNs. The proposed
specific routine uses have been reviewed to ensure the minimum amount of personally identifiable information shared has been established.
(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

Access to the records is limited to person(s) responsible for servicing the record in performance of their official duties and who are properly
screened and cleared for need-to-know. Physical entry is restricted by the use of Security Guards, Identification Badges, Key Cards, and
Closed Circuit TV, and is only accessible to authorized personnel. Paper records are contained and stored in regulation safes/filing cabinets
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which are located in a Sensitive Compartmented Information Facility (SCIF) with limited access. Access to the NISS is restricted by User
Identification, Intrusion Detection System, Encryption, Firewall, External Certificate Authorities, DoD Public Key Infrastructure
Certificates and Common Access Card and PIN.
2

b. What is the PII confidentiality impact level ?

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.

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

The Primary system consists of servers located within the DCSA Data Center East, which has physical controls (e.g., security cards,
restricted access) and virtual (e.g., encryption, firewalls) access control measures in place and is located at Telegraph Rd. Quantico, VA.
The back-up system consists of servers located within the DCSA Data Center West, which has similar physical and virtual access control
measures in place and is located in Monterey, CA.
(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?

Role Based Access Control. Risk Management Framework (RMF) Security Controls applied at High/High/Moderate categorizations.

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