Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-98925

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-7570310-093772

2a Name:

5/8/2020 7:27:47 AM

CureTB (CureTB)
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)?

8b Planned Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Business Steward

POC Name

Jennifer Buigut

POC Organization CDC/OID/NCEZID/DGMQ
POC Email

[email protected]

POC Phone

770.488.4552
New
Existing
Yes
No
July 8, 2020
Not Applicable

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11 Describe the purpose of the system.
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
about the specific data elements.)
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?

15

The goal of the CureTB program is to ensure treatment
completion, decrease of Tuberculosis (TB) transmission, and
Patient's name, address, phone/email, medical history, medical
labs, medical reports, diagnoses, treatment are collected.
Internal users will use PIV and Active directory ( which has it's
CureTB provides referrals and continuity of care services for TB
patients and their families when traveling between the United
States and other parts of the world. The program serves as an
Yes
No

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

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)

<100
For patient identification and to determine necessary
treatment and to follow-up with patient to ensure treatment is
completed
N/A

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20 Describe the function of the SSN.

N/A

20a Cite the legal authority to use the SSN.

N/A

21

Identify legal authorities governing information use Public Health Service Act, Section 301, "Research and
Investigation," (42 U.S.C. 241); Section 311, "General grant of
and disclosure specific to the system and program.
authority for cooperation"(42 U.S.C. 243)

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.

09-20-0171: Quarantine- and Traveler-Related
Activities, Including Records for Contact
TracingInvestigation and Notification under 42

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.

24 Is the PII shared with other organizations?

N/A
Yes
No

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Within HHS
Other Federal
Agency/Agencies
24a

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

To accurately identify patient
State or Local
Agency/Agencies
To accurately identify patient
Private Sector

Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
The CureTB program has an MOU with the partners that
24b Matching Agreement, Memorandum of
provide input in the system.
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?

N/A
CDC does not collect the original data. PII and other personal
information are collected by CDC partners and then CDC
reaches out to the individuals to collect additional information.
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
Individuals may decline to provide the requested PII's
object to the information collection, provide a
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
The consent for original uses is obtained during the initial PII
28 and/or data uses have changed since the notice at
the time of original collection). Alternatively, describe collection by the CDC partners.
why they cannot be notified or have their consent
obtained.
This is handled by CDC external partners.
If there is a PII incident where an individual believes their data
has been compromised or is inaccurate, they would contact
the external partner. In the case of a discrepancy, the
submitter must provide identification and be able to
Describe the process in place to resolve an
individual's concerns when they believe their PII has reasonably identify the record and specify the information
29 been inappropriately obtained, used, or disclosed, or being contested, the reasons for requesting the correction, and
that the PII is inaccurate. If no process exists, explain the corrective action sought along with supporting
information to show how the record is inaccurate, incomplete,
why not.
untimely, or irrelevant. The CDC Official will work with the CDC
testing laboratory to investigate and resolve the data security
issue or discrepancy. CDC would facilitate the resolution based
on the individual’s request and report back to the individual
agency following a successful resolution so they may report
back to the submitter.

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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.

The program will put processes in place for program period
reviews of PII contained in the system to ensure the data's
completeness, integrity, availability, accuracy and relevancy.
Users

Administrators

31

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

Developers

Contractors

To perform their daily duties and
responsibilities; such as conducting
interviews accessing records to
determine what information is missing
To perform their daily duties and
responsibilities; such as conducting
interviews accessing records to
determine what information is missing
Will have access to the system in order
to develop and enhance the system
that will allow the users to adequately
perform their duties. Developers may
The CureTB group includes some
Direct Contractors that will be users of
the CureTB system. They will be
accessing the system to perform their

Others
Describe the procedures in place to determine which The Role-based access (RBAC) will be used in the CureTB
32 system users (administrators, developers,
system. User identification process is through CDC Secure
contractors, etc.) may access PII.
Access Management Services (SAMS). After a user is approved

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. CureTB 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 will only access their data based on their
role.

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 is provided.

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

CDC Role-based training. All system users will be 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?

Yes
No

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Records will be retained and disposed of in accordance with
the CDC Records Control Schedule. Records are retained for 20
years; for longer periods if further study is needed.
CureTB system adheres to the CDC’s Scientific and Research
Project Records Control Schedule.

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

Routine reports are maintained for five years (GRS 5.2 item 20).
Other input/output records are disposed of when no longer
needed (GRS 5.2 item 20). Record copy of study reports are
maintained in agency for ten 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.
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. External users will only be able to
access the system via the Secured Access Management System
(SAMS) where they go through a level III authentication. The
system will be 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 security guards.

General Comments

OPDIV Senior Official
for Privacy Signature

signed by Jarell
Jarell Oshodi Digitally
Oshodi -S
Date: 2020.05.20 10:41:50
-S
-04'00'

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