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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-36958

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-6816363-513315

2a Name:

8/21/2018 8:52:42 AM

National Youth Tobacco Survey (NYTS)
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.

Development
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

ISSO

POC Name

Cindy Allen

POC Organization NCCDPHP
POC Email

[email protected]

POC Phone

770-488-5388
New
Existing
Yes
No
December 31, 2018
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

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

The National Youth Tobacco Survey (NYTS) system is an
electronic survey system that collects and stores anonymous
The system collects and maintains rudimentary responses of
survey questionnaires from approximately 20,000 anonymous
middle school and high school students annually. The survey is
voluntary and students are asked about their behaviors,
National Youth Tobacco Survey system is a survey data
collection that utilizes mobile Android application tablet
devices and a web-based as a front-end client. Survey
Yes
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
User ID
Password

Employees
Public Citizens
16

Indicate the categories of individuals about whom PII
is collected, maintained or shared.

Business Partners/Contacts (Federal, state, local agencies)
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
The emails will be used to establish an access account in order
to allow them to securely accessing the system for
administration, development, and maintenance purposes.
PII is used for communication purposes.

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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
and disclosure specific to the system and program.
Investigation" (42 U.S.C. 241).

22

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

Yes
No
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?
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?

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.

N/A
Yes
No
Users are made aware of their PII being collected at the time
they are identified as needing access to use the system. PII is
collected from the system administrators only, not for the
study.
Voluntary
Mandatory
No option for administrators to opt-out of having their user
credentials and emails used because it is required for their role.
This information is necessary to establish an account in
supporting the study and accessing the system.

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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.
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.
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.

PII identified is an authentication credential for system
administrator. There is no process in place to notify and obtain
consent from the individuals when there are major changes
occur to the system because those changes would require
themselves as an administrator, to perform or take action.
System administrators may send an email to their supervisor if
issues arise. PII is not collected from the study participants so
no process is necessary.
PII identified is an authentication credential for system
administrator. There is no process in place to periodically
reviews of PII.
Users
Administrators

31

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

System administrator have access to
the structures and hardware
supporting the information system.

Developers
Contractors
Others

Describe the procedures in place to determine which Administrator is granted access based on their roles as
32 system users (administrators, developers,
authorized by the project manager and the information system
contractors, etc.) may access PII.
manager. Granulated rights at both application and server

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.

Role based access controls are in place to ensure the concept
of "least privilege" is implemented. Based on the technical
director and project director’s assessment of each team
member, the network administrator creates and implements
network access groups. The access groups include system
administrator, data analyst, database administrator, and web
developer working on data validation, processing, etc . Each
individual assigned to work on the project is assigned to a
group associated with their role. Access rights are then
derived from that role. The project network directory structure
is organized such that access to each sub folder is restricted to
one or more network access groups, effectively ensuring that
an individual’s access to data containing PII is restricted only to
network areas pertaining to tasks the individual is required to
perform.

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.

CDC contractors are required to complete the Information
Security Awareness Training (SAT) annually which covers all
aspects of systems and data security and confidentiality.
Systems and network staff with higher roles and
responsibilities are require to complete additional training on
contingency plan and disaster recovery training on an annual
basis.

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

Systems and network infrastructure staff receive specific
security training based on the technology they support on an
ongoing basis and receive additional security training as
necessary to meet contract 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
User accounts and associated PII are removed when no longer
needed for access. The PII and user accounts are temporary
administrative records and not subject to long term records
retention.
CDC Records Control Schedule GRS-24-13a PKI Administrative
Records.
User accounts are reviewed annually.
PII identified is an authentication credential for system
administrator.

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

Administrative Controls: include a security plan, file back-up,
least privilege, and training.
Technical Controls: Only the system administrator will have
access to the authentication credential. The users' credential
will be encrypted at the database level.
Physical Controls: include ID Badges, Key Cards, and Closed
Circuit TV (CCTV) for servers.

General Comments

OPDIV Senior Official
for Privacy Signature

signed by Jarell
Jarell Oshodi Digitally
Oshodi -S
Date: 2018.12.31 15:15:35
-S
-05'00'

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