Privacy Narrative

Privacy Narrative
Annual Submission of the Ingredients Added to, and the Quantity of Nicotine Contained in, Smokeless Tobacco Manufactured, Imported, or Packaged in the U.S. 0920-0338

Title: _______________________________________________________________________________________

Joann Yoon Kang
Point of Contact: _____________________________________________________________________________
1. This ICR data collection does not involve collecting information in identifiable form. Respondents
are business entities, not individuals. Each respondent entity is represented by a contact person;
however, no personal information is being collected.
2. CDC/OSH receives ingredient information from tobacco companies. Respondents are smokeless
tobacco and nicotine product manufacturers, packagers, and importers. Except for the identification
of a contact person for each respondent, data collection associated with this clearance does not collect
any personally identifiable information or personally sensitive information.
However, because the information collection involves the disclosure of tobacco ingredients and
nicotine data used in commercial products, the information collection is considered proprietary with
appropriate protections afforded to trade secrets. This information collected through ingredient
reports is entered into Tobacco Ingredient and Nicotine Reporting System (TINRS), a secure,
standalone computer. TINRS has a removable harddrive, which is stored along with hardcopies that
are maintained in a locked safe with only 2 FTEs and 2 contractors having access to the information.
3. The information received will be retained for 75 years, but can be moved to the FRC (Federal
Records Center) after 20 years or earlier if the data storage room (safes) is running out of space, as
long as the FRC keeps the records under lock and key and in confidential storage.
4. Annually, OSH sends a certificate of compliance letter to each entity that has submitted the
required information. The letter includes a reminder of responsibilities related to future reporting. If a
submission contains incomplete entries or possible errors, CDC will follow up by sending a request
for additional information.
5. The confidential information is and has been maintained in its current state as mandated by the
Comprehensive Smoking Education Act of 1984 (15 U.S.C. '1331; Public Law 98-474) and Statutory
Provisions on Confidentiality (18 U.S.C. ' 1905, 5 U.S.C. ' 552). Additional information about this
requirement, and penalties for disclosure, can be found in Attachment 7 of the ICR Supporting
Statement A.
This ICR has been reviewed by staff in CDC's NCCDPHP, who determined that the Privacy Act is not
applicable. Respondents are business entities, not individuals. Each respondent entity is represented
by a contact person; however, no personal information is being collected. All information is filed and
retrieved by name of the smokeless tobacco and nicotine product manufacturer or the attorney
representing the manufacturer, therefore, the information does not fall under the purview of the
Privacy Act.
C/I/O Approvals:
Information Systems Security Officer

Cynthia
Allen -S

Digitally signed by
Cynthia Allen -S
Date: 2018.12.21
10:26:34 -05'00'

Associate Director for Science

Digitally signed by

Rachel
Rachel Kaufmann -S
2018.12.21
Kaufmann -S Date:
09:55:11 -05'00'