Privacy Narrative

Date
9/1/2021

Information Collection Request - Privacy Narrative

Annual Submission of the Ingredients Added to, and the Quantity of Nicotine Contained in, Smokeless

Title: ______________________________________________________________________________________
Tobacco Manufactured, Imported, or Packaged in the U.S. 0920-0338
Joann Yoon Kang
Point of Contact: _____________________________________________________________________________

Description
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. This ICR has an existing PIA that is unchanged.
2. CDC/OSH receives ingredient and nicotine analysis data from tobacco companies. Respondents
are smokeless tobacco 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, the ICR
involves the disclosure of tobacco ingredients used in commercial products, the IC is considered
proprietary with appropiate protections affored to trade secrets. This information collected through
ingredient and nicotine analysis reports is entered into the Tobacco Ingredient and Nicotine Reporting
System (TINRS), a database solely housed using a secure, standalone computer. TINRS has a
removable harddrive, which is stored along with hardcopies of reports 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 (safe) is running out of space, as
long as the FRC keeps the records under lock and key and in confidential storage.
4. 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. All information is filed and retrieved by name of the smokeless tobacco
manufacturer or the attorney representing the manufacturer, therefore, the information does not fall
under the purview of the Privacy Act.

Does this ICR request any PII?

Yes

✔ No

If yes, describe: _____________________________________

Does this ICR include a form that requires a Privacy Act Statement?
Does this ICR require a PIA?

Yes

No

Yes

✔

No

If yes, does a signed PIA already exist?

C/I/O Approval
Associate Director for Science

Comments:

Information Systems Security Officer

✔

Yes

No