Privacy Impact Assessment (PIA)

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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-21838

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-9346231-979130

2a Name:

1/22/2019 10:06:52 AM

Communities Organized for the Prevention of Arboviruses
(COPA)
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

Health Scientist

POC Name

Stephen H (Steve) Waterman

POC Organization NCEZID/DB
POC Email

[email protected]

POC Phone

787.706.2465
New
Existing
Yes
No
April 11, 2019
Not Applicable

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11 Describe the purpose of the system.

The National Center for Emerging and Zoonotic Infectious
Diseases (NCEZID)-Division of Vector Borne Diseases (DVBD) Dengue Branch (DB) is developing the Communities Organized
for the Prevention of Arboviruses (COPA) system to collect,
manage and analyze data related to the knowledge, attitudes
and practices of communities potentially hosting viral diseases
transmitted to humans by infected mosquitoes i.e., Dengue,
West Nile, chikungunya, Yellow Fever, and Zika and assist in
the arboviral prevention and control.
The objective of COPA is to collect data on what actions an
individual will take once bitten by mosquitoes or demonstrate
ability to recognize and eliminate breeding containers and
educating residents about dengue mosquito and arboviral
prevention and control by community residents.
COPA data are entomological surveys conducted to measure
response and action in population areas where mosquitoes
could potentially transmit viral disease infections to humans
i.e., Dengue, West Nile, Chikungunya, Yellow Fever, and Zika.

Data will be collected from randomly selected households with
individuals supplying information related to their mosquito
bite prevention behaviors, whether or not they know about
Describe the type of information the system will
dengue, how it is spread, and if they can identify breeding
collect, maintain (store), or share. (Subsequent
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questions will identify if this information is PII and ask sites. The system will collect Name, Date of Birth (DOB), Phone
Numbers, E-mail/Physical Address, Global Positioning System
about the specific data elements.)
(GPS) coordinates, and Dwelling type.
The CDC Tablet-based EpiInfo survey tool requires users to
authenticate using CDC/HHS credentials (Smart Card and
userID and Password) to collect community data and to upload
into the COPA servers. The user authentication process
requires temporary storage based on technology for survey
members.

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COPA is a Tablet-based EpiInfo survey tool, a statistical
software for epidemiology developed by the CDC. The
objective of COPA is to collect data on what actions an
individual will take once bitten by mosquitoes or demonstrate
ability to recognize and eliminate breeding containers and
educating residents about dengue mosquito and arboviral
prevention and control by community residents.
Data will be analyzed by Dengue Branch epidemiologists and
study personnel. CDC Dengue Branch will be the steward/
owner of the data processed by this system. The data will be
used by epidemiologists and study personnel to understand
mosquito prevention behaviors in the community study and
evaluate future interventions for the prevention of arboviral
diseases.
Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

Data will be collected from randomly selected households with
individuals supplying information related to their mosquito
bite prevention, whether or not they know about dengue, how
it is spread, and if they can identify breeding sites. COPA
Survey Teams will collect demographic information while
demonstrating/showing resident(s) the potential for and/or
existence of mosquito breeding environment where life
threatening infectious diseases (Dengue/Zika/West Nile) could
multiply beyond isolated location. The system will collect
from residents the Name, DOB, Phone Numbers, E-mail/
Physical Address, GPS coordination, and Dwelling type.
The CDC Tablet-based EpiInfo survey tool requires users to
authenticate using CDC/HHS credentials (Smart Card and
userID and Password) to collect community data and to upload
into the COPA servers. The user authentication process
requires temporary storage based on technology for survey
members.
Many COPA support elements are Direct Contractors and have
access to system through use CDC/HHS credentials.

14 Does the system collect, maintain, use or share PII?

Yes
No

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15

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
GPS coordinates
Dwelling type
HHS User Credential Information

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?

100-499
General Public: PII collected from the public is used for analysis
purposes related to mosquito mitigation behavior.
The HHS user credentials are used to identify the CDC
employee conducting the collection of data.

19

Describe the secondary uses for which the PII will be
used (e.g. testing, training or research)

None

20 Describe the function of the SSN.

Not Applicable

20a Cite the legal authority to use the SSN.

Not Applicable

21

Identify legal authorities governing information use Public Health Service Act, Section 301, ‘‘Research and
Investigation,’’ (42 U.S.C. 241); and Sections 304, 306 and
and disclosure specific to the system and program.
308(d)

22

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

Yes
No

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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?

In Progress.
Yes
No
CDC requires non-governmental participants in the COPA
survey to give consent with the research or public health event
by capturing a certified electronic signature from each
participant in the research protocol or study beforehand.
Individuals participating in COPA survey grant their consent
through the COPA Consent Form.
Voluntary
Mandatory

Individuals may choose not to participate by refusing to sign
Describe the method for individuals to opt-out of the the consent form.
collection or use of their PII. If there is no option to
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Collection of employees Non-Sensitive Internal CDC Business
object to the information collection, provide a
Contact Information related contact information is for user
reason.
identification with assigned responsibility in order to perform
specific functions of their employment.
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 information is collected using the Consent Forms. Any
28 and/or data uses have changed since the notice at
major changes would be explained in those forms thereby
the time of original collection). Alternatively, describe giving the appropriate notice.
why they cannot be notified or have their consent
obtained.

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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.

The CDC’s DVBD COPA surveys provide individuals with a
Consent Form based on purpose of collected information.
Consent Form lists Points of Contact for responding to an
individual’s concerns including any questions related to the
accuracy of information collected. CDC will review concerns
and respond to resolve inquiry of the individual.
COPA Business and Technical Stewards conduct at a minimum
annual reviews and periodic (monthly/quarterly) of all data,
including PII contained in the system to ensure the data's
integrity, availability, accuracy and relevancy are maintained.
The system administrator performs database monitoring and
maintenance when new data is entered into the system or
changes are requested by the users.
Security controls are reviewed during the annual security selfassessments and recertification process.
Users

Identify who will have access to the PII in the system
31
and the reason why they require access.

Administrators

Users (Investigators) collecting the PII
and those performing analysis on the
data where potential outbreak of
Arboviruses.
Oversee users and evaluate findings.

Developers
Contractors
Others

Describe the procedures in place to determine which System Administrators in coordination with Business Steward
32 system users (administrators, developers,
will assign designated collection survey teams for read/write to
contractors, etc.) may access PII.
data fields and Subject Matter Experts for role based
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.

Least privilege, Role Based Access methods are used to allow
those with access to PII to only access the minimum amount of
information necessary to perform their job. The system
administrator is responsible for setting up the user access to
the system based on the CDC user ID and the permissions
assigned to it.

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.

All CDC personnel are required to complete annual Security
and Privacy Awareness Training.

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

Users with significant security and privacy responsibilities are
provided additional CDC and system specific Role-Based
training.

Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?

Yes
No

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

The records are maintained in accordance with General
Records Schedule (GRS) and comply with CDC Records Control
Schedule (RCS). Final reports are created to document
programmatic decisions, policies, and other related issues and
are maintained permanently (CDC RCS, B-321, 4-1). Input data
of Non-electronic records manually data entered are
maintained and disposed of when no longer needed. Other
input/output records are disposed of when no longer needed:
GRS 20.6 and CDC RCS, B-321, 4-1. 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.
Administrative controls: Completion of training requirements;
risk analyses performed annually; branch management
reviewing access requests and granting minimal amount of
access.

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

Technical controls: Users are authenticated and data secured
using operating system and server security, administered by
the local system administrator. PII data is encrypted at rest and
in transits with access restricted to specific authorized users as
required by HHS and CDC policy.
Physical controls: Facility access controls; server protected in a
guarded building.

General Comments

OPDIV Senior Official
for Privacy Signature

signed by Jarell
Jarell Oshodi Digitally
Oshodi -S
Date: 2019.05.14 16:17:19
-S
-04'00'

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