PIA Form

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

TBD

2a Name:

07/28/20

Awardee Lead Profile Assessment
General Support System (GSS)
Major Application

3

The subject of this PIA is which of the following?

Minor Application (stand-alone)
Minor Application (child)
Electronic Information Collection
Unknown

3a

Identify the Enterprise Performance Lifecycle Phase
of the system.

Operations and Maintenance
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)?

No
Yes
No
Agency
Contractor
POC Title

Lead Health Scientist

POC Name

Perri Ruckart

POC Organization NCEH
POC Email

[email protected]

POC Phone

700-488-3808
New
Existing
Yes
No

8b Planned Date of Security Authorization
Not Applicable

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8c

Briefly explain why security authorization is not
required

Several authorized CDC systems will be used to collect and
maintain the data from this study.

10

Describe in further detail any changes to the system
that have occurred since the last PIA.

N/A

11 Describe the purpose of the system.

The purpose of this data collection is to collect information
that CDC can use to: 1) identify common characteristics of
funded childhood lead poisoning prevention programs, and 2)
inform guidance, resource development, and technical
assistance for the activities that the CDC conducts in support of
the ultimate goal to eliminate blood lead in children.
The system will collect and maintain the following types of
information:
Program (program name, name, email, city, and state)
Survey (governing laws/policies, prevention strategies,
nutritional assessments, developmental assessments,
reimbursement rates, blood lead level action rates,
interventions, etc.)

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.)

Only cooperative agreement recipients will be asked to
participate in this survey. Data will be collected annually from
the project managers of funded lead poisoning prevention
programs of state and local governments (or their bona fide
fiscal agents) through our cooperative agreement. Only
aggregrate data will be disseminated.
Data will be collected using a web-based link to an Epi Info 7
survey or using an emailed survey in Microsoft Word format.
The data will then transfered to Microsoft Excel for storage on
the CDC shared drive. Data will be protected with appropriate
controls as described in the system documentation for the Epi
Info web survey, an authorized CDC information collection
system.

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The purpose of this annual assessment under the cooperative
agreement is to identify jurisdictional legal frameworks
governing CDC-funded childhood lead poisoning prevention
programs in the United States and strategies for implementing
childhood lead poisoning prevention activities.
The system will collect and maintain the following types of
information:
Program (program name, name, email, city, and state)
Survey (governing laws/policies, prevention strategies,
nutritional assessments, developmental assessments,
reimbursement rates, blood lead level action rates,
interventions, etc.)

Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

Program information is collected to contact cooperative
agreement recipients about the survey.
Survey information is collected to: 1) identify common
characteristics of funded childhood lead poisoning prevention
programs and 2) inform guidance, resource development, and
technical assistance activities conducted by the CDC
Childhood Lead Poisoning Prevention Program (CLPPP) in
support of the ultimate goal, which is blood lead elimination in
children
The PII used in the study is already in the center because these
individuals are POCs for grants and cooperative agreements.
The purpose of the study is to send a survey to these
individuals to evaluate these programs. T
Assessment findings will be shared on the CDC CLPPP website
and in response to inquiries by the public, press, and Congress.
The dissemination of results will support the ability for both
funded and non-funded jurisdictions to: 1) identify policies and
other factors that support or hinder childhood lead poisoning
prevention efforts, 2) understand what strategies are being
used by funded state and local governments (or their bona fide
fiscal agents) to implement childhood lead poisoning
prevention activities, and 3) use this knowledge to develop and
apply similar strategies to support the national agenda to
eliminate childhood lead poisoning.
Data will be collected using a web-based link to an Epi Info 7
survey or using an emailed survey in Microsoft Word format.
The data will then transfered to Microsoft Excel for storage on
the CDC shared drive. Data will be protected with appropriate
controls as described in the system documentation for the Epi
Info web survey, an authorized CDC information collection
system.

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

Yes
No

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Indicate the type of PII that the system will collect or
15
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

Other...

city and state

Other...

Other...

Other...

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
The primary purpose of the PII is to contact the survey
participants.
There is not secondary purpose of the PII.

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
N/A
and disclosure specific to the system and program.

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.

Published:
Published:
In Progress

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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?

OMB revision package is currently undergoing review. The
Awardee Lead Profile Assessment was previously approved
under OMB Control No. 0920-1215, expiration date 2/28/2021.
Yes
No
Within HHS

24a

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

Other Federal
Agency/Agencies
State or Local
Agency/Agencies
Private Sector

Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
There are no agreements in place that authorize the
24b Matching Agreement, Memorandum of
information sharing or disclosure.
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?

The system does not disclose information outside CDC.
There is no process in place to notify individuals that the PII will
be collected. PII is already collected as part of their cooperative
agreement application.
Voluntary
Mandatory

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Describe the method for individuals to opt-out of the
There is no process to opt-out of the collection or use of their
collection or use of their PII. If there is no option to
27
PII. PII is already collected as part of their cooperative
object to the information collection, provide a
agreement application.
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
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.

There is no process to notify and obtain consent from the
individuals PII in the system. This PII was already collected by
another system.

There is no process in place to resolve an individual's concerns.
PII is collected as part of the survey participants' cooperative
agreement applications.
There is no process in place for periodic reviews of
PII contained in the system. The PII was collected by another
system.
Users
Administrators

31

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

To maintain data

Developers
Contractors
Others

Describe the procedures in place to determine which The study's principal investigator (PI) determines who will have
32 system users (administrators, developers,
access to PII. The PI will configure the permissions each user
contractors, etc.) may access PII.
will receive for accessing study data.

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 privilege method is used to ensure that those with
access to PII are only able to access the minimum amount
necessary to perform their job responsibilities. Examples of
controls that are employed are: (1) SQL read/write permissions
that are controlled by user roles and privileges. (2) Active
Directory controls administrator access. (3) E-Authentication
control for external users.

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.

Personnel are required to undergo Annual Security and Privacy
Awareness Training (SAT).

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

Users receive no additional training beyond general security
and privacy awareness 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.

Records are retained, disposed, stored, handled, and viewed in
accordance with the ATSDR Comprehensive Records Control
Schedule (B-371), GSR 20.2c& d, and GSR 20.6. Current
procedures allow the system manager to keep the records for
20 years unless needed for further study. Registry records will
be actively maintained as long as funding is provided for by
legislation. Retention periods vary depending on the type of
record. Source documents for computer tapes or disks are
disposed of when no longer needed in the study as
determined by the system manager, and as provided in the
signed consent form, as appropriate.
The PII in the system is secured using a layered approach with
appropriate administrative, technical, and physical controls,
being implemented.

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

The administrative controls educate system users of their
responsibility to protect PII and legally bind them to do so.
These controls include signed rules of behavior , nondisclosure agreements, CDC privacy and security awareness
training, and records management training. Records are
maintained according to CDC record control policies and
procedures.
The technical controls, implemented by the system, act to
either allow access to system PII data only to approved users or
to make PII data unreadable outside of the system. These
controls include encryption, authentication, firewalls, intrusion
detection systems, and anti-malware systems.
The physical controls, implemented by the system, restrict
access to CDC buildings and areas housing computers used by
this system. These controls include guards, identification
badges, key cards, locked doors, cipher locks, fences, alarms
and closed circuit TV.

39 Identify the publicly-available URL:
40 Does the website have a posted privacy notice?

http://www.cdc.gov/EpiInfo
Yes
No

40a

Is the privacy policy available in a machine-readable
format?

Yes

41

Does the website use web measurement and
customization technology?

Yes

42

Does the website have any information or pages
directed at children under the age of thirteen?

Yes

43

Does the website contain links to non- federal
government websites external to HHS?

Yes

Is a disclaimer notice provided to users that follow
43a external links to websites not owned or operated by
HHS?

Yes

No
No

No

No
No

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Reviewer Questions

Answer

REVIEWER QUESTIONS: The following section contains Reviewer Questions which are not to be filled out unless the user is an OPDIV
Senior Officer for Privacy.

Reviewer Questions
1

Are the questions on the PIA answered correctly, accurately, and completely?

Answer
Yes
No

Reviewer
Notes
2

Does the PIA appropriately communicate the purpose of PII in the system and is the purpose
justified by appropriate legal authorities?

Yes

Do system owners demonstrate appropriate understanding of the impact of the PII in the
system and provide sufficient oversight to employees and contractors?

Yes

No

Reviewer
Notes
3

No

Reviewer
Notes
4

Does the PIA appropriately describe the PII quality and integrity of the data?

Yes
No

Reviewer
Notes
5

Is this a candidate for PII minimization?

Yes
No

Reviewer
Notes
6

Does the PIA accurately identify data retention procedures and records retention schedules?

Yes
No

Reviewer
Notes
7

Are the individuals whose PII is in the system provided appropriate participation?

Yes
No

Reviewer
Notes
8

Does the PIA raise any concerns about the security of the PII?

Yes
No

Reviewer
Notes
9

Is applicability of the Privacy Act captured correctly and is a SORN published or does it need
to be?

Yes
No

Reviewer
Notes
10

Is the PII appropriately limited for use internally and with third parties?

Yes
No

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Reviewer Questions

Answer

Reviewer
Notes
11

Does the PIA demonstrate compliance with all Web privacy requirements?

Yes
No

Reviewer
Notes
12

Were any changes made to the system because of the completion of this PIA?

Yes
No

Reviewer
Notes

General Comments

OPDIV Senior Official
for Privacy Signature

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2020.08.28
for Privacy
14:39:46 -04'00'

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