Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

Form Date

Question

Answer

1

OPDIV:

CDC/NCHHSTP/DHAP

2

PIA Unique Identifier:

0920-22FI

2a Name:

6/17/2022

National HIV Behavioral Surveillance - Brief HIV Bio-behavioral A
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.

Initiation
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

Epidemiologist

POC Name

Susan Cha

POC Organization CDC
POC Email

[email protected]

POC Phone

404-718-5486
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

N/A

10

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

This is a new information collection.

11 Describe the purpose of the system.

The primary purpose of the project is to develop a surveillance
information collection to monitor HIV prevalence, risk
behaviors, prevention and testing in 2 states funded to
conduct brief mixed-methods assessments in priority
populations from geographic areas of interest with limited biobehavioral HIV data.
The quantitative survey will include Name, email address,
phone numbers, mailing address, core questions on sexual risk
behaviors, injection and non-injection drug use behaviors,
testing for HIV and other sexually transmitted infections (STIs),
and use of prevention and health care services. Standard sets
of questions tailored to specific populations (e.g., persons who
inject drugs, men who have sex with men) will cover topics
appropriate to the priority population. These may include
questions about sexual partners, drug treatment, and history of
adverse health outcomes such as overdose, experiences with
homelessness, experiences with law enforcement, and
experiences with violence. Additional questions may include
topics of local interest by funded states.

Questions for qualitative interviews or focus groups will be
tailored to the population of interest and will evolve over the
course of data collection based on preceding and existing
information (e.g., probing further on identified themes in prior
Describe the type of information the system will
interviews). Topics may include healthcare access and services,
collect, maintain (store), or share. (Subsequent
sexual risk behaviors, HIV treatment and prevention, STIs, drug
12
questions will identify if this information is PII and ask use, social determinants of health, stigma, discrimination, and
about the specific data elements.)
social capital. Other qualitative data sources may include
observations, mapping (e.g., mapping areas with discarded
syringes/syringe litter in areas where drug use occurs), and
brief intercept surveys that focus on a few general topics (e.g.,
how a sub-population feels about a local community based
organization, where sub-populations congregate).
Participants may have the option to provide limited contact
information to BHBA project staff on a voluntary basis for
participants' convenience or for facilitating local operational
processes (e.g., mail self-testing kits, return test results, send
appointment reminders, facilitate linkage to HIV care and other
services). In all cases, participant contact information will NOT
be linked or linkable to the participant’s responses to questions
in the quantitative or qualitative interviews. Contact
information will be stored and secured locally by trained
project staff, and never shared with CDC or with anyone
outside of the project. Contact information will be destroyed
by the end of the data collection.

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Name, email address, phone numbers, mailing address and
data will be collected locally using computers that are solely
used for National HIV Behavioral Surveillance -- Brief HIV Biobehavioral Assessments (NHBS-BHBA) data collection activities.
The computers will be protected by using a coded password
only known by authorized project staff. Electronic data will be
stored on a secured computer drive that is password-protected
and accessible only to the staff with tasks that require access to
the data. Computers will be kept with the project staff at all
times when in the field. Any portable computers will be
collected and secured by the field supervisor after the last
interview of the day. When not in use in the field, the portable
computers will be locked in a drawer or office at the health
department or the contracted agency conducting the
surveillance.
Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

The funded states (Massachusetts and Florida) will collect and
submit BHBA data to CDC. Authorized staff will ensure data are
transmitted to Research Electronic Data Capture (REDCap), a
secure web-based application for administering surveys.
Quantitative data will be submitted online via REDCap upon
completion of each interview. CDC will work with project staff
to address data quality issues. Qualitative data such as
summary information, transcripts, interview or focus group
notes, observations, and maps will be submitted to CDC using
FileZilla - a secure file transfer protocol by authorized project
staff.
CDC will not receive or maintain any personally identifying
information (PII). From the CDC perspective this project does
not collect PII as no PII will ever be accessible to CDC staff.
Data will be maintained indefinitely as this is a surveillance
project with the potential to continue.
Yes

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

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

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

Other...

Other...

Other...

Other...

Other...

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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)

500-4,999
Participants may have the option to provide limited contact
information on a voluntary basis for their convenience and
facilitating local operational processes (e.g., mail self-testing
kits, return test results, send appointment reminders, facilitate
linkage to HIV care and other services).
None

20 Describe the function of the SSN.

N/A. No Social Security Number is being collected

20a Cite the legal authority to use the SSN.

N/A

Public Health Service Act, Section 301, "Research and
Identify legal authorities governing information use Investigation," (42 U.S.C. 241); and Sections 304, 306 and 308(d)
21
which discuss authority to maintain data and provide
and disclosure specific to the system and program.
assurances of confidentiality for health research and related
activities (42 U.S.C. 242 b, k, and m(d)).
22

Yes

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

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?

To be assigned once OMB approves.
Yes
No
Within HHS

Identify with whom the PII is shared or disclosed and
24a
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
24b Matching Agreement, Memorandum of
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.

CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
The process to notify participants is during the informed
consent process that notifies participants about collection and
handling of their personal information. No PII will be linked to
NHBS-BHBA data.

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26

Voluntary

Is the submission of PII by individuals voluntary or
mandatory?

Mandatory

CDC will not receive or maintain any PII. From the CDC
Describe the method for individuals to opt-out of the perspective this project does not collect PII as no PII will ever
collection or use of their PII. If there is no option to
be accessible to CDC staff.
27
object to the information collection, provide a
reason.
Participants will have the option to not provide their contact
information to still participate in the project.

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.

CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
Participant contact information will not be linked to NHBSBHBA data. Funded states will follow their Institutional Review
Board (IRB) approved procedures for handling PII and notify
the IRB and CDC if there are any adverse events. Once NHBSBHBA data have been collected, any PII used for facilitating
local operational processes will be destroyed, so there will not
be "major changes" to the system.
CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
Consent process information for study participants will include
how to contact senior project staff (e.g. principle investigator)
for any issues or concerns.
CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
Funded states will develop and update a data management
plan that includes how they will collect, store, and destroy
contact information.
Users
Administrators

31

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

Developers
Contractors

State-funded NHBS-BHBA personnel
will have access to PII. CDC will not
CDC will not receive or maintain any PII. From the CDC
Describe the procedures in place to determine which perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
32 system users (administrators, developers,
contractors, etc.) may access PII.
Only trained project staff in funded states will have access to
PII, as needed.
Others

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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.

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

CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
PII access will be limited to state-funded NHBS-BHBA
personnel. The PII recorded is the minimal necessary to
facilitate project procedures (e.g. call a patient with a test result
if using local laboratory for confirmatory testing; email
incentives to participants who completed an interview).
CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
Funded states will have IRB-approved procedures in place for
training project staff to conduct research activities per their
protocol.
N/A

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

Yes
No
CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.

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

Funded states will follow CDC Records schedule, Part 7 ATSDR,
1-17 Scientific Records.
Authorized Disposition: Do not transfer to an FRC. Destroy 5
years after completion of final health assessment, consultation,
etc.
CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.

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

Electronic contact information will be maintained in a secure,
password-protected electronic form to which only authorized
project staff will have access.
Administrative control: only project staff will have access,
Technical control: it is in a secure password-protected
database, and
Physical control: paper records will be kept in a locked file
cabinet in a secured office.

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

Answer

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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

Reviewer
Notes
11

Does the PIA demonstrate compliance with all Web privacy requirements?

Yes
No

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Reviewer Questions

Answer

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: 2022.08.17
for Privacy
13:52:33 -04'00'

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