PayVA PIA 2023

Privacy Impact Assessment for the VA IT System called:

PayVA
Veterans Administrations Central Office
(VACO)
Debt Management Center; Maintained by VA Capital Region
Readiness Center (CRRC)/Enterprise Web Infrastructure Support
(EWIS)
Date PIA submitted for review:
08/14/2023
System Contacts:
System Contacts

Name
Morgen Egesdal

E-mail
[email protected]

Phone Number
612-725-4353

Information System
Security Officer (ISSO)

James Weinhold

[email protected]

612-946-4428

Information System
Owner

Karen L. Kelly

[email protected]

202-876-7958

Privacy Officer

Abstract
The abstract provides the simplest explanation for “what does the system do?” and will be published
online to accompany the PIA link.
PayVA is a custom-developed application (which is a website; https://www.pay.va.gov) that is used
by the Debt Management Center (DMC) to verify debts are active at DMC before the Veteran makes
a payment. PayVA collects basic debt information from users, redirects them to pay.gov (Department
of Treasury) for online payments and collects responses from pay.gov. The Veteran enters their
personal information to include File Number, Payee Number, Deduction Code, First Name, Last
Name, Phone Number, and Payment Amount. VA DMC and Information Technology employees
access the system through an internal administrative console using Single Sign-On (SSOi). The
production site with a secure certificate has already been created.

Overview
The overview is the most important section of the PIA. A thorough and clear overview gives the reader
the appropriate context to understand the responses in the PIA. The overview should contain the
following elements:
1

General Description
A. The IT system name and the name of the program office that owns the IT system.
PayVA, Debt Management Center: maintained by the VA Capital Region Readiness Center
(CRRC)/Enterprise Web Infrastructure Support (EWIS)

B. The business purpose of the program, IT system, or technology and how it relates to the
program office and agency mission.
Verification of active debts of veterans with the debt management center.

C. Indicate the ownership or control of the IT system or project.
VA Owned and VA Operated Debt Management Center, maintained by the VA Capital Region
Readiness Center (CRRC)/Enterprise Web Infrastructure Support (EWIS)

2. Information Collection and Sharing
D. The expected number of individuals whose information is stored in the system and a brief
description of the typical client or affected individual.
100,000+ veterans with an active debt.

E. A general description of the information in the IT system and the purpose for collecting this
information.
PayVA is a custom-developed application (which is a website; https://www.pay.va.gov)
that is used by the Debt Management Center (DMC) to verify debts are active at DMC before
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the Veteran makes a payment. PayVA collects basic debt information from users, redirects
them to pay.gov (Department of Treasury) for online payments and collects responses from
pay.gov. The Veteran enters their personal information to include File Number, Payee
Number, Deduction Code, First Name, Last Name, Phone Number, and Payment Amount.
VA DMC and Information Technology employees access the system through an internal
administrative console using Single Sign-On (SSOi). The production site with a secure
certificate has already been created. PayVA is housed in the WebOps server farm at the
Capital Region Readiness Center (CRRC) in Martinsburg, WV. The system purpose is
verification of active debts of veterans with the debt management center, and provide a portal
for payment of debts to the Department of Treasury (Pay.gov)
F. Any information sharing conducted by the IT system. A general description of the modules
and subsystems, where relevant, and their functions.
PayVA receives information (a table containing PII) from the Centralized Accounts
Receivable System /Central Accounts Receivable On-Line System (CARS/CAROLS) an
internal VA system, via a SQL job 3 times a week. PayVA also receives information each
time a payment is completed via a form submission from Pay.Gov which is owned by the
Department of Treasury.

G. Whether the system is operated in more than one site, and if so, a description of how use of
the system and PII is maintained consistently in all sites and if the same controls are used
across sites.
PayVA is operated at one site, the Capital Region Readiness Center, (CRRC)

3. Legal Authority and SORN
H. A citation of the legal authority to operate the IT system.
Title 10 United States Code (U.S.C.) chapters 106a, 510, 1606 and 1607 and Title 38,
U.S.C., section 501(a) and Chapters 11, 13, 15, 18, 23, 30, 31, 32, 33, 34, 35, 36, 39, 51, 53, and
55. PayVA SORN 194VA189 (https://www.oprm.va.gov/privacy/systems_of_records.aspx

I. If the system is in the process of being modified and a SORN exists, will the SORN require
amendment or revision and approval? If the system is using cloud technology, does the SORN
for the system cover cloud usage or storage?
No.

D. System Changes
J. Whether the completion of this PIA will result in circumstances that require changes to
business processes
No

K. Whether the completion of this PIA could potentially result in technology changes
No
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Section 1. Characterization of the Information
The following questions are intended to define the scope of the information requested and collected as
well as the reasons for its collection as part of the program, IT system, or technology being developed.
1.1 What information is collected, used, disseminated, created, or maintained in the system?
Identify and list all Sensitive Personal Information (SPI) that is collected and stored in the system,
including Individually Identifiable Information (III), Individually Identifiable Health Information (IIHI),
Protected Health Information (PHI), and Privacy- Protected Information. For additional information on
these information types and definitions, please see VA Directives and Handbooks in the 6500 series
(https://vaww.va.gov/vapubs/). If the system creates information (for example, a score, analysis, or
report), list the information the system is responsible for creating.
If a requesting system receives information from another system, such as a response to a background
check, describe what information is returned to the requesting system.
This question is related to privacy control AP-1, Authority To Collect, and AP-2, Purpose Specification.
The information selected below must match the information provided in question 2.1 as well as the data
elements columns in 4.1 and 5.1.
Please check any information listed below that your system collects, uses, disseminates, creates, or
maintains. If additional SPI is collected, used, disseminated, created, or maintained, please list those in
the text box below:
Name
Health Insurance
Integrated Control
Beneficiary Numbers
Social Security
Number (ICN)
Account numbers
Number
Military
Certificate/License
Date of Birth
History/Service
numbers*
Mother’s Maiden Name
Connection
Vehicle License Plate
Personal Mailing
Next of Kin
Number
Address
Other Data Elements
Internet Protocol (IP)
Personal Phone
(list below)
Address Numbers
Number(s)
Medications
Personal Fax Number
Medical Records
Personal Email
Race/Ethnicity
Address
Tax Identification
Emergency Contact
Number
Information (Name, Phone
Medical Record
Number, etc. of a different
individual)
Number
Financial Information
Gender

File Number (which is sometimes the SSN and sometimes the SSN, reformatted); Payee Number;
Deduction Code (which can be found in a letter the user received from the DMC), Person entitled
(Payee) and Payment amount. PayVA then verifies the information entered by the user against a
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table provided by CARS/CAROLS (an internal VA system). If the information entered is correct the
user is directed to the Department of Treasury’s Pay.Gov where payment is made, and then a form
submission with the user’s partial bank account number/credit card number and payer name is
provided to PayVA and stored in its database.

PII Mapping of Components (Servers/Database)
PayVA consists of 1 key component (servers/databases). Each component has been analyzed to determine
if any elements of that component collect PII. The type of PII collected by PayVA and the reasons for the
collection of the PII are in the table below.
Note: Due to the PIA being a public facing document, please do not include the server names in the table.
The first table of 3.9 in the PTA should be used to answer this question.
Internal Database Connections

Database Name of
the information
system
collecting/storing PII

Does this
system collect
PII? (Yes/No)

payva_restore data

Yes

Does
this
system
store
PII?
(Yes/No)
Yes

Type of PII
(SSN, DOB,
etc.)

Reason for
Collection/
Storage of PII

Safeguards

File Number
(SSN), Payee
Number, First
Name, Last
Name, Phone
Number, and
Payment
Amount

SSN is required
for proper
identification
of veteran.

Encryption
(SSL/HTTPS)

1.2 What are the sources of the information in the system?
These questions are related to privacy controls DI-1, Data Quality, and IP-1, Consent.
1.2a List the individual, entity, or entities providing the specific information identified above. For
example, is the information collected directly from the individual as part of an application for a
benefit, or is it collected from other sources such as commercial data aggregators?
PayVA receives the following information from the user, directly, First Name, Last Name, Daytime
Phone, File Number, Payee Number, Person Entitled, Deduction Code, and Payment Amount.
PayVA, then checks whether the information entered by the user matches what is in the
CARS/CAROLS table that is received by PayVA, 3 times a week; each time the table is refreshed the
former table is deleted (no historical data from CARS/CAROLS is stored in PayVA). If the
information entered by the User matches what is in the table received from CARS/CAROLS the user
is transferred to Pay.Gov (which is managed by the Department of Treasury), where the payment is
made. The only information PayVA shares with Pay.Gov is the first name, last name, and debt
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amount. The user then enters the following information to Pay.Gov, the Payment Amount, Account
Type, Routing Number, and Account Number (which would be covered by the Department of
Treasury’s accreditation documentation). Once the payment is completed Pay.Gov passes payment
results including partial bank account number, credit card number, and payer name which is stored in
PayVA’s Database.

1.2b Describe why information from sources other than the individual is required. For example, if a
program’s system is using data from a commercial aggregator of information or data taken from
public Web sites, state the fact that this is where the information is coming from and then in question
indicate why the system is using this source of data.
CARS/CAROLS is a VA internal application, the data elements of which are used only to verify that
the information the user enters is accurate.

1.2c If the system creates information (for example, a score, analysis, or report), list the system as a
source of information.
The system does not create any information such as a score, analysis, or report.
1.3 How is the information collected?
These questions are related to privacy controls DI-1, Data Quality, and IP-1, Consent.
1.3a This question is directed at the means of collection from the sources listed in question 1.2.
Information may be collected directly from an individual, received via electronic transmission from
another system, or created by the system itself. Specifically, is information collected through
technologies or other technologies used in the storage or transmission of information in identifiable
form?
PayVA first receives information directly from the user. The user must go to https://www.pay.va.gov
and select, “Pay Online,” then they will be taken to a new screen where they will populate their First
Name, Last Name, Daytime Phone, File Number, Payee Number, Person Entitled, Deduction Code,
and Payment Amount. The information entered is then checked against a table provided by CAROLS
3 times a week via a SQL job.
1.3b If the information is collected on a form and is subject to the Paperwork Reduction Act, give the
form’s OMB control number and the agency form number.
Information is collected through the web portal. OMB Number: 2900-0663 Estimated Burden: 10 minutes

1.4 How will the information be checked for accuracy? How often will it be checked?
These questions are related to privacy controls DI-1, Data Quality, and DI-2, Data Integrity and
Integrity Board.
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1.4a Discuss whether and how often information stored in the system is checked for accuracy. Is
information in the system checked against any other source of information (within or outside your
organization) before the information is used to make decisions about an individual? For example, is
there a computer matching agreement in place with another government agency? For systems that
receive data from internal data sources or VA IT systems, describe the system checks to ensure that
data corruption has not occurred during transmission.
PayVA checks for accuracy immediately. If the information entered by the user does not match the
information PayVA receives from CARS, the user gets the following message and is not able to
proceed with the payment: “Please call the Debt Management Center at 1-800-827-0648 before
proceeding with this payment on Pay.gov.”
1.4b If the system checks for accuracy by accessing a commercial aggregator of information,
describe this process and the levels of accuracy required by the contract.
Commercial aggregation sources are not used to check the data for accuracy.
1.5 What specific legal authorities, arrangements, and agreements defined the collection of
information?
List the full legal authority for operating the system, specifically the authority to collect the
information listed in question 1.1. Provide the authorities in a manner understandable to any
potential reader, i.e., do not simply provide a legal citation; use statute names or regulations in
addition to citations. Legal authorities include Federal laws, regulations, statutes, and Executive
Orders. This question is related to privacy control AP-1, Authority to Collect
AUTHORITY FOR MAINTENANCE OF THE SYSTEM: Title 10 United States Code (U.S.C.)
Chapters 106a, 510, 1606 and 1607 and Title 38, U.S.C., section 501(a) and
Chapters 11, 13, 15, 18, 23, 30, 31, 32, 33, 34, 35, 36, 39, 51, 53, and 55.
1.6 PRIVACY IMPACT ASSESSMENT: Characterization of the information
Consider the specific data elements collected and discuss the potential privacy risks and what steps,
if any are currently being taken to mitigate those identified risks. (Work with your System ISSO to
complete this section)
Consider the following Fair Information Practice Principles (FIPPs) when assessing the risk to
individual privacy:
Principle of Purpose Specification: Explain how the collection ties with the purpose of the
underlying mission of the organization and its enabling authority.
Principle of Minimization: Is the information directly relevant and necessary to accomplish the
specific purposes of the program?

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Principle of Individual Participation: Does the program, to the extent possible and practical, collect
information directly from the individual?
Principle of Data Quality and Integrity: Are there policies and procedures for VA to ensure that
personally identifiable information is accurate, complete, and current?
This question is related to privacy control AR-1, Governance and Privacy Program, and AR-2,
Privacy Impact and Risk Assessment.
Follow the format below when entering your risk assessment:
Privacy Risk: The system collects Personally Identifiable Information (PII) and stores the name,
partial bank account number, and sometimes the SSN (if used as the File Number). Due to the
sensitive nature of this data, there is a risk that, if the data were accessed by an unauthorized
individual or otherwise breached, serious personal, professional or financial harm may result for the
individuals affected.

Mitigation: The system employs a variety of security measures designed to ensure the information
is not disclosed or released. Safeguards and security controls are in place (to include access control,
security awareness training, and audit and accountability). PayVA is a VA managed application
which operates under guidance provided in the National Institute of Standards and Technology
(NIST) Special Publication 800-37 and specific VA directives.

Section 2. Uses of the Information
The following questions are intended to clearly delineate the use of information and the accuracy of
the data being used.
2.1 Describe how the information in the system will be used in support of the program’s
business purpose.
Identify and list each use (both internal and external to VA) of the information collected or
maintained. This question is related to privacy control AP-2, Purpose Specification.
Name – Used as identifier.
SSN – Sometimes used as the File Name which is used as an identifier.
Payee Number – Used as identifier.
Deduction Code – Used as identifier.
Financial Account Information –Used as identifier and proof of payment.

2.2 What types of tools are used to analyze data and what type of data may be produced?
These questions are related to privacy controls DI-1, Data Quality, DI-2, Data Integrity and
Integrity Board, and SE-1, Inventory of Personally Identifiable Information.
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2.2a Many systems sift through large amounts of information in response to a user inquiry or
programmed functions. Systems may help identify areas that were previously not obvious and need
additional research by agents, analysts, or other employees. Some systems perform complex
analytical tasks resulting in, among other types of data, matching, relational analysis, scoring,
reporting, or pattern analysis. Describe any type of analysis the system conducts and the data that is
created from the analysis.
PayVA data is entered by the user, and then is checked against data (a table provided via a SQL job 3
times a week by another internal VA system, CARS/CAROLS). PayVA only keeps the most recent
table provided by CARS/CAROLS; (information regarding records for CARS/CAROLS files can be
found in the CARS/CAROLS PIA). Once the data entered by the user is checked against the
CARS/CAROLS table and/if the information matches, the user is directed to Pay.Gov (owned by the
Department of Treasury) where the payment is made. At that time, Pay.gov provides the payment
results, including partial bank account number/credit card number and payee name to PayVA and
that information is stored in the PayVA database indefinitely.
2.2b If the system creates or makes available new or previously unutilized information about an
individual, explain what will be done with the newly derived information. Will it be placed in the
individual's existing record? Will a new record be created? Will any action be taken against or for
the individual identified because of the newly derived data? If a new record is created, will the newly
created information be accessible to Government employees who make determinations about the
individual? If so, explain fully under which circumstances and by whom that information will be
used.
The system neither creates, nor makes available new or previously unutilized information about an
individual. A new record is created by Pay.gov (Department of Treasury) which is the payment
transaction record, which includes the payee name and partial bank account/credit card number, and
is stored in the PayVA database for financial audit purposes.

2.3 How is the information in the system secured?
These questions are related to security and privacy controls SC-9, Transmission Confidentiality, and
SC-28, Protection of Information at Rest.
2.3a What measures are in place to protect data in transit and at rest?
All information of data in transit uses Secure Socket Layers/Transport Layer Security over
Hypertext Transfer Protocol (HTTPS). Data at rest is protected on the Storage Area Network (SAN)
through ONTAP Internetwork Operating System (iOS), which is a fully FIPS 140-2, level 1
encryption compliant and meets the VA6500 requirements for data at rest encryption.
2.3b If the system is collecting, processing, or retaining Social Security Numbers, are there
additional protections in place to protect SSNs?
All information of data in transit uses Secure Socket Layers/Transport Layer Security over Hypertext
Transfer Protocol (HTTPS). Data at rest is protected on the Storage Area Network (SAN) through
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ONTAP Internetwork Operating System (iOS), which is a fully FIPS 140-2, level 1 encryption
compliant and meets the VA6500 requirements for data at rest encryption.
2.3c How is PII/PHI safeguarded in accordance with OMB Memorandum M-06-15?
VA employees and contractors are required to take annual privacy training through the VA’s
Training Management System (TMS) and sign Rules of Behavior. Any employee or contractor who
fails to recertify annually will have their VA network and application access suspended until they are
in compliance with the requirement. VA employees and contractors are required to report all
incidences of suspected or actual PII disclosure to a VA Information System Security Officer (ISSO)
within one hour of discovering the incident. VA Handbook 6500.2, dated June 30, 2023, is the
enterprise-wide Privacy Incident Response Plan. Privacy Service, OIT and Data Breach Response
Service (DBRS) are responsible for implementation of VA Handbook 6500.2 as well as Privacy
incident response plan procedures, including investigation and extra-agency reporting.

2.4 PRIVACY IMPACT ASSESSMENT: Use of the information.
Describe any types of controls that may be in place to ensure that information is handled in
accordance with the uses described above. Example: Describe if training for users of the project
covers how to appropriately use information. Describe the disciplinary programs or system
controls (i.e. denial of access) that are in place if an individual is inappropriately using the
information.
Consider the following FIPPs below to assist in providing a response:
Principle of Transparency: Is the PIA and SORN, if applicable, clear about the uses of the
information?
Principle of Use Limitation: Is the use of information contained in the system relevant to the mission
of the project?
This question is related to privacy control AR-4, Privacy Monitoring and Auditing, AR-5, Privacy
Awareness and Training, and SE-2, Privacy Incident response.
2.4a How is access to the PII determined?
All system administrators granted access to VA systems are given access based on their position,
duties and a job related need to know. All system administrators are also required to have extensive
training prior to receiving access and are required to recertify and resign the VA Rules of Behavior,
annually, or lose their access to the VA network and applications until they are in compliance with
the training requirements. System Administrator access is granted via ePAS.
2.4b Are criteria, procedures, controls, and responsibilities regarding access documented?
Supervisory approval for system administrators is documented in ePAS. Required Privacy and
Security Training is documented in the VA Training Management System.
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2.4c Does access require manager approval?
All system administrators granted access to VA systems are given access based on their position,
duties and a job related need to know, and requires management approval. All system administrators
are also required to have extensive training prior to receiving access and are required to recertify and
resign the VA Rules of Behavior, annually. System Administrator access is granted via ePAS, and
requires management approval. End Users of PayVA must have a copy of the letter sent to the
debtor by the Debt Management Center (DMC) to utilize the system which is used to verify the
user’s identity. They must then enter the information found in the upper right-hand corner of the
letter from DMC. The debtor must then enter the same information found in the letter in lines 2
through 4 on the PayVA webpage. If the data entered by the user does not match, the debtor is not
able to move forward with the payment and gets the following message: “Please call the Debt
Management Center at 1-800-827-0648 before proceeding with this payment on Pay.gov.”
2.4d Is access to the PII being monitored, tracked, or recorded?
Administrative access and actions are logged in the VA’s system and application log aggregation
system, SPLUNK. Activity Reports may be run on an ad-hoc basis.
2.4e Who is responsible for assuring safeguards for the PII?
PayVA and DMC employ an Information System Security Officer (ISSO) whose primary duty is to
monitor sensitivity levels assigned to PayVA and DMC personnel, and to ensure appropriate security
levels are assigned.

Section 3. Retention of Information
The following questions are intended to outline how long information will be retained after the initial
collection.
3.1 What information is retained?
Identify and list all information collected from question 1.1 that is retained by the system.
This question is related to privacy controls DM-1, Minimization of Personally Identifiable
Information, and DM-2, Data Retention and Disposal

Payment results are provided by Pay.Gov (system owned by the Department of Treasury) upon
payment completion. The payment results contain the following PII which is stored indefinitely in
PayVA’s Database is: partial bank account number/credit card number, and the payer name. PayVA
also receives a table from CARS/CAROLS (an internal system to VA) 3 times a week via a SQL job
that contains the following PII, File Number (which is sometimes the SSN), Payee Number and
Deduction Code.
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3.2 How long is information retained?
In some cases VA may choose to retain files in active status and archive them after a certain period
of time. State active file retention periods, as well as archived records, in number of years, for the
information and record types. For example, financial data held within your system may have a
different retention period than medical records or education records held within your system,
please be sure to list each of these retention periods. The VA records officer should be consulted
early in the development process to ensure that appropriate retention and destruction schedules are
implemented. If the system is using cloud technology, will it be following the NARA approved
retention length and schedule? This question is related to privacy control DM-2, Data Retention and
Disposal.
These records are retained and disposed of in accordance with the General Records Schedule 3.1
010-020, approved by National Archives and Records Administration (NARA)
https://www.archives.gov/files/records-mgmt/grs/grs03-1.pdf. A retention policy specific to PayVA
is being drafted. This PIA will be updated with that information upon completion; until that time,
PayVA is retaining all records indefinitely.
3.3 Has the retention schedule been approved by the VA records office and the National
Archives and Records Administration (NARA)?
An approved records schedule must be obtained for any IT system that allows the retrieval of a
record via a personal identifier. The VA records officer will assist in providing a proposed schedule.
The schedule must be formally offered to NARA for official approval. Once NARA approves the
proposed schedule, the VA records officer will notify the system owner. Please work with the system
Privacy Officer and VA Records Officer to answer these questions.
This question is related to privacy control DM-2, Data Retention and Disposal.
3.3a Are all records stored within the system of record indicated on an approved disposition
authority?
Yes - These records are retained and disposed of in accordance with the General Records Schedule
1.1 010-011 and 3.1 010-020, approved by National Archives and Records Administration (NARA)
https://www.archives.gov/files/records-mgmt/grs/grs01-1.pdf and
https://www.archives.gov/files/records-mgmt/grs/grs03-1.pdf.

3.3b Please indicate each records retention schedule, series, and disposition authority.
General Records Schedule 1.1 010-011 - DAA-GRS2013-0003-0001, DAA-GRS2013-00030002 and General Records Schedule 3.1 010-020 - DAA-GRS2013-0005-0006, DAA-GRS20130005-0007, DAA-GRS2013-0005-0008, DAA-GRS2013-0005-0009.
https://www.va.gov/vhapublications/rcs10/rcs10-1.pdf

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3.4 What are the procedures for the elimination or transfer of SPI?
Explain how records are destroyed, eliminated or transferred to NARA at the end of their mandatory
retention period. Please give the details of the process. For example, are paper records shredded
on site, or by a shredding company and accompanied by a certificate of destruction, etc.? This
question is related to privacy control DM-2, Data Retention and Disposal.
Financial transaction records related to … collecting debts (GRS 1.1 010, 11): Destroy 6 years after
final payment or cancellation, but longer retention is authorized if required for business use. Destroy
when business use ceases. Project Records (3.1 010, 011): Destroy 5 years after project is
terminated, but longer retention is authorized if required for business use. Special Purpose Programs
and Applications (3.1 012): Delete when related master file or database has been deleted, but longer
retention is authorized if required for business use. Information Technology Records (3.1 020):
Destroy 3 years after agreement, control measures, procedures, project, activity, or transaction is
obsolete, completed, terminated, or superseded, but longer retention is authorized if required for
business use. PayVA adheres to VA Directive 6500, VA Cybersecurity Program, and VA Handbook
6500.2, Management of Breaches Involving Sensitive Personal Information, among other VA
directives, to manage the protection of, and minimize the usage of, sensitive personal information
(SPI).

3.5 Does the system, where feasible, use techniques to minimize the risk to privacy by using PII
for research, testing, or training?
Organizations often use PII for testing new applications or information systems prior to deployment.
Organizations also use PII for research purposes and for training. These uses of PII increase the
risks associated with the unauthorized disclosure or misuse of the information. Please explain what
controls have been implemented to protect PII used for testing, training and research. This question
is related to privacy control DM-3, Minimization of PII Used in Testing, Training and Research.

The use of PII during research, testing, and training is reduced when possible, to minimize risk. Risk
minimization includes data obfuscation (use of partial PII), use of stale data, or use of anonymized
data. Any use of data that may include PII must be documented and approved for use by VA
leadership in accordance with VA Handbook 6502, VA Enterprise Privacy Program and VA
Handbook 6508.1, Procedures for Privacy Threshold Analysis and Privacy Impact Assessment.
3.6 PRIVACY IMPACT ASSESSMENT: Retention of information
Discuss the risks associated with the length of time data is retained and what steps, if any, are
currently being taken to mitigate those identified risks. (Work with your System ISSO to complete all
Privacy Risk questions inside the document this section).

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While we understand that establishing retention periods for records is a formal process, there are
policy considerations behind how long a project keeps information. The longer a project retains
information, the longer it needs to secure the information and assure its accuracy and integrity. The
proposed schedule should match the requirements of the Privacy Act to keep the minimum amount of
PII for the minimum amount of time, while meeting the Federal Records Act. The schedule should
align with the stated purpose and mission of the system.
Consider the following FIPPs below to assist in providing a response:
Principle of Minimization: Does the project retain only the information necessary for its purpose? Is
the PII retained only for as long as necessary and relevant to fulfill the specified purposes?
Principle of Data Quality and Integrity: Has the PIA described policies and procedures for how PII
that is no longer relevant and necessary is purged?
This question is related to privacy controls DM-1, Minimization of Personally Identifiable
Information, and DM-2, Data Retention and Disposal.
Follow the format below:
Privacy Risk: PII may be held for long after the original record was required to be disposed. The
extension of retention periods increases the risk that SPI may be breached or otherwise put at risk.

Mitigation: The privacy risk is mitigated by retaining the information in accordance with the
approved NARA retention schedules. These records are retained and disposed of in accordance with
the General Records Schedule 3.1 010-020, approved by National Archives and Records
Administration (NARA) https://www.archives.gov/records-mgmt/grs.html. A retention policy
specific to PayVA is being drafted This PIA will be updated with that information upon completion;
until that time, PayVA is retaining all records indefinitely.

Section 4. Internal Sharing/Receiving/Transmitting and Disclosure
The following questions are intended to define the scope of information
sharing/receiving/transmitting within VA.
4.1 With which internal organizations is information shared/received/transmitted? What
information is shared/received/transmitted, and for what purpose? How is the information
transmitted?
NOTE: Question 3.9 (second table) on Privacy Threshold Analysis should be used to answer
this question.
Identify and list the names of any program offices, contractor-supported IT systems, and any other
organization or IT system within VA with which information is shared.
State the purpose for the internal sharing. If you have specific authority to share the information,
provide a citation to the authority.
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For each interface with a system outside your program office, state what specific data elements
(PII/PHI) are shared with the specific program office, contractor-supported IT system, and any other
organization or IT system within VA.
Describe how the information is transmitted. For example, is the information transmitted
electronically, by paper, or by some other means? Is the information shared in bulk, on a case-bycase basis, or does the sharing partner have direct access to the information?
This question is related to privacy controls AP-2, Purpose Specification, AR-3, Privacy Requirements
for Contractors and Service Providers, AR-8, Accounting of Disclosures, TR-1, Privacy Notice, and
UL-1, Internal Use.
Data Shared with Internal Organizations

List the Program
Office or IT System
information is
shared/received with
Central Accounts
Receivable
System/Centralized
Accounts Receivable OnLine System
(CARS/CAROLS)

List the purpose of
the information
being shared
/received with the
specified program
office or IT system
To ensure the
payment is allotted
to the correct
debt/debtor

List the specific PII/PHI
data elements that are
processed
(shared/received/transmitted)
with the Program Office or
IT system
File Number which is the SSN
for newer debts and is the SSN
(but reformatted) for older
debts.

Describe the
method of
transmittal

SQL JOB (3 times
a week

4.2 PRIVACY IMPACT ASSESSMENT: Internal sharing and disclosure
Discuss the privacy risks associated with the sharing of information within the Department and what
steps, if any, are currently being taken to mitigate those identified risks. (Work with your System
ISSO to complete all Privacy Risk questions inside the document this section).
This question is related to privacy control UL-1, Internal Use.

Follow the format below:
Privacy Risk: Privacy information may be released to unauthorized individuals by authorized users.

Mitigation:
• All personnel with access to Veteran’s information are required to complete the VA Privacy
and
• Information Security Awareness training and Rules of Behavior annually.
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•
•
•

The Debt Management Center adheres to all information security requirements instituted by
the VA Office of Information Technology (OIT).
Information is shared in accordance with VA Handbook 6500.
Windows and Unix access controls are provided by VA’s Infrastructure Operations (IO),
along with the following security controls: Audit and Accountability, Awareness Training,
Security Assessment and Authorization, Incident Response, Personnel Security, and
Identification and Authentication.

Section 5. External Sharing/Receiving and Disclosure
The following questions are intended to define the content, scope, and authority for information
sharing external to VA, which includes Federal, State, and local governments, and the private sector.
5.1 With which external organizations (outside VA) is information shared/received? What
information is shared/received, and for what purpose? How is the information transmitted and
what measures are taken to ensure it is secure?
Is the sharing of information outside the agency compatible with the original collection? If so,
is it covered by an appropriate routine use in a SORN? If not, please describe under what legal
mechanism the IT system is allowed to share the information in identifiable form or personally
identifiable information outside of VA.
NOTE: Question 3.10 on Privacy Threshold Analysis should be used to answer this question.
Identify and list the names of any Federal, State, or local government agency or private sector
organization with which information is shared.
For each interface with a system outside VA, state what specific data elements (PII/PHI) are shared
with each specific partner.
What legal mechanisms, authoritative agreements, documentation, or policies are in place detailing
the extent of the sharing and the duties of each party? For example, is the sharing of data compatible
with your SORN? Then list the SORN and the applicable routine use from the SORN. Is there a
Memorandum of Understanding (MOU), Computer Matching Agreement (CMA), or law that
mandates the sharing of this information?
Describe how the information is transmitted to entities external to VA and what security measures
have been taken to protect it during transmission.
This question is related to privacy control UL-2, Information Sharing with Third Parties

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Data Shared with External Organizations

List External
Program Office
or IT System
information is
shared/received
with

List the
purpose of
information
being
shared /
received /
transmitted
with the
specified
program
office or IT
system

List the specific PII/PHI data
elements that are processed
(shared/received/transmitted)with
the Program or IT system

Department of
Treasury
(PayVA.gov)

To ensure
record of
payment by
the Veteran.

SSN (File number), Name, Amount
of payment

List the
legal
authority,
binding
agreement,
SORN
routine use,
etc. that
permit
external
sharing
(can be
more than
one)
SORN
194VA189.
Agency
Participation
Agreement

List the
method of
transmission
and the
measures in
place to
secure data

Open
Collections
Interface
(OCI)

5.2 PRIVACY IMPACT ASSESSMENT: External sharing and disclosure
Discuss the privacy risks associated with the sharing of information outside the Department and
what steps, if any, are currently being taken to mitigate those identified risks.
Discuss whether access controls have been implemented and whether audit logs are regularly
reviewed to ensure appropriate sharing outside of the Department. For example, is there a
Memorandum Of Understanding (MOU), contract, or agreement in place with outside agencies or
foreign governments.
Discuss how the sharing of information outside of the Department is compatible with the stated
purpose and use of the original collection.
This question is related to privacy control AR-2, Privacy Impact and Risk Assessment, AR-3, Privacy
Requirements for Contractors and Service Providers, and AR-4, Privacy Monitoring and Auditing
Follow the format below:
Privacy Risk: There is a risk that data could be shared with an inappropriate and/or unauthorized
external organization or institution.

Mitigation: The safeguards implemented to ensure data is not shared with the wrong external
organization are use of secure data transfer protocols and encryption (Secure Socket
Layers/Transport Layer Security over Hypertext Transfer Protocol (HTTPS).

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Section 6. Notice
The following questions are directed at providing notice to the individual of the scope of information
collected, the right to consent to uses of the information, and the right to decline to provide
information.
6.1 Was notice provided to the individual before collection of the information? If yes, please
provide a copy of the notice as an Appendix-A 6.1 on the last page of the document. Also
provide notice given to individuals by the source system (A notice may include a posted privacy
policy, a Privacy Act notice on forms, or a system of records notice published in the Federal
Register.) If notice was not provided, why not?
These questions are related to privacy control TR-1, Privacy Notice, and TR-2, System of Records
Notices and Privacy Act Statements, and TR-3, Dissemination of Privacy Program Information.
6.1a This question is directed at the notice provided before collection of the information. This refers
to whether the person is aware that his or her information is going to be collected. A notice may
include a posted privacy policy, a Privacy Act statement on forms, or a SORN published in the
Federal Register, Notice of Privacy Practice provided to individuals for VHA systems. If notice was
provided in the Federal Register, provide the citation.
At U.S. Department of Veterans Affairs - Pay Online (va.gov), A Privacy Notice is available for
the user to click on via a link entitled, “Read Important Privacy Information.” A copy of the Privacy
Information is included as Appendix A. The legal authorities are provided in the first paragraph of
the PayVA Privacy Information (38.U.S.C.5701; Privacy Act of 1974; The PayVA SORN is
194VA189. SORNs 58VA21/22 Compensation, Pension, Education and Rehabilitation Records-VA,
and 88VA244, Accounts Receivable Records-VA (as can be seen below and in Appendix
A).“Privacy Act Information: The information you furnish on this form, including your Social
Security Number, is used to associate your payment with your accounts receivable record so that we
may properly credit your account. Disclosure is voluntary. However, without disclosure, a credit card
transaction or direct debit transaction cannot be processed. The responses you submit are confidential
and protected from unauthorized disclosure by 38 U.S.C. 5701. The information may be disclosed
outside the Department of Veterans Affairs (VA) only when authorized by the Privacy Act of 1974,
as amended. The routine uses for which VA may disclose the information can be found in VA
systems of records, including 58VA21/22, Compensation, Pension, Education and Rehabilitation
Records-VA, and 88VA244, Accounts Receivable Records-VA. VA systems of records and
alterations to the systems are published in the Federal Register. Any information provided by you,
including your Social Security Number, may be used in computer matching programs conducted in
connection with any proceeding for the collection of an amount owed by virtue of your participation
in any benefit program administered by VA.”

6.1b If notice was not provided, explain why. If it was provided, attach a copy of the current notice.
Notice is provided at https://www.pay.va.gov/index.cfm?action=step1
“Privacy Act Information: The information you furnish on this form, including your Social Security
Number, is used to associate your payment with your accounts receivable record so that we may
properly credit your account. Disclosure is voluntary. However, without disclosure, a credit card
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transaction or direct debit transaction cannot be processed. The responses you submit are
confidential and protected from unauthorized disclosure by 38 U.S.C. 5701. The information may be
disclosed outside the Department of Veterans Affairs (VA) only when authorized by the Privacy Act
of 1974, as amended. The routine uses for which VA may disclose the information can be found in
VA systems of records, including 58VA21/22, Compensation, Pension, Education and Rehabilitation
Records-VA, and 88VA244, Accounts Receivable Records-VA. VA systems of records and alterations
to the systems are published in the Federal Register. Any information provided by you, including
your Social Security Number, may be used in computer matching programs conducted in
connection with any proceeding for the collection of an amount owed by virtue of your
participation in any benefit program administered by VA.”

6.1c Describe how the notice provided for the collection of information is adequate to inform those
affected by the system that their information has been collected and is being used appropriately.
Provide information on any notice provided on forms or on Web sites associated with the collection.
The notice provided has been vetted by VA Chief Privacy Officer as being in compliance with
Federal and VA requirements for disclosure of information collection to the public/end user.

Notice is provided at https://www.pay.va.gov/index.cfm?action=step1
“Privacy Act Information: The information you furnish on this form, including your Social Security
Number, is used to associate your payment with your accounts receivable record so that we may
properly credit your account. Disclosure is voluntary. However, without disclosure, a credit card
transaction or direct debit transaction cannot be processed. The responses you submit are
confidential and protected from unauthorized disclosure by 38 U.S.C. 5701. The information may be
disclosed outside the Department of Veterans Affairs (VA) only when authorized by the Privacy Act
of 1974, as amended. The routine uses for which VA may disclose the information can be found in
VA systems of records, including 58VA21/22, Compensation, Pension, Education and Rehabilitation
Records-VA, and 88VA244, Accounts Receivable Records-VA. VA systems of records and alterations
to the systems are published in the Federal Register. Any information provided by you, including
your Social Security Number, may be used in computer matching programs conducted in
connection with any proceeding for the collection of an amount owed by virtue of your
participation in any benefit program administered by VA.”

6.2 Do individuals have the opportunity and right to decline to provide information? If so, is a
penalty or denial of service attached?
This question is directed at whether the person from or about whom information is collected can
decline to provide the information and if so, whether a penalty or denial of service is attached. This
question is related to privacy control IP-1, Consent, IP-2, Individual Access, and IP-3, Redress.
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The individual has the right to decline to provide information; however, on-line payment cannot be
processed if the individual refuses to provide information as is stated in the PayVA Privacy
Information link; “Privacy Act Information: The information you furnish on this form, including
your Social Security Number, is used to associate your payment with your accounts receivable record
so that we may properly credit your account. Disclosure is voluntary. However, without disclosure, a
credit card transaction or direct debit transaction cannot be processed. The responses you submit are
confidential and protected from unauthorized disclosure by 38 U.S.C. 5701.”
6.3 Do individuals have the right to consent to particular uses of the information? If so, how
does the individual exercise the right?
This question is directed at whether an individual may provide consent for specific uses or the
consent is given to cover all uses (current or potential) of his or her information. If specific consent
is required, how would the individual consent to each use? This question is related to privacy control
IP-1, Consent.
The individual consents to an overall usage of their information by choosing to proceed with the online payment as is stated in the Privacy Information link. “Privacy Act Information: The information
you furnish on this form, including your Social Security Number, is used to associate your payment
with your accounts receivable record so that we may properly credit your account. Disclosure is
voluntary. However, without disclosure, a credit card transaction or direct debit transaction cannot be
processed. The responses you submit are confidential and protected from unauthorized disclosure by
38 U.S.C. 5701.”

6.4 PRIVACY IMPACT ASSESSMENT: Notice
Describe the potential risks associated with potentially insufficient notice and what steps, if any, are
currently being taken to mitigate those identified risks. (Work with your System ISSO to complete all
Privacy Risk questions inside the document this section).
Consider the following FIPPs below to assist in providing a response:
Principle of Transparency: Has sufficient notice been provided to the individual?
Principle of Use Limitation: Is the information used only for the purpose for which notice was
provided either directly to the individual or through a public notice? What procedures are in place to
ensure that information is used only for the purpose articulated in the notice?
This question is related to privacy control TR-1, Privacy Notice, AR-2, Privacy Impact and Risk
Assessment, and UL-1, Internal Use.
Follow the format below:
Privacy Risk: The user may choose not to read the link that discusses the Privacy Information for
PayVA.

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Mitigation: The user is told in a Warning (without having to select the Privacy Information link,
“This U.S. Government computer system is for official use only. The files on this system include
Federal records that contain sensitive information. All activities on this system may be monitored to
measure network performance and resource utilization; to detect unauthorized access to or misuse of
the system or individual files and utilities on the system, including personal use; and to protect the
operational integrity of the system. Further use of this system constitutes your consent to such
monitoring. Misuse of or unauthorized access to this system may result in criminal prosecution and
disciplinary, adverse, or other appropriate action.”

Section 7. Access, Redress, and Correction
The following questions are directed at an individual’s ability to ensure the accuracy of the
information collected about him or her.
7.1 What are the procedures that allow individuals to gain access to their information?
These questions are related to privacy control IP-2, Individual Access, and AR-8, Accounting of
Disclosures.
7.1a Cite any procedures or regulations your program has in place that allow access to information.
These procedures, at a minimum, should include the agency’s FOIA/Privacy Act practices, but may
also include additional access provisions. For example, if your program has a customer
satisfaction unit, that information, along with phone and email contact information, should be
listed in this section in addition to the agency’s procedures. See 5 CFR 294 and the VA FOIA Web
page at http://www.foia.va.gov/ to obtain information about FOIA points of contact and
information about agency FOIA processes.
Individuals cannot access their information in PayVA. It is simply a place to submit their
information. PayVA is used to verify the amount of debt prior to payment to Department of
Treasury’s Pay.Gov. This can be found on the PayVA website. “If you have comments regarding this
burden estimate or any other aspect of this collection of information, contact: U.S. Department of
Veterans Affairs Debt Management Center P.O. Box 11930 Ft. Snelling, MN 55111 1-800-827-0648
(Toll Free) 612-970-5688 (fax)”
7.1b If the system is exempt from the access provisions of the Privacy Act, please explain the basis
for the exemption or cite the source where this explanation may be found, for example, a Final Rule
published in the Code of Federal Regulations (CFR).
The system is not exempt from the access provisions of the Privacy Act.

7.1c If the system is not a Privacy Act system, please explain what procedures and regulations are in
place that covers an individual gaining access to his or her information.
The system is a privacy act system.

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7.2 What are the procedures for correcting inaccurate or erroneous information?
Describe the procedures and provide contact information for the appropriate person to whom such
issues should be addressed. If the correction procedures are the same as those given in question 7.1,
state as much. This question is related to privacy control IP-3, Redress, and IP-4, Complaint
Management.
If inaccurate information is provided by the user on the PayVA website, the user is not able to move
forward with payment and the following message is received: “Please call the Debt Management
Center at 1-800-827-0648 before proceeding with this payment on Pay.gov.”
7.3 How are individuals notified of the procedures for correcting their information?
How are individuals made aware of the procedures for correcting his or her information? This may
be through notice at collection or other similar means. This question is meant to address the risk that
even if procedures exist to correct information, if an individual is not made fully aware of the
existence of those procedures, then the benefits of the procedures are significantly weakened.
This question is related to privacy control IP-3, Redress, and IP-4, Complaint Management.
Individuals are told via the PayVA website, “If you have comments regarding this burden estimate or
any other aspect of this collection of information, contact : U.S. Department of Veterans Affairs Debt
Management Center P.O. Box 11930 Ft. Snelling, MN 55111 1-800-827-0648 (Toll Free) 612-9705688 (fax)”
7.4 If no formal redress is provided, what alternatives are available to the individual?
Redress is the process by which an individual gains access to his or her records and seeks
corrections or amendments to those records. Redress may be provided through the Privacy Act and
Freedom of Information Act (FOIA), and also by other processes specific to a program, system, or
group of systems. Example: Some projects allow users to directly access and correct/update their
information online. This helps ensures data accuracy.
This question is related to privacy control IP-3, Redress, and IP-4, Complaint Management.

The individual must contact the Debt Management Center as is stated on the PayVA website.

7.5 PRIVACY IMPACT ASSESSMENT: Access, redress, and correction
Discuss what risks there currently are related to the Department’s access, redress, and correction
policies and procedures for this system and what, if any, steps have been taken to mitigate those
risks. For example, if a project does not allow individual access, the risk of inaccurate data needs
to be discussed in light of the purpose of the project. For example, providing access to ongoing law
enforcement activities could negatively impact the program’s effectiveness because the individuals
involved might change their behavior. (Work with your System ISSO to complete all Privacy Risk questions
inside the document this section).

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Consider the following FIPPs below to assist in providing a response:
Principle of Individual Participation: Is the individual provided with the ability to find out whether a
project maintains a record relating to him?
Principle of Individual Participation: If access and/or correction is denied, then is the individual
provided notice as to why the denial was made and how to challenge such a denial?
Principle of Individual Participation: Is there a mechanism by which an individual is able to prevent
information about him obtained for one purpose from being used for other purposes without his
knowledge?
This question is related to privacy control IP-3, Redress.
Follow the format below:
Privacy Risk: There is a risk the user will not enter the correct information from their DMC
letter.
Mitigation: The payment will not be able to be processed and they will have to contact the Debt
Management Center at 1-800-827-0648 (Toll Free) or 612-970-5688 (fax).

Section 8. Technical Access and Security
The following questions are intended to describe technical safeguards and security measures.
8.1 What procedures are in place to determine which users may access the system, and are they
documented?
These questions are related to privacy control AR-7, Privacy-Enhanced System Design and
Development.
8.1a Describe the process by which an individual receives access to the system.
System Administrators are granted access via Electronic Permission Access System (EPAS) which
is a VA system that is monitored and audited. Procedure for New Account/ Modification/ Reactivation/ Deactivation of accounts:1) Requestor – submits an ePAS request with all appropriate
access noted and routed to Supervisor for approval. The request will be submitted by completing a
request through the Infrastructure Operations (IO) ePAS link. 2) For new accounts only a)
(Employee) Human Resource Security - validates information for new Full Time Employees (FTE)
and routes the request to the Information Security Officer (ISO) for approval. b) (Contractor)
Physical Security - validates new contractor employee and routes the request to the ISO for
approval.3) ISSO - reviews, validates the request and routes it to Delegate Authority Official (DAO)
for verification and approval. If the request is denied, ISSO sends the notification of denial to the
requestor.4) Once the DAO approves the request it is automatically routed to the appropriate
Administrative group(s) for access to the systems for processing to create/remove accounts. System
Administrators will process the ePAS request based on the access requested by the requestor.5) The
requestor will receive the notification that the request is completed. Anyone may access the PayVA
website, but the user must verify their identity by entering information found in their letter received
from the DMC. If the information is entered incorrectly, the user receives the following message,
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“Please call the Debt Management Center at 1-800-827-0648 before proceeding with this payment on
Pay.gov.”
8.1b Identify users from other agencies who may have access to the system and under what roles
these individuals have access to the system. Who establishes the criteria for what PII can be shared?
No users from other agencies have access to PayVA.
8.1c Describe the different roles in general terms that have been created to provide access to the
system. For example, certain users may have "read-only" access while others may be permitted to
make certain amendments or changes to the information.
No users of PayVA have permissions sufficient to change the data served on PayVA.gov.
8.2 Will VA contractors have access to the system and the PII? If yes, what involvement will
contractors have with the design and maintenance of the system? Has a contractor
confidentiality agreement, Business Associate Agreement (BAA), or a Non-Disclosure
Agreement (NDA) been developed for contractors who work on the system?
If so, how frequently are contracts reviewed and by whom? Describe the necessity of the access
provided to contractors to the system and whether clearance is required. If Privacy Roles and
Responsibilities have been established to restrict certain users to different access levels, please
describe the roles and associated access levels. Explain the need for VA contractors to have access
to the PII. This question is related to privacy control AR-3, Privacy Requirements for Contractors
and Service Providers.
Contractors may have access to PayVA. All contractors sign the VA Rules of Behavior, just as VA
Employees do, and they pass a Background Investigation prior to receiving access to PayVA.VA
contract employee access is verified through the Contracting Officer’s Representative (COR) and
other VA supervisory/administrative personnel before access is granted to any VA system.
Contractor access is reviewed annually at a minimum. The contractors who provide support to the
system are required to complete annual VA Privacy and Information Security and Rules of behavior
training via the VA Talent Management System (TMS). All contractors are vetted using the VA
background investigation process and must obtain the appropriate level background investigation for
their role. Contractors with systems administrative access are required to complete additional rolebased training prior to gaining system administrator access. Generally, contracts are reviewed at the
start of the initiation phase of acquisitions and again during procurement of option years by the
Contracting Officer, Information Security Officer, Privacy Officer, COR, Procurement
Requestor/Program Manager and any other stakeholders required for approval of the acquisition.
Contracts generally have an average duration of 1-3 years and may have option years stipulated in
the original contract.
8.3 Describe what privacy training is provided to users either generally or specifically relevant
to the program or system?

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VA offers privacy and security training. Each program or system may offer training specific to the
program or system that touches on information handling procedures and sensitivity of information.
Please describe how individuals who have access to PII are trained to handle it appropriately.
This question is related to privacy control AR-5, Privacy Awareness and Training.
Personnel that will be accessing information systems must read and acknowledge their receipt and
acceptance of the VA National Rules of Behavior (ROB) or VA Contractor's ROB prior to gaining
access to any VA information system or sensitive information. The rules are included as part of the
VA Privacy and Security Awareness training which all personnel must complete via the VA’s Talent
Management System (TMS). After the user’s initial acceptance of the Rules, the user must re-affirm
their acceptance annually as part of the privacy and security awareness training. Acceptance is
btained via electronic acknowledgment and is tracked through the TMS system. The following
questions are directed at providing notice to the individual of the scope of information collected, the
right to consent to uses of the information, and the right to decline to provide information. System
administrators are required to complete additional role-based training.
8.4 Has Authorization and Accreditation (A&A) been completed for the system?
YES
8.4a If Yes, provide:
1. The Security Plan Status: Approved
2. The System Security Plan Status Date: 10/17/2022
3. The Authorization Status: Authority to Operate (ATO)
4. The Authorization Date: 01/09/2023
5. The Authorization Termination Date: 01/09/2024
6. The Risk Review Completion Date: 09/21/2022
7. The FIPS 199 classification of the system (LOW/MODERATE/HIGH): Moderate
Please note that all systems containing SPI are categorized at a minimum level of “moderate” under
Federal Information Processing Standards Publication 199.

8.4b If No or In Process, provide your Initial Operating Capability (IOC) date.

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Section 9 – Technology Usage
The following questions are used to identify the technologies being used by the IT system or project.

9.1 Does the system use cloud technology? If so, what cloud model is being utilized?
If so, Does the system have a FedRAMP provisional or agency authorization? If the system does
use cloud technology, but does not have FedRAMP authorization, explain how the Cloud Service
Provider (CSP) solution was assessed and what FedRAMP documents and processes were used
for the assessment in order to comply with VA Handbook 6517. Types of cloud models include:
Software as a Service (SaaS), Infrastructure as a Service (IaaS), Platform as a Service (PaaS),
Commercial off the Shelf (COTS), Desktop as a Service (DaaS), Mobile Backend as a Service
(MBaaS), Information Technology Management as a Service (ITMaaS). This question is related
to privacy control UL-1, Information Sharing with Third Parties.
Note: For systems utilizing the VA Enterprise Cloud (VAEC), no further responses are
required after 9.1. (Refer to question 3.3.1 of the PTA)
The system does not use Cloud technology.

9.2 Does the contract with the Cloud Service Provider, Contractors and VA customers
establish who has ownership rights over data including PII? (Provide contract number
and supporting information about PII/PHI from the contract). (Refer to question 3.3.2 of
the PTA) This question is related to privacy control AR-3, Privacy Requirements for
Contractors and Service Providers.
The system does not use Cloud technology.

9.3 Will the CSP collect any ancillary data and if so, who has ownership over the ancillary
data?
Per NIST 800-144, cloud providers hold significant details about the accounts of cloud
consumers that could be compromised and used in subsequent attacks. Ancillary data also
involves information the cloud provider collects or produces about customer-related activity in
the cloud. It includes data collected to meter and charge for consumption of resources, logs and
audit trails, and other such metadata that is generated and accumulated within the cloud
environment.
This question is related to privacy control DI-1, Data Quality.
The system does not use Cloud technology.

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9.4 NIST 800-144 states, “Organizations are ultimately accountable for the security and
privacy of data held by a cloud provider on their behalf.” Is this principle described in
contracts with customers? Why or why not?
What are the roles and responsibilities involved between the organization and cloud provider,
particularly with respect to managing risks and ensuring organizational requirements are met?
This question is related to privacy control AR-3, Privacy Requirements for Contractors and
Service Providers.
The system does not use Cloud technology.

9.5 If the system is utilizing Robotics Process Automation (RPA), please describe the role of the
bots.
Robotic Process Automation is the use of software scripts to perform tasks as an automated
process that executes in parallel with or in place of human input. For example, will the
automation move or touch PII/PHI information. RPA may also be referred to as “Bots” or
Artificial Intelligence (AI).
The system does not use RPA.

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Section 10. References
Summary of Privacy Controls by Family
Summary of Privacy Controls by Family

ID

Privacy Controls

AP

Authority and Purpose

AP-1

Authority to Collect

AP-2

Purpose Specification

AR

Accountability, Audit, and Risk Management

AR-1

Governance and Privacy Program

AR-2

Privacy Impact and Risk Assessment

AR-3

Privacy Requirements for Contractors and Service Providers

AR-4

Privacy Monitoring and Auditing

AR-5

Privacy Awareness and Training

AR-7

Privacy-Enhanced System Design and Development

AR-8

Accounting of Disclosures

DI

Data Quality and Integrity

DI-1

Data Quality

DI-2

Data Integrity and Data Integrity Board

DM

Data Minimization and Retention

DM-1

Minimization of Personally Identifiable Information

DM-2

Data Retention and Disposal

DM-3

Minimization of PII Used in Testing, Training, and Research

IP

Individual Participation and Redress

IP-1

Consent

IP-2

Individual Access

IP-3

Redress

IP-4

Complaint Management

SE

Security

SE-1

Inventory of Personally Identifiable Information

SE-2

Privacy Incident Response

TR

Transparency

TR-1

Privacy Notice

TR-2

System of Records Notices and Privacy Act Statements

TR-3

Dissemination of Privacy Program Information

UL

Use Limitation
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ID

Privacy Controls

UL-1

Internal Use

UL-2

Information Sharing with Third Parties

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Signature of Responsible Officials
The individuals below attest that the information provided in this Privacy Impact
Assessment is true and accurate.

MORGEN
EGESDAL

Digitally signed by MORGEN
EGESDAL
Date: 2023.08.24 16:30:57 -05'00'

Privacy Officer, Morgen Egesdal

James W
Weinhold 3565781

Digitally signed by James W Weinhold 3565781
Date: 2023.08.28 14:16:07 -05'00'

Information Systems Security Officer, James Weinhold

Karen L. Kelly
105014

Digitally signed by Karen L. Kelly
105014
Date: 2023.08.28 16:10:32 -04'00'

Information Systems Owner, Karen L. Kelly

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APPENDIX A-6.1
Please provide a link to the notice or verbiage referred to in Section 6 (a notice may include a
posted privacy policy, a Privacy Act notice on forms).
“Privacy Act Information: The information you furnish on this form, including your Social Security
Number, is used to associate your payment with your accounts receivable record so that we may
properly credit your account. Disclosure is voluntary. However, without disclosure, a credit card
transaction or direct debit transaction cannot be processed. The responses you submit are
confidential and protected from unauthorized disclosure by 38 U.S.C. 5701. The information may be
disclosed outside the Department of Veterans Affairs (VA) only when authorized by the Privacy Act
of 1974, as amended. The routine uses for which VA may disclose the information can be found in
VA systems of records, including 58VA21/22, Compensation, Pension, Education and Rehabilitation
Records-VA, and 88VA244, Accounts Receivable Records-VA. VA systems of records and alterations
to the systems are published in the Federal Register. Any information provided by you, including
your Social Security Number, may be used in computer matching programs conducted in
connection with any proceeding for the collection of an amount owed by virtue of your
participation in any benefit program administered by VA.”

https://www.pay.va.gov/index.cfm?action=step1

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HELPFUL LINKS:
Record Control Schedules:
https://www.va.gov/vhapublications/rcs10/rcs10-1.pdf

General Records Schedule 1.1: Financial Management and Reporting Records (FSC):
https://www.archives.gov/files/records-mgmt/grs/grs01-1.pdf

National Archives (Federal Records Management):
https://www.archives.gov/records-mgmt/grs

VHA Publications:
https://www.va.gov/vhapublications/publications.cfm?Pub=2

VA Privacy Service Privacy Hub:
https://dvagov.sharepoint.com/sites/OITPrivacyHub

Notice of Privacy Practice (NOPP):
VHA Notice of Privacy Practices
VHA Handbook 1605.04: Notice of Privacy Practices

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