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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:

Public Health Law Fellowship Program Information Collection
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

OPHLS Director

POC Name

Matthew Penn

POC Organization CDC
POC Email

[email protected]

POC Phone

404.498.0452
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

The evaluations will be administered through Redcap, a CDC
system with a moderate-level security authorization.

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 the information collection is to evaluate the
Public Health Law Program (PHLP) fellowship throughout its
life cycle. This PHLP fellowship program ("Fellowship")
supports CDC's broad mission to build and develop the
nation's public health workforce and increase diversity in the
workforce.

The types of information to be collected, maintained, and
shared include a wide array of data related to the evaluation of
the Fellowship. The types of information collected on the
fellows include: sname, email address, self-assessed
Describe the type of information the system will
knowledge of public health law; college or university;
collect, maintain (store), or share. (Subsequent
voluntary demographic data (race, gender, disability
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questions will identify if this information is PII and ask identification); satisfaction level with the fellowship program;
about the specific data elements.)
and post-graduation employment/plans. Information will also
be collected from additional interested parties such as host
institutions about the benefits and challenges of working with
fellows. Outreach efforts for fellows and hosts will also be
evaluated.
The purpose of the information collection is to evaluate the
Public Health Law Program (PHLP) fellowship throughout its
life cycle. This PHLP fellowship program ("Fellowship")
supports CDC's broad mission to build and develop the
nation's public health workforce.

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

In order to understand the value of the fellowship, both to the
individual fellows and the the broader field of the public health
workforce, we need to ask fellows and other interested parties
about the knowledge the fellows gained throughout the
program. We need to know the fellows' employment plans
after graduation to make sure the fellowship is contributing to
the public health workforce. Names and email addresses will
be collected.
Our funding requires us to support equity and build a diverse
workforce. Therefore, we need to measure our outreach efforts
and ask fellows some demographic questions about their race,
gender, and disability status to identify any possible
differences in experience and make sure we have attracted
diverse candidates.
We intend to retain identifiable information temporarily, and
deidentified information permanently.

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

Race

Occupation information

Gender
Disability status

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 Fellows who have matriculated in the Public Health
Law Fellowship program, preceptors of fellows in the

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)

100-499
The primary purpose for collecting PII is to evaluate the
Fellowship to ensure equitable and robust experiences for
fellows and hosts
The secondary purpose for collecting PII is to evaluate outreach
efforts and ensure equitable and diverse recruitment of fellows
and hosts

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
5 USC 301, Departmental regulations
and disclosure specific to the system and program.

22

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

Yes
No

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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
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?

The OMB information collection approval for this information
collection is still in process.
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

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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

Survey instructions will note that some questions may, when
combined, lead to identification of individuals in limited
circumstances. Instructions will explain that all questions are
voluntary and that these questions are asked to evaluate the
fellowship. The instructions will also alert participants that
they may choose not to answer any question and explain that
PII will not be shared with outside entities; however,
aggregated responses that are non-identifiable may be shared.
Voluntary

Is the submission of PII by individuals voluntary or
mandatory?

Mandatory

Describe the method for individuals to opt-out of the
collection or use of their PII. If there is no option to
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object to the information collection, provide a
reason.

The collection is best characterized as "opt-in," so participants
will be asked to provide information but are never required to
do so. All PII questions contain a "prefer not to respond"
answer choice. Additionally, no questions are required.

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.

Individuals will be emailed the first survey (welcome or presurvey) via a non-public web link. These email addresses are
not part of data collection and are not associated with
individual responses. However, the Fellowship will already
have these email addresses as part of administrating the
fellowship and can provide change updates and request
consent via these email addresses. Consent cannot be
obtained from individuals who no longer use the email
addresses we have on file.

Collected information would only identifiable in limited
circumstances. If a respondent believes they have responded
to questions so uniquely as to make that information
Describe the process in place to resolve an
identifiable, they can request the information be removed. If
individual's concerns when they believe their PII has we are able to identify which record belongs to that
29 been inappropriately obtained, used, or disclosed, or respondent, we will remove the record. Individuals with
that the PII is inaccurate. If no process exists, explain concerns that their PII has been inappropriately obtained,
why not.
used, or disclosed, or that the PII is inaccurate, can address
their concerns to the Evaluation Lead of the Public Health Law
Fellowship, Organization: Public Health Law Program, CSTLTS,
CDC.
Describe the process in place for periodic reviews of
PII contained in the system to ensure the data's
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integrity, availability, accuracy and relevancy. If no
processes are in place, explain why not.

31

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

Fellowship leadership/evaluation team will review data
collection and retention at the start of each cohort. Participants
will be provided with Fellowship contact information to allow
them to inform the Fellowship if their contact information
changes
Users

Fellowship leadership/evaluation team

Administrators

Fellowship leadership/evaluation
team

Developers
Contractors
Others

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Describe the procedures in place to determine which REDCap, which is the system where the data will be stored,
permits user groups that allow administrators to set
32 system users (administrators, developers,
permissions for viewing PII. Only fellowship leadership/
contractors, etc.) may access PII.
evaluation team will have permissions to view PII.
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.

REDCap permits user groups that allow administrators to set
permissions for viewing PII. When adding new users to
REDCap, program leadership/evaluation team will decide prior
to granting access the correct level of permissions for that user
and will grant access to PII only when necessary. Only program
leadership/evaluation team will have permissions to view PII.

Identify training and awareness provided to
personnel (system owners, managers, operators,
contractors and/or program managers) using the
34
system to make them aware of their responsibilities
for protecting the information being collected and
maintained.

All personnel with access to PII will be coached on their
responsibilities for protecting the information collected and/or
maintained.

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

All personnel with access to PII will be coached in granting or
restricting REDCap access, permissions, and related data
functions.

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

Yes
No
Records may be transferred to a Federal Records Center for
storage when no longer needed for evaluation or analysis.
Disposal methods include the paper recycling process, burning
or shredding hard copy records, and erasing computer files.

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

The records retention schedule is CDC 3-6, Instructional and
Problem-Solving Records, (Training Program Records) (GRS 1,
Item29a1) Documents created to identify and analyze training
problems such as principles and techniques of problem
analysis, system design, and evaluation of training needs.
Authorized Disposition: Destroy when 5 years old or 5 years
after completion of a specific training program.
Administrative: All users with access to PII will be coached on
data privacy and appropriate access prior to being granted
user access to PII data. Only designated personnel will be
granted access.

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

Technical: PII will be collected behind CDC's Secure Access
Management System (SAMS) server(s) in REDCap Main. No
users aside from designated fellowship leadership/evaluators
will be granted access to the data records. All data collection
involving PII will be collected exclusively online via SAMS in
REDCap.
Physical: All PII will be electronically collected. There are no
physical controls because no PII will be generated in a physical
form.

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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: 2023.02.28
for Privacy
07:19:32 -05'00'

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