KAP PIA updates 10102023 CPO signed

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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:

08/25/23

Knowledge Attitudes and Practices (KAPs)
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.

Planning
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

Health Communication Specialist

POC Name

Jennifer Farramola

POC Organization NCBDDD/DBDID
POC Email

[email protected]

POC Phone

404-498-2262
New
Existing
Yes
No

8b Planned Date of Security Authorization
Not Applicable

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8c

9

Briefly explain why security authorization is not
required

Indicate the following reason(s) for updating this PIA.
Choose from the following options.

Not applicable.
PIA Validation (PIA
Refresh/Annual Review)
Anonymous to NonAnonymous
New Public Access
Internal Flow or Collection

Significant System
Management Change
Alteration in Character of
Data
New Interagency Uses
Conversion

Commercial Sources
OMB submission
10

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

11 Describe the purpose of the system.

Not applicable.
Knowledge Attitudes and Practices (KAPs) project is formative
research focus group project that will be conducted among
Hispanic/Latina women of reproductive age to examine folic
acid and fortified food awareness, food and supplement use
practices, as well as messaging and channels to reach Hispanic/
Latina women. The result of this project will inform future
intervention activities to prevent neural tube defects among
Hispanic/Latina women of reproductive age.
The KAPs data collection will include information from
Hispanic/Latina women of reproductive age including the
following data elements; first and last name, email address,
race, ethnicity, country of origin and phone number (for the
sole purpose of screening potential participants and
contacting focus group respondents). Respondents will be
contacted via text/phone, or email (whichever method they
prefer) to complete an online screener, informed consent, and
receive reminders with information on their focus group
location/date/time.

Describe the type of information the system will
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask A link to the online screener and online consent form will be
shared with each respondent. The screener will also inform
about the specific data elements.)
participants of the nature of the study and the voluntary
nature of participation. Study data will be collected and
maintained until data collection for the project ends.

Non-direct contractor is administering the project using a
UserID and password for privilege and/or standard users to
access the network prior to being able to access the KAPs
forms. Staff information (name, email address, and phone
number) to be used to issue their user credentials (username
and password) for system authentication purposes.

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KAPs is a focus group study with Hispanic/Latina women of
reproductive age to understand their folic acid knowledge and
use. Temporary data will be collected by a contractor and will
only be retained until the end of the contract, after
disaggregating and summarizing the results of the study for
CDC.

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

PII will be collected from the Hispanic/Latina women using an
online platform (i.e., Qualtrics) that contains a screening form
for potential participants of either an in-person or virtual focus
group. The screening form will collect the following: first name,
last name, email address, ethnicity, race, country of origin and
phone number (for the sole purpose of contacting
respondents). In addition, an informed consent form will be
provided to those who have agreed to participate in a focus
group and will be administered as either a paper-based or
digital form (i.e., using Microsoft Forms). The consent form will
collect first name, last name, and email address (for the sole
purpose of confirming those individuals who agree to
participate in the focus group and to send an incentive upon
completing the focus group).
A link to the online screener and online consent form will be
shared with each respondent. Study data will be collected and
maintained until data collection for the project ends.
Non-direct contractor is administering the project using a
UserID and password for privilege and/or standard users to
access the network prior to being able to access the KAPs
forms. Staff information (name, email address, and phone
number) to be used to issue their user credentials (username
and password) for system authentication purposes.
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

Country of origin

Ethnicity

Other...

Race

Other...

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Employees
Public Citizens
16

Indicate the categories of individuals about whom PII
is collected, maintained or shared.

Business Partners/Contacts (Federal, state, local agencies)
Vendors/Suppliers/Contractors
Patients
Other

17 How many individuals' PII is in the system?

18 For what primary purpose is the PII used?

19

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

<100
PII will be used to screen people for eligibility to join a focus
group and to contact all eligible focus group participants. First
and last names, email addresses, ethnicity, race, country of
origin, and phone numbers will be collected when screening
potential participants for focus group eligibility. Subsequently,
those who are eligible to participate in a focus group will be
contacted using their email address and/or phone number to
follow up with participants in an effort to invite them to be
scheduled for a focus group. Email addresses and phone
numbers will also be used to send reminder/follow-up emails
about when to attend the focus group and acquire their name
(signature) on a consent form before participating in the focus
group. Upon completing a focus group, email addresses will be
used to send an electronic gift card.
None

20 Describe the function of the SSN.

Not applicable

20a Cite the legal authority to use the SSN.

Not applicable

21

Identify legal authorities governing information use Public Health Service Act, Section 301, "Research and
and disclosure specific to the system and program.
Investigation," (42 U.S.C. 241)

22

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

Yes
No
Published:

Identify the number and title of the Privacy Act
System of Records Notice (SORN) that is being used
22a
to cover the system or identify if a SORN is being
developed.

09-20-0136, Epidemiologic Studies and Surveilla

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?

Approval pending
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
No agreement is in place because the information will not be
24b Matching Agreement, Memorandum of
shared with anyone outside of the project staff from the
Understanding (MOU), or Information Sharing
contract agency.
Agreement (ISA)).
Describe the procedures for accounting for
24c
disclosures

CDC does not plan to disclose a record outside for any reason
other than the Freedom of Information Act (FOIA). CDC will not
have access to PII that the contractor will collect. All data will
be shared in aggregate form.

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.

Participants will be provided through an informed consent
form (paper and online) and a screener (paper and online).
These documents will include a Privacy Act Statement
disclosing that personal information will be collected.

26

Is the submission of PII by individuals voluntary or
mandatory?

Voluntary
Mandatory

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Describe the method for individuals to opt-out of the
collection or use of their PII. If there is no option to
27
object to the information collection, provide a
reason.

Individuals will be given the opportunity to opt-in to the
collection by signing an informed consent form and may
choose to not answer a question during the focus group. The
opt-out process is not participating.
No major changes are expected to the online data collection.
The online data collection forms will only be used to screen
individuals for eligibility to participate in a focus group and
obtain consent from those who are confirmed participants.
There will not be ongoing use of the PII-related data collected.

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 Alternatively, note that CDC publishes project reporting
requirements and announces major changes in Federal
why they cannot be notified or have their consent
Register Notices.
obtained.

Since all PII will be collected and handled by the entity,
individuals will have access to a contact person, email address
Describe the process in place to resolve an
individual's concerns when they believe their PII has and phone number with the project to handle concerns or
29 been inappropriately obtained, used, or disclosed, or answer questions. Participants may choose to call
that the PII is inaccurate. If no process exists, explain 202-794-8199 and reference the KAPs Women's Health Study if
there are any concerns . Any concerns will be considered,
why not.
investigated, and resolved through processes that are in place
with the contract agency.

Describe the process in place for periodic reviews of
PII contained in the system to ensure the data's
30
integrity, availability, accuracy and relevancy. If no
processes are in place, explain why not.

The information collected will be gathered at the inception for
screening, with only a subset of information collected again on
the informed consent form (i.e., first and last names, email
address). Participants who are screened and deemed eligible
(using demographic information collected) to join a focus
group, will then be contacted using their email addresses and
phone numbers to schedule a time to participate in a focus
group. Scheduled participants will also receive email and text
reminders leading up to their scheduled focus group date.
Upon completing a focus group, email addresses will be used
to mail an electronic gift card to all participants. No additional
processes will be in place for periodic review. Once PII is used
for its intended purpose (i.e., screen and contact confirmed
participants) and participants are successfully reached to join
the study, no additional reviews of PII will be needed. PII will be
destroyed by the contractor at the end of the contract on
September 28, 2024.
Users
Administrators

31

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

Developers
Contractors

Research staff and analysts will use the
data to follow up with participants

Others

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The project director and program manager is responsible for
ensuring that personnel have controlled access only to what is
Describe the procedures in place to determine which relevant to their specific work on the project. The project
32 system users (administrators, developers,
director oversees the personnel supporting the data collection,
contractors, etc.) may access PII.
assigns roles and responsibilities, and routinely reviews and
assesses personnel's need-to-know status. The program
manager will ensure specific access rights are implemented.
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.

Only staff who will be involved in collecting screening forms
and informed consent will have access to the online platforms
that are used to collect PII. This includes the project manager
and project director at the contracting agency.

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.

The contractors that process these data files complete training
annually (e.g., 2023 Cybersecurity Training) in standards and
procedures to maintain the security and confidentiality of PII.
Audits are conducted throughout the year to ensure
adherence to these standards.

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

None

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

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

Yes
No
Contractors (i.e., the entity) will transfer de-identified records
to CDC before the end of the award through their password
protected SharePoint site. Contractors will destroy PII at the
end of the contract on September 28, 2024. CDC will not have
access to the systems that the entity will be using and is
therefore limited in its ability to validate the destruction of the
PII by the contractor. Within CDC, any program records that
summarize the results of this data collection will be retained,
stored, and disposed of in accordance with CDC’s records
control schedule for Scientific and Research Project Records,
N1-442-09-01.
PII data will be encrypted and stored on the contractor’s
secured server.

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

• Administrative Controls:
Administrative controls include a security plan, contingency
plan, file back-up, least privilege, and training to ensure the
necessary protections for the PII are in place
• Technical Controls:
PII data is encrypted and stored in a secure database. Technical
controls are in place to manage user identity, identity proofing,
authentication, and authorization.
• Physical Controls:
Computer facilities at all sites have restricted access and are
protected from potential fire and water damage.

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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

Beverly E.
Walker -S

Digitally signed by
Beverly E. Walker -S
Date: 2023.10.10
15:49:27 -04'00'

HHS Senior
Agency Official
for Privacy

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