QARS - Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-57568

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-8428690-011835

2a Name:

7/14/2022 9:56:16 AM

Quarantine Activity Reporting System (QARS)
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.

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)?

8a Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Business Steward

POC Name

Maryan Reynolds

POC Organization CDC/OID/NCEZID/DGMQ
POC Email

[email protected]

POC Phone

404.498.6027
New
Existing
Yes
No

Sep 23, 2022

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11 Describe the purpose of the system.

The Quarantine Activity Reporting System (QARS) is owned
and operated by the CDC's Division of Global Migration and
Quarantine (DGMQ). QARS collects data on individuals subject
to quarantine or isolation orders, ill travelers (i.e., passengers
and crew), contacts of ill travelers and/or individuals exposed
or suspected of being exposed to serious communicable
diseases.
QARS is an internal CDC system for collecting data on
individuals subject to quarantine or isolation orders, ill
travelers (i.e., passengers and crew), contacts of ill travelers,
and/or individuals exposed or suspected of being exposed to
serious communicable diseases.

The Information collected from select general population
individuals are: Name, address, telephone number(s), date of
birth, e-Mail address, military status, Passport Number, foreign
Describe the type of information the system will
travel information, and medical information (case reports,
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask illness response forms, medical assessments, medical records
(including but not limited to clinical, hospital and laboratory
about the specific data elements.)
data and data from other relevant tests). Documents collected
are for the purpose of carrying out agency responsibilities
under sections 311 and 361-368 of the Public Health Services
Act. Passenger and crew manifests from conveyances carrying
individuals subject to 42 CFR parts 70 and 71.
Access to data is via Personal Identity Verification (PIV) card
authentication via CDC Active Directory. Active Directory is a
separate system with its own Privacy Impact Assessment.

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

QARS maintains records on the conduct of activities (e.g.,
quarantine, isolation) that fulfills the Department of Health and
Human Services (HHS)'s and CDC's statutory authority under
sections 311, 361-368 of the Public Health Service Act to
prevent the introduction, transmission and spread of
communicable diseases. Records are collected when
individual known or suspected to have been exposed to
serious communicable diseases arrives into the United States
from foreign countries or is engaged in interstate or
international movement. These records are used to take such
actions (e.g., quarantine or isolation individual above) as
necessary to prevent the introduction, transmission, and
spread of serious communicable diseases from persons
arriving into the United States from foreign countries or
persons engaged in interstate or international movement.
The Information collected from select general population
individuals are: Name, address, telephone number(s), date of
birth, e-Mail address, military status, Passport Number, foreign
travel information, and medical information (case reports,
illness response forms, medical assessments, medical records
(including but not limited to clinical, hospital and laboratory
data and data from other relevant tests).
Access to data is PIV authentication by CDC Active Directory
(AD)/Personal Identity Verification (PIV) card. AD is a separate
system with its own Privacy Impact Assessment.

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Yes

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

15

No

Indicate the type of PII that the system will collect or
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
Foreign travel information
Medical records information
Laboratory and other relevant tests

Employees
Public Citizens
16

Business Partners/Contacts (Federal, state, local agencies)

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

Vendors/Suppliers/Contractors
Patients
Other

17 How many individuals' PII is in the system?
18 For what primary purpose is the PII used?

19

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

500-4,999
PII is collected for the identification of ill travelers who are
suspected of having a disease of public health interest.
PII may be used for confirming case travel details, locating
potentially exposed contacts, and initiating community-based
investigation.

20 Describe the function of the SSN.

NA

20a Cite the legal authority to use the SSN.

NA

21

Identify legal authorities governing information use Public Health Service Act, Section Sections 311, 361-368 (42
and disclosure specific to the system and program.
U.S.C. 242k) and 42 CFR parts 70 and 71.

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.

09-20-0171, Quarantine-and-Traveler-Related
Activities, Including Records for Contact Tracing
Investigation and Notification

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?

OMB Control No.0920-0134, CDC ID 0920-19MG Expires
August 31, 2022 Renewal pending with OMB.
Yes
No

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Within HHS
Purpose: To more effectively deal with outbreaks and other
significant public health conditions.
Other Federal
Agency/Agencies

24a

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

Purpose: To more effectively deal with outbreaks and other
significant public health conditions.
State or Local
Agency/Agencies
Purpose: To more effectively deal with outbreaks and other
significant public health conditions.
Private Sector
Purpose: To medical personnel providing evaluation and
care for ill or exposed persons, including travelers.

Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
24b Matching Agreement, Memorandum of
None
Understanding (MOU), or Information Sharing
Agreement (ISA)).

24c

Describe the procedures for accounting for
disclosures

Describe the process in place to notify individuals
25 that their personal information will be collected. If
no prior notice is given, explain the reason.
26

Is the submission of PII by individuals voluntary or
mandatory?

All disclosures of information are processed through CDC's
Epidemic Information Exchange System (Epi-X). QARS
maintains a record of each disclosure sent to Epi-X for
processing and has the capability to produce detailed reports
and summaries of those disclosures.
During a personal encounter, the individual is notified that
personal information will be collected.
Voluntary
Mandatory

Due to CDC's Public Health mandate and the time sensitive
nature of public health events, DGMQ does not request formal
consent to collect or use PII. If the individual does not wish to
Describe the method for individuals to opt-out of the provide the information, only partial information will be
collection or use of their PII. If there is no option to
collected. However, if an individual refuses to provide the
27
object to the information collection, provide a
requested information and it is reasonably believed that the
reason.
individual is infected with or has been exposed to a
quarantinable communicable disease, CDC may quarantine,
isolate, or place the individual under surveillance under 42 CFR
71.32 and 71.33.
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.

The QARS system's Authorization to Operate on the CDC
network does not allow allow changes that would contradict
the disclosure and/or data uses described in Privacy Act
System of Records Notice (SORN) 09-20-0171, Quarantine- and
Traveler-Related Activities, Including Records for Contact
Tracing Investigation and Notification under 42 CFR Parts 70
and 71. Therefore this process is not applicable and has not
been developed.

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To report and resolve concerns, individuals may contact
Director, NCPDCID, Coordinating Center for Infectious
Diseases, Bldg. 1, Rm. 6013, MS C12, Centers for Disease
Control and Prevention, 1600 Clifton Road, NE., Atlanta, GA
30333. The correspondence should reasonably identify the
record and specify the information being contested, the
corrective action sought, and the reasons for requesting the
Describe the process in place to resolve an
individual's concerns when they believe their PII has correction, along with supporting information to show how
29 been inappropriately obtained, used, or disclosed, or the record is inaccurate, incomplete, untimely, or irrelevant.
that the PII is inaccurate. If no process exists, explain
Person having complaints, concerns, or questions about
why not.
Quarantine Activity Reporting System privacy practices can
send these inquiries via email, phone, or postal mail. General
public communications are directed to CDC's Human Research
Protection Office or their designee, for internal review, and
then are forwarded to CDC’s Senior Agency Official for Privacy,
as necessary to review concerns and respond to resolve the
individual’s inquiry.

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 system has validation and integrity rules in place. Subject
Matter Experts conduct at a minimum annual reviews and
thereafter periodic (monthly/quarterly) review data to ensure
accuracy. Data is collected on a case by case basis for
immediate identification of ill travelers who are suspected of
having a disease of public health interest. Although
immediate efforts may be made to confirm information during
the investigation of an event, no efforts are made to
periodically (outside the initial investigation) follow-up or
review the integrity, availability, accuracy, and/or relevancy of
the PII data collected.
Users

31

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

Administrators

Contact ill passengers for follow-up,
contact tracing because of possible
exposure to disease of public health
significance.
Maintenance (Patches, updates) and
compliance to integrity, accountability
and confidentiality is maintained.

Developers
Contractors
Others
Describe the procedures in place to determine which The Business Steward is limiting access to the smallest possible
32 system users (administrators, developers,
number of people necessary to access PII data for conducting
contractors, etc.) may access PII.
official responsibilities through specific Role-based

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.

QARS access roles are designed to ensure user access to PII is
limited to the minimum amount of information necessary to
perform their job. Least privilege, Role Based Access methods
are used to allow those with access to PII to only access the
minimum amount of information necessary to perform their
job. The system administrator is responsible for setting up the
user access to the system based on the CDC user ID and the
permissions assigned to it.

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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 CDC personnel are required to complete annual Security
and Privacy Awareness Training.

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

All CDC employees who have access to PII/sensitive
information are required to complete HHS/CDC Role based
training.

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
Records are maintained in accordance with General Records
Schedule (GRS) and comply with CDC Records Control
Schedule (RCS). In accordance with GRS 5.2, final reports are
created to document programmatic decisions, policies, and
other related issues and are maintained permanently (CDC
RCS, B-321, 2&4). Input data of Non- electronic records
manually data entered are maintained and disposed of when
no longer needed. Other input/output records are disposed of
when no longer needed: Disposal methods include erasing
computer tapes, burning or shredding paper materials or
transferring records to the Federal Records Center when no
longer needed for evaluation and analysis.
Administrative controls: Completion of training requirements;
risk analyses performed annually; branch management
reviewing access requests and granting minimal amount of
access.

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

Technical controls: Users are authenticated and data secured
using operating system and server security, administered by
the local system administrator. PII data is encrypted at rest and
in transits with access restricted to specific authorized users as
required by HHS and CDC policy.
Physical- The server is housed on CDC property with gate
security guards at the entrances to the property, individual
user access credentials are required for each non-public
building , floor, and office. Closed Circuit TV is also used by the
internal security guards to check for and grant access to
authorized individuals.

General Comments

OPDIV Senior Official
for Privacy Signature

signed by Jarell
Jarell Oshodi Digitally
Oshodi -S
Date: 2022.07.29 11:52:59
-S
-04'00'

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