Pia

Att 6 PIA_MARI_Rev1.pdf

[NCHHSTP] Formative Research and Tool Development

PIA

OMB: 0920-0840

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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:

PRA-0920-2134

2a Name:

06/21/24

Evaluation of the Minority HIV/AIDS Research Initiative: 2003-pre
General Support System (GSS)
Major Application

3

Minor Application (stand-alone)

The subject of this PIA is which of the following?

Minor Application (child)
Electronic Information Collection
Unknown

3a

Identify the Enterprise Performance Lifecycle Phase
of the system.

Initiation
Yes

3b Is this a FISMA-Reportable system?

4

Does the system include a Website or online
application available to and for the use of the general
public?

5

Identify the operator.

6

Point of Contact (POC):

7

Is this a new or existing system?

8

Does the system have Security Authorization (SA)?

No
Yes
No
Agency
Contractor
POC Title

Epidemiologist

POC Name

Kimberly Evans

POC Organization CDC
POC Email

[email protected]

POC Phone

404-639-1440
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

No new data systems are being created to support data
collection as part of this cooperative agreement.

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 system will collect data to evaluate the Minority HIV/AIDS
Research Initiative (MARI), which is a training program for earlycareer investigators to build capacity for HIV prevention and
treatment research in racial/ethnic minority communities
disproportionately affected by HIV. This study will evaluate
MARI to understand its impact on communities of color and on
researchers’ careers in order to garner insight into how to
improve MARI as a research training program for early-career
investigators. We propose to survey all previously funded MARI
investigators.

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
about the specific data elements.)

A survey will be used to collect data on the evaluation of the
MARI training program. The survey will include name,
demographic questions (e.g., race/ethnicity, gender identity),
insight on studies that the participant completed during MARI
(e.g., brief overview of studies, the communities served, and
impacts), and feedback about MARI as a training program.

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

All PII (name, demographic questions), and non-PII
(information about the MARI studies, impact on principal
investigator career, and impact on the communities where the
MARI study was implemented) will be collected in the data
system. The data collected will inform MARIs impact on
communities of color and on researchers’ careers in order to
improve MARI as a research training program for early-career
investigators. Data will be collected using Microsoft Forms,
REDCap, or SurveyMonkey. Each of these software systems use
encryption for data storage and transmittal of data files. All
collected data will be stored on a CDC secured server on a
MARI shared drive folder. Only persons who have training and
are staff who work on MARI are granted access to these folders.

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/Ethnicity
Gender
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)

<100
The purpose of this study is to assess the impact MARI had on
communities of color for the past two decades and on
researchers’ careers. The PII collected will inform the future
direction of MARI as an early-career training program for
equitable funding and research opportunities for communities
of color disproportionately affected by HIV-related disparities
and for equitable training opportunities for racial/ethnic
minority investigators who are often marginalized.
Evaluation

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 42 U.S.C. 241, Chapter 6a - Public Health Service; Subchapter Ii General Powers and Duties Part A - Research and
and disclosure specific to the system and program.
Investigations.

22

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

Yes
No

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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?

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?

0920-0840; 03/31/2027
Yes
No
Individuals will be sent an email requesting their participation
in the MARI evaluation study and directed to a website link
which will contain the informed consent and the option to not
participate or skip any survey question. Participants will be
advised to reach out to MARI Program Lead for any questions
before consenting to their participation in the study. Any PII
submitted is voluntary and any question can be skipped.
Voluntary
Mandatory

Describe the method for individuals to opt-out of the
collection or use of their PII. If there is no option to
Individuals will have the option to not answer any questions
27
object to the information collection, provide a
that include PII or may make them feel uncomfortable.
reason.
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
This is a single, one-time data collection. There is no need to
28 and/or data uses have changed since the notice at
the time of original collection). Alternatively, describe contact individuals about changes in the system.
why they cannot be notified or have their consent
obtained.

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Should an individual have a concern, they will be advised to
contact the MARI program lead and administrator of the survey
for any questions. We will also limit the inappropriate use of PII
Describe the process in place to resolve an
collected data by de-identifying data before any reports are
individual's concerns when they believe their PII has published. We will not use identifiers in qualitative quotes to
29 been inappropriately obtained, used, or disclosed, or ensure the identities of our participants remain confidential.
that the PII is inaccurate. If no process exists, explain Only de-identified data will be published. Any breach in data
why not.
privacy and confidentiality will be reported to the CDC’s
Division of HIV Research Branch Associate Chiefs of Science
within 24 hours and in accordance with the Division’s policies
and procedures.
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.

All collected data will be stored on a CDC secured server on a
MARI shared drive folder. Only persons who have training and
are staff who work on MARI are granted access to these folders.
The MARI program lead and administrator of this survey, will
routinely review files to ensure the data's integrity, availability,
accuracy and relevancy.
Users
Administrators

31

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

MARI Lead for oversight of survey and
data analysis (as needed).

Developers
Contractors

Direct badged contractors (data
analysts) will have access to the data

Others
The MARI Program Lead/administrator only grants access to
Describe the procedures in place to determine which individuals whose roles (e.g., MARI data analyst, MARI project
officer) are affiliated with MARI duties. Only persons who have
32 system users (administrators, developers,
access to CDC's secure MARI folder (must be granted access by
contractors, etc.) may access PII.
the MARI Program Lead/administrator) will have access to the
PII collected.
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.

The data manager/contractor and the MARI program lead/
adminstrator will have access to the survey results that will
contain the PI. The data manager will create the database,
check for data quality, and de-identify the data prior to the
analysis. The administrator will review the database to ensure
all procedures are followed appropriately.

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 staff and contractors receive records management training
and must adhere to the policies yearly.

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

N/A

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

Yes
No

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

Records will be processed and managed in accordance with
CDC Records Control Schedule (RCS) N1-442-09-001, Survey
Records.
Tehcnical:
All collected data will be collected in an encrypted system and
then stored on a CDC secured server on a MARI shared drive
folder with role-based and least privilege (only those with jobrelated duties associated with MARI).

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

Administrative:
Only persons who have training and are staff who work on
MARI are granted access to these folders.
Physical:
Servers are located in a secure environment with security
guards, close circuit television, proximity cards and readers.

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

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Reviewer Questions
7

Answer

Are the individuals whose PII is in the system provided appropriate participation?

Yes
No

Reviewer
Notes
8

Does the PIA raise any concerns about the security of the PII?

Yes
No

Reviewer
Notes
9

Is applicability of the Privacy Act captured correctly and is a SORN published or does it need
to be?

Yes
No

Reviewer
Notes
10

Is the PII appropriately limited for use internally and with third parties?

Yes
No

Reviewer
Notes
11

Does the PIA demonstrate compliance with all Web privacy requirements?

Yes
No

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: 2024.07.15
11:04:26 -04'00'

HHS Senior
Agency Official
for Privacy

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