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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-0920-2127

2a Name:

05/06/24

Adolescent Mental Health Journey Mapping Project
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.

Implementation
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

Public Health Analyst

POC Name

Hallie Carde

POC Organization CDC/DDNID/NCIPC/OD
POC Email

[email protected]

POC Phone

803-920-0469
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

This in a electronic data collection

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.

As a response to the national emergency for children and
adolescent mental health declared in 2022, CDC’s National
Center for Injury Prevention and Control’s (NCIPC) Office of
Policy and Partnerships (OPP) is looking to better understand
the mental health experiences of adolescent youth (ages
13-17) identifying as girls/female or nonbinary living in rural
areas of New Mexico, Montana, and North Carolina. We will not
explicitly be asking youth about any traumatic experiences.
This project is formative in nature and intended to guide CDC’s
programmatic planning to address adolescent mental health
needs in the US. The questions focus on identifying trusted
resources and building resiliency for teens through social
support systems, coping skills, and mental health literacy. The
data will be collected through interviews, focus groups, and
brainstorming sessions.
Prior to the interviews, focus groups, and brainstorming
sessions, parent/guardian contact information, adolescent
contact information, and adult mentor contact information
(name and email address) will be collected in the screening
process to send invitations to participants to join the sessions
and share their compensation with them after the sessions.

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 This project will include the collection of notes and audio
about the specific data elements.)
recordings from the interviews, focus groups, and
brainstorming sessions. All files will be de-identified and
password protected. To further protect participant privacy, the
project team will remind the participants to refer to themselves
using only their first name or a fake name. These sessions will
not collect PII.

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Parent/guardian contact information, adolescent contact
information, and adult mentor contact information (name and
email address) will be collected in the screening process to
send invitations to participants to join the sessions and share
their compensation with them after the sessions. The names
and email addresses will be deleted at the completion of the
project. Only the project team will have access to participant
contact information.

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

The team will record only the audio of each session and store
the recordings on a secure cloud-based Zoom Video
Communications platform. The team will use the recording to
make sure our notes are correct and to summarize what we
hear across all groups. Only our project team will have access
to these recordings, and the recordings will be deleted once
our team updates the session transcription and notes. The
session transcription and notes will be destroyed by or before
September 2024. The written recording, written transcription,
and session notes will not hold personally identifiable
information of participants. At the end of in-person sessions,
worksheets will be collected from participants to serve as
design artifacts; individual identifying information will not be
retained on any of these artifacts. The worksheets will be
scanned, digitized, uploaded to the password-protected
network storage location accessible only to the research team.
Paper copies will be destroyed upon upload.
For the virtual sessions, a member of the Deloitte project team
will join the Zoom meeting early and mark individuals as
present as they enter the virtual waiting room. At the start of
the sessions, participants will be renamed, provide verbal
consent to be audio recorded and will be reminded they can
leave at any time and will still receive compensation, what they
share will not be shared outside of the group and will not be
linked to their name (unless it indicates harm to self or others),
and that they do not have to answer any question they do not
want to answer.

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

Other...

Other...

Other...

Other...

Other...

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)

100-499
Parent/guardian contact information, adolescent contact
information, and adult mentor contact information (name and
email address) will be collected in the screening process to
send invitations to participants to join the sessions and share
their compensation with them after the sessions. The names
and email addresses will be deleted at the completion of the
project.
There are no secondary uses for the PII.

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 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

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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:

N/A

Published:

N/A

Published:

N/A
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.

OMB Control No: 0920-1154
ICR Reference No: 202210-0920-013
Expiration Date: 03/31/2026
Yes

24 Is the PII shared with other organizations?

No
Within HHS
Other Federal
Agency/Agencies
State or Local
Agency/Agencies

Identify with whom the PII is shared or disclosed and
24a
for what purpose.

Private Sector
Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
24b Matching Agreement, Memorandum of
N/A
Understanding (MOU), or Information Sharing
Agreement (ISA)).
24c

Describe the procedures for accounting for
disclosures

N/A

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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

The last page of the screening survey asks for the potential
participant's name and email address so the project team can
follow up with a consent and scheduling form and a notice of
when their session is. The last page provides a justification for
the collection of contact information. For example, this is how
it reads on the parental screening survey: "If your teen is
selected to take part in a session, their time and efforts will
help the CDC make better programs and services for teen
mental health in the future. In order to contact your teen for a
brief survey and assent (agreement) form, similar to this survey
you just completed, please confirm your teen’s contact
information:"
Voluntary

Is the submission of PII by individuals voluntary or
mandatory?

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.
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.
Describe the process in place to resolve an
individual's concerns when they believe their PII has
29 been inappropriately obtained, used, or disclosed, or
that the PII is inaccurate. If no process exists, explain
why not.
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.

Mandatory
Individuals who do not wish to share their name and email do
not need to complete the screening survey and will not be
considered for participation in a session. Participation in a
session is completely voluntary and driven by individual
interest.

There are no changes expected to occur to the system. The
screening survey will remain the same from start to finish of
the data collection.

Individuals can reach out via email to the
[email protected] if they have a concern about the use
of their PII.
In addition to regularly reviewing the spreadsheet output of
the screening survey for eligible participants, the 1-2
contractor project team members will conduct a monthly
review of the results of the screening surveys and remove any
faulty or irrelevant data entries.
Users
Administrators

31

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

Developers
Contractors

1-2 direct contractor members on the
project team with HHS badges and

Others
The contractor team and CDC team aligned on limiting access
only to those who will be sending out follow-up/reminder
Describe the procedures in place to determine which communications and compensation information to session
32 system users (administrators, developers,
participants. Only 1-2 members of the contractor team will be
contractors, etc.) may access PII.
sending those communications and scheduling the sessions,
so those are the only people with access to the names and
email addresses of interested participants.

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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.

Names and emails will be collected through a survey system,
where only 1-2 individuals on the contractor team will have
access to the data. This system is housed within the Qualtrics
tool, which is protected by Deloitte's Single Sign On login
procedures and requires access to a VPN.

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 contractor members of the project team have received
their Collaborative Institutional Training Initiative (CITI) Human
Subjects Research Certification and Deloitte's Confidential
Information Management Plan training to prepare them for
storage of the PII collected through the screening survey.

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

While no additional training is required, self-guided training
resources are available for users to operate the screening
survey platform.

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

Yes
No

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General Records Schedule (GRS) 3.2, Item 60, Public Key
Infrastructure (PKI) Administrative Records.

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

PII will only be used to screen for, and to contact, respondents
who match the specified respondent profile for the session. PII
will be collected via a web-based survey application as part of
the prescreening process. PII for each selected individual will
be destroyed before the conclusion of this effort in September
2024. Individuals not selected for a session will not be
contacted and their information will immediately be deleted.
PII will not be retained or used to link respondents’ individual
comments during the session or during the analysis. All
findings will be reported in the aggregate. PII will also not be
used to describe the respondents in the room or to provide
context to the analysis. Data are treated in a private manner,
unless otherwise compelled by law. No paper documents with
PII will be collected. Data containing PII will be disposed of as
soon as session participants have been contacted and
scheduled for sessions. Emails will be disposed of after the
incentive has been sent to the participants. Participants will
have the option to turn their Zoom camera on, but it will not
be mandatory during any of the virtual sessions and only audio
will be recorded for all sessions. Names of participants entering
the Zoom group discussion will be changed to their first names
only (last names will be removed) to protect the privacy of the
individual.
Audio recordings and transcriptions will be stored on a secure,
password-protected cloud storage. Audio will be recorded via
Zoom and recordings will be encrypted and transcribed using
Zoom’s transcription mechanism which will only be used by
the project team to validate the transcribed audio. Transcripts
of the audio recordings will be de-identified prior and during
analysis. Access to audio and de-identified transcript files is
limited to authorized project team personnel only. Session
audio files will be destroyed once the session has been
transcribed including deleting files from the passwordprotected cloud and any local file storage. All staff and
contractors working on the project agree to safeguard the data
and not to make unauthorized disclosures. Responses in
published reports are presented in aggregate form and no
individuals are identified by name.
All consent forms include appropriate information about
privacy, including purpose for collecting the data, with whom
identifiable information will be shared, the voluntary nature of
the information collection and the effect upon the respondent
for not participating.

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

Administrative - The contractor members of the project team
have received their CITI Human Subjects Research Certification
and Deloitte's Confidential Information Management Plan
training. Contractors will review monthly the results of the
screening surveys and remove any faulty or irrelevant data
entries. All PII is intended to be deleted at the end of the
project and all other project data will be retained for 3 years
from the conclusion of the project, per the initial Information
Resources Board(IRB) feedback we received citing the code of
federal regulations
Technical - The PII will be collected via a secure Qualtrics
platform and will be uploaded to a secure password-protected
folder shared between the 1-2 contractor team members that
have access to the PII. The laptops used to access the survey
tool that hosts the PII will be password protected, require twofactor authentication, and have the ability to be remotely
erased in the very rare event that the laptops get lost or stolen.
Physical - Data will be stored in a secure AWS server building in
Ashburn, VA, USA and the data will remain confidential.

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

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Reviewer Questions
6

Does the PIA accurately identify data retention procedures and records retention schedules?

Answer
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

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: 2024.06.04
for Privacy
13:57:21 -04'00'

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