Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

0920-0995

Question

11/30/22

Answer

1

OPDIV:

CDC/NCHHSTP/DSTDP

2

PIA Unique Identifier:

0920-0995

2a Name:

Form Date

National Network of Sexually Transmitted Disease Clinical Preve
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

Health Scientist

POC Name

Oluwatosin Ariyo

POC Organization NCHSTTP
POC Email

[email protected]

POC Phone

404.639.6352
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.

N/A Because this not a system.
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
Other...
10

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

11 Describe the purpose of the system.

This is a renewal request of currently approved data collection
instruments.
The purpose of this information collection is to evaluate how
well the National Network of Sexually Transmitted Disease
Clinical Prevention Training Centers' (NNPTC) training and
technical assistance reaches the Division of Sexually
Transmitted Diseases' (DSTDP) intended audiences and
impacts the knowledge, skills, and practice patterns of
providers of Sexually Transmitted Disease (STD) screening,
diagnosis, treatment over time. The evaluation will measure
trainee satisfaction with NNPTC services and changes in
capacity, knowledge, skills, practice patterns and self-efficacy
as a result of NNPTC training and technical assistance. This is a
renewal request of currently approved instruments. The
resulting data will be used to monitor and improve the
NNPTC's program delivery through assessment of trainee
satisfaction and short-term and long-term outcomes of the
DSTDP's program.

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Data will be collected online using surveys with closed- and
open-ended questions or in-person as necessary at training
and technical assistance events. The information will be
collected from healthcare professionals who attend training or
technical assistance events delivered by the NNPTC. The
NNPTC "Health Professional Application for Training" (NNPTC
HPAT) is the only instrument that collects categories of
information in identifiable format from individual respondents
such as: name, organization address, work phone numbers,
work email address, organization name, gender, race and
Describe the type of information the system will
ethnicity, and sexual orientation. These identifiable NNPTC
collect, maintain (store), or share. (Subsequent
HPAT data elements are needed to send information about the
12
questions will identify if this information is PII and ask training or technical assistance for which they have registered,
about the specific data elements.)
send electronic invitations to complete evaluation instruments,
and identify county of workplace and type of employment
setting to analyze reach.
A unique identifier will be generated for all data collection
instruments to enable linking data from multiple data
collection tools. The identifiable information collected by the
National Evaluation Center (NEC) is stored behind firewalls at
the NEC in password protected files and are available only to
authorized users of the NEC, not CDC.
Data gathered under this information collection activity
includes electronic (web-based) surveys to be completed by
healthcare professionals who attend training or technical
assistance events delivered by the NNPTC.

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

The NNPTC "Health Professional Application for
Training" (NNPTC HPAT) is the only instrument that collects
categories of information in identifiable format from individual
respondents such as: name, organization address, work phone
numbers, work email address, organization name, gender, race
and ethnicity, and sexual orientation. These identifiable NNPTC
HPAT data elements are needed to send information about the
training or technical assistance for which they have registered,
send electronic invitations to complete evaluation instruments,
and identify county of workplace and type of employment
setting to analyze reach.
Final datasets will be delivered to CDC in de-identified format.
Additionally, data files will be delivered using a secured CDCapproved file transfer mechanism. When reporting data from
this study, only aggregate data will be used to report study
results.

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

gender

Business Contact Information sexual orientation
Race & Ethnicity

county of workplace

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?

10,000-49,999
Business related contact data elements are needed to send
information about the training or technical assistance for
which participant have registered to send electronic invitations
to complete evaluation instruments, and identify county of
workplace and type of employment setting to analyze reach.
The NNPTC HPAT data transmitted to CDC will include no
identifying information.

19

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

Data on race and ethnicity and sexual orientation are collected
on the NNPTC HPAT because STDs disproportionally impact
African Americans and Latino/as, and Men who have Sex with
Men (MSM). As such, it is important to make sure the NNPTC is
training diverse providers who work with diverse populations.

20 Describe the function of the SSN.

N/A No social security numbers are being collected.

20a Cite the legal authority to use the SSN.

N/A

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Public Health Service Act, Section 301, "Research and
Identify legal authorities governing information use Investigation," (42 U.S.C. 241); and Sections 304, 306 and 308(d)
21
which discuss authority to maintain data and provide
and disclosure specific to the system and program.
assurances of confidentiality for health research and related
activities (42 U.S.C. 242 b, k, and m(d)).
22

Yes

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

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.

Privacy Act System Notice 09-20-0161 Records of

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?

0920-0995
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

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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

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?

NA
Training participants are provided opportunities to review the
registration form and surveys prior to completion. The
instruments include guided prompts to only answer questions
of their choice.
Voluntary
Mandatory

CDC will not receive or maintain any PII. From the CDC
Describe the method for individuals to opt-out of the perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
collection or use of their PII. If there is no option to
27
object to the information collection, provide a
Training participants have the option to not answer any of the
reason.
post-training survey questions. Registration information is
required prior to attending trainings and receiving credit.

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.

CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
The identifiable data are collected to send information about
the training or technical assistance for which participants have
registered, send electronic invitations to complete evaluation
instruments, and identify county of workplace and type of
employment setting to analyze reach. There will be no changes
in use to data already collected, any prospective changes will
be communicated prior to data collection and prospective
individuals will be notified in advance.
CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
Individuals (training participants) with concerns can contact
the NEC administrators at:
Denver Prevention Training Center/Public Health Institute at
Denver Health
Phone: 303-704-3837
Phone: 303-602-3638
CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
NEC will develop and update a data management plan that
includes how they will collect, store, and destroy non-sensitive
contact information.

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Users
Administrators
31

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

Developers
Contractors

To contact willing participants for
scheduling data collection

Others
CDC will not receive or maintain any PII. From the CDC
Describe the procedures in place to determine which perspective this project does not collect PII as no PII will ever
32 system users (administrators, developers,
be accessible to CDC staff.
contractors, etc.) may access PII.
Only NEC administrators will have access to PII, as needed.
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.

CDC will not receive or maintain any PII. From the CDC
perspective this project does not collect PII as no PII will ever
be accessible to CDC staff.
Access to PII is restricted solely to the NEC administrators

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 team members who have CDC network access will
complete CDC's annual security awareness training.

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

All team members have completed CDC and Collaborative
Institutional Training Initiative (CITI) ethics trainings.

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
The NEC (NPTC3) is required to maintain all information in
accordance with Executive Order 13556 -- Controlled
Unclassified Information, National Archives and Records
Administration (NARA) records retention policies and
schedules and HHS policies and are informed that they are not
to dispose of any records unless authorized by HHS.
Technical Controls: PII collected by the National Evaluation
Center (NEC) is stored behind firewalls at the NEC in password
protected files

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

Physical Controls: PII collected are available only to authorized
users of the NEC. As noted above, no PII is provided to the
DSTDP.
Administrative Controls: The business identifying information
(i.e., respondents’ name, business email address, business
address, and business phone number) will be maintained in a
secure file that is separate from the response data and only
NEC project staff will have access to it.

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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: 2022.12.12
for Privacy
13:59:34 -05'00'

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