Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-30715

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-6974999-438812

2a Name:

7/26/2021 10:17:46 AM

Message Validation, Processing, and Provisioning System
(MVPS)
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)?

8b Planned Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Business Steward

POC Name

Indira Srinivasan

POC Organization CDC/OPHSS/CSELS
POC Email

[email protected]

POC Phone

404-498-6619
New
Existing
Yes
No
September 10, 2021
Not Applicable

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11 Describe the purpose of the system.

The Message Validation, Processing, and Provisions System
(MVPS) is a multifaceted public health disease surveillance
system that gives public health officials powerful capabilities
to monitor the occurrence and spread of diseases. Facets of
MVPS will be used by numerous state, territorial, tribal, and
local health departments; and by partner organizations, such
as the Council of State and Territorial Epidemiologists (CSTE).
The primary goal of MVPS is to develop a common
infrastructure for public health agencies that allows the
Federal, state, and local level public health agencies to store
and exchange data using a common set of business
procedures, metadata, and capabilities that can be defined
from the start.
MVPS contains patient (case) contact data: Names, mailing
address, email addresses, phone numbers, Citizenship/
Nationality, medical notes, DOB, Sex/ Race, county, marital
status and census tract.

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 External Users access the system via CDC’s Secure Access
Management System (SAMS) the authentication platform for
about the specific data elements.)
external non-CDC users, and internal users via CDC's Active
Directory. Active Directory and SAMS are separate systems
covered by separate PIAs.

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

The primary goal of MVPS is to develop a common
infrastructure for public health agencies that allows the
Federal, state, and local level public health agencies to store
and exchange data using a common set of business
procedures, metadata, and capabilities that can be defined
from the start and not be introduced ad-hoc.
The MVPS system is a message processing system. Messages
are received and are then validated.
MVPS contains patient (case) contact data: Names, mailing
address, email addresses, phone numbers, Citizenship/
Nationality, medical notes, DOB, Sex/ Race, county, marital
status and census tract.
External Users access the system via CDC’s Secure Access
Management System (SAMS) the authentication platform for
external non-CDC users, and internal users via CDC's Active
Directory. Active Directory and SAMS are separate systems
covered by separate PIAs.

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

Yes
No

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15

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
Citizenship/Nationality
Race/Sex
County
Census Tract
Marital Status
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?

100,000-999,999

18 For what primary purpose is the PII used?

The PII data is strictly used for research purposes only for
disease surveillance and reporting. The system needs to be
able to associate disease trends among groups like people
within a certain age bracket, gender, geographic location,
nationality, or race in order to attempt to provide useful
information to public health officials

19

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

Business contact information, names and email addresses are
used to exchange data within this system.

20 Describe the function of the SSN.

N/A

20a Cite the legal authority to use the SSN.

N/A

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)).

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22

Yes

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

No
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?

0920-0728, Exp. 04/30/2022
Yes
No
No prior notice is given by CDC because MVPS does not collect
information directly from any individuals. The actual collection
of MVPS data is done by participating state public health
agencies. As the original collectors of data, obtaining consent
from individuals and notifying individuals about data
collection and use are the responsibility of those participating
agencies.
Voluntary
Mandatory

Describe the method for individuals to opt-out of the The MVPS platform is a "downstream" recipient of data that
has already been collected by healthcare agencies at the point
collection or use of their PII. If there is no option to
27
of service in their healthcare facilities; individuals requesting to
object to the information collection, provide a
opt-out must do so according to the policies and procedures in
reason.
place at those facilities.

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The MVPS platform does not have a process to obtain consent
Describe the process to notify and obtain consent
from or notify individuals about data collection and use. MVPS
from the individuals whose PII is in the system when is a "downstream" recipent of data that has already been
major changes occur to the system (e.g., disclosure
collected by healthcare agencies at the point of service in their
28 and/or data uses have changed since the notice at
healthcare facilities; obtaining consent from and notification of
the time of original collection). Alternatively, describe individuals about data use is the responsibility of the agencies
why they cannot be notified or have their consent
that collect it. As a public health authority, the healthcare
obtained.
agencies can exchange the information with CDC to perform
health activities without obtaining the individual's consent.
The MVPS system does not have a process in place to work
with individuals regarding concerns about their PII stored in
Describe the process in place to resolve an
the system because the records in the system are not
individual's concerns when they believe their PII has collected by CDC. Further consent, notification, and such
29 been inappropriately obtained, used, or disclosed, or interactions are conducted between individuals and the
that the PII is inaccurate. If no process exists, explain healthcare agencies collecting the PII, and are out of scope of
why not.
the MVPS project and system and individuals would have to
contact their local public health authority to express their
concerns.
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.

31

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

There is an annual review process between the MVPS program
and the sending jurisdictions to reconcile and confirm the
integrity of case data sent from participating healthcare
agencies and data received by the MVPS system. This is
conducted with each participating agency at least once every
365 days, and can be done more frequently if a need to do so is
determined.
Users

Access for data analysis, reporting
activities.

Administrators

General access for management of
system resources and users.

Developers
Contractors
Others

Describe the procedures in place to determine which MVPS program management review, on a case-by-case basis,
32 system users (administrators, developers,
which system users may access PII. The decision is based on
contractors, etc.) may access PII.
the users' job requirements consistent with Role-Based Access.

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.

Users are given access according to their jurisdiction and/or
program only has access to that information after proofing and
approval. The data steward oversees the approval process and
determines who get access to the information he or she is
responsible for. The least Privileged model is used for all
access grants, and enforced with row-level security in the
database.

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 take annual Privacy and
Security Awareness Training (SAT).

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

All CDC personnel are required acknowledge HHS Rules of
Behavior annually during the SAT.

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
MVPS data is kept by the CDC as a historical public health
record, per CDC's "Scientific and Research Project Records
Control Schedule", section 1a ("Authorized Disposition:
PERMANENT"). Records Schedule N1-442-09-1. 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:
Users are assigned roles and privileges depending on their job
requirements. MVPS program management approves all CDC
user access on a case-by-case basis according to the leastprivilege principle. MVPS program management also vets and
approves access for non-CDC users (“Jurisdictional” Users and
Data Managers) also according the principle of least privilege.

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

Technical:
MVPS data is protected by restricting access to two points: via
CDC’s Secure Access Management System (SAMS) the
authentication platform for external non-CDC users, and via
CDC's Active Directory infrastructure for internal CDC users.
Once authenticated, users’ access to system PII is limited by
Role-Based Access Control (RBAC) features built into the MVPS
platform. System data is also protected by firewalls, intrusion
detection systems, anti-malware systems, and encryption
methods provided by CDC’s Applied Hosting Branch.
Physical Controls:
Production and test servers are stored in a server room secured
by the CDC. Access tools are in place to secure entry into CDC
buildings (Guards, ID Badges, Key Card, Cipher Locks, Closed
Circuit TV).

General Comments

OPDIV Senior Official
for Privacy Signature

signed by Jarell
Jarell Oshodi Digitally
Oshodi -S
Date: 2021.08.11 13:44:13
-S
-04'00'

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