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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-17302

Form Date

Question

Answer

1

OPDIV:

NIH

2

PIA Unique Identifier:

P-5029624-466843

2a Name:

10/10/2019 1:00:30 PM

Graduate Student Recruitment Program Application System
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

Chief Intramural Diversity
Workforce Branch

POC Name

Dr. Ofelia Olivero

POC Organization NCI Center for Cancer Training
POC Email

oliveroo@dc37a.nci.nih.gov

POC Phone

240-276-6890
New
Existing
Yes
No

Jul 23, 2019

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11 Describe the purpose of the system.

The Graduate Student Recruitment Program (GSRP)
Application System is a web-based application used by the
National Cancer Institute (NCI) Center for Cancer Training (CCT)
and run by Information Management Systems Inc, a third party
contractor. It is designed to allow application to the NCI
Graduate Student Recruiting Program and evaluation of these
applications.
Information collected and stored in the GSRP Application
System includes the following.
Applicant information:
• Name
• Address (Home, School)
• Phone
• E-mail
• Gender
• Race/Ethnicity
• Date of Birth
• Place of Birth
• Citizenship
• Current Visa Status
• Education (degree, month/year awarded/expected, major,
minor, university)
• Unofficial Transcripts
• Personal Statement of Research and Career Goals
• Curriculum Vitae
• Research Topic, Research Target, Research Approach
• Abstract
• How applicant heard about the GSRP
• Permission to make application available to NCI investigators
if not invited to the event

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 Referee information:
about the specific data elements.)
• Name
• Institution
• Job Title
• Position/Role (e.g. dissertation advisor)
• Address
• Phone
• E-mail
• Letter of recommendation for applicant
• Date that Advisor expects applicant will receive PhD
• Reason Advisor disagrees with applicant over date PhD
degree is expected
Reviewer, NCI Principal Investigator, and Administrator
Information:
• Name
• Degrees
• Employer
• Position Title
• Address
• Phone
• E-mail
• Research Topic, Research Target, Research Approach
(reviewer only)

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

15

Indicate the type of PII that the system will collect or
maintain.

The GSRP Application System is a web-based application used
by the NCI Center for Cancer Training (CCT) and run by
Information Management Systems Inc, a third party contractor.
Yes
No
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
Education History
Demographics
Curriculum Vitae
Letters of Recommendation
Personal Statement, Research Interests
Employees
Public Citizens
16

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

Business Partners/Contacts (Federal, state, local agencies)
Vendors/Suppliers/Contractors
Patients
Other

17 How many individuals' PII is in the system?

500-4,999

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The GSRP Application System will disclose PII as follows:

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)

• Referees will have access to minimal PII for applicants who
have requested that they provide letters of recommendation.
Minimal PII will be displayed to identify the applicant to the
referee.
• Reviewers will have access to limited PII for those applicants
which they are assigned to review for a limited period. Limited
PII will include information needed to identify the applicant
and facilitate review.
• Administrators will have access to PII for all applications. In
particular, contact information will be available to reach the
applicant.
• NCI Principal Investigators will have access to limited PII
following review for a limited period. Limited PII will allow the
principal investigators to contact an applicant to discuss
training opportunities.
Aggregate demographic information may be used to provide a
profile of the applicant pool. The information may also be
used to compare different cohorts over the years, conducting
research/ evaluations to improve the application system as
well as the training program.

20 Describe the function of the SSN.

N/A

20a Cite the legal authority to use the SSN.

N/A

• 42 U.S.C. 284(b)(1)(C) authorizes Director to conduct and
support research training for which fellowship support is not
provided under section 487 and which is not residency training
Identify legal authorities governing information use of physicians or other health professionals.
21
and disclosure specific to the system and program.
• 42 U.S.C. 285a-2 (b) (3) states that the NCI Director shall
support appropriate programs of education and training
(including continuing education and laboratory and clinical
research training).
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.

9-25-0158 (Administration: Records of
Applicants and Awardees of the NIH Intramural
Research Training Awards Program)

Published:

Published:
In Progress

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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?

0925-0761 and expiration date 7/31/2022
Yes
No
A link to the Privacy Statement exists on each web page. The
Privacy Statement indicates that "application for this program
is voluntary; however, in order for the CCT to process an
application, the applicant must complete the required fields."
For non-required PII, an explanation is provided in the
application that indicates that this PII will be provided in
aggregate form to provide a profile of the applicant pool.
Voluntary
Mandatory

Describe the method for individuals to opt-out of the
Application to the program is voluntary. If a candidate applies,
collection or use of their PII. If there is no option to
27
certain information is optional including, gender, race/
object to the information collection, provide a
ethnicity, birth place and birth date.
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
In the event that disclosure and/or data uses change, users are
28 and/or data uses have changed since the notice at
the time of original collection). Alternatively, describe emailed and provided a link to the updated privacy statement.
why they cannot be notified or have their consent
obtained.

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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.

There is a “Contact Us” feature on the website that can be used
for the individual to send their concern. The contact mailbox is
monitored during business hours. Once notified by the
individual, a web site administrator can correct the data, delete
the data, or otherwise resolve the issue.

Automated audit trails are monitored on all server-based
systems deployed at IMS. All of the Linux workstations and the
Windows systems have the ability to track resources as small as
a single file. File usage logging will be done for files specified
by the HHS organization. Audit records and server logs will be
reviewed daily for anomalies. Windows servers log user access
and resource usage. An automated reporting tool will be used
to analyze the server logs to look for abnormal activity.
Automated audit trails also play an important part in
governing the access granted to users outside the Contractor’s
Local Area Network (LAN). A firewall is in place that logs all
incoming and outgoing connections to the LAN. This includes
connections to the Linux workstations and the Windows
servers. This log will be maintained and checked for evidence
of attempted unauthorized access to the Contractor’s LAN.
Computer center staff performs weekly security checks of the
computer center resources using a vulnerability scanner.
Users

Administrators
31

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

Developers

Contractors

Others

Website administrators will have
access to PII to review qualifications of
applicants and to contact applicants, if
necessary.
Linux administrators and database
administrators have access to PII for
backup and restore purposes.
Developers have access to PII to debug
user problems.
Only contractors who are website
administrators have access to PII to
debug user problems and contact
applicants in regard to these problems.
(Reviewers) for reviewing qualifications
of applicants

Describe the procedures in place to determine which The contractor that runs this website maintains an Application
32 system users (administrators, developers,
Support Environment (ASE). As part of the ASE, Linux system
contractors, etc.) may access PII.
administrators and database administrators have access to the
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.

All users are assigned a role when user accounts are created.
Both reviewers and NCI Principal Investigators are assigned a
role that is used to provide limited access to PII.
Administrators are assigned a role that provides full access to
PI.

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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.

The NIH Security Awareness Training course is used to satisfy
this requirement. According to NIH policy, all personnel who
use NIH applications must attend security awareness training
every year. There are four categories of mandatory IT training
(Information Security, Counterintelligence, Privacy Awareness,
and Records Management). Training is completed on the
http://irtsectraining.nih.gov site with valid NIH credentials.

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

Website administrators are provided a beta site to understand
the functions of the system and are shown the methods for
creating new administrator accounts and approving
investigator accounts. Responsibilities for protecting PII are
discussed as part of this training.

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

Yes
No
Records are retained and disposed of under the authority of
NIH Records Control Schedule contained in NIH Manual
Chapter 1743, Appendix 1 - "Keeping and Destroying
Records" ( HHS Record Management Manual, Appendix B-361),
item 4000-E-3.

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

Records are maintained within NCI for a time of no less than six
years after a password is altered or an user account is
terminated in accordance with NARA record retention
schedule: 3.2.031, System access records; Systems requiring
special accountability for access; DAA-GRS-2013-0006-0004
Records are maintained within NCI for one year after the
system is superseded by a new iteration or when no longer
needed for agency/Information Technology (IT) administrative
purposes to ensure a continuity of security controls
throughout the life of the system in accordance with NARA
record retention schedule:
3.2.010, Systems and data security records: DAAGRS-2013-0006-0001

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Administrative Controls: Access requests are managed,
validated, and audited by system administrators and
scheduled audits are performed to ensure accounts are
validated and/or revoked if needed.

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

Technical Controls:
For NIH users: Access to the system is controlled by NIH log-in.
The level and permissions are controlled by the system and
based on user, role, organizational unit, and status of the
report. All servers have been configured to remove all unused
applications and system files and all local account access
except when necessary to manage the system and maintain
integrity of data.
For non-NIH users
All logical access to the underlying systems is hosted and
controlled by a third party, Information Management Services
Inc. All servers utilized by this application have been
configured to remove all unnecessary applications and system
files.
Physical Controls: The servers reside in one of the co-location
facilities of Information Management Systems Inc., at any given
time. The facilities are located in Sterling VA, and Baltimore
MD. All facilities have controlled access and are SOC 2 type II
audited and have been reviewed by FISMA auditors for
compliance with appropriate facility related controls.

39 Identify the publicly-available URL:

https://nci-gsrp.cancer.gov
Yes

40 Does the website have a posted privacy notice?

No

40a

Is the privacy policy available in a machine-readable
format?

Yes

41

Does the website use web measurement and
customization technology?

Yes

No
No
Technologies

Yes

Web beacons

No
Yes

Web bugs
Select the type of website measurement and
41a customization technologies is in use and if it is used
to collect PII. (Select all that apply)

No

Session Cookies
Persistent Cookies

Does the website have any information or pages
directed at children under the age of thirteen?

Yes
No
Yes
No
Yes

Other...
42

Collects PII?

No
Yes
No

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43

Does the website contain links to non- federal
government websites external to HHS?

General Comments

Yes
No

This module is under the National Cancer Institue Local Network (NCI LAN) General Support System (GSS)
whose Universal Unique Identifier (UUID) is 93F1C7DB-B2F0-4282-9FAD-7168D5B63F91.

Digitally signed by

OPDIV Senior Official
for Privacy Signature

Celeste E.
Celeste E. Dade-vinson -S
2019.11.14 12:10:00
Dade-vinson -S Date:
-05'00'

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