Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

Form Date

Question

Answer

1

OPDIV:

ATSDR

2

PIA Unique Identifier:

TBD

2a Name:

02/21/20

APPLETREE Performance Measures (PMs)
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.

Planning
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

Team Lead, State Coag Team

POC Name

Trent LeCoultre

POC Organization ATSDR
POC Email

tll7@cdc.gov

POC Phone

770.488.3799
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

APPLETREE will use multiple CDC authorized systems as part of
the electronic information 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.

The purpose of the data collection is to monitor progress of the
APPLETREE program toward program goals and objectives, and
for program quality improvement. The APPLETREE program
identifies pathways of exposure to hazardous substances at
hazardous waste sites and releases; identifies, implements,
and coordinates public health interventions to reduce
exposures to hazardous substances; and provides training at
the state level to promote and achieve the safe siting of child
care facilities in the United States.
The type of data the system will collect and maintain is:

Recipient Contacts (name, work phone, work email)
Site information (site name, site type, event venue, street
address, city, state, zip code, etc.)
Qualitative Performance Metrics (success stories, project
accomplishments, progress summaries, future direction
narratives, etc.)
Quantitative Performance Metrics (proportion of activities
completed, proportion of site-specific assessments completed,
number of internal/external capacity building opportunities,
Describe the type of information the system will
estimated number of people protected from hazardous
collect, maintain (store), or share. (Subsequent
exposures, etc.)
12
questions will identify if this information is PII and ask Education Activities (date, education type, activity descriptions,
about the specific data elements.)
number trained, aggregate training evaluation data, etc.)
Technical Assistance (date, primary contaminant, exposure
pathways, assistance summaries, request/response,
organizational partners, number of people exposed, number of
people assessed, number of people potentially exposed, etc.)
Recommendations (recommendation summary,
recommendation category, potential health concern, date
adopted, types of stakeholders, implementation progress
summary, actions taken, etc.)
Internal users are authenticated via CDC's active directory and
state users are authenticated via user name and password.

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The type of data the system will collect and maintain is:
Recipient Contacts (name, work phone, work email)
Site information (site name, site type, event venue, street
address, city, state, zip code, etc.)
Qualitative Performance Metrics (success stories, project
accomplishments, progress summaries, future direction
narratives, etc.)
Quantitative Performance Metrics (proportion of activities
completed, proportion of site-specific assessments completed,
number of internal/external capacity building opportunities,
estimated number of people protected from hazardous
exposures, etc.)
Education Activities (date, education type, activity descriptions,
number trained, aggregate training evaluation data, etc.)
Technical Assistance (date, primary contaminant, exposure
pathways, assistance summaries, request/response,
organizational partners, number of people exposed, number of
people assessed, number of people potentially exposed, etc.)
Recommendations (recommendation summary,
recommendation category, potential health concern, date
adopted, types of stakeholders, implementation progress
summary, actions taken, etc.)

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

APPLETREE recipients perform health assessments for
environmental exposure at sites. They report Site Information
to account for the level of effort expended at each site in a
given budget period. This information is directly tied into their
performance and success measures. In addition to the
standard work products required at sites (Public Health
Assessments, Health Consultations, Exposure Investigations,
etc.), recipients are often asked to provide Technical Assistance
for additional purposes, and report these activities to give
ATSDR a full 360 degree understanding of the recipient's effort,
performance, and success.
ATSDR uses the recipient contact information to identify the
POC who is submitting the Project Managers in case there are
any questions about the information they are submitting.
Site information, qualitative/quantitative performance metrics,
education activities, and technical assistance are collected
from the recipients to evaluate their progress in accomplishing
the goals of the program.
Recommendation information is provided to ATSDR by the
recipients and is used to track progress towards community
adoption of health assessment recommendations.
User name and password is used to authenticate state/local
recipients that are required to report data to ATSDR for the
APPLETREE program.
The data will not be shared outside CDC.

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
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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...

username and password

Other...

Other...

Other...

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?

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
PII is primarily used to capture the name and contact
information of the recipient point of contacts who are
submitting the forms.
Not applicable

20 Describe the function of the SSN.

Not applicable

20a Cite the legal authority to use the SSN.

Not applicable

Sections 104(i)(15) of the Comprehensive Environmental
Identify legal authorities governing information use Response, Compensation, and Liability Act (CERCLA) of 1980,
21
and disclosure specific to the system and program.
as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986 [42 U.S.C. 9604(i)(15)]
22

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

Yes
No

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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.

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?

"APPLETREE Performance Measures"
OMB Control No. 0923-0057, Expiration Date 07/31/2020
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

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

ATSDR has no plans to share information with external entities.
However, as part of the study's data management plan, if
sharing is required ATSDR will share data sets with external
entities via data use agreements (DUA) with each data
recipient.
Accounting of disclosures will be a manual process where the
program keeps track of disclosures in a spreadsheet.

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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

Notice is given at the APPLETREE kick-off meeting where
recipient point of contacts (POCs) will be asked to provide their
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.

Mandatory
Recipients who wish to opt out may choose not to deliver the
their contact information in the information collection forms in
"APPLETREE Performance Measures" OMB Control No.
0923-0057, Expiration Date 07/31/2020.

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
ATSDR will contact individuals whose PII is in the system via
28 and/or data uses have changed since the notice at
email, telephone, and/or mail when major changes to the
the time of original collection). Alternatively, describe occur that affect their PII.
why they cannot be notified or have their consent
obtained.
Individuals that have a concern that their PII has been
inappropriately used, obtained, or disclosed, or that their PII is
inaccurate should contact the cooperative agreement
program manager using the information provided to them in
the kick off meeting for this project.

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 The individual may be directed to contact the project data
that the PII is inaccurate. If no process exists, explain manager to identify the record and specify the information
being contested, the corrective action sought, and the reasons
why not.
for requesting the correction, along with supporting
information to show how the record is inaccurate, incomplete,
untimely, or irrelevant. If an incident has occurred, the program
or data manager will report the potential incident to the CDC
Security Incident Response Team and the Privacy Officer.
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.

The PII in the system will be reviewed annually to ensure the
data's integrity, availability, accuracy and relevancy during
meetings with recipients. PII will be reviewed, updated or
deleted at this time as necessary.
Users
Administrators

31

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

Users will use the PII to contact POCs at
the state and local level about this
Administrators may use the PII to
troubleshoot issues with the systems

Developers
Contractors
Others

Describe the procedures in place to determine which
The project manager will determine which users should have
32 system users (administrators, developers,
access to the PII. It will be on a need to know basis.
contractors, etc.) may access PII.
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.

Any user with access to PII will have access to all of the PII in
the system.

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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.

Study staff will all go through annual CDC security awareness
training.

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

No additional training will be provided.

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 process and guidelines in place with regard to the
retention and destruction of PII for this activity will be
governed by ATSDR records control schedule 1-5 "Copies of
Extramural Records (Contracts, Cooperative Agreements,
Grants, MOUs, and IAGs) That Are Needed for Cost Recovery or
Site-Specific Activities" (http://intranet.cdc.gov/ocoo/docs/
services/ATSDR-retention-schedules.docx).
Records will be maintained in an inactive file after the project
has ended, transferred to a federal records center 1 year after
cutoff, and destroyed when 40-years old, or when all cost
recovery activity has ended, whichever comes first.
PII will be secured using the following administrative controls:
Rules of Behavior, non-disclosure agreements, and data use
agreements.

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

PII will be secured using the following technical controls: whole
disk encryption, e-Auth Level 1, smart cards, and access control
lists in multiple authorized CDC IT systems.
PII will be secured using the following physical controls:
controlled physical access, guards, key card access, and locked
rooms.

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

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Reviewer Questions

Answer

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

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

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OPDIV Senior Official
for Privacy Signature

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2020.03.25
for Privacy
14:26:24 -04'00'

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