Pia

1. OPDIV

National Institutes of Health

2. PIA Unique Identifier
2a. Name

NEI Electronic Individual Development Plan

3. The subject of this PIA is
Tier 4
which of the following?
3a. Identify the Enterprise
Performance Lifecycle Phase Operational
of the system.
3b. Is this a
No
FISMA-Reportable system?
4. Does the system include a
Website or online
application available to and No
for the use of the general
public?
Accept / Reject Status
Question 4 Comment
5. Identify the operator.

Agency

6. Point of Contact (POC)
POC Title

Training Director

POC Name

Cesar Perez-Gonzalez

POC Organization

National Eye Institute, NIH

POC Email

cesarp@nei.nih.gov

POC Phone

301-827-7755

Accept / Reject Status
Question 6 Comment
7. Is this a new or existing
system?

New

8. Does the system have
Security Authorization
(SA)?

Yes

Accept / Reject Status
For Official Use Only (FOUO)

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Question 8 Comment
8a. Date of Security
Authorization

Jan 29, 2020

9. Indicate the following
reason(s) for updating this
PIA. Choose from the
following options.
Other
Accept / Reject Status
Question 9 Comment

10. Describe in further detail
any changes to the system
that have occurred since the
last PIA.
Accept / Reject Status
Question 10 Comment

11. Describe the purpose of
the system.

The electronic Individual Development Plan (eIDP) system is used
by the National Eye Institute’s (NEI) intramural training program to
help fellows and trainees identify their career goals and professional
development needs.

Accept / Reject Status
Question 11 Comment
12. Describe the type of
information the system will
collect, maintain (store), or
share. (Subsequent questions
will identify if this
information is PII and ask
about the specific data
elements.)

The majority of the Personally Identifiable Information (PII)
information comes from NIH Enterprise Directory (NED), the NIH
Fellowship Payment System (FPS), and NIH nVision. Personally
Identifiable Information (PII) includes name, email, phone number,
race, and gender and ethnicity (optional).
eIDP uses specific login information to assign permissions/user roles
which is considered Personally Identifiable Information (PII).
For Official Use Only (FOUO)

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However, this is done by using the NIH Identity, Credential, and
Access Management Services: Identity Management Services (IMS),
formerly known as the Active Directory (AD), which combines the
identity and authentication tools and capabilities used throughout the
NIH enterprise. The IMS has its own approved PIA on record,
including all legal authorities documented.
Accept / Reject Status
Question 12 Comment
The electronic Individual Development Plan (eIDP) system is used
by the National Eye Institute’s (NEI) intramural training program to
help fellows and trainees identify their career goals and professional
development needs.

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

The majority of the Personally Identifiable Information (PII)
information comes from NIH Enterprise Directory (NED), the NIH
Fellowship Payment System (FPS), and NIH nVision. Personally
Identifiable Information (PII) includes name, email, phone number,
race, and gender and ethnicity (optional).
eIDP uses specific login information to assign permissions/user roles
which is considered Personally Identifiable Information (PII).
However, this is done by using the NIH Identity, Credential, and
Access Management Services: Identity Management Services (IMS),
formerly known as the Active Directory (AD), which combines the
identity and authentication tools and capabilities used throughout the
NIH enterprise. The IMS has its own approved PIA on record,
including all legal authorities documented.

Accept / Reject Status
Question 13 Comment
14. Does the system collect,
Yes
maintain, use or share PII?
Accept / Reject Status
Question 14 Comment

15. Indicate the type of PII
that the system will collect

Name, E-Mail Address, Phone Numbers, Gender, Race and ethnicity

For Official Use Only (FOUO)

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or maintain.

Accept / Reject Status
Question 15 Comment
16. Indicate the categories of
individuals about whom PII
Employees
is collected, maintained or
shared.
Accept / Reject Status
Question 16 Comment
17. How many individuals'
PII is in the system?

100-200

Accept / Reject Status
Question 17 Comment

18. For what primary
purpose is the PII used?

The PII information used by the eIDP system identifies NEI Trainees
and Fellows that need to create an Individual Development Plan
(IDP). The PII data is used to identify the NEI staff. The gender
and race of the staff is used for aggregate data reporting.

Accept / Reject Status
Question 18 Comment
19. Describe the secondary
uses for which the PII will
N/A
be used (e.g. testing, training
or research)
Accept / Reject Status
Question 19 Comment
For Official Use Only (FOUO)

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20. Describe the function of
N/A
the SSN.
Accept / Reject Status
Question 20 Comment
20a. Cite the legal authority
to use the SSN.

N/A

21. Identify legal authorities
governing information use
42 U.S.C. 241(d), 281
and disclosure specific to the
system and program.
22. Are records on the
system retrieved by one or
more PII data elements?

Yes

Accept / Reject Status
Question 22 Comment

22a. Identify the number and title of the Privacy Act System of Records Notice (SORN) that is
being used to cover the system or identify if a SORN is being developed.
Published:

09-25-0216 NIH Electronic Directory (NED)

Published:
Published:
In Progress
23. Identify the sources of
PII in the system.

Online, Within the OPDIV

Accept / Reject Status
Question 23 Comment
23a. Identify the OMB
information collection
approval number and
expiration date.

An OMB collection approval number is not needed as the eIDP
Website/Database only uses the PII of federal employees for internal
use only.

For Official Use Only (FOUO)

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24. Is the PII shared with
other organizations?

No

Accept / Reject Status
Question 24 Comment

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

N/A

Other Federal
Agency/Agencies

N/A

State or Local
Agency/Agencies

N/A

Private Sector

N/A

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

25. Describe the process in
place to notify individuals
that their personal
information will be
collected. If no prior notice
is given, explain the reason.

PII data is sourced from existing, assess and approved NIH systems
(NED, FPS, NIH nVision). Trainees will enter additional PII
information that is not found in any NIH systems (gender, race, and
ethnicity, at their option). The Trainees will submit the completed
IDP for approval. The individuals will review all data that the
system stores prior to their approval of the final submitted IDP.
Sources systems maintain their own HHS Approved Privacy Impact
Assessments, including all legal authorities documented.

Accept / Reject Status
For Official Use Only (FOUO)

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Question 25 Comment
26. Is the submission of PII
by individuals voluntary or
mandatory?

Voluntary

Accept / Reject Status
Question 26 Comment

27. Describe the method for
individuals to opt-out of the
collection or use of their PII.
If there is no option to object
to the information collection,
provide a reason.

It is optional for the Trainees to complete an IDP. However, this can
potentially disqualify them from the fellowship program since it is a
requirement of the program.
Information that is pulled from source systems offer opt-out options
during their PII submission processes. All source systems maintain
their own HHS Approved PIAs, with legal authorities documented.

Accept / Reject Status
Question 27 Comment
28. 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
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.

NEI Trainees will have the opportunity to view changes to their PII
information during the IDP renewal process. They will go through a
submission and approval process for IDP renewals. They will know
when a change occurs during the renewal period.
Information that is pulled from source systems obtain consent during
their PII submission processes. All source systems maintain their
own HHS Approved PIAs, with legal authorities documented.

Accept / Reject Status
Question 28 Comment
29. Describe the process in
place to resolve an
individual's concerns when

The eIDP System source of most of the PII data is from NIH
systems. The additional PII information requested from the Trainee
is optional. The Trainee does not have to enter the optional PII data.
For Official Use Only (FOUO)

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they believe their PII has
The Trainee can update their PII information by logging into NED
been inappropriately
and/or contacting their Administrative Officer to update incorrect PII
obtained, used, or disclosed, data.
or that the PII is inaccurate.
If no process exists, explain
why not.
Accept / Reject Status
Question 29 Comment
30. Describe the process in
place for periodic reviews of
PII contained in the system
to ensure the data's integrity,
availability, accuracy and
relevancy. If no processes
are in place, explain why
not.

The PIA review will be conducted each time major eIDP
functionalities are released that utilizes addition data (NED, nVision)
or new PII data beyond the data included in the previous PIA.
Minimally, a PIA review will be conducted yearly.

Accept / Reject Status
Question 30 Comment
31. Identify who will have access to the PII in the system and the reason why they require access.
Users

Yes
Trainees, mentors, administrative officers complete and view the
eIDP as it goes through the system.

Administrators

Yes
Responsible for access control.

Developers

Yes
Testing and customer defect resolution.

Contractors
Others
32. Describe the procedures
in place to determine which All requests for access to the eIDP system will be assigned an
system users (administrators, appropriate profile (role) and approved by the System Owner before
developers, contractors, etc.) being implemented by the technical support team.
may access PII.
Accept / Reject Status
For Official Use Only (FOUO)

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Question 32 Comment
33. Describe the methods in
place to allow those with
access to PII to only access Role based access controls are used to limit users' access to PII based
the minimum amount of
on their defined job function and system role.
information necessary to
perform their job.
Accept / Reject Status
Question 33 Comment
34. Identify training and
awareness provided to
personnel (system owners,
managers, operators,
contractors and/or program
managers) using the 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.

Accept / Reject Status
Question 34 Comment
35. Describe training system
users receive (above and
None
beyond general security and
privacy awareness training).
Accept / Reject Status
Question 35 Comment
36. Do contracts include
Federal Acquisition
Regulation and other
Yes
appropriate clauses ensuring
adherence to privacy
For Official Use Only (FOUO)

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provisions and practices?
Accept / Reject Status
Question 36 Comment
37. Describe the process and
guidelines in place with
regard to the retention and
destruction of PII. Cite
specific records retention
schedules.

Records are maintained within eIDP until superseded, 3 years old, or
1 year after separation, in accordance with the National Archives and
Records Administration (NARA) approved disposition schedule:
DAA-GRS-2016- 0014-0003.

Accept / Reject Status
Question 37 Comment
Administrative safeguards: NIH staff take mandatory security and
privacy training and include system security and contingency plan.
Access is via least privilege through role-based access, and policies
for retention and destruction of PII are in place. User rights are
provisioned based on controls within the system, allowing users only
access to the minimum amount of PII necessary to perform their job.
Files are backed up regularly and stored offsite. Contract clauses
ensure adherence to privacy provisions and practices.

38. Describe, briefly but
with specificity, how the PII
will be secured in the system
Physical Safeguards: Physical access to the system is controlled by
using administrative,
security guards, employee badging, proximity cards, card readers,
technical, and physical
and security cameras. Access to the server is controlled by card
controls.
readers at the server room door. There is a battery backup for power
until the backup generator starts. Fire protection including sprinklers,
and flooding sensors at the floor level.
Technical Controls: Technical Safeguards include restricting files
using secure socket layer encryption, a two-factor authentication and
role-based access controls.
Accept / Reject Status
Question 38 Comment

39. Identify the
publicly-available URL.

N/A
For Official Use Only (FOUO)

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Accept / Reject Status
Question 39 Comment
40. Does the website have a
N/A
posted privacy notice?
Accept / Reject Status
Question 40 Comment

40a. Is the privacy policy
available in a
machine-readable format?

N/A

41. Does the website use
web measurement and
customization technology?

N/A

Accept / Reject Status
Question 41 Comment

41a. Select the type of website measurement and customization technologies is in use and if it is
used to collect PII. (Select all that apply).
Web Beacons
Collects PII?
Web Bugs
Collects PII?
Session Cookies
Collects PII?
Persistent Cookies
Collects PII?
Other ...
Collects PII?

For Official Use Only (FOUO)

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42. Does the website have
any information or pages
directed at children under the N/A
age of thirteen?
Accept / Reject Status
Question 42 Comment

42a. Is there a unique
privacy policy for the
website, and does the unique
privacy policy address the
N/A
process for obtaining
parental consent if any
information is collected?
43. Does the website contain
links to non-federal
N/A
government websites
external to HHS?
Accept / Reject Status
Question 43 Comment

43a. Is a disclaimer notice
provided to users that follow
N/A
external links to websites not
owned or operated by HHS?

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.
1. Are the questions on the
PIA answered correctly,
accurately, and completely?
Reviewer Notes
Accept / Reject Status
For Official Use Only (FOUO)

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Question 1 Comment
2. Does the PIA
appropriately communicate
the purpose of PII in the
system and is the purpose
justified by appropriate legal
authorities?
Reviewer Notes
Accept / Reject Status
Question 2 Comment
3. Do system owners
demonstrate appropriate
understanding of the impact
of the PII in the system and
provide sufficient oversight
to employees and
contractors?
Reviewer Notes
Accept / Reject Status
Question 3 Comment
4. Does the PIA
appropriately describe the
PII quality and integrity of
the data?
Reviewer Notes
Accept / Reject Status
Question 4 Comment
5. Is this a candidate for PII
minimization?
Reviewer Notes
Accept / Reject Status
For Official Use Only (FOUO)

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Question 5 Comment
6. Does the PIA accurately
identify data retention
procedures and records
retention schedules?
Reviewer Notes
Accept / Reject Status
Question 6 Comment
7. Are the individuals whose
PII is in the system provided
appropriate participation?
Reviewer Notes
Accept / Reject Status
Question 7 Comment
8. Does the PIA raise any
concerns about the security
of the PII?
Reviewer Notes
Accept / Reject Status
Accept / Reject Status
Question 8 Comment
9. Is applicability of the
Privacy Act captured
correctly and is a SORN
published or does it need to
be?
Reviewer Notes
Accept / Reject Status
Accept / Reject Status

For Official Use Only (FOUO)

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Question 9 Comment
10. Is the PII appropriately
limited for use internally and
with third parties?
Reviewer Notes
Accept / Reject Status
Question 10 Comment
11. Does the PIA
demonstrate compliance
with all Web privacy
requirements?
Reviewer Notes
Accept / Reject Status
Question 11 Comment
12. Were any changes made
to the system because of the
completion of this PIA?
Reviewer Notes
Accept / Reject Status
Question 12 Comment
General Comments
Status and Approvals
IC Status

Undefined

OSOP Status

Undefined

OPDIV Senior Official for
Privacy Signature
HHS Senior Agency Official
for Privacy

For Official Use Only (FOUO)

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