Draft Privacy Impact Assessment

PRIVACY IMPACT ASSESSMENT (PIA)
PRESCRIBING AUTHORITY: DoD Instruction 5400.16, "DoD Privacy Impact Assessment (PIA) Guidance". Complete this form for Department of Defense
(DoD) information systems or electronic collections of information (referred to as an "electronic collection" for the purpose of this form) that collect, maintain, use,
and/or disseminate personally identifiable information (PII) about members of the public, Federal employees, contractors, or foreign nationals employed at U.S.
military facilities internationally. In the case where no PII is collected, the PIA will serve as a conclusive determination that privacy requirements do not apply to
system.
1. DOD INFORMATION SYSTEM/ELECTRONIC COLLECTION NAME:

Holm Center Web Intensive New Gains System (WINGS) Application
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

08/03/22

United States Air Force
Department of the Air Force, Air Education and Training Command
SECTION 1: PII DESCRIPTION SUMMARY (FOR PUBLIC RELEASE)
a. The PII is: (Check one. Note: Federal contractors, military family members, and foreign nationals are included in general public.)
From members of the general public

From Federal employees

from both members of the general public and Federal employees

Not Collected (if checked proceed to Section 4)

b. The PII is in a: (Check one.)
New DoD Information System

New Electronic Collection

Existing DoD Information System

Existing Electronic Collection

Significantly Modified DoD Information System
c. Describe the purpose of this DoD information system or electronic collection and describe the types of personal information about individuals
collected in the system.

The Web Intensive New Gains System (WINGS) is the Holm Center Enterprise Resource Planning system that is used to track prospect,
trainee, and staff information for the Air Force Junior Reserve Officer Training Corps (AFJROTC), Air Force Reserve Officer Training
Corps (AFROTC), and Air Force Officer Training School (OTS). WINGS collects and maintains personal information required to process
instructor and scholarship applications, cadet curriculum, financial transactions, and evaluate performance as required by Holm Center
programs to support accession of cadets as officers in the USAF. PIA information collected is Citizenship, Employment Information,
Home/Cell Number, Military records, Official Duty Address, Place of Birth, Race/Ethnicity, Records, Work E-mail Address, Birth Date,
Disability Information, Education Information, Financial Information, Law Enforcement Information, Martial Status, Official Duty
Telephone Phone, Personal Email Address, Position/Title, Rank/Grade, Security Information, Child Information, Emergency Contact,
Gender/Gender Identification, Name (s), Other ID Number, Photo, and Social Security Number.

d. Why is the PII collected and/or what is the intended use of the PII? (e.g., verification, identification, authentication, data matching, mission-related use,
administrative use)

Identification, verification, authentication, data matching, and mission related
e. Do individuals have the opportunity to object to the collection of their PII?

Yes

No

(1) If "Yes," describe the method by which individuals can object to the collection of PII.
(2) If "No," state the reason why individuals cannot object to the collection of PII.

Applications for entry into Holm Center programs have consent statements and required PII collection. If no consent is given or required
information is not provided, applicant may not enter Holm Center as an JROTC instructor or ROTC Cadet.
f. Do individuals have the opportunity to consent to the specific uses of their PII?

Yes

No

(1) If "Yes," describe the method by which individuals can give or withhold their consent.
(2) If "No," state the reason why individuals cannot give or withhold their consent.

The general consent statement is that information will not be distributed and is for internal use only. When entering an obligated status there
is an additional consent that information will be shared for pay, performance, and personnel tracking purposes.
g. When an individual is asked to provide PII, a Privacy Act Statement (PAS) and/or a Privacy Advisory must be provided. (Check as appropriate and
provide the actual wording.)
Privacy Act Statement

Privacy Advisory

Not Applicable

JROTC Instructor Application
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Air Force JROTC
Privacy Act Statement:
AUTHORITY: 10 United States Code (U.S.C.) 2031 - Junior Reserve Officers' Training Corps, 10 U.S.C 2033 - Instructor Qualifications,
10 U.S.C. 9013 - Secretary of the Air Force implementing JROTC Air Force Instruction 36-2010 - Junior Reserve Officers’ Training Corps
Program, DoD Instruction 1205.13 - Junior Reserve Officers Training Corps (JROTC) Program, and Executive Order 9397 (SSN) Numbering System for Federal Accounts Relating to Individual Persons.
PURPOSE: To evaluate individual's qualifications for employment as an AFJROTC instructor.
ROUTINE USES: As indicated in system notice F036 AETC B, Air Force Junior ROTC (AFJROTC) Applicant/Instructor System. Records
from this system of records may be disclosed for any of the blanket routine uses published by the Air Force. This information may be
disclosed to federal, state, or local agencies maintaining civil, criminal, or other relevant enforcement in formation, obtain information
concerning hiring or retention of an employee, issuance of a security clearance, letting of a contract, or issuance of a license, grant or other
benefit; to a federal agency in response to its request in connection with the hiring or retention of an employee, issuance of a security
clearance, reporting of an investigation of an employee, letting of a contract, issuance of a license, grant, or other benefit by the requesting
agency to the extent that the information is relevant and necessary to the requesting agency's decision on the matter; to NARA for records
management functions; and to the Department of Justice for pending or potential litigation; to agencies, entities, and persons necessary to
assist Components efforts with data breach remediation in connection to suspected or confirmed data compromise.
DISCLOSURE: Furnishing information is voluntary. Failure to provide information could result in non-selection of AFJROTC instructor
duty.
Select "Yes" to acknowledge that:
I have read and agree to provide personal information required to be evaluated as for an AFJROTC Instructor position.
Yes
No
Air Force ROTC Pre-Screen
PRIVACY ACT STATEMENT
AUTHORITY: 10 USC 33 - Original Appointments of Regular Officers in Grades Above Warrant Officer Grades, 10 U.S.C. 103 - Senior
Reserve Officers' Training Corps as implemented by Air Force Reserve Officers' Training Corps Instruction (AFROTCI) 36-2011, 10
U.S.C. 2107- Financial Assistance Program of Specially Selected Members, Executive Order 9897 - Amendments to Regulations Relating to
Commissioned Officers and Employees of the Public Health Service, Executive Order, and 9397 (SSN) - Numbering System for Federal
Accounts Relating to Individual Persons .
PURPOSE: To identify an AFROTC applicant's intention to either apply, accept, or decline an offer for ROTC membership or scholarship.
ROUTINE USES: As indicated in System of Record Notice (SORN) F036 AETC X, College Scholarship Program Files and for processing
the application for membership in the ROTC program. Information will not be released outside of the DoD.
DISCLOSURE IS VOLUNTARY: Failure to provide requested information may hinder processing and may preclude activating a
scholarship.
Select "Yes" to acknowledge that:
I am 13 years old or older AND
I have read and agree to provide personal information required to fully participate in the Air Force ROTC Program.
Yes
No
AF ROTC
PRIVACY ACT STATEMENT
AUTHORITY: AUTHORITY: 10 USC 33 - Original Appointments of Regular Officers in Grades Above Warrant Officer Grades, 10
U.S.C. 103 - Senior Reserve Officers' Training Corps as implemented by Air Force Reserve Officers' Training Corps Instruction
(AFROTCI) 36-2011, 10 U.S.C. 2103, Eligibility for Membership, 10 U.S.C. 2104, Advanced Training; Eligibility for, Executive Order
9897 - Amendments to Regulations Relating to Commissioned Officers and Employees of the Public Health Service, Executive Order, and
9397 (SSN) - Numbering System for Federal Accounts Relating to Individual Persons .
PURPOSE: To process and manage selected students for acceptance into the USAF ROTC program.
ROUTINE USES: As indicated in System of Record Notice (SORN) F036 AETC X, College Scholarship Program Files and for processing
the application for membership in the ROTC program. Records from this system of records may be disclosed for any of the blanket routine
uses published by the Air Force. This information may be disclosed for federal, state, local or foreign law enforcement authorities for
investigating or prosecuting a violation or potential violation of law; to federal, state, or local agencies to obtain information concerning
hiring or retention of an employee, issuance of a security clearance, letting of a contract, or issuance of a license, grant or other benefit; to a
federal agency in response to its request in connection with the hiring or retention of an employee, issuance of a security clearance, reporting
of an investigation of an employee, letting of a contract, issuance of a license, grant, or other benefit by the requesting agency to the extent
that the information is relevant and necessary to the requesting agency's decision on the matter; to a congressional office in response to their
inquiry made at the request of the individual; to the Office of Management and Budget in connection with review of private relief legislation
as set forth in OMB Circular A-19; to foreign law enforcement, security, investigatory, or administrative authorities to comply with
requirements of international agreements and arrangements; to the state and local taxing authorities in accordance with Treasury Fiscal
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Requirements Manual Bulletin 7607; to the Office of Personnel Management (OPM) concerning information on pay and leave, benefits,
retirement deductions, and other information necessary for OPM to carry out its functions; to NARA for records management functions;
and to the Department of Justice for pending or potential litigation; to agencies, entities, and persons necessary to assist Components efforts
with data breach remediation in connection to suspected or confirmed data compromise.
DISCLOSURE: Furnishing the information is voluntary. Failure to provide requested information will hinder processing.
Select "Yes" to acknowledge that:
I am 13 years old or older AND
I have read and agree to provide personal information required to fully participate in the Air Force ROTC Program.
Yes
No
Air Force Officer Training School
PRIVACY ACT STATEMENT
AUTHORITY: 10 USC 907 – Schools and camps as implemented by Air Force Instruction 36-2013 Airman Commissioning Programs and
Officer Training School, 10 U.S.C. 33 Original Appointments of Regular Officers in Grades Above Warrant Officer Grades, 10 U.S.C.
Chapter 907 Schools and Camps, Executive Order 9897 Amendments to Regulations Relating to Commissioned Officers and Employees of
the Public Health Service, Executive Order 9397, Numbering System for Federal Accounts Relating to Individual Persons.
PURPOSE: To monitor the progress of an individual toward completion of the program. Records may be grouped by class, squadron, flight,
or performance factor in the accomplishment of evaluations of the program or the individual in relation of peers.
ROUTINE USES: As indicated in System of Record Notice (SORN) F036 AETC K, Officer Training School Flight Training Information
System and for studies, analyses, and evaluations that use the records are intended to rank order graduates for each class and determine
award winners. Post-graduation analysis of student records will be used to evaluate program effectiveness and to plan for future sessions.
Records from this system of records may be disclosed for any of the blanket routine uses published by the Air Force. This information may
be disclosed for federal, state, local or foreign law enforcement authorities for investigating or prosecuting a violation or potential violation
of law; to federal, state, or local agencies to obtain information concerning hiring or retention of an employee, issuance of a security
clearance, letting of a contract, or issuance of a license, grant or other benefit; to a federal agency in response to its request in connection
with the hiring or retention of an employee, issuance of a security clearance, reporting of an investigation of an employee, letting of a
contract, issuance of a license, grant, or other benefit by the requesting agency to the extent that the information is relevant and necessary to
the requesting agency's decision on the matter; to a congressional office in response to their inquiry made at the request of the individual; to
the Office of Management and Budget in connection with review of private relief legislation as set forth in OMB Circular A-19; to foreign
law enforcement, security, investigatory, or administrative authorities to comply with requirements of international agreements and
arrangements; to NARA for records management functions; and to the Department of Justice for pending or potential litigation; to agencies,
entities, and persons necessary to assist Components efforts with data breach remediation in connection to suspected or confirmed data
compromise; to appropriate entities when security or confidentiality of the information in the system of records has been compromised, there
is a risk of harm to economic or property interests, identity theft or fraud, disclosure made is reasonably necessary to assist in responding to
the suspected or confirmed compromise.
DISCLOSURE IS VOLUNTARY: Failure to provide requested information will hinder processing and may preclude continuing in Officer
Training School.
Select "Yes" to acknowledge that:
I have read and agree to provide personal information required to fully participate in the Air Force OTS Program.
Yes
No

h. With whom will the PII be shared through data/system exchange, both within your DoD Component and outside your Component?
(Check all that apply)
Within the DoD Component

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Specify.

AFPC, ARPC, MilPDS, AF/SG, USAFA, AFRS

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Other DoD Components (i.e. Army, Navy, Air Force)

Specify.

Other Federal Agencies (i.e. Veteran’s Affairs, Energy, State)

Specify.

State and Local Agencies

Specify.

Contractor (Name of contractor and describe the language in
the contract that safeguards PII. Include whether FAR privacy
clauses, i.e., 52.224-1, Privacy Act Notification, 52.224-2,
Privacy Act, and FAR 39.105 are included in the contract.)

Specify.

Other (e.g., commercial providers, colleges).

Specify.

DFAS, DEERS, DoDMERB, DTS, US Space Force

University attended by Cadets receiving Scholarships

i. Source of the PII collected is: (Check all that apply and list all information systems if applicable)
Individuals

Databases

Existing DoD Information Systems

Commercial Systems

Other Federal Information Systems

j. How will the information be collected? (Check all that apply and list all Official Form Numbers if applicable)
E-mail

Official Form (Enter Form Number(s) in the box below)

In-Person Contact

Paper

Fax

Telephone Interview

Information Sharing - System to System

Website/E-Form

Other (If Other, enter the information in the box below)

k. Does this DoD Information system or electronic collection require a Privacy Act System of Records Notice (SORN)?
A Privacy Act SORN is required if the information system or electronic collection contains information about U.S. citizens or lawful permanent U.S. residents that
is retrieved by name or other unique identifier. PIA and Privacy Act SORN information must be consistent.
Yes

No

If "Yes," enter SORN System Identifier

F036 AETC B, F036 AETC K, F036 AE

SORN Identifier, not the Federal Register (FR) Citation. Consult the DoD Component Privacy Office for additional information or http://dpcld.defense.gov/
Privacy/SORNs/
or
If a SORN has not yet been published in the Federal Register, enter date of submission for approval to Defense Privacy, Civil Liberties, and Transparency
Division (DPCLTD). Consult the DoD Component Privacy Office for this date
If "No," explain why the SORN is not required in accordance with DoD Regulation 5400.11-R: Department of Defense Privacy Program.

l. What is the National Archives and Records Administration (NARA) approved, pending or general records schedule (GRS) disposition authority
for the system or for the records maintained in the system?
(1) NARA Job Number or General Records Schedule Authority.

N1-AFU-92-13, N1-AFU-90-03

(2) If pending, provide the date the SF-115 was submitted to NARA.

(3) Retention Instructions.

T 10 - 13 R 13.01; Cadet Evaluation or applications for AFROTC College Scholarship Program - Destroy after 1 year or when no longer
needed, whichever is sooner.
T 10 - 15 R 18.00; AFROTC Scholarship Program -- Destroy 1 year after termination of board cycle.
T 10 - 15 R 21.00; Air Force Junior Reserve Officer Training Corps (AFROTC) -- Destroy 30 days after withdraw or termination of
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eligibility.
T 65 - 24 R 08.00; AF Junior Instructor Pay - Destroy 6 years after individual has terminated employment, or 1 year after grievance or
appeal is settled.
T 36 - 47 R 01.00; Applications for Officer Training School, Airmen Education and Commissioning Program, Flying Training...[cont.] -Destroy after 1 year.
Among the dispositions cited in this field, the one with the longest retention time will be used on the system’s records data.
m. What is the authority to collect information? A Federal law or Executive Order must authorize the collection and maintenance of a system of
records. For PII not collected or maintained in a system of records, the collection or maintenance of the PII must be necessary to discharge the
requirements of a statue or Executive Order.
(1) If this system has a Privacy Act SORN, the authorities in this PIA and the existing Privacy Act SORN should be similar.
(2) If a SORN does not apply, cite the authority for this DoD information system or electronic collection to collect, use, maintain and/or disseminate PII.
(If multiple authorities are cited, provide all that apply).
(a) Cite the specific provisions of the statute and/or EO that authorizes the operation of the system and the collection of PII.
(b) If direct statutory authority or an Executive Order does not exist, indirect statutory authority may be cited if the authority requires the
operation or administration of a program, the execution of which will require the collection and maintenance of a system of records.
(c) If direct or indirect authority does not exist, DoD Components can use their general statutory grants of authority (“internal housekeeping”) as
the primary authority. The requirement, directive, or instruction implementing the statute within the DoD Component must be identified.

- System of Record (SORN) F036 AETC B Air Force Junior ROTC (AFJROTC) Applicant/Instructor System
- System of Record (SORN) F036 AETC X College Scholarship Program (CSP)
- System of Record (SORN) F036 AETC K, Officer Training School Flight Training Information System
- 10 U.S.C. (United States Code) 9013, Secretary of the Air Force implementing JROTC Air Force Instruction 36-2010, Junior Reserve
Officers’ Training Corps Program
- 10 U.S.C. 2031, Junior Reserve Officers' Training Corps
- 10 U.S.C. 2033, Instructor Qualifications
- DoD Instruction 1205.13 Junior Reserve Officers Training Corps (JROTC) Program
- 10 U.S.C. 2103, Eligibility for Membership
- 10 U.S.C. 2104, Advanced Training; Eligibility for
- 10 U.S.C. 2107, Financial Assistance Program for Specially Selected Members
- 10 U.S.C. 103, Senior Reserve Officers' Training Corps, as implemented by Air Force Reserve Officers' Training Corps Instruction
36-2011, Air Force Reserve Officer Training Corps
- 10 U.S.C. 33 Original Appointments of Regular Officers in Grades Above Warrant Officer Grades
- 10 U.S.C. Chapter 907 Schools and Camps
- Executive Order 9897 Amendments to Regulations Relating to Commissioned Officers and Employees of the Public Health Service
- Executive Order 9397, Numbering System for Federal Accounts Relating to Individual Persons
n. Does this DoD information system or electronic collection have an active and approved Office of Management and Budget (OMB) Control
Number?
Contact the Component Information Management Control Officer or DoD Clearance Officer for this information. This number indicates OMB approval to
collect data from 10 or more members of the public in a 12-month period regardless of form or format.
Yes

No

Pending

(1) If "Yes," list all applicable OMB Control Numbers, collection titles, and expiration dates.
(2) If "No," explain why OMB approval is not required in accordance with DoD Manual 8910.01, Volume 2, " DoD Information Collections Manual:
Procedures for DoD Public Information Collections.”
(3) If "Pending," provide the date for the 60 and/or 30 day notice and the Federal Register citation.

PENDING: OMB 0701-0105 AFROTC Application, currently expired. The 60 Day Notice and the Federal Register citation was sent to the
SAF/CNZA office 21 Sept 23 for review and publication.
PENDING: OMB 0701-XXXX AFJROTC Instructor Application, the 60 Day Notice and the Federal Register citation was published the
week of 12 May 23. The OMB package and Supporting Documentation have been sent to the OMB office for review prior to posting to the
PRA Tracker.

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SECTION 2: PII RISK REVIEW
a. What PII will be collected (a data element alone or in combination that can uniquely identify an individual)? (Check all that apply)
Biometrics

Birth Date

Child Information

Citizenship

Disability Information

DoD ID Number

Driver's License

Education Information

Emergency Contact

Employment Information

Financial Information

Gender/Gender Identification

Home/Cell Phone

Law Enforcement Information

Legal Status

Mailing/Home Address

Marital Status

Medical Information

Military Records

Mother's Middle/Maiden Name

Name(s)

Official Duty Address

Official Duty Telephone Phone

Other ID Number

Passport Information

Personal E-mail Address

Photo

Place of Birth

Position/Title

Race/Ethnicity

Rank/Grade

Protected Health Information (PHI)1
Religious Preference

Records

Security Information

Work E-mail Address

If Other, enter the information in the box below

Social Security Number (SSN) (Full or in any
form)

If the SSN is collected, complete the following questions.
(DoD Instruction 1000.30 states that all DoD personnel shall reduce or eliminate the use of SSNs wherever possible. SSNs shall not be used in spreadsheets,
hard copy lists, electronic reports, or collected in surveys unless they meet one or more of the acceptable use criteria.)
(1) Is there a current DPCLTD approved SSN Justification on Memo in place?
Yes

No

If "Yes," provide the signatory and date approval. If “No,” explain why there is no SSN Justification Memo.

Signed by Holm Center/CC, Brig Gen Houston R. Cantwell, dated 27 Jul 23

(2) Describe the approved acceptable use in accordance with DoD Instruction 1000.30 “Reduction of Social Security Number (SSN) Use within DoD”.

(3) Security Clearance Investigation or Verification. The initiation, conduct,
adjudication, verification, quality assurance, and billing fund control of background
investigations and security clearances requires the use of the SSN. The SSN is the single
identifier that links all of the aspects of these investigations together. This use case is also linked
to other Federal agencies that continue to use the SSN as a primary identifier. WINGS uses the SSN for instructor and cadet background
investigations, security clearance applications, and to acquire Common Access Cards (CAC).
(5) Confirmation of Employment Eligibility. Federal statute requires that all persons
employed within the United States provide an SSN or comparable identifier to prove that they
are eligible to work for or with the U.S. Government. Any system that deals with employment
eligibility may contain the SSN. WINGS uses the SSN to verify employment eligibility for instructors.
(8) Computer Matching. Systems, processes, or forms that interact with other
Government agencies may require the continued use of the SSN as a primary identifier until such
time as the applications to which they are linked move to some other identifier as a primary means for transferring, matching, or checking
information. WINGS interfaces with other DoD Systems that require the use of the SSN to provide computer matching between systems as
verification of an individual’s identity.
(11) Legacy System Interface. WINGS interfaces with many DoD systems of record that have not transitioned to the DoD ID Numbers as a
unique identifier and require the SSN be provided.
(3) Describe the mitigation efforts to reduce the use including visibility and printing of SSN in accordance with DoD Instructoin 1000.30, “Reduction of
Social Security Number (SSN) Use within DoD”.

The SSN only used when positive identification is needed. The SSN is not printed on documents unless no other choice exists. The SSN is
stored in WINGS on one table as a non-key field. An Employee ID (system generated unique ID) is used across the WINGS system to
uniquely identify the instructor or student. The SSN is also required by other DoD systems and will have to be retained until other systems no
longer require the SSN.
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