Privacy Impact Assesment

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:

National Industrial Security System (NISS)
3. PIA APPROVAL DATE:

2. DOD COMPONENT NAME:

03/28/23

If Other, enter the Component name in the box below.
Defense Counterintelligence and Security Agency (DCSA)
SECTION 1: PII DESCRIPTION SUMMARY (FOR PUBLIC RELEASE)
a. The PII is: (Check one. Note: foreign nationals are included in general public.)
From members of the general public

From Federal employees and/or Federal contractors

From both members of the general public and Federal employees and/or
Federal contractors

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.

NISS is DCSA's electronic repository of industrial security facility clearance information. NISS data is indexed and retrieved by the name or
Cage code associated with a NISP facility and provides users with a nationwide perspective on NISP facilities as well as facilities under
DCSA oversight in the DoD conventional Arms, Ammunition, and Explosives (AA&E) program. All industrial security personnel use NISS
to track industrial security facility clearances and actions in connection with any NISP or AA&E facility. For Key Management Personnel
(KMP) and for Culpable individuals involved in Security violations, NISS collects first, middle, and last name, SSN, date of birth, place of
birth (city, state, country), citizenship data, and personnel security clearance information.
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)

All industrial security personnel use NISS to track industrial security facility clearances and actions in connection with any NISP or AA&E
facility.
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.

Participation in the NISP is voluntary. During system account creation, users must assert that they have read the Privacy Act Statement in
order to submit their account request. The Privacy Act Statement outlines the Authorities, Purpose, Routine Use(s) and Disclosures for
specific uses of their PII within the system. If a user doesn't consent to the Privacy Act Statement, their account request will not be approved.
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.

During system account creation, users must assert they have read the Privacy Act Statement in order to submit their account request. The
Privacy Act Statement outlines the specific uses for their PII information within the NISS system.
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

Authority: E.O. 12829, National Industrial Security Program (NISP); 32 CFR Part 117, National Industrial Security Program Operating
Manual; DoD Instruction 5220.22, National Industrial Security Program; and E.O. 9397 (SSN), as amended.
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Purpose: The National Industrial Security System (NISS) maintains and processes unclassified company and personal information necessary
to conduct the DCSA security oversight mission. It will provide the United States Government (USG) and Industry stakeholders with a datadriven, collaborative, capability to assess and mitigate the risk of the loss or compromise of classified information. DCSA is responsible for
an industrial base of more than 12,000 cleared facilities, 40,000 classified information systems, and 900,000 cleared industry personnel.
Routine Uses: In addition to those disclosures generally permitted under 5 U.S.C. 552a (b) of the Privacy Act of 1974, as amended, the
records contained herein may specifically be disclosed outside the DoD as a routine use pursuant to 5 U.S.C. 552(b)(1) as follows:
To DCSA personnel for the purpose of being issued an Internal NISS user account, those individuals will have access to Personal
Identification Data information.
To security and contracting personnel for other (non-DoD) Federal agencies, in connection with FCL Verification Requests, Facility
Security Officer (FSO) name and telephone number will be available for any cleared company. Special requests for additional information
may be made, and these requests will be coordinated and adjudicated in accordance with Agency standard procedures.
To security personnel working for cleared companies. Information in NISS regarding a particular cleared company will be available for
review by authorized security personnel working for that company. Authorized personnel working for cleared companies who are verifying
the facility clearances of other companies may obtain core facility information and FSO name and telephone number.
Disclosure: Voluntary; however, failure to provide all the data requested may result in our inability to maintain accurate historic facility
security information, may slow down the performance against classified contracts and provides an area of error in the maintenance of
transparency between Industry and Government stakeholders.
h. With whom will the PII be shared through data exchange, both within your DoD Component and outside your Component? (Check all that apply)

Within the DoD Component

Specify.

Other DoD Components

Specify.

Other Federal Agencies

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.

Authorized DCSA personnel may be issued an internal NISS
user account; those individuals will have access to all
Personal Identification Data (PID) Information. The primary
user is the Industrial Security Program (ISP) for maintaining
information of those facilities participating in the NISP.
Information provided to external users at a given facility
will include KMP List and name/telephone/email of those
persons associated with the facility. For general FCL
information requests for all external users, FSO name and
telephone number will be available for any valid company
searched.
Information provided to external users at a given facility
will include KMP List and name/telephone/email of those
persons associated with the facility. For general FCL
information requests for all external users, FSO name and
telephone number will be available for any valid company
searched.
To any criminal, civil, security, or regulatory authority
(whether Federal, State, territorial, local, or tribal) for the
purpose of providing background search information on
individuals for legally authorized purposes.
The contractors developing and sustaining this system may
have access to PII for the purpose of operations and
sustainment of the system, for no other use. Contractors who
will be the users of the system will be provided notices
regarding PII protections applicable to all users.

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

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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)

Face-to-Face 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
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.

As discussed with the Program Managers of NISS, it was determined that the NISS IT system does not meet the definition of a Privacy Act
System of Records; therefore there’s no requirement to establish a NISS standalone System of Records Notice.
When data is retrieved from NISS, the records are not retrieved by PII of key management personnel. Data is only retrieved by company
name or cage code associated with a NISP facility. Records are company based, and the data unique to key management personnel is
contained within the company’s record. There is no functionality in NISS to search by individual user information or SSN.
The NISS Privacy Impact Assessment was updated to reflect no SORN is required.
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.

DAA-0446-2017-0001

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

(3) Retention Instructions.

Maintain at a minimum 6 months of activity data prior to archival. Archived data must preserve metadata, and the metadata must be linkable
to archived data at all times in case of a system migration. All other data will be archived based on the DCSA retention policy for facility
information.
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.

E.O. 12829, National Industrial Security Program (NISP); 32 CFR Part 117, National Industrial Security Program Operating Manual; DoD
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Instruction 5220.22, National Industrial Security Program; and E.O. 9397 (SSN), as amended.
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.

OMB Control Number: 0705-0006. Expiration Date: 02/29/2024

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