Attachment 6 B CDC Data Systems ROB Systems Administrators

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Centers for Disease Control and
Prevention
National Center for HIV/AIDS, Viral Hepatitis,
STD, & TB Prevention
CDC Data Systems

________________________________________________
Rules of Behavior for the Administration of
CDC Data Systems
Agency System Administrators

________________________________________________
July 2011

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This document contains information that may be exempt from public release under the Freedom of Information Act (FOIA)
(5 U.S.C. 552), exemption 2 applies. Approval by the Centers for Disease Control and Prevention Document Control
Officer (OSEP) and the CDC FOIA Officer, prior to public release via the FOIA Office is required.
This document was prepared by the Data System and Analysis Team (Shubha Rao, swr2@cdc.gov and John Beltrami,
hzb3@cdc.gov).

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TABLE OF CONTENTS
1. INTRODUCTION ............................................................................................. 2
1.1 PURPOSE AND SCOPE .................................................................................... 2
1.2 LEGAL, REGULATORY, AND POLICY REQUIREMENTS .......................................... 2
1.3 STATEMENT OF SYSTEM POLICY...................................................................... 3
1.4 NO EXPECTATION OF SYSTEM USE PRIVACY .................................................... 4
1.5 PENALTIES FOR NON-COMPLIANCE.................................................................. 4
2. SYSTEM ADMINISTRATOR RESPONSIBILITIES ......................................... 4
2.1 ETHICAL CONDUCT......................................................................................... 4
2.2 AUTHENTICATION MANAGEMENT ..................................................................... 4
2.2.1 Granting Access ................................................................................... 5
2.2.2 Levels of Access ................................................................................... 5
2.2.3 Terminating Access .............................................................................. 6
2.2.4 Use of Passwords ................................................................................. 6
2.2.5 Administration of Proxies ...................................................................... 6
2.3 INFORMATION MANAGEMENT AND DOCUMENT HANDLING .................................. 6
2.3.1 Storage ................................................................................................. 7
2.3.2 Disposal ................................................................................................ 7
2.3.3 Release of Data .................................................................................... 8
2.3.4 Encryption ............................................................................................. 8
2.3.5 Backing Up Data ................................................................................... 9
2.4 SYSTEM ACCESS AND USAGE ....................................................................... 10
2.4.1 Portable Equipment ............................................................................ 10
2.4.2 Physical Security of Equipment .......................................................... 11
2.4.3 Dial-Up Access ................................................................................... 11
2.4.4 Locking Workstations .......................................................................... 11
2.4.5 Disable Browser Password Caching ................................................... 11
2.5 INCIDENT REPORTING ................................................................................... 12
2.5.1 Breaches of Confidentiality ................................................................. 12
2.5.2 Unauthorized Intrusions ...................................................................... 12
2.6 TRAINING AND AWARENESS .......................................................................... 13
2.7 CDC DATA SYSTEM SECURITY AGREEMENTS ................................................ 13
3. USER ASSISTANCE AND ADDITIONAL RESOURCES.............................. 13
4. REVISIONS AND RENEWAL........................................................................ 14
5. ACKNOWLEDGEMENT AND AGREEMENT OF RULES OF BEHAVIOR
FOR CDC DATA SYSTEMS AGENCY SYSTEM ADMINISTRATORS ............. 15
Sensitive but Unclassified (SBU)
This document contains information that may be exempt from public release under the Freedom of Information Act (FOIA)
(5 U.S.C. 552), exemption 2 applies. Approval by the Centers for Disease Control and Prevention Document Control
Officer (OSEP) and the CDC FOIA Officer, prior to public release via the FOIA Office is required.
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1. Introduction
1.1 Purpose and Scope
The purpose of this “Rules of Behavior” for CDC data systems Agency System
Administrators (ROB-ASA) is to provide administrators of CDC data systems
guidelines for policies and practices related to National HIV Prevention Program
Monitoring and Evaluation (NHM&E) data collection and web-based reporting. All
Agency System Administrators of CDC data systems should review the topics
discussed in this guide and sign it. Additional rules of behavior may be appended
if required by state or local law or are otherwise necessary.
For purposes of this document, the term “CDC data systems” refers to CDCfunded Information Technology (IT) systems used for collecting and reporting
NHM&E data.
CDC data systems are browser-based software systems for reporting NHM&E
data. CDC data systems are made available to CDC grantees who wish to use
them for data collection and reporting. Grantees choosing to use CDC data
systems must develop rules for systems users who comply with these guidelines.
The information presented within the ROB addresses the:
 Scope, boundaries, and applicability of the system rules
 Governing law and policy applicable to the system
 Statements of policy related to expected Agency System
Administrators’ behaviors and responsibilities
 Broad range of consequences possible for policy violation
 Descriptions of the CDC data systems Agency System Administrators’
responsibilities
 Listing of any system-specific prohibited actions
 Process for obtaining system help and a listing of additional resources
 Process for publishing and acknowledging revisions
 Formal acknowledgement and agreement mechanism (signature)

1.2 Legal, Regulatory, and Policy Requirements
CDC data systems are part of CDC System Enterprise Architecture and are held
to a high standard of performance with regard to security. The following
standards were applied to CDC data systems:

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

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Clinger-Cohen Act of 1996 (Public Law 104-106)
http://www.cio.gov/documents_details.cfm/uid/1F432CB6-2170-9AD7F2F9BFC351F83400/structure/Laws,%20Regulations,%20and%20Guidan
ce/category/IT%20Related%20Laws%20and%20Regulations
OMB Budget Circular A-130, Appendix III, Security of Federal Automated
Information Resources
http://www.whitehouse.gov/omb/circulars_a130_a130appendix_iii
Federal Information Security Management Act (FISMA)
http://csrc.nist.gov/groups/SMA/fisma/index.html
HHS Information Security Program Policy HHS-IRM-2004-0002
http://www.hhs.gov/ocio/policy/2004-0002.001.html
National Institute of Standards and Technology Special Publications 800
Series http://csrc.nist.gov/publications/PubsSPs.html
Executive Orders, Directives, Regulations, Publications, Guidance(s)

Compliance requirements for the operation of CDC data systems include
participation in the following processes and filing/signing the relevant
documents:
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Certification & Authentication (C&A) process
CDC Capitol Planning Investment Control (CPIC) OMB reporting
Enterprise System cataloguing
Various service agreements that must be executed

Agencies may be required to meet additional data security requirements
based on current legal, regulatory, and policy requirements for the C&A
process.
With respect to these laws and regulations, prohibited uses include:




Accessing or inappropriately using information which is protected by
the Privacy Act or other federally mandated confidentiality provisions
and/or by OMB Circular A-130, Management of Federal Information
Resources
Violating copyrights or software licensing agreements

1.3 Statement of System Policy
At each grantee site, the Agency System Administrator is responsible for
overseeing activities that help prevent the unauthorized use of, and access to,
system resources. This duty includes complying with all stated policy
requirements, taking due care and reasonable precautions when handling
system data or using system resources, and in the management and protection
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of system authentication controls (e.g., passwords, certificates, etc.). When in
doubt, administrators are strongly encouraged to contact the NHM&E Service
Center helpdesk (phone: 1-888-736-7311, e-mail: pemsservice@cdc.gov) for
assistance.

1.4 No Expectation of System Use Privacy
CDC or local Agency System Administrators may periodically monitor both the
system and user activities for purposes including, but not limited to,
troubleshooting, performance assessment, usage patterns, indications of attack
or misuse, and the investigation of a complaints or suspected incidents or
security breaches. Users are provided system access for the purpose of
facilitating federal, state, local, and agency public health missions.

1.5 Penalties for Non-Compliance
Agency System Administrators and CDC data system users who do not comply
with the prescribed ROB are subject to penalties that can be imposed under
existing policy and regulations including reprimands, suspension of system
privileges, and suspension from duty, termination, or criminal prosecution.

2. System Administrator Responsibilities
2.1 Ethical Conduct
Agency System Administrators should ensure that CDC data system users are
only permitted to access: the data that they enter, the data that belong to their
individual organization, and specific data to which they have been given rights.
Using system resources to copy, release, or view data without authorization must
be prohibited. Altering data improperly or otherwise tampering with the system
must be prohibited. Agency System Administrators have access to client-specific
data and are therefore responsible for the protection of confidential information
and must promptly manage and report any breaches.

2.2 Authentication Management
Access to NHM&E data files and CDC data system software must be restricted to
authorized users. Agency System Administrators will verify a potential user’s
need to access NHM&E data, establish user accounts, limit activities within the
system, and terminate access when employees leave, change jobs, or breach
agency policies. Agency System Administrators must make sure that system
users who share the same computer have and use separate logins and secure
data network security certificates. Authentication requirements will be determined
based on the security level assessed for the application or data system by CDC’s
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Office of the Chief Information Security Officer (OCISO). Users of these data
systems or applications are required to comply with authentication requirements
set forth by OCISO. The Agency System Administrator will be responsible for
ensuring that all staff members that use the application meet all authentication
requirements.

2.2.1 Granting Access
The Agency System Administrator or an officially designated individual grants
access to staff requiring the use of CDC data systems and NHM&E data. The
steps in this process for CDC grantees that choose to use CDC data systems
software are as follows:
 Application for a security certificate
 Application for CDC data system access (to include a letter from
Agency System Administrator)
This is done in writing through the user’s supervisor and should include a
description of the user’s duties related to CDC data systems. Once a certificate
is granted, the Agency System Administrator then establishes an account in the
system for that user. This account should have specific permissions and levels
of access that limit the user to levels necessary to perform the required duties.
Users are assigned a user ID and a means of authenticating who they are, such
as a password. An Agency System Administrator’s responsibility also includes
restricting access to parts of CDC data systems according to the role of the user,
modifying access within the system when a user’s duties change, and
terminating access when employees leave, change jobs, or breach agency
policies.
Users of CDC data systems who have access to confidential data or secured
areas should sign binding, non-disclosure agreements before being given access
to CDC data systems and confidential NHM&E data (trainings in the policies and
procedures concerning NHM&E data security and confidentiality are also highly
recommended).

2.2.2 Levels of Access
The Agency System Administrator is responsible for restricting access to parts of
CDC data systems according to the roles of the user and modifying access within
the system when a user’s duties change. These restrictions are based on the
roles and official duties of the user. All users do not need access to all parts of
the system. Access to the various parts of CDC data systems should be
restricted based upon the role of the user. For example, typical roles include
data entry, generating reports, system administration, and viewing information.
Some people may need to read information about clients but not enter data.
Others may need to analyze aggregate data but not view case-specific
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information. As the Agency System Administrator, you will assign each system
user specific roles and access rights.

2.2.3 Terminating Access
As soon as it is known that an individual is changing duties within an agency,
leaving the agency, or has breached agency policies, it is the Agency System
Administrator’s responsibility to modify or terminate their access. The jobtransition protocol of the agency should include immediate notification to the
CDC data systems administrator of any change in employee status so that the
proper actions can be taken to protect the system and its data.

2.2.4 Use of Passwords
Passwords must be used to confirm user identity. Passwords should be changed
periodically (at least every 60 days) and not shared among staff. Separate
passwords may also be used to protect specific data sets or applications within
the system. For example, a user may need to enter their individual password to
get access to the system, but then may need to enter a second, different
password in order to get access to information about a certain set of clients. The
CDC data systems password policy is that the passwords should be at least 8
characters long, contain a mix of at least three of the four types of keyboard
elements (i.e., upper case letters, lower case letters, numerals, and punctuation
marks or special characters), and cannot be the individual’s name.

2.2.5 Administration of Proxies
CDC data systems provide the ability to identify and assign proxies (i.e., the
ability to assign one person’s permissions to someone else). Although multiple
users can be granted proxies for an individual, only one user should log in at a
time as a proxy of another user. Only an Agency System Administrator should
have permission to grant and delete a proxy. The Agency System Administrator
is responsible for developing rules at the site level to determine how long proxies
may last and how they should be administered. All CDC data system users must
comply with the rules of proxy administration.

2.3 Information Management and Document Handling
At the local level, data collection for NHM&E variables will not only exist on the
CDC data system servers. These data may also be on data collection forms or
counselor notes, client files, floppy disks, CD-ROMs, personal digital assistants
(PDAs), or other information storage media. Since all these media may contain
confidential information, the agency must develop policies and procedures for the
secure use, storage, transmission, and disposal of data for each medium used to
record or store NHM&E data.
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The computers (desktop and laptop), PDAs, servers, and all other electronic
equipment used to collect, enter, copy, store, analyze, or report NHM&E data
should be under the control of the grantee. The use of equipment related to CDC
data systems, including internet connections, e-mail, photocopiers, facsimile
machines, and other equipment that might be used to copy, transmit, or process
NHM&E data should be regulated by written policies and procedures. The
policies should require that computers have screensaver locks that automatically
engage when the computer is not used for a set time period and should require
that personnel electronically lock their computers when they leave their desk. In
Windows this is done by depressing the Ctrl, Alt, and Delete keys
simultaneously, then depressing the Enter key.

2.3.1 Storage
Agencies should establish policies and procedures that outline when it is
appropriate to export NHM&E data to password protected and encrypted storage
media. All storage media should be clearly labeled. Removable storage media
such as zip disks, CD-ROMs, etc., should be destroyed or sanitized with disk
wiping tools before reuse or disposal. Storage media, whether removable or
fixed, paper or electronic, containing NHM&E data should be stored in a secured
area. Data removed from secured areas for analysis should be de-identified first.
Personal disks, laptops, thumb drives, and other storage media must not be used
to store confidential NHM&E data. When used for data storage, these devices
must contain only the minimum non-confidential data necessary to perform a
given task, must be encrypted or stored under lock and key when not in use, and
(except for backups) be sanitized immediately following the task completion.
Cleaning crews, maintenance staff, and other personnel unauthorized to access
NHM&E data must be escorted into secured areas by designated staff.
Encryption of electronic data during storage is recommended.

2.3.2 Disposal
Many states have laws or regulations concerning how long client records must be
stored, and also when and how they must be destroyed. Agencies must develop
policies and procedures that comply with these state regulations. When client
records are to be destroyed, these should include not only the paper records but
also the electronic records. Please note that “deleting” a file or record does not
actually remove the data from the system. Even overwriting or formatting may
not sanitize it; special sanitization programs or physical destruction of the storage
media may be required. Agencies must be sure to sanitize or destroy hard drives
of computers scheduled for disposal or transfer to staff not authorized to use
CDC data systems.

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2.3.3 Release of Data
Agencies must develop a written policy and procedure for releasing data. This
policy should be periodically reviewed and modified to improve the protection of
confidential information. Policies concerning the release of de-identified and
aggregate data that prevent indirectly identifying clients through small
denominators should also be established. Access to any data containing
confidential information or case-specific data should be contingent on having a
signed, current, and binding non-disclosure agreement currently on file at the
individual agency. These agreements must include discussion of possible
employee ramifications and criminal and civil liabilities for unauthorized
disclosure of information.
Reporting data to CDC: Reporting data to CDC should be done according to the
schedule specified by CDC. While data may be entered into CDC data systems
at any time, it is not reported to CDC until the appropriate files are submitted to
CDC through a secure data network by the authorized personnel of each agency.
Policies and procedures should be developed to specify the data quality
assurance process being implemented and the administrative approval and CDC
notification process being followed prior to reporting or submitting data to CDC.
Releasing data to partners: In order to assist other agencies in tracking
referrals or for other related public health purposes, agencies may enter into
agreements with other agencies to share limited information about specific
clients. Data sharing should be based upon written agreements and clients
should be advised on how their confidential information will be managed and/or
shared with other agency partners. Agencies must develop policies and
procedures to comply with state regulations regarding release of data.
Releasing data to the public: Except under conditions specified in writing and
explained to clients, only authorized staff members who have signed a binding
non-disclosure agreement (and who have a need to know) should be allowed
access to sensitive client-indentifying data. Agencies should have a policy and
protocol for releasing de-identified data for use in analysis, grant applications,
reporting, and administrative functions. This policy should specify what data may
be released, in what form, to whom data may be released, and who may approve
the release of data.

2.3.4 Encryption
NHM&E data are sensitive, confidential information that may have legal and
personal implications for clients; therefore, data should be protected from
unauthorized access. NHM&E data should always be encrypted during
transmission and often should be encrypted during storage, such as during
collection in the field. Data transmitted to the CDC through the secure data
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network are secured through the use of several security controls. However, it is
the responsibility of the grantee to assure all NHM&E data security until they are
submitted to CDC.
If an organization decides to send data to anyone other than CDC, those data
should be encrypted. NHM&E data scanned into the CDC provided scanning
data tools should be encrypted and sent to CDC via a secure data network (for
reference, this scanning tool will be retired and may not be applicable to future
data submissions). All data should remain encrypted until entering the CDC
network and reaching the secure data network staff at which time the data are
decrypted.
The following is a list of client variables that will be encrypted in CDC data
systems.
Client Information
G105 - Last Name
G106 - First Name
G107 - Middle Initial
G108 - Nick Name
G109 - Aliases
G110 - Date of Birth-Month
G111 - Date of Birth-Day
G125 - Physical Description
G128 - Address Type
G129 - Street Address 1
G130 - Street Address 2
G131 - City
G132 - County
G133 - State
G134 - Zip Code
G135 - Phone Number (Day)
G136 - Phone Number (Evening)
G137 - Primary Occupation
G138 - Employer
"Table G1 Notes"

Partner Information
PCR203 - Last Name
PCR204 - First Name
PCR205 - Middle Initial
PCR206 - Nickname
PCR210 - Date of Birth-Month
PCR211 - Date of Birth-Day
PCR219 - Physical Description
PCR220 - Address Type
PCR221 - Street Address 1
PCR222 - Street Address 2
PCR223 - City
PCR224 - State
PCR225 - Zip Code
PCR226 - Phone Number (Day)
PCR227 - Phone Number (Evening)
PCR228 - Primary Occupation
PCR229 - Employer
"Table PCR2 Notes"

2.3.5 Backing Up Data
CDC regularly backs up all NHM&E data stored on CDC database servers.
CDC data system data that are not yet transmitted to CDC, either because they
have not yet been entered in the system or because data are not being stored on
CDC servers, must be backed up periodically by the grantee. Frequency of
backup should depend upon how often the data change and how significant
those changes are, but should be done based on a fixed schedule that is part of
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the normal system maintenance. Backup copies should be tested to make sure
they are actually usable; copies should be stored under lock and key in a secure
area and a separate copy of data kept at a secure off-site location if possible.

2.4 System Access and Usage
As an Agency System Administrator, you will review all grantee accounts
annually to make sure they are appropriately assigned and current.
As an Agency System Administrator you agree to limit system access to
authorized users and make users aware of their responsibilities in preventing
unauthorized access to system resources.
As an Agency System Administrator you have the authority to create and
manage all administrators for all of your directly funded agencies.
As an Agency System Administrator, you should have the ability to manage
permissions to all modules and sub-modules, both administrative and nonadministrative, for your users.
As an Agency System Administrator, you are responsible for ensuring that all
staff members that use the application or data system comply with all system
authentication requirements.
As an Agency System Administrator you have the responsibility of ensuring that
all agency staff members that access and use the system are properly trained in
maintaining the security and confidentiality of NHM&E data.

2.4.1 Portable Equipment
While the use of portable computers has its advantages, it also creates additional
security risks, such as loss or theft of the computer and data it stores. If
computers are used outside the office or usual secure areas, agencies should
establish policies regarding physical security (e.g., the computer should be
locked to an immovable object) and digital security (e.g., the computer should be
protected with a unique username, complex password, and sensitive data should
be encrypted). Laptop computers and other portable hardware that receive
NHM&E data should store those data in encrypted formats. Laptops should
employ whole disk encryption in order to protect any sensitive data that may be
stored on the hard drive. No security certificates should be saved or stored on
portable media.

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2.4.2 Physical Security of Equipment
CDC data system Agency System Administrators should maintain an inventory of
all system hardware and software provided to system users, and periodic audits
should be conducted to account for all assets. Visitors or unauthorized
personnel should not be allowed unescorted access to areas containing
computers holding NHM&E data. All computer equipment should be protected
by surge suppressors and emergency battery power to prevent data loss in case
of fluctuations in the power supply. All computers and other equipment used for
CDC data systems should be housed or stored in secure areas and physically
attached to an immovable object, if possible. All rooms where NHM&E data are
stored in computers or on paper or other storage media should be locked at all
times when not in use, and it should be known with whom all keys reside.

2.4.3 Dial-Up Access
The grantee must develop a policy regarding dial-up or other external access to
their work location computer system for the purposes of accessing CDC data
systems or NHM&E data. Since the CDC data systems contains sensitive,
confidential information, dial-up or other external access to the system is strongly
discouraged as this creates more opportunities for unauthorized often malicious
intrusion into the system. If external access is permitted, it should be restricted
to the minimum number of persons possible, and additional security measures
should be taken to ensure identification and authentication to obtain access in
addition to restricting access to as few as possible.

2.4.4 Locking Workstations
All users should secure their workstations before leaving them. Automatic
screen saver locks should also be set to engage whenever the system is left idle
(e.g., 15 minutes of inactivity). In order to unlock the screensaver, the system
should require entry of the user’s ID and password.

2.4.5 Disable Browser Password Caching
All CDC data system users who will be accessing that system should disable the
ability (if any) of their web browser to cache (save) their passwords. This will
prohibit others who use the same computer to have access to passwords and
forms with personal information that the web browser has cached for you.
Please refer to the equipment owner’s manual for directions on how users can
disable browser password caching.

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2.5 Incident Reporting
2.5.1 Breaches of Confidentiality
A breach of confidentiality is any failure to follow confidentiality protocols,
whether or not information is actually released. This includes a security infraction
that results in the release of private information, with or without harm to one or
more individuals. All suspected or confirmed breaches of confidentiality or
security involving personally identifiable information (PII) such as names,
addresses, identification numbers, dates (except year), etc., should be reported
to the CDC Information Systems Security Officer (phone 404.639.1806;
e-mail:rxv2@cdc.gov) and the CDC Division of HIV/AIDS Prevention (DHAP)
Program Evaluation Branch (PEB) Data Security Steward (phone: 404-639-0938;
e-mail: dad5@cdc.gov) within one hour of discovery. All other suspected
breaches of confidentiality or security (e.g., possible viruses, hackers, password
divulgence, lost or misplaced storage media without PII, failure to follow secure
storage policies, etc.) should be reported immediately to the Agency System
Administrator. The Agency System Administrator will determine the cause,
develop and implement process improvements, and/or determine if the incident
should be reported to the CDC Computer Security Incident Response Team and
DHAP PEB Data Security Steward. In determining whether a non-PII breach of
NHM&E data or records should be reported to CDC, Agency System
Administrators should consider reporting such breaches to CDC if there is a
strong possibility that PII will be breached, CDC data and data systems will be
compromised, or that CDC’s public health mission will be negatively impacted.
At the local level, sanctions for violations of confidentiality protocols should be
established in writing, as part of the organizational policies, and should be
consistently enforced.

2.5.2 Unauthorized Intrusions
Any computer attached to the internet is subject to unauthorized intrusions, such
as hackers, computer viruses, and worms. In addition, authorized users may
attempt to access parts of the system for which they do not have access
authority. Grantees must take all reasonable precautions to protect their systems
from these types of unauthorized penetrations. A plan must be developed and
implemented to prevent and, if necessary, recover from changes to the system
caused by unauthorized penetrations of the computer system. Typical
precautions include using effective passwords, installing firewalls and currently
updated anti-virus software, making backup copies of software, saving data at
regular intervals so that the system can be restored to a previous state, and
training staff in basic computer security (such as keeping passwords secret and
not downloading materials from the Internet or other unauthorized software onto
computers that have CDC data system access).
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2.6 Training and Awareness
All agency staff dealing with NHM&E data and the CDC data system should be
trained on policies and procedures established by the agency, the legal aspects
of data collection, and the ethics of their responsibility to the clients. Every new
employee who requires access to NHM&E data and resources must complete
data security training conducted by your agency before access is granted.
Current employees are also required to complete a refresher course on data
security every year. All data security trainings should cover state regulations and
the agency’s policies concerning confidentiality, computer security, and legal
obligations under non-disclosure agreements. Grantee staff should be aware of
common threats to data confidentiality and security, contingency plans for
breaches of confidentiality and security, and the penalties associated with
breaches of NHM&E data confidentiality and security. Each agency staff
member with access to NHM&E data should receive CDC data system training,
including security updates.
Personnel are as much a part of a data collection and reporting system as
computer hardware and collection forms. People are usually the weakest link in
any security system. Each agency should have a policy on NHM&E data
confidentiality and security. The confidentiality and security policy must explain
that authorized users are responsible for knowing the confidentiality and security
policies and procedures, challenging unauthorized users, reporting possible
breaches, and protecting equipment and data. Staff should be required to
annually sign a statement acknowledging that they have been made aware of the
confidentiality and security requirements for the agency. The signed statement
should be kept in the employee’s file.

2.7 CDC Data System Security Agreements
In an effort to provide maximum protection of the data that are entered into CDC
data systems, in addition to the physical and system security measures
explained in this document, agency system administrators will develop and make
available an ROB for CDC data system users covering all of the additional duties
of CDC data system users. CDC also will be executing a Memorandum of
Understanding (MOU) with each directly funded grantee organization.

3. User Assistance and Additional Resources
For assistance in using CDC data systems, contact the NHM&E Service Center
at pemsservice@cdc.gov or 1-888-PEMS-311 (1-888-736-7311) or your local
Information Technology Support Group.

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4. Revisions and Renewal
Revisions to this document will be released as needed. Notifications of the
availability of the revised documents will be made through the CDC data systems
announcement function and other established communication channels. Unless
notified otherwise, it will be assumed that all grantees using CDC data systems
accept the revisions. Comments and concerns should be sent to the NHM&E
Service Center at pemsservice@cdc.gov.

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5. Acknowledgement and Agreement of Rules of
Behavior for CDC Data Systems Agency System
Administrators
I have read and agree to comply with the terms and conditions governing the
appropriate and allowed use of CDC data systems and NHM&E data as defined
by this document, applicable agency policy, and state and federal law. I
understand that infractions of these rules will be considered violations of CDC
and agency standards of conduct and may result in disciplinary action, including
the possibility of supervisory notification, official reprimand, suspension of system
privileges, suspension from duty, termination, and/or criminal and civil
prosecution.
I certify that all CDC data system users at our agency have signed the rules of
behavior for CDC data system agency users.

_______________________________________________
(Signature / Date)

________________________________________________________________
(Printed Name)

________________________________________________________________
(Title)

________________________________________________________________
(Agency Name)

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