Privacy Impact Assessment

Department of the Interior
Privacy Impact Assessment Template
Name of Project: Endangered and Threatened Wildlife, Experimental Populations
Bureau: U.S. Fish and Wildlife Service
A. CONTACT INFORMATION:
1) Who is the person completing this document?
Deborah Crouse, Biologist
U.S. Fish and Wildlife Service
MS: ES
5275 Leesburg Pike
Falls Church, VA 22041-3803
Phone: (703) 358-2471
Email: debby_crouse@fws.gov
2) Who is the system owner?
See Section E.
3) Who is the system manager for this system or application?
The administration and management of data collected for experimental populations is not
accomplished by a single office or individual. FWS biologists in different field offices around
the country will be responsible for ensuring proper use of the data relating to a particular
experimental population.
4) Who is the IT Security Manager who reviewed this document?
Not applicable.
5) Who is the Bureau/Office Privacy Act Officer who reviewed this document?
Melissa Allen
U.S. Fish and Wildlife Service
Division of Information Resources & Technology Management
5275 Leesburg Pike
MS: IRTM
Falls Church, VA 22041
Phone: (703) 358-2470
Email: melissa_allen@fws.gov
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6) Who is the Reviewing Official?
Shelley Hartmann
U.S. Fish and Wildlife Service
Division of Information Resources & Technology Management
5275 Leesburg Pike
MS: IRTM
Falls Church, VA 22041
Phone: (703) 358-2004
Email: shelley_hartmann@fws.gov
B. SYSTEM APPLICATION/GENERAL INFORMATION:
1) Does this system contain any information about individuals?
Experimental populations established under section 10(j) of the Endangered Species Act (ESA),
as amended, require information collection and reporting to the U.S. Fish and Wildlife Service
(Service, we). We collect information on the experimental populations listed in 50 CFR 17.84 to
help further the recovery of the species and to assess the success of the reintroduced populations.
The respondents notify us when an incident occurs, so there is no set frequency for collecting the
information. We use the information to:
•
•
•

Document the locations of reintroduced animals.
Improve management techniques for reintroduction.
Determine causes of mortality and conflict with human activities so that Service
managers can minimize conflicts with people.

Reporting parties include, but are not limited to, individuals or households, businesses, farms,
nonprofit organizations, and State/local/Tribal governments. We collect the information by
means of telephone calls or facsimiles from the public to Service offices specified in the speciesspecific regulations. Standard information collected includes:
•
•
•
•
•
•

Name, address, and phone number of reporting party.
Species involved.
Type of incident.
Take (quantity).
Location and time of reported incident.
Description of the circumstances related to the incident.

Records of reported incidents will be maintained in paper copies. Due to limitations in funding
and staff time, we do not have any plans to create a system for electronic submission of reported
incidents, or to make the information available to the public over the Internet.

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a. Is this information identifiable to the individual 11?
The collected names, addresses, and phone numbers of reporting parties are identifiable to
individuals.
b. Is the information about individual members of the public?
Yes, some of the identifiable information may be about individual members of the public.
c. Is the information about employees?
Yes, some of the identifiable information may be about employees.
2) What is the purpose of the system/application?
This information collection collects information about the status and health of individual animals
of experimental populations of ESA-listed endangered or threatened species. Service species
recovery specialists use the information to determine the success of reintroductions in relation to
established recovery plan goals for the threatened and endangered species involved.
The information collected also helps us assess the effectiveness of control activities and develop
means to reduce problems with livestock for those species where depredation is a problem.
3) What legal authority authorizes the purchase or development of this
system/application?
The legal authorities for establishing experimental populations are the ESA (16 U.S.C. 1531 et
seq.) and its implementing regulations at 50 CFR Part 17, Subpart H. The authorities for
collecting information regarding the status and health of individual animals of experimental
populations of ESA-listed endangered or threatened species are further elaborated in the
regulations establishing each specific experimental population and OMB information collection
control number ICR 1018-0095.
C. DATA in the SYSTEM:
1) What categories of individuals are covered in the system?
Paper records include information collected from reporting parties. These reporting parties
include, but are not limited to, individuals or households, businesses, farms, nonprofit
organizations, and State/local/Tribal governments.
11

“Identifiable Form” - According to the OMB Memo M-03-22, this means information in an IT system or online
collection: (i) that directly identifies an individual (e.g., name, address, social security number or other identifying
number or code, telephone number, email address, etc.) or (ii) by which an agency intends to identify specific
individuals in conjunction with other data elements, i.e., indirect identification. (These data elements may include a
combination of gender, race, birth date, geographic indicator, and other descriptors).

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2) What are the sources of the information in the system?
a. Is the source of the information from the individual or is it taken from
another source? If not directly from the individual, then what other source?
Each reported incident is unique. Individuals may report incidents.
b. What Federal agencies are providing data for use in the system?
Other Federal agencies provide us with the vast majority of the information on experimental
populations. Apart from National Wildlife Refuges, FWS Division of Law Enforcement,
Migratory Bird Management, Fisheries, etc., other Federal agencies that might supply
information about the species include Wildlife Services in the Animal and Plant Health
Inspection Service (APHIS), Bureau of Land Management, U.S. Forest Service, and National
Park Service, etc.
c. What Tribal, State and local agencies are providing data for use in the
system?
Individuals from any State/local/Tribal governments that might encounter an individual plant or
animal of an experimental population may provide data to the species lead biologist.
d. From what other third party sources will data be collected?
Businesses, farms, and nonprofit organization are potential third-party sources. Most of the
contacts with these third parties deal primarily with the reporting of sightings of animals from
specific experimental populations, or the inadvertent discovery of an injured or dead animal from
an experimental population.
e. What information will be collected from the employee and the public?
Standard information collected from the employee and the public includes the following:
•
•
•
•
•
•

Name, address, and phone number of reporting party.
Species involved.
Type of incident.
Take (quantity).
Location and time of reported incident.
Description of the circumstances related to the incident.

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3) Accuracy, Timeliness, and Reliability
a. How will data collected from sources other than DOI records be verified for
accuracy?
Primarily, the FWS lead biologist for the experimental population in question would be verifying
the information regarding the species’ incident with the reporting party. Verification of contact
information would be done by the biologist in case they need to verify the information about the
species’ incident or if the incident includes either a potential legal violation of the ESA or
potential depredation of livestock by a member of the experimental population. In those cases,
we would provide all of the information to FWS Law Enforcement officers or the U.S.
Department of Agriculture/APHIS Division of Wildlife Damage Management.
b. How will data be checked for completeness?
Verification usually requires physical examination of the site and injured animal or carcass,
which requires travel on the part of FWS personnel.
c. Are the data current?
We rely on prompt public reporting on the location of sick, injured, or orphaned animals in order
to implement the necessary animal husbandry and specimen collection activities. Therefore, a
time sensitive requirement for reporting problems (generally within 24 hours) to the appropriate
Service office is necessary.
Each reported incident is unique. There is some potential for duplication if someone contacts
both the Service and another agency regarding an experimental population animal, but generally
there is sufficient information available to the public through interagency outreach efforts to
make reporting protocols well known.
d. Are the data elements described in detail and documented? If yes, what is
the name of the document?
Individual animals of designated experimental populations for species listed as threatened or
endangered under the ESA (16 U.S.C. 1531 et seq.) are categorically protected. Documentation
of dead, injured or sick animals, mortalities, human-related mortalities, recovery of dead
specimens, and animal husbandry actions necessary to manage the populations and other types of
take related to the status of experimental populations is important for monitoring the success of
reintroduction efforts and recovery efforts in general. To minimize potential conflict with
humans that could undermine recovery efforts, livestock depredations connected with
experimental populations of listed species require prompt attention for purposes of determining
the location, timing, and nature of the predatory behavior involved, accurate determination of the
species responsible for a livestock kill, and the timely application of necessary control measures.
We collect information in non-form format. The information collection requirements are in 50
CFR 17.84 and 50 CFR 17.85.

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D. ATTRIBUTES OF THE DATA:
1) Is the use of the data both relevant and necessary to the purpose for which the
system is being designed?
Yes. The consequence of not collecting the information or reduced information collection would
result in our inability to address the species’ needs and/or measure the implementation
effectiveness of particular experimental population recovery goals. It would also prevent us
from seeking ways to reduce livestock interactions by experimental populations such as the
Mexican wolf.
2) Will the system derive new data or create previously unavailable data about an
individual through aggregation from the information collected, and how will this
be maintained and filed?
The paper records will neither derive new data nor create previously unavailable data about the
reporting individual through aggregation from the information collected.
3) Will the new data be placed in the individual’s record?
Not applicable.
4) Can the system make determinations about employees/public that would not be
possible without the new data?
Not applicable.
5) How will the new data be verified for relevance and accuracy?
FWS staff will do most of the verification. Where we cannot, we will work with the U.S.
Department of Agriculture/APHIS Division of Wildlife Damage Management and other Federal
agencies, as necessary, when investigating or confirming information received regarding any of
the experimental populations.
6) If the data are being consolidated, what controls are in place to protect the data
from unauthorized access or use?
The data will be kept in the files of specific experimental populations of endangered and
threatened species around the country, which are maintained by the lead biologist managing each
experimental population. There is no reason, or system, for consolidating them further.
7) If processes are being consolidated, are the proper controls remaining in place to
protect the data and prevent unauthorized access? Explain.
There will be no consolidation. The records are for the purpose of evaluating the impacts of the
incidents on the species’ population.
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8) How will the data be retrieved? Does a personal identifier retrieve the data? If
yes, explain and list the identifiers that will be used to retrieve information on
the individual.
No, the data are not retrieved by a personal identifier. Data will be retrieved according to the
experimental population to which the animal belongs.
9) What kinds of reports can be produced on individuals? What will be the use of
these reports? Who will have access to them?
There will be no reports produced on human individuals. Any reports that might be produced
would be on the animals and their status and condition.
10) What opportunities do individuals have to decline to provide
information (i.e., where providing information is voluntary) or to consent to
particular uses of the information (other than required or authorized uses), and
how individuals can grant consent)?
Individuals are required to report an incident according to the regulations under CFR 17.84 and
17.85 and OMB information collection control number 1018-0095, but providing any additional
information is voluntary.
E. MAINTENANCE AND ADMINISTRATIVE CONTROLS:
1) If the system is operated in more than one site, how will consistent use of the
system and data be maintained in all sites?
The records will be maintained in the paper files for each separate experimental population.
2) What are the retention periods of data in this system?
The data on human individuals are retained within the data on the listed animal species until (1)
the species is taken off the threatened or endangered list and (2) the data can be disposed
according to the NARA-approved FWS Records Disposition Schedule (LIST-900 Species
Reference Files (N1-022-05-01/57)).
3) What are the procedures for disposition of the data at the end of the retention
period? How long will the reports produced be kept? Where are the procedures
documented?
The procedures outlined in the FWS Regional/Program Records Disposition Certification
(http://www.fws.gov/irm/bpim/docs/FWS_RECORDS_CERTIFICATION_TEMPLATE.doc)
will be used for disposition of the PII data.
4) Is the system using technologies in ways that the DOI has not previously
employed (e.g., monitoring software, Smart Cards, Caller-ID)?
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Not applicable, as the records are maintained in paper files.
5) How does the use of this technology affect public/employee privacy?
Not applicable, as the records are maintained in paper files that are stored in accordance with
physical safeguard requirements.
6) Will this system provide the capability to identify, locate, and monitor
individuals? If yes, explain.
Not applicable.
7) What kinds of information are collected as a function of the monitoring of
individuals?
Not applicable.
8) What controls will be used to prevent unauthorized monitoring?
Not applicable.
9) Under which Privacy Act systems of records notice does the system operate?
Provide number and name.
Not applicable.
10) If the system is being modified, will the Privacy Act system of records notice
require amendment or revision? Explain.
Not applicable.

F. ACCESS TO DATA:
1) Who will have access to the data in the system?
The biologists who manage the species.
2) How is access to the data by a user determined? Are criteria, procedures,
controls, and responsibilities regarding access documented?
FWS Law Enforcement or APHIS agents may become involved when documenting a livestock
depredation.
3) Will users have access to all data on the system or will the user’s access be
restricted? Explain.
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Except as needed for investigating a livestock depredation or legal incident, only the biologist
who manages the species would have access to any PII and that would be only to verify the
information provided.
4) What controls are in place to prevent the misuse (e.g., unauthorized browsing) of
data by those having access?
The species files in which the data reside are managed only by the species’ biologist in paper
files in FWS offices. Access such as electronic browsing would not be physically possible and
physical safeguards will be in place to prevent unauthorized access.
5) Are contractors involved with the design and development of the system and will
they be involved with the maintenance of the system? If yes, were Privacy Act
contract clauses inserted in their contracts and other regulatory measures
addressed?
Contractors have not been involved in the design and development of the system and are not
anticipated to be involved with the maintenance of the system. However, should the assistance
of a contractor be necessary in the future, standard government contracts would be issued that
include provisions of the Privacy Act and other applicable regulations.
6) Do other systems share data or have access to the data in the system? If yes,
explain.
Only if FWS Law Enforcement or APHIS becomes involved in documenting a livestock
depredation or a violation of the ESA.
7) Who will be responsible for protecting the privacy rights of the public and
employees affected by the interface?
FWS biologists in different field offices around the country will be keeping the individual
records in paper files. Each record will be kept in the files relating to the particular experimental
population (animal) involved.
8) Will other agencies share data or have access to the data in this system (Federal,
State, Local, Other (e.g., Tribal))?
We work with the U.S. Department of Agriculture/APHIS Division of Wildlife Damage
Management and other Federal agencies, as necessary, when investigating or confirming
information received regarding any of the experimental populations.
9) How will the data be used by the other agency?
Other Federal agencies and State wildlife agencies will use the data for the conservation and
management of endangered and threatened species under the ESA, including the conservation
and management of experimental populations.
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10) Who is responsible for assuring proper use of the data?
FWS biologists in different field offices around the country will be responsible for ensuring
proper use of the data relating to the particular experimental population (animal) involved.
See Attached Approval Page

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The Following Officials Have Approved this Document
1) System Manager There is no singular System Manager (see A. (3)).
____________________________ (Signature) ________________ (Date)
Name
Title

2) IT Security Manager PAPER RECORDS - NO IT SECURITY MANAGER APPROVAL
NEEDED
_____________________________ (Signature) ________________ (Date)
Name
Title

3) Privacy Act Officer

Melissa Allen

Digitally signed by Melissa Allen
DN: cn=Melissa Allen, o=IRTM,
ou=U.S. Fish and Wildlife Service,
email=melissa_allen@fws.gov, c=US
Date: 2014.08.27 09:20:41 -04'00'

____________________________

(Signature)

8/27/2014 (Date)

Name: Melissa Allen
Title: FWS Freedom of Information Act/Privacy Act Officer

4) Reviewing Official
signed by
shelley_hartmann@ Digitally
shelley_hartmann@fws.gov
DN: cn=shelley_hartmann@fws.gov
fws.gov
Date: 2014.10.01 11:39:12 -04'00'
_____________________________

10/1/2014
(Signature) ________________
(Date)

Name
Title

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