PIA Form

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Privacy Impact Assessment Form
v 1.45
Status Draft

Form Number

F-64436

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-2727152-422137

2a Name:

11/18/2014 11:14:32 AM

Electronic Disease Notification (EDN)
General Support System (GSS)
Major Application

3

Minor Application (stand-alone)

The subject of this PIA is which of the following?

Minor Application (child)
Electronic Information Collection
Unknown

3a

Identify the Enterprise Performance Lifecycle Phase
of the system.

Operations and Maintenance
Yes

3b Is this a FISMA-Reportable system?

4

Does the system include a Website or online
application available to and for the use of the general
public?

5

Identify the operator.

6

Point of Contact (POC):

7

Is this a new or existing system?

8

Does the system have Security Authorization (SA)?

8a Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Technical Steward

POC Name

Yoni Haber

POC Organization NCEZID
POC Email

dlv8@cdc.gov

POC Phone

404-985-1396
New
Existing
Yes
No

1/19/2012 12:00:00 AM

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9

Indicate the following reason(s) for updating this PIA.
Choose from the following options.

PIA Validation (PIA
Refresh/Annual Review)
Anonymous to NonAnonymous
New Public Access
Internal Flow or Collection

Significant System
Management Change
Alteration in Character of
Data
New Interagency Uses
Conversion

Commercial Sources

10

Describe in further detail any changes to the system
that have occurred since the last PIA.

11 Describe the purpose of the system.

None
Immigrants and refugees entering the United States are
required by law to possess certain U.S. Department of State
medical screening information and documentation as part of a
visa request. The medical information is based on overseas
examinations to include any of several health related
conditions that may exist. The purpose of EDN is to document
these health conditions and provide the case to the
destination state health department for further follow up and
tracking.

Describe the type of information the system will
Medical screening information and documentation of
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask immigrants and refugees entering the United States as part of
a visa request.
about the specific data elements.)
Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

This application will network CDC researchers, quarantine
stations, and state health departments that perform
surveillance for immigrants requiring medical treatment
follow-up upon entering the United States.
Yes

14 Does the system collect, maintain, use or share PII?

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

No
Social Security Number

Date of Birth

Name

Photographic Identifiers

Driver's License Number

Biometric Identifiers

Mother's Maiden Name

Vehicle Identifiers

E-Mail Address

Mailing Address

Phone Numbers

Medical Records Number

Medical Notes

Financial Account Info

Certificates

Legal Documents

Education Records

Device Identifiers

Military Status

Employment Status

Foreign Activities

Passport Number

Taxpayer ID

Alien Number.

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Employees
Public Citizens
16

Business Partners/Contacts (Federal, state, local agencies)

Indicate the categories of individuals about whom PII
is collected, maintained or shared.

Vendors/Suppliers/Contractors
Patients
Other Aliens

17 How many individuals' PII is in the system?

18 For what primary purpose is the PII used?

19

Describe the secondary uses for which the PII will be
used (e.g. testing, training or research)

100,000-999,999
The primary purpose is for state and local health departments
to be able to follow up on migrants with medical conditions
that arrive to their jurisdiction..
N/A

20 Describe the function of the SSN.

N/A

20a Cite the legal authority to use the SSN.

N/A

21

Identify legal authorities governing information use
Public Health Service Act, Section 301
and disclosure specific to the system and program.

22

Are records on the system retrieved by one or more
PII data elements?

Yes
No
Published:

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

09-20-0136

Published:
Published:
In Progress

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Directly from an individual about whom the
information pertains
In-Person
Hard Copy: Mail/Fax
Email
Online
Other
Government Sources
23

Within the OPDIV
Other HHS OPDIV
State/Local/Tribal
Foreign
Other Federal Entities
Other

Identify the sources of PII in the system.

Non-Government Sources
Members of the Public
Commercial Data Broker
Public Media/Internet
Private Sector
Other
23a

Identify the OMB information collection approval
number and expiration date.

1405-0113 Expiration: 09/30/2017
Yes

24 Is the PII shared with other organizations?

No
Within HHS

24a

Other Federal
Agency/Agencies
State or Local
Agency/Agencies

Identify with whom the PII is shared or disclosed and
for what purpose.

State and Local Health Departments for federally mandated
follow-up to persons’ arrival in their jurisdiction.
Private Sector
Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
24b Matching Agreement, Memorandum of
N/A
Understanding (MOU), or Information Sharing
Agreement (ISA)).
24c

Describe the procedures for accounting for
disclosures

The EDN Helpdesk tracks for accounting for disclosures in an
Access database. There is also an organized email folder
system for requests that come in through the email box.

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

26

Voluntary

Is the submission of PII by individuals voluntary or
mandatory?

Describe the method for individuals to opt-out of the
collection or use of their PII. If there is no option to
27
object to the information collection, provide a
reason.
Describe the process to notify and obtain consent
from the individuals whose PII is in the system when
major changes occur to the system (e.g., disclosure
28 and/or data uses have changed since the notice at
the time of original collection). Alternatively, describe
why they cannot be notified or have their consent
obtained.
Describe the process in place to resolve an
individual's concerns when they believe their PII has
29 been inappropriately obtained, used, or disclosed, or
that the PII is inaccurate. If no process exists, explain
why not.
Describe the process in place for periodic reviews of
PII contained in the system to ensure the data's
30
integrity, availability, accuracy and relevancy. If no
processes are in place, explain why not.

31

CDC does not collect the original data. PII and other personal
information are collected by the forms of the U.S. Department
of State in immigrant or refugee medical exams. Privacy Act
Notice on the form states how the information is going to be
used. Immigrants or refugees may decline to provide the PII
requested by the U.S. Department of State. In that event the
U.S. Department of State may delay or prevent the processing
of their case.

Identify who will have access to the PII in the system
and the reason why they require access.

Mandatory
Immigrants or refugees may decline to provide the PII
requested by the U.S. Department of State. In that event the
U.S. Department of State may delay or prevent the processing
of their case.

Privacy Act Notice on the form states how the information is
going to be used.

Immigrants or refugees may notify CDC or state/local health
department if their PII is incorrect or inappropriately used.

The review and validation of PII information is done constantly
by State and Local Health Departments outside of CDC.

Users

Data Entry

Administrators

Maintenance of EDN

Developers

EDN Programming

Contractors

EDN Programming

Others
Describe the procedures in place to determine which Role-based access. There are 2 system administrators have full
access to the system and 15 Data entry personnel to enter data
32 system users (administrators, developers,
into the system. Other State Health Department and Q-Station
contractors, etc.) may access PII.
users have access only to their state and Q-Station data.
Describe the methods in place to allow those with
33 access to PII to only access the minimum amount of
information necessary to perform their job.

The Least privileged model is utilized

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Identify training and awareness provided to
personnel (system owners, managers, operators,
contractors and/or program managers) using the
34
system to make them aware of their responsibilities
for protecting the information being collected and
maintained.

Annual security and privacy awareness training

Describe training system users receive (above and
35 beyond general security and privacy awareness
training).

CDC Role-based training

Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?

Yes
No

Describe the process and guidelines in place with
37 regard to the retention and destruction of PII. Cite
specific records retention schedules.

Records are retained and disposed of in accordance with the
CDC Records Control Schedule. Record copy of study reports
are maintained in agency from two to three years in
accordance with retention schedules. Source documents for
computer are disposed of when no longer needed by program
officials. Personal identifiers may be deleted from records
when no longer needed in the study as determined by the
system manager, and as provided in the signed consent form,
as appropriate. Disposal methods include erasing computer
tapes, burning or shredding paper materials or transferring
records to the Federal Records Center when no longer needed
for evaluation and analysis. Records are retained for 20 years;
for longer periods if further study is needed.

Describe, briefly but with specificity, how the PII will
38 be secured in the system using administrative,
technical, and physical controls.

Access to the CDC Clifton Road facility where the mainframe
computer is located is controlled by a cardkey system. Access
to the computer room is controlled by a cardkey and security
code (numeric keypad) system. Access to the data entry area is
also controlled by a cardkey system. The hard copy records are
kept in locked cabinets in locked rooms. The computer room is
protected by an automatic sprinkler system, numerous
automatic sensors (e.g., water, heat, smoke, etc.) are installed,
and a proper mix of portable fire extinguishers is located
throughout the computer room. The system is backed up on a
nightly basis with copies of the files stored off site in a secure
fireproof safe. Security guard service in buildings provides
personnel screening of visitors.

REVIEWER QUESTIONS: The following section contains Reviewer Questions which are not to be filled out unless the user is an OPDIV
Senior Officer for Privacy.

Reviewer Questions
1

Are the questions on the PIA answered correctly, accurately, and completely?

Answer
Yes
No

Reviewer
Notes
2

Does the PIA appropriately communicate the purpose of PII in the system and is the purpose
justified by appropriate legal authorities?

Yes
No

Reviewer
Notes

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Reviewer Questions
3

Do system owners demonstrate appropriate understanding of the impact of the PII in the
system and provide sufficient oversight to employees and contractors?

Answer
Yes
No

Reviewer
Notes
4

Does the PIA appropriately describe the PII quality and integrity of the data?

Yes
No

Reviewer
Notes
5

Is this a candidate for PII minimization?

Yes
No

Reviewer
Notes
6

Does the PIA accurately identify data retention procedures and records retention schedules?

Yes
No

Reviewer
Notes
7

Are the individuals whose PII is in the system provided appropriate participation?

Yes
No

Reviewer
Notes
8

Does the PIA raise any concerns about the security of the PII?

Yes
No

Reviewer
Notes
9

Is applicability of the Privacy Act captured correctly and is a SORN published or does it need
to be?

Yes
No

Reviewer
Notes
10

Is the PII appropriately limited for use internally and with third parties?

Yes
No

Reviewer
Notes
11

Does the PIA demonstrate compliance with all Web privacy requirements?

Yes
No

Reviewer
Notes
12

Were any changes made to the system because of the completion of this PIA?

Yes
No

Reviewer
Notes

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General Comments

OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by Beverly E. Walker -S
DN: c=US, o=U.S. Government,
ou=HHS, ou=CDC, ou=People,
0.9.2342.19200300.100.1.1=100144034
3, cn=Beverly E. Walker -S
Date: 2014.12.23 10:36:45 -05'00'

HHS Senior
Agency Official
for Privacy

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