Pia

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

0920-0969

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

TBD

2a Name:

08/21/18

Monitoring Changes in Attitudes and Practices among Family Pl
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.

Initiation
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)?

8b Planned Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Health Scientist

POC Name

Lauren Zapata

POC Organization National Center for Chronic Disea
POC Email

lzapata@cdc.gov

POC Phone

770-488-6358
New
Existing
Yes
No

tbd
Not Applicable

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8c

Briefly explain why security authorization is not
required

10

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

N/A, new PIA request for Reinstatement ICR.
The purpose of this data collection -- a survey of familyplanning healthcare providers and administrators -- is to
support CDC's efforts to monitor changes in attitudes and
practices among family planning providers and clinics.

11 Describe the purpose of the system.

The survey will assess diffusion and use of federal
contraception prescribing guidelines published in August 2016
in clinical practice, as well as attitudes. This information will be
used by CDC to understand current attitudes and practices of
providers as well as any persisting misconceptions and/or gaps
in clinic-level practices (e.g., low provision of preconception
health services) that may warrant continued and more tailored
dissemination and educational activities.
Questionnaire domains include healthcare providers' safety
attitudes; clinical practices; sources of information and tools;
awareness of guidelines; health center systems and programs;
demographics and training.

Describe the type of information the system will
collect, maintain (store), or share. (Subsequent
A unique identifier will be assigned to each response by the
12
questions will identify if this information is PII and ask data collection contractor .
about the specific data elements.)
CDC will provide the contractor with business contact
information (name, address, phone, email address) from preexisting data sources. This information already exists; it is not
being collected by this project.

Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

PII in the form of contact information will be used to invite
healthcare providers to participate in the survey. CDC will use
the American Medical Association's (AMA) Physician Masterfile
and a national database of public-sector family planing
providers to obtain names, addresses, phone numbers and
email addresses [where available] of physicians and health
centers. CDC will provide this information to the data
collection contractor which will assign a unique identification
number (UID) to each respondent. For tracking responses
during the collection period, the contractor will maintain the
link between the UID and contact information in a passwordprotected file that is not shared with CDC or any other party.
The PII will not be included in the file of survey responses. CDC
will not be able to identify respondents based on their UID at
any time.
Survey data will be transmitted to CDC at the end of the data
collection period. The survey responses will be used to make
evidence-based recommendations that promote awareness
and adoption of existing guidance into practice through
additional dissemination activities and development of
educational interventions and provider tools.

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

Yes
No

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

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

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 Physicians, Other Health Care Providers, and Health
Clinic Administrators

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)

5,000-9,999
PII in existing databases will be used for the sole purpose of
contacting survey participants.
N/A

20 Describe the function of the SSN.

NA

20a Cite the legal authority to use the SSN.

NA

21

Identify legal authorities governing information use
Section 301 of the Public Health Service Act [42 U.S.C. 241]
and disclosure specific to the system and program.

22

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

Yes
No

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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.

24 Is the PII shared with other organizations?
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

Is the submission of PII by individuals voluntary or
mandatory?

Reinstatement of OMB Number 0920-0969; Expiration Date
05/31/2014.
Yes
No
N/A, no PII is being collected from individuals. PII comes from
pre-existing data sources external to CDC.
Voluntary
Mandatory

CDC is purchasing pre-existing lists of providers' contact
information. The contact list brokers are responsible for the
opt-out process regarding the initial collection of contact
Describe the method for individuals to opt-out of the information. For the AMA Physician Masterfile, physicians
voluntarily chose to provide their contact information. For the
collection or use of their PII. If there is no option to
27
national data base of public-sector family planning health
object to the information collection, provide a
centers, clinics voluntarily chose to provide their contact
reason.
information.
There is no opt-out process because the first contact with the
respondent involves the use of the PII. When contacted,
potential respondents may opt out of participating in the
survey.

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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.

CDC does not have a process in place to notify the providers
about any changes to the data collection because the PII is not
owned or controlled by CDC but was purchased from preexisting lists.

The source of the PII is not owned or controlled by CDC.
Participants must contact the data broker to resolve any
concerns.
No process is in place because all PII will be destroyed within
eight months after the end of the data collection period.
Users
Administrators

31

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

Developers
Contractors

Contractor will use the PII to contact
the participants.

Others
Describe the procedures in place to determine which The project director will determine the limited number of staff
who has access to the PII based on specific roles and
32 system users (administrators, developers,
responsibilities. A user's access is limited to the information
contractors, etc.) may access PII.
which is essential to their job functions.
Only those contractor staff who are responsible for recruiting
respondents will have access to the file with PII for the purpose
of sending out the initial mailing and following up with nonresponders.
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.

Technical (i.e., password-protected files) and administrative
controls will be used to protect respondent information.
CDC will use a password-protected electronic file to transmit
the names, addresses, phone numbers and email addresses of
physicians and health centers selected to participate in the
survey to the contractor. The password to unlock the file will
be provided to the contractor via telephone and not in written
form (technical control).

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.

CDC staff complete Security and Privacy Training on an annual
basis. The contractors will complete in-house security
awareness and privacy training.

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

N/A

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

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

Yes
No
All PII will be destroyed within eight months after the end of
the data collection period. Paper-copy survey data will be
entered into electronic databases (one for the provider survey
and one for the health center administrator survey). The two
databases, stripped of any identifiers other than the UID, will
be permanent federal records and will be maintained in
accordance with Records Control Schedule DAAGRS-2-13-0002-0008.
Administrative:
The password to unlock the file with PII will be provided to the
contractor via telephone and not in written form. The
contractor will assign each participant a UID number. Surveys
will only have the UID number, and the contractor will be the
sole source of a password-protected electronic file linking
sampled physicians and health centers with their assigned
UIDs.
Information held by the contractor is housed on a network that
is controlled and protected through strict administrative
controls.

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

At CDC, password protection will impose user name and
password log in requirements to prevent unauthorized access.
Each user name will be assigned limited access rights to files
and directories at varying levels to control file sharing.
Technical:
Access to the contractor's web-based server requires two–
factor authentication and advanced, complex passwords with
strict established rules. Non-admin users are prevented from
sharing any company owned or managed files. In the event of
a data breach or loss of company owned equipment, the IT
Manager will initiate a remote wipe which will delete all
company data and any local copies of files from a computer
when that computer comes online.
Physical:
Computer facilities at all sites have restricted access and are
protected from potential fire or water damage.

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

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Reviewer Questions
2

Answer

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

Yes

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

Yes

No

Reviewer
Notes
3

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

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Reviewer Questions

Answer

Reviewer
Notes

General Comments

OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by
Beverly E. Walker -S
Date: 2018.08.21
19:54:05 -04'00'

HHS Senior
Agency Official
for Privacy

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