CDC?OCISO Media or Third-Party Site Security Survey /Plan

Office of the Chief Information Security Officer (OCISO)

U.S. Department of Health and Human Services
Centers for Disease Control and Prevention
OCISO Social Media or Third-Party Site Security Survey/Plan
Submitted to CISO
DHHS/CDC/OCOO/OCIO/OCISO
4770 Buford Highway, F-35
Atlanta, GA 30341

Approved:
Cheri L. Gatland-Lightner
Chief Information Security Officer

Date:

___

OCISO Social Media or Third-Party Site Security Survey/Plan
VERSION Control
Date

Author/Editor

Version

06/21/2018

K. Carter

0.1

07/02/2018

C. Frazier

1.0

Notes

2
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OCISO Social Media or Third-Party Site Security Survey/Plan

OCISO Social Media or Third-Party Site Security Survey/Plan
Note: Gray highlighted text identifies the content each program must fill in when
completing a plan – please delete highlighting in completed plans
PROGRAM/DIVISION/CENTER or OFFICE: OSTLTS
SITE NAME AND NAME OF CDC PROFILE(S): _Qualtrics – PHHS Block Grant Assessment
PROGRAM OFFICIAL: Bobbie Erlwein, Branch Chief, rxe5@cdc.gov, 404.498.0262
TECHNICAL REPRESENTATIVES: Cassandra Frazier, Health Scientist, bkx9@cdc.gov,
404.498.0581
ISSO: Kerey Carter, OCISO, kvc2@cdc.gov, 770.488.8674
1. BUSINESS AND TECHNICAL CONSIDERATIONS.
a. FUNCTIONAL DESCRIPTION (what will the site provide the public/partners?):
The PHHS Block Grant evaluation team will use Qualtrics for its PHHS Block Grant Assessment. The
purpose of the assessment is to assess select cross-cutting outputs and outcomes of the Preventive
Health and Health Services Block Grant and demonstrates the utility of the grant on a national level.
Qualtrics will enable the PHHS Block Grant Evaluation Team to create a web-based survey with
advanced controls and logic and distribute the survey.

b. BUSINESS JUSTIFICATION (why does CDC need to use this medium/technology to
achieve its mission? What is the impact if CDC does not use it?):
The PHHS Block Grant evaluation eeam (PBGET) will use Qualtrics’ robust functionality to program
and distribute a survey designed to capture data tailored to each respondent. Specific functions
include advanced logic, such as incorporating skip logic into qualitative matrices, response
validatation, multi-select responses and narrative. PBGET will also use Qualtrics to increase
response validity and accuracy by enabling its feature that allows respondents to download and
review responses prior to finalizing and submitting the survey.
Used for the initial PHHS Block Grant Assessment conducted in Fall 2017 (genIC Preventive Health
and Health Services Block Grant Assessment OMB No: 0920-0879 Exp. 03/31/2018), Qualtrics has
demonstrated its ability to handle a technically complex web-based survey. If PBGET discontinues
the use of Qualtrics for this assessment, it will delay or potentially prevent the impelemtation of the
survey. PBGET will need to identify a new platform that offers the same level functionality, which
could increase cost and delay the implementation of the survey. If PBGET does not identify an
equally robust platform, then the assessment would need to be canceled. As a result, PBGET will be
unable to assess outputs and outcomes associated with the grant or demonstrate the utility of the
grant.

c. TECHNICAL DESCRIPTION (what functionality does the site use?):
Qualtrics allows its customers to create and customize online surveys with numerous options during
the survey build process. Customers can allow respondents to use custom branding and
styles/logos, use web services (such as to link information from RSS feeds or dynamically change a
survey’s questions or answer choices), send email alerts, create dynamic panels, set response
quotas, translate questions into other languages, upload files, and export data to Excel and SPSS.
The survey distribution functionality includes the ability to create in-webpage pop-ups, use advanced
logic to determine which survey questions respondents see, real-time reporting dashboards, and
allows the printing and saving of surveys in Word and PDF formats. The survey report functionality
allows customers to create graphs and tables, summary statistics, perform analyses (such as cross
tabulations and conjoint analysis). According to the Qualtrics website, the survey solution has SAS 70
Certification and meets Health Insurance Portability and Accountability Act (HIPAA) privacy
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standards. The Qualtrics website also states that Qualtrics deploys the general requirements set
forth by many Federal Acts, including FISMA. The website provides real-time data replication.

d. INFORMATION TYPES: Based on NIST SP 800-60 analysis, this site’s categorization is
LOW, based on use of the following information types:
Information Types & Impact Levels1
Information
Type
Management
Improvement

NIST SP
800-60 R1
Reference

Confidentiality

Integrity

Availability

N/A*

Low

Low

N/A

Low

Low

C.2.3.7

OVERALL RATINGS

Justification for Enhanced
Control
The data collected under this
information type is not linked
(directly or indirectly) to any
individuals, and the nonidentified survey responses
in isolation do not reveal
confidential information.
Therefore, the confidentiality
rating is N/A.

Note: data posted to social media or third-party sites must have a security categorization of Not
Applicable (NA) for Confidentiality (all public information) and no greater than LOW impact for
Integrity and Availability. Therefore, social media or third-party sites cannot be used for
communicating, storing or processing Personally Identifiable Information (PII), information that is
otherwise deemed sensitive or protected, including but not limited to Personal Health Information
(PHI), financial information, Sensitive But Unclassified, or Controlled Unclassified Information.

e. All content posted to the site must be approved for public release through authorized
CDC channels and meet OADC Public Communications guidance. Specifically, scientific
information must meet Clearance of Information Products Disseminated Outside CDC for
Public Use policy.
2. RISK CONSIDERATIONS.
a. GENERAL. The CDC program officials listed above are implementing the safeguards
described in Tab A to meet CDC and HHS policies, as well as safeguard CDC
information, information systems, and/or the public and professional reputation of CDC.
b. SPECIFIC DESCRIPTION AND MITIGATION OF RISKS. The table below elaborates
on risks identified with using the particular site, profiles, technologies and/or data
involved, and how that risk will be reduced. The table clearly specifies any
deviations/adjustments from the safeguards in Tab A.

1

If necessary, additional rows may be added to this table.
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Risk Area A: CDC External



# Risk Description



1



Public/Part
ner (site
user)
privacy

Background/History

Risk Reduction Controls

Qualtrics advertises that
the company provides a
protective privacy policy
regarding email
addresses and personal
information. Personallyidentifiable information
should not be collected
or maintained in any
CDC surveys created
using the service.



Application of the
following safeguards listed
in Tab A: 3 through 15



OSTLTS will not collect
any personally identifiable
information within its
survey.



Qualtrics adheres to
safeguards in TAB A:3-15



Qualtrics provides a
protective privacy policy
statement at
https://www.qualtrics.com/priva
cy-statement



2



Public/Part
ner (site
user)
exposure
to malware
or other
online
threats

The Qualtrics website
may be exposed to
malicious content or
infections. CDC survey
responders could be
exposed to malware that
can infect local
workstations.



Qualtrics complies with
the U.S. and E.U. Safe
Harbor Framework and
the U.S.and Swiss Safe
Harbor Framework as set
forth by the U.S.
Department of Commerce



Application of the
following safeguards listed
in Tab A:6, 9, 11, 12



The Qualtrics service adhere
to safeguards in Tab A:6, 9,
11



Qualtrics provides a security
statement at
https://www.qualtrics.com/securitystatement. Qualtrics has SAS

70 Certification and meets
HIPAA standards.


Qualtrics routinely
undergoes monthly patch
updates.

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

3



Embarrass
ment to /
penalties
against
(legal,
financial,
etc.) CDC

CDC survey responders
may provide incorrect or
misleading responses.
Incorrect survey results
may damage the
reputation of the agency
or compromise the
integrity of the project.



Application of the following
safeguards listed in Tab A:
2, 3, 7 through 19



The Qualtrics service
adheres to Tab A: 2, 3, 7-19
and poses no
embarrassment to/penalties
against the agency.



Qualtrics has certified that it
adheres to the Safe Harbor
Privacy Principles

Risk Area B: CDC Internal Systems



# Risk Description



1



Exposure
to malware
or other
online
threats
during site
administrati
on

Background/History
While conducting survey
administration on the
Qualtrics website, CDC
staff could be redirected
to a malicious website
that can compromise the
user’s workstation.

Risk Reduction Controls


Application of the following
safeguards listed in Tab A: 6
through 12



CDC users will use USGB
compliant workstations with
enterprise virus protection
installed using the up-to-date
virus/malware/spyware
signatures.



Software adhere to
safeguards in Tab A:6 – 12



Qualtrics provides a security
statement at
https://www.qualtrics.com/securitystatement. Qualtrics has SAS

70 Certification and meets
HIPAA standards.


Qualtrics routinely undergoes
monthly patch updates.

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Qualtrics provides an
acceptable use statement at



https://www.qualtrics.com/acceptabl
e-use-statement. Qualtrics

states that the company
website has a zero tolerance
policy for spam, pornography,
and warez (pirated software).
Any surveys found to contain,
promote, or link to such
content are subject to
immediate removal from the
Qualtrics service.



2



Exposure
to malware
by
downloadin
g data from
the site to
CDC
networks
(only if
required)

While conducting survey
administration on the
Qualtrics website, CDC
staff could be redirected
to a malicious website
that can compromise the
user’s workstation.



Use of OCISO-approved
USB encrypted drives with
malware detection
capability



Specific CDC computers
or shares where the data
will be downloaded,
stored, and processed



Detailed
procedures/protections
used



CDC users will use USGB
compliant workstations
with enterprise virus
protection installed using
the up-to-date
virus/malware/spyware
signatures.

Qualtrics supports ethical
research data collection by
using secure, encrypted
storage under US-EU Safe
Harbor Principles.



Qualtrics Security Statement:
http://www.qualtrics.com/securitystatement
NOTE: See links referenced in
section 2C.

Risk Area C: CDC Internal Information
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

# Risk Description



1



2





Background/History

Risk Reduction Controls

Loss of
information
due to
technical
reasons
(malicious
or
operational
)

No sensitive data or PII
will be present in the
surveys. Loss of
information does not
pose a confidentiality,
integrity, or availability
risk to CDC.



Application of the
following safeguards listed
in Tab A: 5 through 7, 11,
12, 15, 16



Qualtrics supports ethical
research data collection
by using secure,
encrypted storage under
US-EU Safe Harbor
Principles

Loss of
information
due to
administrati
ve or
procedural
reasons

No sensitive data or PII
will be present in the
surveys. Loss of
information does not
pose a confidentiality,
integrity, or availability
risk to CDC.



Application of the
following safeguards listed
in Tab A: 2 through 5, 16

c. RISK AREA REFERENCE LINKS (to “Background/History” references above)
1) Qualtrics -- http://www.qualtrics.com/
2) Qualtrics Survey Software: Handbook for Research Professionals -http://cloudfront.qualtrics.com/q1/wpcontent/uploads/2012/02/QualtricsSurveySoftware.pdf
3) Qualtrics Security Statement: http://www.qualtrics.com/security-statement
4) Qualtrics Privacy Statement: https://www.qualtrics.com/privacy-statement
5) U.S.-EU & U.S.-Swiss Safe Harbor Frameworks: http://export.gov/safeharbor/
3. RISK ACCEPTANCE.
The representative of the coordinating office must circle the appropriate concurrence
statement, then sign (electronic signature preferred) and date their name to the right.
All comments should be captured below the concurrence block or attached as a
separate sheet--include the commenter’s name and the date. The signed plan must
then be forwarded to the supporting ISSO for his/her concurrence. The program
maintaining the social media/third-party site must also retain a copy of this
concurrence, along with all supporting documents (such as the Terms of Service and
Privacy Policy). A completed copy of this document must be scanned and emailed to
OCISOThirdParty@cdc.gov for review.

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TAB A (Safeguards)
1.

Use of the site has been coordinated with the CDC Social Media Council and the Office of
the Assistant Director / Division of News and Electronic Media (OADC/DNEM), applying
CDC best practices.

2.

Use of the site and application of appropriate information security and privacy controls
have been coordinated with the supporting ISSO.

3.

Based on NIST SP 800-60 analysis, this site’s categorization is LOW based on
identified information types (see paragraph 1d of the survey/plan). Note: Data
posted to social media or third-party sites must have a security categorization
of Not Applicable (NA) for Confidentiality (all public information) and no
greater than LOW impact for Integrity and Availability. Therefore, social media
or third-party sites cannot be used for communicating, storing or processing
Personally Identifiable Information (PII), information that is otherwise deemed
sensitive or protected, including but not limited to Personal Health Information
(PHI), financial information, Sensitive But Unclassified, or Controlled
Unclassified Information.

4.

All content posted to the site must be approved for public release through authorized
CDC channels and meet OADC Public Communications guidance. Specifically, scientific
information must meet Clearance of Information Products Disseminated Outside CDC for
Public Use policy. (see paragraph 1e of the Social Media or Third-Party Site Security
Survey/Plan, if applicable)

5.

The program has site-specific Rules of Behavior (RoB) for personnel who administer
the site (e.g., create, maintain, access and store site content). Each person reads and
acknowledges the RoB.

6.

Program personnel administering the site acknowledge and follow the CDC prohibited
use policy and HHS/CDC Rules of Behavior (RoB) in relation to the programs activities on
the site. See the CDC policy, Use of CDC Information Technology Resources (CDC-GA2005-02).

7.

The program administers the site using a computer with a current machine image
approved by ITSO and meets CDC configuration standards.

8.

The program uses passwords meeting CDC standards for all site access, maintenance
included.

9.

The program applies the CDC Secure Web Application Coding Guidelines for any applications
used on the site.

10.

The program posts a comment moderation policy/statement is posted on the site (if
applicable).

11.

The program conducts content reviews of its presence on the site at least weekly,
checking the following integrity, availability and confidentiality issues.
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a.
b.
c.

Content: updating or editing outdated, inaccurate, offensive, or otherwise
inappropriate content.
Security: look for defacements and/or vulnerabilities embedded in site content
See Appendix F of DNEM’s Social Media Security Mitigations for additional guidance.

12.

The program has an incident response plan for the site that covers the following (in
accordance with CDC incident response standards):
a. what constitutes an incident;
b. the offices and individuals to whom an incident is reported and within what
timeframe (including the program’s ISSO and CDC CSIRT); and
c. how the responders (program, ISSO, CSIRT) resolve an incident.

13.

The program constrains or controls web tracking technology (e.g., cookies) as required
by OMB, HHS and CDC policies.

14.

The program uses appropriate constraints or controls regarding privacy as required by
OMB, HHS and CDC policies, including:
a. documenting the review and acceptability of the site’s privacy policy (initial, then
periodically after use begins);
b. a Privacy Impact Assessment (PIA), if required;
c. posting the CDC/HHS privacy rules and requirements within the program’s
presence on the site, where appropriate; and
d. Meeting SORN requirements, if applicable.

15.

The program has a signed Terms of Service (TOS) agreement for use of the site that
meet HHS guidance. Digitalgov.gov and OADC guidance and the CDC Office of the
General Counsel (OGC) are consulted as required.

16.

The program maintains all information posted to, or downloaded from (if allowed), the
site as required by the appropriate Records Schedule/Records Management processes
(as determined by the program in consultation with their Senior Records Liaison).

17.

The program posts disclaimers on the profile for the site, stating that official CDC
information can be found at CDC.gov and that in the case of any discrepancies that the
content on CDC.gov be considered correct. CDC’s presence should also provide an
alternative government email address where users can send feedback.

18.

The program uses appropriate CDC branding on the site to distinguish the agency’s
activities from those of non-government actors.

19.

The program posts an alert on links from an official CDC site to any external site.

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TAB B (References)
U.S. Office of Government Ethics
5 C.F.R. Part 2635, Standards of Ethical Conduct for Employees of the Executive Branch

OMB
M-11-02, Sharing Data While Protecting Privacy
M-10-23, Guidance for Agency Use of Third-Party Websites and Applications
M-10-22, Guidance for Online Use of Web Measurement and Customization Technologies
M-07-16, Safeguarding Against and Responding to the Breach of Personally Identifiable Information

NIST
NIST SP 800-60 Rev 1, Guide for Mapping Types of Information and Information Systems to Security
Categories, Volume I
NIST SP 800-60 Rev 1, Guide for Mapping Types of Information and Information Systems to Security
Categories, Volume II

GSA
Digitalgov.gov Negotiated Terms of Service Agreements

NARA
Social Media and Digital Engagement at the National Archives

HHS CIO COUNCIL
Privacy Best Practices for Social Media
HHS Information Systems Security and Privacy Policy (IS2P) – July 2014 Edition
HHS CIO Memorandum, Usage of Unauthorized External Information Systems to Conduct Department
Business
HHS-OCIO Policy for Managing the Use of Third-Party Websites and Applications
HHS CIO Memorandum, Updated Departmental Standard for the Definition of Sensitive Information
HHS CIO Memorandum, Implementation of OMB M-10-22 and M-10-23
HHS.gov Social Media Terms of Service Agreements

CDC
CDC Enterprise Social Media Policy
Use of CDC Information Technology Resources
Controlled Unclassified Information
Records Management
Wireless Security
CDC Enterprise Blogging Policy
Clearance of Information Products Distributed Outside CDC for Public Use
Employee Communication Branding
Protection of Information Resources
CDC IT Security Program Implementation Standards
CDC Implementation of the HHS Rules of Behavior for Use of HHS Information Technology Resources
Office of the Associate Director for Communication
OADC Division of Public Affairs

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OCISO Social Media or Third-Party Site Security Survey/Plan
CDC Social Media Council
CDC Social Media Tools, Guidelines & Best Practices
Social Media Security Mitigations
Standard Baseline Configurations
OCISO Social Media & Third-Party Websites

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Position

Choice 1

Choice 2

Choice 3

Signature and Date
7/23/2018

Program Official

Concur

Concur
w/Comment

Nonconcur

X
Program Official
Signed by: Roberta K. Erlwein -S

ISSO

Concur

Concur
w/Comment

Nonconcur

7/23/2018

X

Kerey Carter

ISSO
Signed by: Kerey L. Carter -S

ISSO Comments:


Qualtrics recently received a FedRAMP accreditation (10/31/2017). Per prior agreement from
OCISO, OCISO plans to evaluate the use of Qualtrics at the enterprise level, as multiple CDC
offices currently use Qualtrics under approved 3rd party site plans. If OCISO re-evaluates
Qualtrics use at CDC and later requires a security assessment and accreditation, OSTLTS
understands that this change can circumvent or impact the 3rd party site plan approval.

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