Appendix G: Final FDP PIA 20201120

Privacy Impact Assessment
Food Delivery Portal (FDP)
Food Delivery Portal (FDP)

Version: 1.0
Date: November 20, 2020
Prepared for: USDA OCIO-Policy
and Directives - Privacy Office

Privacy Impact Assessment
FNS WIC Food Delivery Portal

Privacy Impact Assessment for the
Food and Nutrition Service, Special
Supplemental Nutrition Program for
Women, Infants, and Children (WIC) Food
Delivery Portal (FDP)
November 20, 2020
Contact Point
Kelly Jackson – Information Owner
Food and Nutrition Service
United States Department of Agriculture
703-305-2677
Reviewing Official
Miguel Marling – Privacy Officer
Food and Nutrition Service
United States Department of Agriculture
(703) 305-1627

Page 3

Privacy Impact Assessment
FNS WIC Food Delivery Portal

Abstract
Food Delivery Portal (FDP) will replace The Integrity Profile (TIP) as the system used to house
State agency vendor management data for the Special Supplemental Nutrition Program for
Women, Infants, and Children (WIC), which is operated by the Department of Agriculture’s
Food and Nutrition Service (FNS). The data housed in FDP will be critical to providing
effective federal oversight of the WIC Program, because the data informs FNS on State agency
performance regarding vendor training, compliance, monitoring, and sanctions. A Privacy
Impact Assessment (PIA) is being conducted because FDP contains personally identifiable
information (PII), specifically full names, business tax identification numbers, and assigned
agency numbers.

Overview
Food Delivery Portal (FDP) is owned and operated by the Department of Agriculture’s Food
and Nutrition Service (FNS). FDP will host vendor management data submitted by State
agencies for the Special Supplemental Nutrition Program for Women, Infants, and Children
(WIC) and will be critical to providing effective federal oversight of the WIC Program. FDP
will contain information on State agency performance regarding vendor training, visits,
investigations, violations, sanctions, compliance, monitoring, and redemptions as well as
vendor information such as store name, store address, tax identification number, and assigned
agency number. An example of a typical transaction within FDP is a State agency uploading
vendor information into the platform, or FNS users searching for vendor information by the tax
identification number. FNS routinely shares information that is housed within FDP. These
routine uses include sharing information for the purposes of audits and oversight; for
Congressional inquiries; for disclosure to contractors as outlined under the Privacy Act of 1974,
as amended, pursuant to 5 USC § 552a(m); for disclosure to the National Archives and Records
Administration; for disclosure to State agencies; and as mandated by law for information security
breaches. FDP utilizes several modules, which include USDA’s eAuthentication system,
MuleSoft, TIP, and UDSA’s Store Tracking and Redemption System (STARS). eAuthentication
is the system used by USDA agencies that enables individual customers and employees to obtain a
single account that will allow them to access USDA Web applications and services via the Internet.
MuleSoft is an integration platform that will allow FNS to access, transform and serve up data
from 3rd party external systems and internal FNS systems (e.g., STARS, TIP) in a secure,
scalable manner at a lower level of effort. TIP is the legacy application database that was
previously used to house State agency vendor management data for the WIC Program. STARS is
the USDA database that stores information on retailers that participate in the Supplemental
Nutrition Assistance Program (SNAP). 7 CFR § 246.12 is the specific legal authority that FNS uses
to collect the information housed in FDP.

Section 1.0 Characterization of the Information

Page 4

Privacy Impact Assessment
FNS WIC Food Delivery Portal

The following questions are intended to define the scope of the information requested and/or
collected as well as reasons for its collection as part of the program, system, rule, or technology
being developed.

1.1

What information is collected, used, disseminated, or maintained in
the system?

FDP collects information on WIC vendor management activities and vendor data. State
agency policy data and Food Delivery Entity (FDE) vendors are the subjects of records in FDP.
Specific information maintained on those subjects includes policy data, state agency users,
annual vendor data, training, redemptions, investigations, violations, compliance buys,
sanctions, hours of operation, store owners and account history. These records are maintained
on each State agency and FDE once they decide to participate in the WIC Program and after
they leave the WIC Program.

1.2

What are the sources of the information in the system?

The vendor management data that will be stored within FDP will be submitted by WIC
State agencies. Data was also migrated from The Integrity Profile (TIP) during development of
FDP.

1.3

Why is the information being collected, used, disseminated, or
maintained?

The information is collected so that FNS can provide effective federal oversite over the
WIC Program. The information will be used to inform FNS on State agency performance
regarding vendor training, compliance, monitoring, and sanctions.

1.4

How is the information collected?

There are several ways that the vendor management data can be input into FDP. State
agency users can either manually input data into the system or can upload data by using CSV
and XML files. The WIC Program also has a data sharing agreement with the SNAP, which
imports data between FDP and the Store Tracking and Reporting System (STARS) systems.

1.5

How will the information be checked for accuracy?

Vendor management data that is submitted into FDP will be checked for accuracy
through validation checks to ensure that the data is accurate before it is saved in the system.
FNS will also review reports generated by FDP to ensure data accuracy.

1.6

What specific legal authorities, arrangements, and/or agreements
defined the collection of information?

Page 5

Privacy Impact Assessment
FNS WIC Food Delivery Portal

7 CFR § 246.12 is the specific legal authority that defines the collection of information.
New System of Records (SOR) Notice (SORN) entitled USDA/FNS-12, Food Delivery Portal
(FDP), which will replace The Integrity Profile (TIP) as the system used to house State agency
vendor management data for the Special Supplemental Nutrition Program (SNAP) for Women,
Infants, and Children (WIC), is in routing for approval to/thru the Departmental Privacy Office
under the Office of the Chief Information Officer using the Executive Correspondence Management
system. This SOR maintains records of activities conducted pursuant to FNS’ mission and
responsibilities authorized by legislation.

1.7

Privacy Impact Analysis: Given the amount and type of data
collected, discuss the privacy risks identified and how they were
mitigated.

The privacy risks associated with FDP are centered around the unauthorized disclosure
of the personally identifiable information (PII) hosted on the platform. FDP utilizes Shield
Platform Encryption to mitigate the threat to unauthorized disclosure of PII. With Shield
Platform Encryption, the System Administrator can encrypt a variety of widely used standard
fields, along with some custom fields and many kinds of files. Shield Platform Encryption also
supports user accounts, cases, search, approval processes, and other key FDP features. Access
to FDP is also tightly controlled through the use of eAuthentication and least role privileges.

Section 2.0 Uses of the Information
The following questions are intended to delineate clearly the use of information and the
accuracy of the data being used.

2.1

Describe all the uses of information.

FNS uses the information on vendor management activities and vendor data to provide
effective federal oversight of the WIC Program. The data analytics options within FDP will
allow FNS to analyze nationwide trends in vendor and contractor data while also providing
assurances to Congress, the Office of Inspector General, senior program managers and the
general public that every reasonable effort is being made to prevent, detect and eliminate fraud,
waste, and abuse. FDP will support FNS in formulating program policies and regulations,
generating an annual report to assess State agency progress in assessing the level of activity that
is being completed to ensure program integrity, and analyzing trends over a 5-year period.

2.2

What types of tools are used to analyze data and what type of data
may be produced?

FDP will support several tools to analyze data, including Salesforce Reports, Salesforce
Dashboards, and Tableau. All of these tools can produce reports or graphics that can summarize
the data.

Page 6

Privacy Impact Assessment
FNS WIC Food Delivery Portal

A Salesforce Report is a list of records that meet a specific set of criteria defined by the
user. It’s displayed in Salesforce in rows and columns, and can be filtered, grouped, or displayed
in a graphical chart. Every report is stored in a folder. Folders can be public, hidden, or shared,
and can be set to read-only or read/write. Administrators control who has access to the contents
of the folder based on roles, permissions, public groups, and license types.
Salesforce Dashboards offer a visual display of key metrics and trends for records. The
relationship between a dashboard component and report is 1:1; for each dashboard component,
there is a single underlying report. However, the same report can be used in multiple dashboard
components on a single dashboard (e.g., use the same report in both a bar chart and pie chart).
Multiple dashboard components can be shown together on a single dashboard page layout,
creating a powerful visual display and a way to consume multiple reports that often have a
common theme. Like reports, dashboards are stored in folders, which control access. If a user
has access to a folder then the user can also view dashboards within the folder. However, to
view the dashboard components, the user would also need access to the underlying reports as
well.
Tableau is a visual analytics platform that enables the user to explore, analyze, manage,
and share data.

2.3

If the system uses commercial or publicly available data please
explain why and how it is used.

FDP utilizes commercial Geographic Information System (GIS) mapping to map the
location of vendor stores.

2.4

Privacy Impact Analysis: Describe any types of controls that may be
in place to ensure that information is handled in accordance with the
above described uses.

USDA safeguards records in this system according to applicable rules and policies,
including all applicable USDA automated systems security and access policies. USDA has
imposed strict controls to minimize the risk of compromising the information that is being
stored. Access to the computer system containing the records in this system is limited to those
individuals who have a need to know the information for the performance of their official duties
and who have appropriate clearances or permissions.
FDP utilizes a robust collection of technical safeguards to ensure the integrity of the
platform. FDP is hosted in a secure server environment that uses a firewall to prevent
interference or access from outside intruders. When accessing FDP, Secure Socket Layer (SSL)
technology protects the user’s information by using both server authentication and data
encryption. FDP administrators will have a suite of security tools that can be used to increase
the security of the system. From a physical security standpoint, the servers that host FDP are
stored in a privately owned data center with strict physical access control procedures in place
to prevent unauthorized access.

Page 7

Privacy Impact Assessment
FNS WIC Food Delivery Portal

Section 3.0 Retention
The following questions are intended to outline how long information will be retained after the
initial collection.

3.1

How long is information retained?

FDP does not have currently have a records schedule that is approved by the National
Archives and Records Administration (NARA). The proposed schedule dictates that the
different information sets will be retained for different periods of time, as described below. The
records within FDP will be kept indefinitely until NARA has approved a records schedule for
FDP.
FDP’s Database/Master file will be retained on a temporary basis and will be destroyed
either 10 years after the termination of the system and the successful migration of the data or
10 years after the termination of the system.
The Electronic Food Delivery Portal Data Entry Form, which represents an Input to
FDP, will be retained in accordance with GRS 5.2, Item 020 on a temporary basis and destroyed
upon verification of the successful creation of the final document or file, or when no longer
needed for business use, whichever is later.
Outputs and Reports generated by FDP, which will be retained in accordance with GRS
5.2, Item 020, can be in any of the following formats: electronic, metadata, reference data, or
paper. Outputs and Reports will be kept on a temporary basis and destroyed upon verification
of the successful creation of the final document or file, or when no longer needed for business
use, whichever is later.
System Documentation for FDP will be retained in accordance with GRS 3.1, Item 051.
System Documentation for FDP includes data system specifications, file specifications,
codebooks, record layouts, user guides, output specifications, and final reports (regardless of
medium) relating to a master file, database or other electronic records. System Documentation
will be retained on a temporary basis and destroyed 5 years after the project/activity/transaction
is completed or superseded, or when the associated system is terminated, or when the associated
data is migrated to a successor system.
The information in FDP will be retained on the abovementioned schedule to allow FNS
to analyze nationwide trends in vendor and contractor data while also providing assurances to
Congress, the Office of Inspector General, senior program managers and the general public that
every reasonable effort is being made to prevent, detect and eliminate fraud, waste, and abuse.
FDP will support FNS in formulating program policies and regulations, generating an annual
report to assess State agency progress in assessing the level of activity that is being completed
to ensure program integrity, and analyzing trends over a 5-year period.

3.2

Has the retention period been approved by the component records
officer and the National Archives and Records Administration
(NARA)?
Page 8

Privacy Impact Assessment
FNS WIC Food Delivery Portal

The proposed retention period has not yet been approved by NARA.

3.3

Privacy Impact Analysis: Please discuss the risks associated with the
length of time data is retained and how those risks are mitigated.

The records schedule proposed to NARA represents ideal timelines for records
retention and disposal. Maintenance and destruction timelines mitigate data protection risk
and ensure currency of information.

Section 4.0 Internal Sharing and Disclosure
The following questions are intended to define the scope of sharing within the United States
Department of Agriculture.

4.1

With which internal organization(s) is the information shared, what
information is shared and for what purpose?

Employees and contractors from the Department’s FNS Program Integrity and
Monitoring Branch (PIMB) are responsible for conducting federal oversight of the WIC
Program and are the primary users of the information housed within FDP. SNAP will be able
to access a portion of the data housed within FDP, in order to facilitate review of and reporting
on food providers that exist in both Programs. Additional Programs operated by the Department,
within FNS, may also receive a designated sub-set of data in the future.

4.2

How is the information transmitted or disclosed?
Users can access FDP by using their eAuthentication login credentials.

4.3

Privacy Impact Analysis: Considering the extent of internal
information sharing, discuss the privacy risks associated with the
sharing and how they were mitigated.

The privacy risks associated with FDP are centered around the unauthorized disclosure
of the personally identifiable information (PII) hosted on the platform. FDP utilizes Shield
Platform Encryption to mitigate the threat to unauthorized disclosure of PII. With Shield
Platform Encryption, the System Administrator can encrypt a variety of widely used standard
fields, along with some custom fields and many kinds of files. Shield Platform Encryption also
supports user accounts, cases, search, approval processes, and other key FDP features. Access
to FDP is also tightly controlled through the use of eAuthentication and least role privileges.

Section 5.0 External Sharing and Disclosure
The following questions are intended to define the content, scope, and authority for information
sharing external to USDA which includes Federal, state and local government, and the private sector.

Page 9

Privacy Impact Assessment
FNS WIC Food Delivery Portal

5.1

With which external organization(s) is the information shared, what
information is shared, and for what purpose?

Consistent with USDA’s information sharing mission, information stored in FDP may
be shared with other USDA components, as well as appropriate Federal, State, local, tribal,
foreign, or international government agencies. This sharing will only take place after USDA
determines that the receiving component or agency has a need to know the information to carry
out national security, law enforcement, immigration, intelligence, or other functions consistent
with the routine uses set forth in FDP’s System of Records Notice, which are also described
below.
In addition to those disclosures generally permitted under 5 U.S.C. § 552a(b) of the
Privacy Act, all or a portion of the records or information contained in this system may be
disclosed to authorized entities, as is determined to be relevant and necessary, outside USDA
as a routine use pursuant to 5 U.S.C. § 552a(b)(3) as follows:
(1) To the Department of Justice (DOJ), including Offices of the United States
Attorneys, or other federal agency conducting litigation or in proceedings before any court,
adjudicative, or administrative body when it is relevant or necessary to the litigation and one of
the following is a party to the litigation or has an interest in such litigation:
(2) To an agency or organization for the purpose of performing audit or oversight
operations as authorized by law, but only such information as is necessary and relevant to such
audit or oversight function.
(3) To a congressional office from the record of an individual in response to an inquiry
from that congressional office made at the request of the individual to whom the record pertains.
(4) To an appropriate federal, state, tribal, local, international, or foreign law
enforcement agency or other appropriate authority charged with investigating or prosecuting a
violation or enforcing or implementing a law, rule, regulation, or order, when a record, either
on its face or in conjunction with other information, indicates a violation or potential violation
of law, which includes criminal, civil, or regulatory violations and such disclosure is proper and
consistent with the official duties of the person making the disclosure.
(5) Disclosure to contractors under section (m): To agency contractors, grantees,
experts, consultants or volunteers who have been engaged by the agency to assist in the
performance of a service related to this system of records and who need to have access to the
records in order to perform the activity. Recipients shall be required to comply with the
requirements of the Privacy Act of 1974, as amended, pursuant to 5 USC § 552a(m).
(6) Disclosure to NARA: Records from this SOR may be disclosed to the National
Archives and Records Administration (NARA) or to the General Services Administration for
records management inspections conducted under 44 USC § 2904 and § 2906.
(7) Disclosure to State agencies: For State agencies to conduct any activities that are
necessary to remain in compliance with the WIC Program requirements.
(8) Information security breaches: To appropriate agencies, entities, and persons when
(1) [the agency] suspects or has confirmed that the security or confidentiality of information in
Page 10

Privacy Impact Assessment
FNS WIC Food Delivery Portal

the system of records has been compromised; (2) the Department has determined that as a result
of the suspected or confirmed compromise there is a risk of harm to economic or property
interests, identity theft or fraud, or harm to the security or integrity of this system or other
systems or programs (whether maintained by the Department or another agency or entity) that
rely upon the compromised information; and (3) the disclosure made to such agencies, entities,
and persons is reasonably necessary to assist in connection with the Department’s efforts to
respond to the suspected or confirmed compromise and prevent, minimize, or remedy such
harm.
(9) To another Federal agency or Federal entity, when USDA determines that
information from this system of records is reasonably necessary to assist the recipient agency
or entity in (1) responding to a suspected or confirmed breach or (2) preventing, minimizing, or
remedying the risk of harm to individuals, the recipient agency or entity (including its
information systems, programs, and operations), the Federal Government, or national security,
resulting from a suspected or confirmed breach.

5.2

Is the sharing of personally identifiable information outside the
Department compatible with the original collection? If so, is it
covered by an appropriate routine use in a SORN? If so, please
describe. If not, please describe under what legal mechanism the
program or system is allowed to share the personally identifiable
information outside of USDA.

The sharing of PII is compatible with the original collection and will be done in
accordance with the routine uses outlined in Section 5.1

5.3

How is the information shared outside the Department and what
security measures safeguard its transmission?

There is currently no expectation that sensitive data from FDP will be shared outside of
the USDA except as in 5.1 and 5.2 above. If a requirement to share such data were to arise in
the future, the data would be protected in accordance with Federal requirements, to include the
use of approved encryption mechanisms.

5.4

Privacy Impact Analysis: Given the external sharing, explain the
privacy risks identified and describe how they were mitigated.

The privacy risks associated with FDP are centered around the unauthorized disclosure
of the personally identifiable information (PII) hosted on the platform. FDP utilizes Shield
Platform Encryption to mitigate the threat to unauthorized disclosure of PII. With Shield
Platform Encryption, the System Administrator can encrypt a variety of widely used standard
fields, along with some custom fields and many kinds of files. Shield Platform Encryption also
supports user accounts, cases, search, approval processes, and other key FDP features. Access
to FDP is also tightly controlled through the use of eAuthentication and least role privileges.

Page 11

Privacy Impact Assessment
FNS WIC Food Delivery Portal

However, FNS does not share PII housed in FDP with any source outside of USDA, so there
are no privacy risks to mitigate.

Section 6.0 Notice
The following questions are directed at notice to the individual of the scope of information collected,
the right to consent to uses of said information, and the right to decline to provide information.

6.1

Does this system require a SORN and if so, please provide SORN
name and URL.

Yes. New SORN USDA/FNS-12, Food Delivery Portal (FDP), is in routing for approval
to/thru the Departmental Privacy Office under the Office of the Chief Information Officer using the
Executive Correspondence Management system. This SOR maintains records of activities
conducted pursuant to FNS’ mission and responsibilities authorized by legislation. 7 CFR § 246.12
is the specific legal authority that defines the collection of information. A URL is yet to be
established.

6.2

Was notice provided to the individual prior to collection of
information?

State Agencies and vendors who choose to participate in the WIC Program are required
to submit specific information to FNS. State Agencies and vendors are notified of the program
and information collection authorities and prior to participating including Privacy Act
Statements when applicable.

6.3

Do individuals have the opportunity and/or right to decline to provide
information?

Vendors and State agencies who choose to participate in the WIC Program do not have
the opportunity and/or right to decline to provide required information.

6.4

Do individuals have the right to consent to particular uses of the
information? If so, how does the individual exercise the right?

Vendors and State agencies who choose to participate in the WIC Program do not have
the right to consent to particular uses of the information.

6.5

Privacy Impact Analysis: Describe how notice is provided to
individuals, and how the risks associated with individuals being
unaware of the collection are mitigated.

Notice is provided to the Vendors and State Agencies who choose to participate in the
WIC Program during their initial onboarding process. There is no risk with the vendors or State

Page 12

Privacy Impact Assessment
FNS WIC Food Delivery Portal

Agencies being unaware of the requirement for collection of information, as State agencies are
responsible for submitting the information they collect on their vendors into FDP.

Section 7.0 Access, Redress and Correction
The following questions are directed at an individual’s ability to ensure the accuracy of the
information collected about them.

7.1

What are the procedures that allow individuals to gain access to their
information?

FDP contains information on WIC vendor management activities, not specific
individuals.

7.2

What are the procedures for correcting inaccurate or erroneous
information?

FDP contains information on WIC vendor management activities, not specific
individuals. State agencies have access to their data and are responsible for correcting any
inaccurate or erroneous information that they have submitted into FDP.

7.3

How are individuals notified of the procedures for correcting their
information?

FDP contains information on WIC vendor management activities, not specific
individuals.

7.4

If no formal redress is provided, what alternatives are available to the
individual?

FDP contains information on WIC vendor management activities, not specific
individuals.

7.5

Privacy Impact Analysis: Please discuss the privacy risks associated
with the redress available to individuals and how those risks are
mitigated.

FDP contains information on WIC vendor management activities, not specific
individuals.

Section 8.0 Technical Access and Security
The following questions are intended to describe technical safeguards and security measures.

Page 13

Privacy Impact Assessment
FNS WIC Food Delivery Portal

8.1

What procedures are in place to determine which users may access
the system and are they documented?

USDA safeguards records in this system according to applicable rules and policies,
including all applicable USDA automated systems security and access policies. USDA has
imposed strict controls to minimize the risk of compromising the information that is being
stored. Access to the computer system containing the records in this system is limited to those
individuals who have a need to know the information for the performance of their official duties
and who have appropriate clearances or permissions.

8.2

Will Department contractors have access to the system?

Yes. Information housed within FDP can be shared with agency contractors, grantees,
experts, consultants or volunteers who have been engaged by the agency to assist in the
performance of a service related to FDP and who need to have access to the records in order to
perform the activity. Recipients shall be required to comply with the requirements of the Privacy
Act of 1974, as amended, pursuant to 5 USC 552a(m).

8.3

Describe what privacy training is provided to users either generally
or specifically relevant to the program or system?

Users will access FDP by utilizing their USDA eAuthentication account. USDA
requires all users who have an eAuthentication account to complete annual Information Security
Awareness training, which includes modules on privacy training.

8.4

Has Certification & Accreditation been completed for the system or
systems supporting the program?

FDP is being added to the FNS Salesforce boundary, which has a current Authorization
to Operate (ATO). The FNS Salesforce ATO will be updated in January 2021, following the
completion of an independent assessment of the security and privacy controls for the solution.

8.5

What auditing measures and technical safeguards are in place to
prevent misuse of data?

FDP has auditing measures in place which can help diagnose potential or real security
issues. It is recommended that ISO perform regular security audits to detect potential abuse.
FDP can perform regular audits of Record Modification Fields, Login History, Field History
Tracking, and Setup Audit Trail.
FDP utilizes a robust collection of technical safeguards to ensure the integrity of the
platform. FDP is hosted in a secure server environment that uses a firewall to prevent
interference or access from outside intruders. When accessing FDP, Secure Socket Layer (SSL)
technology protects the user’s information by using both server authentication and data
encryption. FDP administrators will have a suite of security tools that can be used to increase

Page 14

Privacy Impact Assessment
FNS WIC Food Delivery Portal

the security of the system. From a physical security standpoint, the servers that host FDP are
stored in a privately owned data center with strict physical access control procedures in place
to prevent unauthorized access.

8.6

Privacy Impact Analysis: Given the sensitivity and scope of the
information collected, as well as any information sharing conducted
on the system, what privacy risks were identified and how do the
security controls mitigate them?

The privacy risks associated with FDP are centered around the unauthorized disclosure
of the personally identifiable information (PII) hosted on the platform. FDP utilizes Shield
Platform Encryption to mitigate the threat to unauthorized disclosure of PII. With Shield
Platform Encryption, the System Administrator can encrypt a variety of widely used standard
fields, along with some custom fields and many kinds of files. Shield Platform Encryption also
supports user accounts, cases, search, approval processes, and other key FDP features. Access
to FDP is also tightly controlled through the use of eAuthentication and least role privileges.

Section 9.0 Technology
The following questions are directed at critically analyzing the selection process for any technologies
utilized by the system, including system hardware and other technology.

9.1

What type of project is the program or system?

FDP is a data collection and reporting system that allows State agencies to export the
State’s WIC system of record results to the federal WIC Program. The development of FDP is
a re-platform of the existing TIP system to the Salesforce Cloud that also enhances the
functionalities currently provided by TIP system. The re-platform and enhancements will
improve the Program’s oversight capabilities.

9.2

Does the project employ technology which may raise privacy
concerns? If so, please discuss their implementation.
No. FDP does not employ technology that will raise privacy concerns.

Section 10.0 Third Party Websites/Applications
The following questions are directed at critically analyzing the privacy impact of using third
party websites and/or applications.

10.1 Has the System Owner (SO) and/or Information Systems Security
Program Manager (ISSPM) reviewed Office of Management and
Budget (OMB) memorandums M-10-22 “Guidance for Online Use of
Web Measurement and Customization Technology” and M-10-23
Page 15

Privacy Impact Assessment
FNS WIC Food Delivery Portal

“Guidance for Agency Use of Third-Party Websites and
Applications”?
Yes.

10.2 What is the specific purpose of the agency’s use of 3rd party websites
and/or applications?
The Agency does not use 3rd party websites or applications to operate FDP.

10.3 What personally identifiable information (PII) will become available
through the agency’s use of 3rd party websites and/or applications.
The Agency does not use 3rd party websites or applications to operate FDP.

10.4 How will the PII that becomes available through the agency’s use of
3rd party websites and/or applications be used?
The Agency does not use 3rd party websites or applications to operate FDP.

10.5 How will the PII that becomes available through the agency’s use of
3rd party websites and/or applications be maintained and secured?
The Agency does not use 3rd party websites or applications to operate FDP.

10.6 Is the PII that becomes available through the agency’s use of 3rd party
websites and/or applications purged periodically?
The Agency does not use 3rd party websites or applications to operate FDP.

10.7 Who will have access to PII that becomes available through the
agency’s use of 3rd party websites and/or applications?
The Agency does not use 3rd party websites or applications to operate FDP.

10.8 With whom will the PII that becomes available through the agency’s
use of 3rd party websites and/or applications be shared - either
internally or externally?
The Agency does not use 3rd party websites or applications to operate FDP.

10.9 Will the activities involving the PII that becomes available through
the agency’s use of 3rd party websites and/or applications require

Page 16

Privacy Impact Assessment
FNS WIC Food Delivery Portal

either the creation or modification of a system of records notice
(SORN)?
The Agency does not use 3rd party websites or applications to operate FDP.

10.10 Does the system use web measurement and customization technology?
FDP will not utilize web measurement or customization technology.

10.11 Does the system allow users to either decline to opt-in or decide to
opt-out of all uses of web measurement and customization
technology?
FDP will not utilize web measurement or customization technology.

10.12 Privacy Impact Analysis: Given the amount and type of PII that
becomes available through the agency’s use of 3rd party websites
and/or applications, discuss the privacy risks identified and how they
were mitigated.
The Agency does not use 3rd party websites or applications to operate FDP.

Page 17

Privacy Impact Assessment
FNS WIC Food Delivery Portal

Agency Responsible Officials
Digitally signed by MARCI GIORDANO
MARCI
GIORDANO
Date: 2020.11.30 09:44:32 -05'00'
________________________________

Marci Giordano
FNS OIT Project Manager
Program Integrity and Monitoring Branch
Food and Nutrition Service
United States Department of Agriculture

Date

Digitally signed by KELLY JACKSON
KELLY
JACKSON
_______________________________Date: 2020.11.23 09:22:51 -05'00'

Kelly Jackson
Information Owner
Program Integrity and Monitoring Branch
Food and Nutrition Service
United States Department of Agriculture

Date

Digitally signed by JOSEPH SHAW
JOSEPH
SHAW
Date: 2020.11.30 09:57:51 -05'00'
________________________________

Joseph Shaw
System Owner
Food and Nutrition Service
United States Department of Agriculture

Date

Agency Approval Signature
Digitally signed by JOSEPH BINNS
JOSEPH
BINNS
Date: 2020.12.01 09:08:08 -05'00'
________________________________

Joseph Binns
ISSPM/ACISO
Food and Nutrition Service
United States Department of Agriculture

Date

Page 18