Privacy Impact Assessment (PIA) - QARS

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Privacy Impact Assessment Form
v 1.47.4
Status Draft

Form Number

F-27137

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-9169586-787809

2a Name:

5/22/2019 2:04:19 PM

Quarantine Activity Reporting System (QARS)
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)?

8b Planned Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Business Steward

POC Name

Todd Mercer

POC Organization CDC/OID/NCEZID/DGMQ
POC Email

Ztc9@cdc.gov

POC Phone

404-639-4489
New
Existing
Yes
No
August 8, 2019
Not Applicable

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11 Describe the purpose of the system.
Describe the type of information the system will
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask
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.
14 Does the system collect, maintain, use or share PII?

15

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

The Quarantine Activity Reporting System (QARS) is owned
and operated by the CDC's Division of Global Migration and
QARS is an internal CDC system for collecting data on
individuals subject to quarantine or isolation orders, ill
travelers (i.e., passengers and crew), contacts of ill travelers,
and/or individuals exposed or suspected of being exposed to
QARS maintains records on the conduct of activities (e.g.,
quarantine, isolation) that fulfills the Department of Health and
Human Services (HHS)'s and CDC's statutory authority under
Yes
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
Foreign Travel

Employees
Public Citizens
16

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

Business Partners/Contacts (Federal, state, local agencies)
Vendors/Suppliers/Contractors
Patients
Other

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)

500-4,999
PII is collected for the identification of ill travelers who are
suspected of having a disease of public health interest.
PII may be used for confirming case travel details, locating
potentially exposed contacts, and initiating community-based
investigation.

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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 Sections 311, 361-368 (42
and disclosure specific to the system and program.
U.S.C. 242k) and 42 CFR parts 70 and 71.

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.

09-20-0171, Quarantine-and-Traveler-Related
Activities, Including Records for Contact Tracing
Investigation and Notification under 42 CFR

Published:

Published:
In Progress
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?

OMB Control No.0920-0134, CDC ID 0920-19MG
Yes
No

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Within HHS
Purpose: To more effectively deal with outbreaks and other
significant public health conditions
Other Federal
Agency/Agencies

24a

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

Purpose: To more effectively deal with outbreaks and other
significant public health conditions
State or Local
Agency/Agencies
Purpose: To more effectively deal with outbreaks and other
significant public health conditions
Private Sector
Purpose: To medical personnel providing evaluation and
care for ill or exposed persons, including travelers.

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

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?

All disclosures of information are processed through CDC's
Epidemic Information Exchange System (Epi-X) which is a
separate system covered by its own PIA. QARS maintains a
record of each disclosure sent to Epi-X for processing and has
the capability to produce detailed reports and summaries of
those disclosures.
During a personal encounter, the individual is notified verbally
that personal information will be collected.
Voluntary
Mandatory

Due to CDC's Public Health mandate and the time sensitive
nature of public health events, DGMQ does not request formal
consent to collect or use PII. If the individual does not wish to
Describe the method for individuals to opt-out of the provide the information, only partial information will be
collection or use of their PII. If there is no option to
collected. However, if an individual refuses to provide the
27
object to the information collection, provide a
requested information and it is reasonably believed that the
reason.
individual is infected with or has been exposed to a
quarantinable communicable disease, CDC may quarantine,
isolate, or place the individual under surveillance under 42 CFR
71.32 and 71.33.
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.

The QARS system's Authorization to Operate on the CDC
network does not allow allow changes that would contradict
the disclosure and/or data uses described in Privacy Act
System of Records Notice (SORN) 09-20-0171, Quarantine- and
Traveler-Related Activities, Including Records for Contact
Tracing Investigation and Notification under 42 CFR Parts 70
and 71. Therefore this process is not applicable and has not
been developed.

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To report and resolve concerns, individuals can contact the
POC listed above (or system manager identified in SORN
09-20-0171). The correspondence should reasonably identify
the record and specify the information being contested, the
corrective action sought, and the reasons for requesting the
correction, along with supporting information to show how
the record is inaccurate, incomplete, untimely, or irrelevant.

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 Person having complaints, concerns, or questions about
that the PII is inaccurate. If no process exists, explain Quarantine Activity Reporting System privacy practices can
why not.
send these inquiries via postal mail to General public
communications are directed to Center for Disease Control &
Prevention, Human Research Protection Office, 1600 Clifton, Rd
NE, Atlanta GA 30329-4027 or their designee, for internal
review, and then are forwarded to CDC’s Senior Agency Official
for Privacy, as necessary to review concerns and respond to
resolve the individual’s inquiry.

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.

The system has validation and integrity rules in place. Subject
Matter Experts conduct at a minimum annual reviews and
thereafter periodic (monthly/quarterly) review data to ensure
accuracy. Data is collected on a case by case basis for
immediate identification of ill travelers who are suspected of
having a disease of public health interest. Although
immediate efforts may be made to confirm information during
the investigation of an event, no efforts are made to
periodically (outside the initial investigation) follow-up or
review the integrity, availability, accuracy, and/or relevancy of
the PII data collected.
Users

31

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

Administrators

Contact ill passengers for follow-up,
contact tracing because of possible
exposure to disease of public health
significance.
Maintenance (Patches, updates) and
compliance to integrity, accountability
and confidentiality is maintained.

Developers
Contractors
Others
Describe the procedures in place to determine which The Business Steward is limiting access to the smallest possible
32 system users (administrators, developers,
number of people necessary to access PII data for conducting
contractors, etc.) may access PII.
official responsibilities through specific Role-based

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.

QARS access roles are designed to ensure user access to PII is
limited to the minimum amount of information necessary to
perform their job. Least privilege, Role Based Access methods
are used to allow those with access to PII to only access the
minimum amount of information necessary to perform their
job. The system administrator is responsible for setting up the
user access to the system based on the CDC user ID and the
permissions assigned to it.

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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.

All CDC personnel are required to complete annual Security
and Privacy Awareness Training.

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

All CDC employees who have access to PII/sensitive
information are required to complete HHS/CDC Role based
training.

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
The records are maintained in accordance with General
Records Schedule (GRS) and comply with CDC Records Control
Schedule (RCS). Final reports are created to document
programmatic decisions, policies, and other related issues and
are maintained permanently (CDC RCS, B-321, 4-1d).
Electronic feed(s) from other electronic systems - Dispose
when no longer needed: GRS 20.2c. Input data of Nonelectronic records manually data entered are maintained and
disposed of when no longer needed: GRS 20.2a.4. Other input/
output records are disposed of when no longer needed: GRS
20.2a.4, 20.2c, and 20.6. 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.
Administrative controls: Completion of training requirements;
risk analyses performed annually; branch management
reviewing access requests and granting minimal amount of
access.

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

Technical controls: Users are authenticated and data secured
using operating system and server security, administered by
the local system administrator. PII data is encrypted at rest and
in transits with access restricted to specific authorized users as
required by HHS and CDC policy.
Physical- The server is housed on CDC property with gate
guards at the entrances to the property, individual user access
credentials are required for each non-public building , floor,
and office. Closed Circuit TV is also used by the internal
security guards to check for and grant access to authorized
individuals.

General Comments

OPDIV Senior Official
for Privacy Signature

signed by Jarell
Jarell Oshodi Digitally
Oshodi -S
Date: 2019.06.05 10:26:08
-S
-04'00'

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