Privacy Impact Assessment

U.S. Department of the Interior
PRIVACY IMPACT ASSESSMENT

Appendix A: DI-4001 PIA Form
Introduction
The Department of the Interior requires PIAs to be conducted and maintained on all IT systems
whether already in existence, in development or undergoing modification in order to adequately
evaluate privacy risks, ensure the protection of privacy information, and consider privacy
implications throughout the information system development life cycle. This PIA form may not
be modified and must be completed electronically; hand-written submissions will not be
accepted. See the DOI PIA Guide for additional guidance on conducting a PIA or meeting the
requirements of the E-Government Act of 2002. See Section 6.0 of the DOI PIA Guide for
specific guidance on answering the questions in this form.
Name of Project: Contact Information
Bureau/Office: Fish and Wildlife Service
Date: TBD
Point of Contact: Associate Privacy Officer
Name: Jennifer L. Schmidt
Title: Associate Privacy Officer
Email: Jennifer_Schmidt@fws.gov
Phone: 703/358-2291
Address: Falls Church, VA

Section 1. General System Information
A. Is a full PIA required?
☒ Y es,inform ation is collected from or m aintained on
☐ M em bers of the generalpublic
☐ Federalpersonnel and/or Federal contractors
☐ V olunteers
☒ A ll
☐ N o: Information is NOT collected, maintained, or used that is identifiable to the
individual in this system. Only sections 1 and 5 of this form are required to be
completed.
B. What is the purpose of the system?
The U.S. Fish and Wildlife Service (FWS or the Service) mission is to work with others
to conserve, protect and enhance fish, wildlife, and plants and their habitats for the
continuing benefit of the American people. To accomplish this mission the Service
regularly interacts with members of the public: employees of non-Federal government

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agencies such as state or Canadian wildlife federations; representatives from non-profit
institutions like museums and universities, and individual hobbyists or wildlife
enthusiasts seeking general FWS information; data from a FWS database; partnering with
FWS on an initiative or providing coordinated emergency response; or interested in
participating in a FWS study or project. As part of these interactions, FWS may collect
minimal Personally Identifiable Information (PII); i.e., the contact information necessary
to distribute information and perform various administrative tasks. This contact
information may be collected and stored by FWS program offices through various means
such as an online application or web form, email, voicemail, face-to-face or paper. Any
FWS program or project that collects Sensitive PII, such as Social Security number, Date
of Birth, or financial or payment information is not covered by this PIA. PIA coverage
for projects that collect Sensitive PII will be provided under a system or program-specific
PIA. For a list of projects covered by this PIA, please refer to the Appendix. The
appendix will be updated as new and similar collections of contact information are
identified.
What is the legal authority?
In general, the Service may collect contact information to facilitate communication the
public under these authorities:
●
●
●
●

5 U.S.C. § 301 – Departmental regulations
16 U.S.C. § 9 – Fish and Wildlife Service
44 U.S.C. § 3101 – Records management by agency heads
44 U.S.C. § 3501 – Federal Information Policy

Contact information may also be collected as part of Service programs or projects that
operate under other specific or derivative authorities. For a digest of all Federal laws
under which the Service functions, please see
https://www.fws.gov/laws/Lawsdigest.html.
C. Why is this PIA being completed or modified?
☒ New Information System
☐ N ew E lectronic C ollection
☒ E xisting Inform ation System under Periodic R eview
☐ M erging of System s
☐ Significantly M odified Inform ation System
☐ C onversion from Paper to E lectronic R ecords
☐ R etiring or D ecom m issioninga System
☐ O ther: Describe
D. Is this information system registered in CSAM?
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☐ Y es
☒No
E. List all minor applications or subsystems that are hosted on this system and covered
under this privacy impact assessment.
Subsystem Name

Purpose

Contains PII
(Yes/No)

None

N/A

N/A

Describe
If Yes, provide a
description.
N/A

F. Does this information system or electronic collection require a published Privacy
Act System of Records Notice (SORN)?
☒ Y es: FW S-27 Correspondence Control System, 64 FR 29055, May 28, 1999. This
SORN currently is under revision to provide general updates and incorporate new Federal
requirements in accordance with OMB Circular A-108.
Due to the variety of FWS programs that may collect contact information, records
containing members of the public’s contact information may be covered by other
Government-wide or DOI Privacy Act system of records which may be viewed at
https://www.doi.gov/privacy/sorn.
☐No
G. Does this information system or electronic collection require an OMB Control
Number?
☒ Y es: D ue to the variety of FWS programs that collect contact information, records
containing members of the public’s contact information may be fall under various OMB
Control Numbers for DOI or FWS information collections. Program managers must
contact the FWS Information Collection Clearance Officer in the Division of Policy,
Economics, Risk Management, and Analytics (PERMA) to coordinate the required
Paperwork Reduction Act (PRA) review to ensure all collections of contact information
are approved as necessary by OMB.
☐No

Section 2. Summary of System Data

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A. What PII will be collected? Indicate all that apply.
☒ N am e
☒ G roup A ffiliation
☒ Personal C ell T elephone N um ber

☒ Personal E m ail A ddress
☒ H om e T elephone N um ber
☒ M ailing/H om e A ddress

B. What is the source for the PII collected? Indicate all that apply.
☒ Individual
☐ Federal agency
☐ T ribalagency
☐ Local agency
☐ D O I records
☐ T hird party source
☐ State agency
☐ O ther: Describe
C. How will the information be collected? Indicate all that apply.
☒ Paper Form at
☒ E m ail
☒ Face-to-Face Contact
☒ W eb site
☐ Fax
☒ T elephone Interview
☐ Inform ation Shared B etw een System s
☐ O ther: Describe
D. What is the intended use of the PII collected?
Authorized uses of the PII include but are not limited to: to disseminate general
information to individuals who have signed up to receive FWS communications; to
provide wildlife or conservation data upon request; to arrange the individual’s
participation in a FWS initiative or study; to notify prior project participants of upcoming
opportunities to submit information; and in order to verify information that the individual
submitted as a participant in a FWS project.
E. With whom will the PII be shared, both within DOI and outside DOI? Indicate all
that apply.
☒ W ithin the B ureau/O ffice: C ontact inform ation m ay be sharedwith FWS personnel,
including contractors, who have a need-to-know in the performance of their official

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duties.
☒Other Bureaus/Offices: Contact information may be shared with DOI personnel who
have a need-to-know in the performance of their official duties.
☒Other Federal Agencies: To enable the agency to respond to an inquiry by an
individual to whom an agency record pertains.
☒ T ribal,State or Local A gencies: T he appropriate Federal,State,tribal,localor foreign
governmental agency that is responsible for investigating, prosecuting, enforcing or
implementing a statute, rule, regulation, order or license, when we become aware of an
indication of a violation or potential violation of the statute, rule regulation, order or
license.
☒Contractor: Authorized contractors hired to work on FWS projects or systems who
have a need-to-know may be involved in the collection or handling of contact
information from members of the public.
☒ Other Third Party Sources: The appropriate agencies, entities, and persons when the
Department determines that there has been a suspected or confirmed breach in order to
assist the Department effort’s to respond to the breach.
F. Do individuals have the opportunity to decline to provide information or to consent
to the specific uses of their PII?
☒ Y es: T he individualvoluntarily provides his or her contact information. If he or she
does not provide all the PII requested, FWS may not be able to provide a response or, the
individual may not be able to participate in a FWS project.
☐ N o: State the reason why individuals cannot object or why individuals cannot give or
withhold their consent.
G. What information is provided to an individual when asked to provide PII data?
Indicate all that apply.
☒ Privacy A ct Statem ent: Privacy A ctStatem ents are included on paper and electronic
forms that request PII from individuals and are maintained in a Privacy Act System of
Record.
☒ Privacy N otice: FW S w ebpages contain a hyperlink to FW S’
s internet privacy policy.

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☒ O ther: T his PIA and SO R N-27 provide further notice to individuals.
☐ N one
H. How will the data be retrieved? List the identifiers that will be used to retrieve
information (e.g., name, case number, etc.).
Information may be retrieved by the individual’s name, project title, date or location.
I. Will reports be produced on individuals?
☐ Y es:
☒No

Section 3. Attributes of System Data
A. How will data collected from sources other than DOI records be verified for
accuracy?
Contact information is provided by the individual directly to the Service.
B. How will data be checked for completeness?
The contact information is collected directly from the individual and is assumed to be
complete and accurate. Often web forms and surveys online utilize required fields which
prevents the submission of incomplete forms. It is the responsibility of the individual to
provide FWS with subsequent updates or any corrections needed.
C. What procedures are taken to ensure the data is current? Identify the process or
name the document (e.g., data models).
It is the responsibility of the individual to ensure that the contact information they
provide is up to date and current.
D. What are the retention periods for data in the system? Identify the associated
records retention schedule for the records in this system.
FWS retains the information no longer than is useful for carrying out the information
dissemination or collaboration purposes for which it was originally collected. Contact
information collected to facilitate communication with the public and related records are
generally kept for no more than seven years in accordance with the Department Records
Schedule (DRS) DAA-0048-2013-0002, Long-term Administrative Records. Mission6

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related records may be categorized under a different, non-administrative schedule.
Program managers are encouraged to work with the FWS Records Management Office to
identify the official retention period for all records under their purview.
E. What are the procedures for disposition of the data at the end of the retention
period? Where are the procedures documented?
Approved disposition methods include shredding or pulping for paper records, and
degaussing or erasing for electronic records, in accordance with NARA guidelines and
384 Departmental Manual 1.
F. Briefly describe privacy risks and how information handling practices at each stage
of the “information lifecycle” (i.e., collection, use, retention, processing, disclosure
and destruction) affect individual privacy.
There is minimal privacy risk to individuals who voluntarily provide their contact
information to FWS for the purposes of facilitating communication. The collection
directly involves the respondents. FWS collects the information directly from individuals
so they are aware that FWS will maintain their information at least temporarily. FWS
collects the minimal amount of information necessary. Individuals receive adequate
notices regarding FWS’ authority to collect, the authorized uses and permissible
disclosures of their information at the time of collection via the hard-copy or electronic
form or website. During the PII’s use and retention, FWS utilizes appropriate physical,
technical and administrative controls to limit access to authorized FWS personnel who
have a need-to-know in the performance of their duties. Paper records are kept secure
while not in use; electronic files are protected via the FWS’ secure network.

Section 4. PIA Risk Review
A. Is the use of the data both relevant and necessary to the purpose for which the
system is being designed?
☒ Y es
☐No
B. Does this system or electronic collection derive new data or create previously
unavailable data about an individual through data aggregation?
☐ Y es
☒No

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C. Will the new data be placed in the individual’s record?
☐ Y es
☒No
D. Can the system make determinations about individuals that would not be possible
without the new data?
☐ Y es
☒No
E. How will the new data be verified for relevance and accuracy?
No new data about individuals can be derived from this system.
F. Are the data or the processes being consolidated?
☐ Y es,data is being consolidated. Describe the controls that are in place to protect the
data from unauthorized access or use.
☐ Y es,processes are being consolidated. Describe the controls that are in place to
protect the data from unauthorized access or use.
☒ N o,data or processes are not being consolidated.
G. Who will have access to data in the system or electronic collection? Indicate all that
apply.
☒ U sers
☒ C ontractors
☐ D evelopers
☒ System A dm inistrator
☐ O ther:
H. How is user access to data determined? Will users have access to all data or will
access be restricted?
Access to records in the system is limited to authorized personnel whose job
responsibilities require such access, i.e. on a “need to know” basis. Electronic data is
protected through user identification, passwords, database permissions and software

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controls. Such security measures establish different access levels for different types of
users through Role Based Access Controls.
I. Are contractors involved with the design and/or development of the system, or will
they be involved with the maintenance of the system?
☒ Y es. A uthorized contractors m ay handle or process PIIor other sensitive information
as part of their official duties. Contractors complete the same onboarding process as
Federal employees and are required to complete annual Information Management and
Technology (IMT), Privacy, Records Management, Section 508 Compliance, Controlled
Unclassified Information, and the Rules of Behavior, Role Based Security Training and
Role Based Privacy Training to maintain network access.
☐No
J. Is the system using technologies in ways that the DOI has not previously employed
(e.g., monitoring software, SmartCards or Caller ID)?
☐ Y es
☒No
K. Will this system provide the capability to identify, locate and monitor individuals?
☐ Y es
☒No
L. What kinds of information are collected as a function of the monitoring of
individuals?
Not applicable.
M. What controls will be used to prevent unauthorized monitoring?
FWS fully complies with NIST and other Federal requirements for data security as part of
a formal program of assessment and authorization, and continuous monitoring. IT
systems maintain an audit trail of activity sufficient to reconstruct security relevant
events. Access to audit logs and audit tools are restricted to authorized personnel only
via access control lists and authorized access to the project. FWS projects follow the
least privilege security principle, such that only the least amount of access is given to a
user to complete their job responsibilities.

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N. How will the PII be secured?
(1) Physical Controls. Indicate all that apply.
☒ Security G uards
☐ K ey G uards
☒ Locked File C abinets
☒ Secured Facility
☒ C losed C ircuit T elevision
☐ C ipher Locks
☒ Identification B adges
☒ Safes
☒ C om bination Locks
☒ Locked O ffices
☐ O ther.Describe
(2) Technical Controls. Indicate all that apply.
☒ Passw ord
☒ Firew all
☒ E ncryption
☒ U ser Identification
☐ B iom etrics
☒ Intrusion D etection System (ID S)
☒ V irtualPrivate Network (VPN)
☒ Public K ey Infrastructure (PK I) C ertificates
☒ Personal Identity V erification (PIV ) C ard
☐ O ther.Describe
(3) Administrative Controls. Indicate all that apply.
☒ Periodic Security A udits
☒ B ackups Secured O ff-site
☒ R ules ofBehavior
☒ R ole-Based Training
☒ R egular M onitoring of U sers’Security Practices
☒ M ethods to E nsure O nly A uthorized Personnel H ave A ccess to PII
☒ E ncryption of B ackups C ontaining Sensitive D ata
☒ M andatory Security,Privacy and R ecords M anagem entTraining
☐ O ther.Describe

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O. Who will be responsible for protecting the privacy rights of the public and
employees? This includes officials responsible for addressing Privacy Act
complaints and requests for redress or amendment of records.
The FWS Associate Privacy Officer, Information System Security Officer and projects’
System Owners and/or Project Managers are responsible for protecting the privacy rights
of the public and FWS personnel whose information we maintain. The FWS Associate
Privacy Officer and the Privacy Act System Managers are responsible for responding to
any complaints or requests for the amendment of records.
P. Who is responsible for assuring proper use of the data and for reporting the loss,
compromise, unauthorized disclosure, or unauthorized access of privacy protected
information?
The Project Manager and/or Information System Owner, the Information System Security
Officer and the FWS Associate Privacy Officer are responsible for assuring proper use of
personal information. Loss, compromise, unauthorized disclosure or unauthorized access
of PII is considered a security incident and is required to be reported to DOI-CIRC within
one hour of discovery. The FWS Records Officer is also notified and is responsible for
the reporting of record loss or the compromise of records to NARA.

Section 5. Review and Approval
PIAs for Bureau or Office level systems must be signed by the designated Information System
Owner, Information System Security Officer, and Bureau Privacy Officer, and approved by the
Bureau Assistant Director for Information Resources as the Reviewing Official. Departmentwide PIAs must be signed by the designated Information System Owner, Information System
Security Officer, and Departmental Privacy Officer, and approved by the DOI Chief Information
Officer/Senior Agency Official for Privacy as the Reviewing Official.
Information System Owner
Email:
shelley_hartmann@fws.gov
First Name: Shelley Last Name: Hartmann
Title:
Deputy Associate Chief Information Officer
Bureau/Agency: FWS
Phone: 703-358-2004
Signature:

TONYA HARTMANN

Digitally signed by TONYA
HARTMANN
Date: 2019.12.16 14:24:47 -05'00'

Information System Security Officer
Email:

jay_mcmaster@fws.gov
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First Name: Jay
Last Name: McMaster
Title: Associate Chief Information Security Officer
Bureau/Agency: FWS
Phone: 703-358-2133
Signature:

signed by JAY MCMASTER
JAY MCMASTER Digitally
Date: 2020.01.09 11:03:43 -05'00'

Privacy Officer
Email:
jennifer_schmidt@fws.gov
First Name: Jennifer Last Name: Schmidt
Title: Associate Privacy Officer
Bureau/Agency: FWS
Phone: 703-358-2291
Signature:

JENNIFER SCHMIDT

Digitally signed by JENNIFER
SCHMIDT
Date: 2019.11.26 14:17:14 -05'00'

Reviewing Official
Email:
paul_gibson@fws.gov
First Name: Paul
Last Name: Gibson
Title: Associate Chief Information Officer
Bureau/Agency: FWS
Phone: 703-358-2636
Signature:

signed by PAUL GIBSON
PAUL GIBSON Digitally
Date: 2020.01.10 14:31:50 -05'00'

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Appendix
Preliminary Aerial Waterfowl Observer Training System
FWS Migratory Bird program hosts a website at
https://www.fws.gov/waterfowlsurveys/welcome.jsp for training and testing biologists and
volunteers to perform aerial waterfowl surveys by improving inflight species classification and
counting. The system is used to train biologists to identify waterfowl to species and count flocks
of birds from an aircraft. The system collects FWS employees and members of the public’s
name, work email address and work phone number. The PII is used to track the training and
accuracy of each observer that participates in FWS surveys in order to increase the quality of
data used to support management decisions.
Federal Employee Viewpoint Survey (FEVS) for Non-permanent FWS employees
The personal email address that FWS short-term personnel (volunteers, interns, etc.) provides
during the onboarding procedures is used to send them the FWS Non-Permanent Employee
FEVS Survey when their summer employment is over and the individual is no longer working
for FWS. Data from this survey will be used to generate summary statistics on non-permanent
employees’ workplace satisfaction at the regional (if number of responses reaches a minimum
threshold to ensure anonymity) and national level.
Endangered and Threatened Wildlife, Experimental Populations
FWS collects information regarding experimental populations listed in 50 CFR 17.84 to help
further recovery of the species and to assess the success of the reintroduced populations.
Respondents are members of the public who notify FWS when an incident occurs and provide
information related to the incident (species involved, location, and circumstance description,
etc.) as well as his or her name, mailing address and phone number. The PII is used by FWS
when necessary to verify or collect further information about the incident.
Lake Sturgeon Sightings
FWS collects information regarding sightings of Lake Sturgeon from members of the public.
Individuals voluntarily provide their name, mailing address and email address; FWS uses this
contact information to contact respondents when necessary to verify or confirm sighting details.
Ridgefield NWRC Use of Information Collection 1018-0140
This information collection allows members of the public to enter a lottery to participate in
hunting and fishing programs that assist in the management of wildlife and their habitats at
FWS’ National Wildlife Refuges. Individuals voluntarily provide their name, mailing address,
phone number and email address in order that the sponsoring Refuge may notify the applicant of

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his or her selection as well as to follow up afterwards to learn of his or her hunting/fishing
experience.
Oral History Project
The USFWS National Conservation Training Center (NCTC) partners with the FWS Retirees
Association, through the FWS-chartered Heritage Committee, to coordinate the Service’s oral
history program. The Committee is comprised of FWS employees and retirees who volunteer to
conduct oral histories with FWS retirees who consent to be interviewed and have their stories
made available to the public at https://training.fws.gov/history/OralHistories.html.
Annual Teen Environmental Art Show
The San Francisco Bay National Wildlife Refuge sponsors an annual art exhibit for teens at the
Refuge’s Environmental Education Center. The Refuge collects the name, address, phone
number and email address of young artists, as well as the parent’s or guardian’s consent, to the
display of the artists’ name and artworks and coordinate logistics for the show.
Sea Lamprey Control Program Database
The Service maintains a database of information critical to the management of invasive sea
lamprey populations in the five Great Lakes. It maintains contact information of land owners in
affected areas so that the Service can coordinate with them accessing the property and treating
the water as necessary.

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