Privacy Impact Statement

U.S. Department of the Interior
PRIVACY IMPACT ASSESSMENT

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.
NOTE: See Section 7.0 of the DOI PIA Guide for guidance on using the DOI Adapted PIA template to
assess third-party websites or applications.

Name of Project: USA National Phenology Network - The Nature’s Notebook Plant and Animal
Observing Program
Date: March 22, 2017
Bureau/Office: U.S. Geological Survey/Ecosystems Mission Area
Bureau/Office Contact Title: Phenology Program Coordinator
Point of Contact
Email: jweltzin@usgs.gov
First Name: Jake
M.I.: F
Last Name: Weltzin
Phone: (520) 626-3821
Address Line 1: 1311 E 4th Street
Address Line 2: Suite 325
City: Tucson
State/Territory: Arizona
Zip: 85721

Section 1. General System Information
A. Is a full PIA required?
Yes, information is collected from or maintained on
Members of the general public
Federal personnel and/or Federal contractors

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

Volunteers
All
No: 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 United States of America National Phenology Network (USA-NPN), established in 2007 by
the U.S. Geological Survey (USGS) in collaboration with other governmental and nongovernmental organizations, is a national-scale science and monitoring initiative focused on
phenology (i.e., the study of seasonal life-cycle events such as leafing, flowering, reproduction
and migration) as a tool to understand how plants, animals, and landscapes respond to
environmental variation and change. Information collected by the USA-NPN through its
national observing system, Nature’s Notebook, is used by researchers and federal, state, and local
agencies and resource managers to: understand and support climate change vulnerability
assessments and adaptation; inform management and assessment of habitats and plant and animal
species; identify, assess, and forecast change in ecosystems and effects of climate change;
identify relationships between environments and wildlife and human health; integrate data and
products for science-based stewardship of natural resources; and provide opportunities for public
stewardship and engagement.
C. What is the legal authority?
Relevant acts include the Organic Act, 43 U.S.C. 31 et seq., 1879; Fish and Wildlife
Coordination Act, 1934; Fish and Wildlife Act, 1956; Migratory Bird Treaty Act, 1918;
Migratory Bird Conservation Act, 1900; Federal Land Policy and Management Act, 1976; Fish
and Wildlife Improvement Act, 1978; Endangered Species Act, 1973; Marine Mammal
Protection Act, 1972; Great Lakes Fishery Act, 1956; Nonindigenous Aquatic Nuisance
Prevention and Control Act, 1990; Water Resources Development Act, 1990; and other
authorizations conveyed to the U.S. Geological Survey.
D. Why is this PIA being completed or modified?
New Information System
New Electronic Collection
Existing Information System under Periodic Review
Merging of Systems
Significantly Modified Information System
Conversion from Paper to Electronic Records
Retiring or Decommissioning a System
Other: Describe

2

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

E. Is this information system registered in CSAM?
Yes: Enter the UII Code and the System Security Plan (SSP) Name 010-000001013 System
Security Plan for Science & Support Systems
No
F. 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)

Describe
If Yes, provide a
description.

None

G. Does this information system or electronic collection require a published Privacy Act
System of Records Notice (SORN)?
Yes: List Privacy Act SORN Identifier(s) Citizen Science and Crowdsourcing – Interior, GS29 (Pending)
No

H. Does this information system or electronic collection require an OMB Control Number?
Yes: Describe OMB Control Number 1028-0103. Expires 03/31/2019.
No

Section 2. Summary of System Data
A. What PII will be collected? Indicate all that apply.
Name
Citizenship
Gender
Birth Date
Group Affiliation
Marital Status
Biometrics
Other Names Used

Truncated SSN
Legal Status
Place of Birth
Religious Preference
Security Clearance
Spouse Information
Financial Information
Medical Information

3

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

Disability Information
Tribal or Other ID Number
Credit Card Number
Personal Email Address
Law Enforcement
Mother’s Maiden Name
Education Information
Home Telephone Number
Emergency Contact
Child or Dependent Information
Driver’s License
Employment Information
Race/Ethnicity
Military Status/Service
Social Security Number (SSN)
Mailing/Home Address
Personal Cell Telephone Number
Other: Specify the PII collected. Virtual Face or Picture
B. What is the source for the PII collected? Indicate all that apply.
Individual
Federal agency
Tribal agency
Local agency
DOI records
Third party source
State agency
Other: Describe
C. How will the information be collected? Indicate all that apply.
Paper Format
Email
Face-to-Face Contact
Web site
Fax
Telephone Interview
Information Shared Between Systems
Other: Describe Android and iOS Mobile Apps
D. What is the intended use of the PII collected?
Names, usernames, email addresses, and states are collected to communicate with participants in
Nature’s Notebook. The USA-NPN communicates program updates and contacts participants in
the event it is necessary to follow up on observations submitted for further detail. If a participant
is affiliated with a group, the group leader uses the name and email to communicate with the
participant. Usernames and states are presented on the project leaderboards.
E. With whom will the PII be shared, both within DOI and outside DOI? Indicate all that
apply.

4

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

Within the Bureau/Office: Describe the bureau/office and how the data will be used.
Other Bureaus/Offices: Describe the bureau/office and how the data will be used.
Other Federal Agencies: Describe the federal agency and how the data will be used.
Tribal, State or Local Agencies: Describe the Tribal, state or local agencies and how the
data will be used.
University of Arizona staff, operating under a Cooperative Agreement with the USGS, which
manages Nature’s Notebook, may access PII to communicate with participants, to provide
updates on the program, and to obtain additional information about observation records as
necessary.
Contractor: Describe the contractor and how the data will be used.
Other Third Party Sources: Describe the third party source and how the data will be used.
Partners of the USA-NPN, which include nature centers and schools, organize local groups to
participate in Nature’s Notebook. Through communication with USA-NPN staff, a “group”
is created in Nature’s Notebook, and the contact at the partner organization is the
administrator of the group. The group administrator then helps observers sign up for
Nature’s Notebook and affiliate themselves with the group. PII for observers affiliated with
the group is visible only to the administrator of that group and is used to facilitate
communication via email between the group administrator and the group member.
F. Do individuals have the opportunity to decline to provide information or to consent to the
specific uses of their PII?
Yes: Describe the method by which individuals can decline to provide information or how
individuals consent to specific uses.
A user is able to visit the USA-NPN website without identifying who he or she is or
providing any personal information. If the user does decide to register with USA-NPN to
facilitate reporting phenological observations or contributing content to the site, the USANPN will not sell, trade, or give away the user’s personal information, which includes name,
username, state, email address, and suggestions or comments made by email. To submit
observations to Nature’s Notebook, participants must provide an email address. Users have
the option to opt out of participation in the leaderboards.
No: State the reason why individuals cannot object or why individuals cannot give or
withhold their consent.

5

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

G. What information is provided to an individual when asked to provide PII data? Indicate
all that apply.
Privacy Act Statement: Describe each applicable format.
Authority: Relevant acts include the Organic Act, 43 U.S.C. 31 et seq., 1879; Fish and
Wildlife Coordination Act, 1934; Fish and Wildlife Act, 1956; Migratory Bird Treaty Act,
1918; Migratory Bird Conservation Act, 1900; Federal Land Policy and Management Act,
1976; Fish and Wildlife Improvement Act, 1978; Endangered Species Act, 1973; Marine
Mammal Protection Act, 1972; Great Lakes Fishery Act, 1956; Nonindigenous Aquatic
Nuisance Prevention and Control Act, 1990; Water Resources Development Act, 1990; and
other authorizations conveyed to the U.S. Geological Survey.
Purpose: The USA-NPN collects names, usernames, email addresses, and states to
communicate with participants.
Routine Uses: The USA-NPN may communicate program updates and contact participants
in the event it is necessary to follow up on observations submitted. If a participant is
affiliated with a group, the group leader uses the name and email to communicate with the
participant. Usernames and states are presented on the USA-NPN leaderboards. Personal
information is not otherwise released to any other party.
Disclosure: Providing this information is voluntary. People may use many of the USANPN website tools and services without registration. To submit observations in Nature’s
Notebook, participants must provide a username and email.
Privacy Notice: Describe each applicable format.

Other: Describe each applicable format.
The USA-NPN website’s terms of use contain General Privacy and Observer Privacy
policies:
1. General Privacy Policy: https://www.usanpn.org/terms#GeneralPrivacy
2. Observer Privacy Policy: https://www.usanpn.org/terms#ObserverPrivacy
None
H. How will the data be retrieved? List the identifiers that will be used to retrieve information
(e.g., name, case number, etc.).

6

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

Data management staff at the University of Arizona access data using common database queries
(text string, numeric ID).
Any website user who downloads phenology data will have access to the unique identification
numbers (Observer_ID) of the observers who made and/or submitted the observations
downloaded. No other PII is publicly accessible.
Group administrators are presented a list of participants for the group that they manage, but the
database is not otherwise searchable.
I. Will reports be produced on individuals?
Yes: What will be the use of these reports? Who will have access to them?
No

Section 3. Attributes of System Data
A. How will data collected from sources other than DOI records be verified for accuracy?
All data in the system are self-reported by individual participants. The USA-NPN assumes that
contact information provided is accurate. A series of quality assurance and quality control
measures are applied to the plant and animal phenology data reported by participants to improve
data accuracy and consistency. These measures include allowed value checks on web interfaces
and flags applied to conflicting records, and are described in full at:
www.usanpn.org/data/quality.
B. How will data be checked for completeness?
Settings on the registration web form prevent incomplete entries of required personal
information. Because participation is voluntary and at the discretion of the participant,
phenology records may be incomplete (for example, an observer may report on flowering but not
fruiting).
C. What procedures are taken to ensure the data is current? Identify the process or name the
document (e.g., data models).
Updated information provided by the participant is immediately updated in the database.
D. What are the retention periods for data in the system? Identify the associated records
retention schedule for the records in this system.

7

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

Under the USGS General Records Disposition Schedule 101-02 (https://www2.usgs.gov/usgsmanual/schedule/432-1-s1/ch100a.html#t101), the retention period for these data is seven years
or when superseded, obsolete, or no longer needed, whichever is later.
E. What are the procedures for disposition of the data at the end of the retention period?
Where are the procedures documented?
Electronic data not subject to permanent retention requirements is deleted from the database at
the end of the retention period. Procedures for the handling of electronic records are documented
in the U.S. Geological Survey Geology Discipline Research Records Schedule:
https://www2.usgs.gov/usgs-manual/schedule/432-1-s5/gd.html#sked.
Permanent records are cutoff after the completion of the project or when the USA-NPN has no
expected research, business, or other purposes for the records, whichever is later, and records are
transferred to the National Archives and Records Administration.
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 a risk to individual privacy because the system contains personal contact information.
Participants do also submit information on the location of their observations, but these locations
are not necessarily their residences. We have several systems in place to ensure that PII is not
made available to unauthorized people. We use a secure HTTPS connection for the web
interface and mobile apps to collect the data. When observational data are made available, no
personally identifying information about the observer is released. Instead, numeric Observation
IDs are provided to data users. Data are stored on servers housed in a secure and conditioned
room at the University of Arizona and are located behind a firewall. Software is regularly
updated to prevent system vulnerabilities.
Only USA-NPN University of Arizona staff members are able to access the personal information
in the database, after logging in with a two-factor authentication system to the University of
Arizona VPN. All staff members have undergone Information Security Awareness Training:
https://security.arizona.edu/all-employee-security-awareness.

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?
Yes: Explanation The collection of basic PII is necessary for the USA-NPN to meet its
mission to collect, store, and share data to support science-based stewardship of natural

8

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

resources, and to provide opportunities for public stewardship and engagement. Without this
information, it would not be possible to maintain an engaged pool of participants or to follow
up with participants for further information about their records.
No
B. Does this system or electronic collection derive new data or create previously unavailable
data about an individual through data aggregation?
Yes: Explain what risks are introduced by this data aggregation and how these risks will be
mitigated.
No
C. Will the new data be placed in the individual’s record?
Yes: Explanation
No
D. Can the system make determinations about individuals that would not be possible without
the new data?
Yes: Explanation
No
E. How will the new data be verified for relevance and accuracy?
There is no new data being derived.
F. Are the data or the processes being consolidated?
Yes, data is being consolidated. Describe the controls that are in place to protect the data
from unauthorized access or use.

Yes, processes are being consolidated. Describe the controls that are in place to protect the
data from unauthorized access or use.

No, data or processes are not being consolidated.

9

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

G. Who will have access to data in the system or electronic collection? Indicate all that apply.
Users
Contractors
Developers
System Administrator
Other: Describe Group Administrators
H. How is user access to data determined? Will users have access to all data or will access be
restricted?
Access to all personal information, other than the Observer_ID, is restricted to system
administrators on a need-to-know basis. The only exception to this is the personal information
about group members that is made available to group administrators.
I. Are contractors involved with the design and/or development of the system, or will they be
involved with the maintenance of the system?
Yes. Were Privacy Act contract clauses included in their contracts and other regulatory
measures addressed?
No
J. Is the system using technologies in ways that the DOI has not previously employed (e.g.,
monitoring software, SmartCards or Caller ID)?
Yes. Explanation
No
K. Will this system provide the capability to identify, locate and monitor individuals?
Yes. Explanation Session information is captured as part of security and troubleshooting.
No geographic location information is tracked. The latitude and longitude of observational
sites are calculated through Google Maps, but no tracking capability of users is enabled.
No
L. What kinds of information are collected as a function of the monitoring of individuals?
Logs are used on USA-NPN systems. User actions, such as user ID, log-on date and time, log-off
date and time, user actions, and data submission sessions, are recorded in the system audit logs, and
the system is monitored for unauthorized access attempts.

10

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

M. What controls will be used to prevent unauthorized monitoring?
We ensure that unauthorized monitoring is not occurring through use of HTTPS protocols. Data
are stored on servers housed in a secure and conditioned room at the University of Arizona and
located behind a firewall. Software is regularly updated to prevent system vulnerabilities.
Access to the servers is limited physically and through security configurations for staff with a
need-to-know function.
N. How will the PII be secured?
(1) Physical Controls. Indicate all that apply.
Security Guards
Key Guards
Locked File Cabinets
Secured Facility
Closed Circuit Television
Cipher Locks
Identification Badges
Safes
Combination Locks
Locked Offices
Other. Describe
(2) Technical Controls. Indicate all that apply.
Password
Firewall
Encryption
User Identification
Biometrics
Intrusion Detection System (IDS)
Virtual Private Network (VPN)
Public Key Infrastructure (PKI) Certificates
Personal Identity Verification (PIV) Card
Other. Describe
(3) Administrative Controls. Indicate all that apply.
Periodic Security Audits
Backups Secured Off-site
Rules of Behavior

11

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

Role-Based Training
Regular Monitoring of Users’ Security Practices
Methods to Ensure Only Authorized Personnel Have Access to PII
Encryption of Backups Containing Sensitive Data
Mandatory Security, Privacy and Records Management Training
Other. Describe
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 Ecosystems Associate Director serves as the Information System Owner and the official
responsible for oversight and management of the USA-NPN security and privacy controls,
including the protection of information processed and stored by the USA-NPN program. The
Information System Owner and the USA-NPN Privacy Act System Manager are responsible for
ensuring adequate safeguards are implemented to protect individual privacy in compliance with
Federal laws and policies for the data managed and stored by the USA-NPN program. The
System Manager is responsible for protecting the privacy rights of the public and employees for
the information collected, maintained, and used in the system of records, and for meeting the
requirements of the Privacy Act, including providing adequate notice, making decisions on
Privacy Act requests for notification, access, and amendments, as well as processing complaints,
in consultation with the USGS Privacy Officer.
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 Ecosystems Information System Owner is responsible for oversight and management of the
USA-NPN security and privacy controls and for ensuring, to the greatest possible extent, that
USA-NPN agency data is properly managed and that all access to agency data has been granted
in a secure and auditable manner. The Information System Owner is also responsible for
ensuring that any loss, compromise, unauthorized access, or disclosure of PII is reported to the
USGS Computer Security Incident Response Team, preferably by the assigned Security Point of
Contact, within one hour of discovery in accordance with Federal policy and established
procedures.

12

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

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. Department-wide 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
Name: Anne E. Kinsinger
Title: Associate Director
Bureau/Office: U.S. Geological Survey/Ecosystems
Phone: (703) 648-4051
Email: akingsinger@usgs.gov
Digitally signed by ANNE
ANNE
KINSINGER
Date: 2017.05.12 16:26:28
KINSINGER
-04'00'
Signature: __________________________
Date: __________________________

May 11, 2017

Information System Security Officer
Name: Linn Kwan
Title: Senior Program Officer
Bureau/Office: U.S. Geological Survey/Ecosystems
Phone: (703) 648-4494
Email: lkwan@usgs.gov

LINN KWAN

Digitally signed by LINN KWAN
DN: c=US, o=U.S. Government, ou=Department
of the Interior, ou=Geological Survey, cn=LINN
KWAN,
0.9.2342.19200300.100.1.1=14001000122572
Date: 2017.05.09 11:09:11 -04'00'

Signature: __________________________ Date: __________________________
Privacy Officer
Name: James Piyavansuthi
Title: Associate Privacy Officer (Acting)
Bureau/Office: U.S. Geological Survey/Office of Enterprise Information
Phone: (703) 648-7017
Email: jpiyavansuthi@usgs.gov
Digitally signed by JAMES

JAMES
PIYAVANSUTHI
Date: 2017.05.15 16:36:57
PIYAVANSUTHI
-04'00'
Signature: __________________________
Date: __________________________

5/15/2017

Reviewing Official
Name: Timothy S. Quinn
Title: Associate Chief Information Officer
13

U.S. Geological Survey - Ecosystems
USA National Phenology Network
Privacy Impact Assessment

Bureau/Office: U.S. Geological Survey/Office of Enterprise Information
Phone: (703) 648-6839
Email: tsquinn@usgs.gov
Digitally signed by TIMOTHY
TIMOTHY
QUINN
Date: 2017.07.11 11:41:38
QUINN
-04'00'
Signature: __________________________
Date: ___________________________

14