Privacy Impact Assessment Form

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

0920- 2131

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

0920-2131

2a Name:

Form Date

Capacity Building Assistance Program: Data Management, Mon
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

No
Yes
No
Agency
Contractor

Point of Contact (POC):

7

Is this a new or existing system?

8

Does the system have Security Authorization (SA)?

8a Date of Security Authorization

POC Title

Behavioral Scientist

POC Name

Karen Kun

POC Organization NCHHSTP/DHP/TEB
POC Email

icn3@cdc.gov

POC Phone

404.639.2639
New
Existing
Yes
No

N/A

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9

Indicate the following reason(s) for updating this PIA.
Choose from the following options.

PIA Validation (PIA
Refresh/Annual Review)
Anonymous to NonAnonymous
New Public Access
Internal Flow or Collection

Significant System
Management Change
Alteration in Character of
Data
New Interagency Uses
Conversion

Commercial Sources
Other...
10

Describe in further detail any changes to the system
that have occurred since the last PIA.

11 Describe the purpose of the system.

Not applicable
The purpose of this information collection is to evaluate the
CDC cooperative agreement program entitled CDC-RFAPS19-1904: Capacity Building Assistance (CBA) for High Impact
HIV Prevention Program Integration.
Specifically, this information collection will assess how well the
Division of HIV Prevention (DHP)’s CBA program meets the
capacity building needs of programs directly and indirectly
funded by CDC to provide HIV prevention services
The system will collect, maintain/store, and share (between
the government and contractors) training and technical
assistance (TA) recipients': (1) demographic details, (2) business
contact information, (3) post-training survey responses, and (4)
post-TA survey responses.

The 25 questions on the Learning Group Registration Form
collects demographic information about training recipients'
Describe the type of information the system will
including: 1) business contact information (e.g., business email
collect, maintain (store), or share. (Subsequent
and telephone number); 2) primary [employment] functional
12
questions will identify if this information is PII and ask role; 3) employment setting; and 4) programmatic and
about the specific data elements.)
population areas of focus. The CDC TRAIN system will store the
information for use during future training registrations.
The demographic and identifiable data are needed to
complete registration, disseminate the Post-Training
Evaluation, and conduct follow-up with program managers.
The identifiable data from the Learning Group Registration is
entered, stored, and transmitted in a separate database from
all the other data collected.

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There are two systems involved in the collection of training
and TA data. The first system is CDC TRAIN. CDC TRAIN is an
existing online learning management system that is primarily
used to deliver eLearning courses. CDC TRAIN also allows
individuals to register for in-person (face-to-face) trainings. This
project uses CDC TRAIN to collect demographic information for
training recipients. CDC TRAIN data access is granted to a small
number of designated DHP, Capacity Development Branch
(CDB) and Translation and Evaluation (TEB) staff, CBA providers,
and the TEB evaluation contractors.
Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.

The second system used by this project is the CBA Tracking
System (CTS). CTS is an existing system customized for this
project. CTS offers survey capabilities beyond the options in
CDC TRAIN. Specifically, CTS collects information beyond
demographics such as the post-training and post-TA surveys.
CTS is a password protected online application with varying
levels of data access granted to DHP CDB and TEB staff, CDCfunded CBA providers, and the TEB evaluation contractors.
CDC TRAIN only administers the Learning Group Registration
Form. CTS administers the Post-Training Evaluation, Post-TA
Evaluation, and the Training and Technical Assistance Followup Survey.
Yes

14 Does the system collect, maintain, use or share PII?

Indicate the type of PII that the system will collect or
15
maintain.

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

Business street address

Business phone number

Other...

Business email address

Other...

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

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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
The business email address will allow the system to send
individuals an email invitation to complete the web-based
version of the post-training survey or post-TA survey. The
business phone number is used to contact individuals if they
do not respond to the email invitation. Name and other
business contact information is used to verify that the person
contacted by phone is the correct individual.
Business contact information is also used during data cleaning
to remove duplicate records before conducting analysis
related to program evaluation.

20 Describe the function of the SSN.

Not applicable.

20a Cite the legal authority to use the SSN.

Not applicable.

Public Health Service Act, Section 301, "Research and
Identify legal authorities governing information use Investigation," (42 U.S.C. 241); and Sections 304, 306 and 308(d)
21
which discuss authority to maintain data and provide
and disclosure specific to the system and program.
assurances of confidentiality for health research and related
activities (42 U.S.C. 242 b, k, and m(d)).
22

Yes

Are records on the system retrieved by one or more
PII data elements?

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.

09-20-0161 Records of Health Professionals in Di

Published:
Published:
In Progress

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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?
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?

0920-1322 and 2/29/24. This current extension request will
update the expiration date once OMB approves it.
Yes
No
Participants are notified online about the collection of personal
information. The online notification is provided during the
time of training or TA registration.
Voluntary
Mandatory

Training participants can opt-out of the collection or use of
their PII by selecting the "opt-out" box in the online LGR form.
The LGR form (within CDC TRAIN) is presented before training
Describe the method for individuals to opt-out of the participants register for their first training course. Training
collection or use of their PII. If there is no option to
participants can update their LGR at any time to opt-in or opt27
object to the information collection, provide a
out as desired. TA participants are able to opt-out online when
reason.
requesting TA in CTS, or TA participants can opt-out verbally
through the CBA provider. The CBA provider should not
electronically submit PII for TA participants that verbally optout of the collection or use of their PII.
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.

There are no major changes expected for this information
collection. However, each system includes functions and
features that allow individuals to be notified by email of system
changes and related consents.

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Each survey cover letter and survey includes a point of
contact's name, phone number, and email address to allow
Describe the process in place to resolve an
individuals to express concerns regarding PII. If an individual
individual's concerns when they believe their PII has voices a concern, the point of contact will follow the agency
29 been inappropriately obtained, used, or disclosed, or and division protocol for confirming the appropriateness or
that the PII is inaccurate. If no process exists, explain inappropriateness of PII use and disclosure. If needed, the
why not.
point of contact will work with the appropriate data security
staff, system administrators, and other project members to
resolve the concerns.
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.

Data is downloaded from each system at least one time per
week. The project's Evaluation Plan, Data Quality Plan, and
Data Transfer Report guide the weekly activities that ensure
the data's integrity, availability, accuracy and relevancy. Weekly
meetings are held with staff responsible for the collection,
management, storage, and reporting of the data to ensure
comprehensive and thorough periodic reviews.
Users

The Public Health Foundation (PHF) is
the CDC TRAIN administrator. PHF is
Identify who will have access to the PII in the system
PHF developers will have access to
Developers
31
and the reason why they require access.
CDC TRAIN. SeKON developers will
Direct contractors embedded within
Contractors
TEB perform data management for
Designated CDC CDB and TEB staff
Others
(i.e., team leads, scientists, and
System users are determined by their role outlined in
respective contracts and cooperative agreements. Each system,
CDC TRAIN and CTS are password protected applications, and
each have formal steps for obtaining system access. CDC TRAIN
and CTS System users are required to complete a form to
Describe the procedures in place to determine which request access. The request is reviewed by the branch to
determine if approval should be granted and the level of
32 system users (administrators, developers,
access to PII that is appropriate (for example, aggregate or
contractors, etc.) may access PII.
disaggregate data). Upon system access approval, user profiles
are customized to limit access to what the user "needs to
know" to perform their job role. System users have unique
logins and are instructed not to share their login information,
especially passwords with colleagues or other individuals to
ensure protection of PII.
Administrators

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.

Each system features varying levels of access. "Super-user"
roles that allow the view of PII collected by this project are
limited to project managers and data management staff that
require greater access to provide system oversight and
monitor data integrity.

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.

Personnel are required to complete the required initial and
annual IT security training such as general security and privacy
awareness training.

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

Webinars are held at least one time per year to discuss data
access and data use. Throughout the year, new users receive
one-to-one orientation for each systems and the orientation
discussion emphasizes proper data access and data use.

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.

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

Yes
No
Personnel will maintain all information in accordance with
N1-442-09-001 Bucket 1.
Administrative controls: Passwords are only assigned to
personnel with a role that requires their use of the PII. The
amount of PII available to personnel is uses a "need-to-know"
basis. Personnel receive training regarding protecting hard
copies and unauthorized electronic access. Access to the data
collected through web-based questionnaires is passwordprotected. The granting of passwords and levels of access are
determined by the branch. The site administrator grants and
revokes access on a rolling basis.
Technical controls: CDC will maintain information in secure
electronic files that will only be accessible to authorized
members of the team. Electronic files will be stored on secure
network servers, and access will be restricted to approved
team members identified by user ID and password. PII is
password protected.
Physical controls: Servers are protected by guards, locks, and ID
badges.

39 Identify the publicly-available URL:

https://www.train.org/cdctrain/welcome
https://wwwn.cdc.gov/CTS
Yes

40 Does the website have a posted privacy notice?
41

No
Yes

Does the website use web measurement and
customization technology?

No
Technologies
Web beacons
Web bugs

Select the type of website measurement and
41a customization technologies is in use and if it is used
to collect PII. (Select all that apply)

Session Cookies
Persistent Cookies
Other...

Collects PII?
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No

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42

Does the website have any information or pages
directed at children under the age of thirteen?

Yes

43

Does the website contain links to non- federal
government websites external to HHS?

Yes

No

No

REVIEWER QUESTIONS: The following section contains Reviewer Questions which are not to be filled out unless the user is an OPDIV
Senior Officer for Privacy.

Reviewer Questions
1

Are the questions on the PIA answered correctly, accurately, and completely?

Answer
Yes
No

Reviewer
Notes
2

Does the PIA appropriately communicate the purpose of PII in the system and is the purpose
justified by appropriate legal authorities?

Yes

Do system owners demonstrate appropriate understanding of the impact of the PII in the
system and provide sufficient oversight to employees and contractors?

Yes

No

Reviewer
Notes
3

No

Reviewer
Notes
4

Does the PIA appropriately describe the PII quality and integrity of the data?

Yes
No

Reviewer
Notes
5

Is this a candidate for PII minimization?

Yes
No

Reviewer
Notes
6

Does the PIA accurately identify data retention procedures and records retention schedules?

Yes
No

Reviewer
Notes
7

Are the individuals whose PII is in the system provided appropriate participation?

Yes
No

Reviewer
Notes
8

Does the PIA raise any concerns about the security of the PII?

Yes
No

Reviewer
Notes
9

Is applicability of the Privacy Act captured correctly and is a SORN published or does it need
to be?

Yes
No

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Reviewer Questions

Answer

Reviewer
Notes
10

Is the PII appropriately limited for use internally and with third parties?

Yes
No

Reviewer
Notes
11

Does the PIA demonstrate compliance with all Web privacy requirements?

Yes
No

Reviewer
Notes
12

Were any changes made to the system because of the completion of this PIA?

Yes
No

Reviewer
Notes

General Comments

OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by
Beverly E. Walker -S
Date: 2024.07.05
10:08:31 -04'00'

HHS Senior
Agency Official
for Privacy

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