PIDS Privacy Impact Assessment

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Privacy Impact Assessment Form
v 1.47.2
Status Draft

Form Number

F-32785

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

P-9372180-188367

2a Name:

11/9/2015 1:42:35 PM

PRAMS Integrated Data Collection System (PIDS)
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

IT Project Manager

POC Name

Aspy Taraporewalla

POC Organization CDC
POC Email

Est3@cdc.gov

POC Phone

770-488-6222
New
Existing
Yes
No
December 28, 2015
Not Applicable

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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

10

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

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.

New technology upgrade
PRAMS Integrated Data Collection System (PIDS) is used to
monitor selected maternal behaviors and experiences that
occur before, during, and after pregnancy among women who
deliver live-born infants by conducting surveys.
The system collects names, addresses, and telephone numbers
of mothers having a recent live birth. Access to this
information shall be controlled so that it is only available to the
state users that submit the information and other state users
Pregnancy Risk Assessment Monitoring System (PRAMS) is an
ongoing state-specific, population-based surveillance system
designed to monitor selected maternal behaviors and
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

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Employees
Public Citizens
16

Business Partners/Contacts (Federal, state, local agencies)

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

Vendors/Suppliers/Contractors
Patients
Other No

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)

100,000-999,999
PII is gathered for the purpose of making contact with mothers
having a recent live birth.
Research

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
N/A
and disclosure specific to the system and program.

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.

09-20-0160

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.

N/A, not required
Yes

24 Is the PII shared with other organizations?

No
Within HHS

24a

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

Other Federal
Agency/Agencies
State or Local
Agency/Agencies
Purpose for contacting respondents to complete PRAMS
survey.
Private Sector

Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
The PRAMS Program has Data Sharing Agreement with all 40
24b Matching Agreement, Memorandum of
states plus NY City for survey data collection activities.
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?

Data is tracked via email logs and spreadsheets
Respondents for PRAMS surveillance are mothers having a
recent live birth. They are contacted by PRAMS states before
the mail survey is sent to them and notified by a pre-letter.
Voluntary
Mandatory

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Describe the method for individuals to opt-out of the
collection or use of their PII. If there is no option to
27
object to the information collection, provide a
reason.

All of the PRAMS surveillance is conducted by PRAMS states,
and they receive information from their vital records regarding
the mothers to be surveyed. Respondents participation is
voluntary basis.

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.

Any major changes to the software system will not impact
encrypted PII information in the database. Hence, the consent
that the respondent provides while completing mail or phone
survey is still valid. PII data is not used beyond data collection
efforts made to contact the individual.

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
that the PII is inaccurate. If no process exists, explain
why not.

A resource list is distributed with study materials which has
contact information for the respective state or local partner.
Complaints should be addressed to the appropriate resource
at the state or local partner level and then communicated
through appropriate channels to CDC.

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.

PII data is not used beyond data collection efforts made to
contact the individual. A batch is imported in PIDS every
month containing information to contact the respondent via
mail or phone mode. The batch normally stays open for 90
days, until when the state contacts the respondent to collect
information for the PRAMS survey. Once the batch is closed,
states do not make further efforts to contact the respondents,
and the PII data is not used after that.
Users
Administrators

31

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

Review

Developers
Contractors
Others

Describe the procedures in place to determine which
32 system users (administrators, developers,
Role based Access Control (RBAC) is utilized
contractors, etc.) may access PII.
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.
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.
Describe training system users receive (above and
35 beyond general security and privacy awareness
training).

The Least privilege model is utilized

Annual Security and Privacy Awareness Training

All system users are either state employees or contractors,
hence they have to comply with their state's security, privacy
awareness and any other training required by the state.

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Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?

Yes
No

Describe the process and guidelines in place with
37 regard to the retention and destruction of PII. Cite
specific records retention schedules.

Records are retained and disposed of in accordance with the
CDC Records Control Schedule. Records are maintained in
agency for two years. Source documents for computer
disposed of when no longer needed by program officials.
Personal identifiers may be deleted from records when no
longer needed in the study as determined by the system
manager, and as provided in the signed consent form, as
appropriate. 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. Records destroyed by paper
recycling process when 20 years old, unless needed for further
study.

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

PII data is encrypted and stored in the database at CDC, and
complies with all security measures. Potentially, a CDC
database administrator can access the PII data, if they have the
decryption routine. In our case, the solution provider has
implemented the encryption/decryption process, and they are
not the database administrator. The system is in a protected
data center with guards at the entry point to the facility.

General Comments

OPDIV Senior Official
for Privacy Signature

Beverly E.
Walker -S

Digitally signed by
Beverly E. Walker -S
Date: 2016.01.12
10:34:52 -05'00'

HHS Senior
Agency Official
for Privacy

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