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Privacy Impact Assessment Form
v 1.47.4
Status Draft
Form Number
F-62894
Form Date
Question
Answer
1
OPDIV:
CDC
2
PIA Unique Identifier:
P-1792400-970349
2a Name:
5/11/2022 8:28:57 AM
Web-based Integrated Surveillance Management System
(WISMS)
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.
Development
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 Specialist
POC Name
Carman Layne
POC Organization NCHHSTP/OD
POC Email
iws6@cdc.gov
POC Phone
770.488.8116
New
Existing
Yes
No
July 15, 2022
Not Applicable
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11 Describe the purpose of the system.
The web-based surveillance management system (WISMS)
with off-line capability will provides project sites with realtime/near real-time data collection, data linkage, data
validations, and data quality checks. The system will be used to
support HIV surveillance activities at the Medical Monitoring
Project (MMP) and National HIV Behavioral Surveillance (NHBS)
operational sites/locations.
WISMS will have extensive automated data acquisition
mechanisms that can be reused. The automation and
integration of the data acquisition will eliminate many manual
steps currently used in data management processing.
The types of data WISMS stores from NHBS and MMP area sites
are: birth-date, sex at birth, year of birth, birth county, gender,
race, ethnicity, zip-code and MMP Participant ID (ParID). The
ParID contains a list of de-identified field variables about the
person's (Public Citizen) disposition which are: interview date,
interview status, date of first contact and attempts, lead
source, data collector IDs, user-name of person syncing and
Describe the type of information the system will
time. Data sets are then returned to the project area sites to
collect, maintain (store), or share. (Subsequent
12
questions will identify if this information is PII and ask use for their local analysis and reporting the national HIV
database.
about the specific data elements.)
External user access to this application is authenticated via the
Secured Authentication Management System (SAMS)
authentication. (CDC) user access is authenticated via Personal
Identity Verification (PIV) and Active Directory (AD). Both
SAMS and AD are separate systems with their own, individual
Privacy Impact Assessment (PIA).
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The web-based surveillance management system (WISMS)
with off-line capability will provides project sites with realtime/near real-time data collection, data linkage, data
validations, and data quality checks. The system will be used to
support HIV surveillance activities for Medical Monitoring
Project (MMP) and National HIV Behavioral Surveillance (NHBS)
System sites.
The purposes of this system is to:
Provide an overview of the system and describe the
13 information it will collect, maintain (store), or share,
either permanently or temporarily.
1. Maintain and update the existing data portal to provide
seamless support to the collection and management of NHBS
and MMP data;
2. Provide a web-based integrated surveillance management
system and supporting modules that replace legacy data
collection instruments currently in use by MMP and NHBS;
3. Produce high quality, timely data sets ready for analyses and
public health action; and
4. Provide operational and technical supports to MMP and
NHBS projects.
Types of data WISMS stores from NHBS and MMP area sites are;
birth-date, sex at birth, year of birth, birth county, gender, race,
ethnicity, zip-code and MMP Participant ID (ParID). The ParID
contains a list of de-identified field variables about the person's
(Public Citizen) disposition which are: interview date, interview
status, date of first contact and attempts, lead source, data
collector IDs, user-name of person syncing and time. Data sets
are then returned to the project area sites to use for their local
analysis and reporting the national HIV database.
External user access to this application is authenticated via the
Secured Authentication Management System (SAMS)
authentication. (CDC) user access is authenticated via Personal
Identity Verification (PIV) and Active Directory (AD). Both
SAMS and AD are separate systems with their own, individual
Privacy Impact Assessment (PIA).
14 Does the system collect, maintain, use or share PII?
Yes
No
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Indicate the type of PII that the system will collect or
15
maintain.
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
Zip codes
year of birth,
race/ ethnicity
gender/sex at birth
birth county
MMP Participant ID (ParID): interview date, interview status,
date of first contact and attempts, lead source, data collector
IDs, user-name of person syncing and time
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
17 How many individuals' PII is in the system?
18 For what primary purpose is the PII used?
19
100,000-999,999
Person (Public Citizen) PII will be used for surveillance and
reporting of cumulative HIV data to CDC.
Describe the secondary uses for which the PII will be
used (e.g. testing, training or research)
20 Describe the function of the SSN.
N/A
20a Cite the legal authority to use the SSN.
N/A
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)).
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22
Yes
Are records on the system retrieved by one or more
PII data elements?
No
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?
N/A
Yes
No
Not applicable. Notice is the responsibility of the state and
local health departments and HIV Surveillance Programs that
originally collect the information and provide it into the
subject system.
Voluntary
Mandatory
Describe the method for individuals to opt-out of the
collection or use of their PII. If there is no option to
The method at the local, state level, individuals have the
27
object to the information collection, provide a
option to decline to answer any of the interview questions.
reason.
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.
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.
It would not be possible to notify individuals because the
system does not process data that would enable contacting
individuals. Any contact with individuals would be the
responsibility of state and local health departments, HIV
Surveillance Programs collecting and providing the data in this
system.
Not applicable. Collecting the data and resolving individual
concerns are performed by the state and local health
departments' HIV Surveillance Programs.
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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 process involves security/privacy reviews that are
conducted annually by National Center for HIV/AIDs, Viral
Hepatitis, STD & TB Prevention (NCHHSTP) security stewards to
determine access and availability of the data to CDC users is inplace. Integrity is ensured by CDC’s routine back-ups.
Users
Administrators
31
Identify who will have access to the PII in the system
and the reason why they require access.
(User) need access to real-time/near
real-time data collection, data linkage,
data validations.
Administrators need access to update
and improve the system and
applicable tools. They also perform
dataset reviews and reporting.
Developers
Contractors
(Direct Contractors) are administrators
and need access to update and
improve the system and applicable
tools. They also perform dataset
Others
There are two roles in WISMS, admin, and user. The admin role
Describe the procedures in place to determine which determines who has access to PII through access control list
32 system users (administrators, developers,
(ACL). Role-based access controls (RBAC) are configured so that
contractors, etc.) may access PII.
each user could access only the data necessary for the user's
role. User roles only access (Public Citizen) data they input.
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).
Do contracts include Federal Acquisition Regulation
36 and other appropriate clauses ensuring adherence to
privacy provisions and practices?
The least-privilege model is utilized to ensure those with
access to data only have access to the minimum amount of
data assigned to them by access-level (i.e., read, write, full)
necessary to perform their job.
(CDC/Direct Contractor): Annual CDC Security and Privacy
Awareness Training (SAT) is required.
Project sites are required to complete their organization
specific Security Awareness training.
N/A
Yes
No
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Describe the process and guidelines in place with
37 regard to the retention and destruction of PII. Cite
specific records retention schedules.
Internal (CDC users) are required to use the CDC Records
Control Schedule. The applicable section is General Records
Schedule (GRS) 4.2: Information Access and Protection Records
which states destruction when 3 years old, but longer
retention is authorized if needed for business use. Information
that would permit identification of any individual or
establishment is collected with a guarantee that it will be held
in confidence, will be used only for purposes stated in
reporting forms, and will not be otherwise disclosed or
released without the consent of the individual or the
establishment in accordance with Sections 306 and 308(d) of
the Public Health Service Act (42 USC 242K and 252m, {d}).
Access to the data set is limited to members of the Division of
HIV/AIDS performing activities or analysis supporting public
health activities. Appeal is to the Director, Division of HIV/AIDS,
National Center for HIV/AIDs, Viral Hepatitis, STD & TB
Prevention (NCHHSTP), or Director, CDC. CDC doesn’t access
the PII, CDC data sets are encrypted when submitted to the
Data Portal. No information will be disclosed to the public,
parties involved in civil, criminal, or administrative litigation, or
non-public-health agencies of the federal, state, or local
government.
Retention and destruction of (Public Citizen) data process is
handled by their state and local health departments, HIV
Surveillance Programs.
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Administrative:
The System Security Plan (SSP) documents the system's inplace security controls. A business continuity plan exists for
the system. Regular backup of critical files and databases are
performed as required by CDC. The project area sites are
responsible for following their organization specific security
procedures, which at a minimum include restricting access to
the PII to only authorized site users. CDC users are required to
follow CDC and HHS, policies and procedures for protecting PII
information. This includes restricting access to PII following
approved access control list (ACL). Annual CDC Security and
Privacy Awareness Training (SAT) is required.
Describe, briefly but with specificity, how the PII will
38 be secured in the system using administrative,
technical, and physical controls.
Technical:
Office of the Information Officer (OCIO) Azure General Support
System (GSS) and WISMS users authorized access through
SAMS authentication. Two-factor authentication is in use for
remote access to system servers. IP address restrictions are in
place for access to server network ports. (Public Citizen) data
in-transit occur over an approved encrypted protocol.
Firewalls and Intrusion Detection Systems are deployed on the
network, which limit connections to the system and report
anomalous traffic. The application utilizes role-based access
controls.
Physical:
Azure Cloud:
CDC is dependent upon Microsoft policy and procedures in its
data centers.
The building hosting the system servers requires PIV card
access 24/7. All CDC facilities are camera monitored 24/7.
Furthermore, Application Hosting Branch (AHB) server rooms
are climate-controlled, have Uninterrupted Power Supply
protection for systems, and cameras that send images to the
Digital Services Office (DSO) personnel.
General Comments
OPDIV Senior Official
for Privacy Signature
Beverly E.
Walker -S
Digitally signed by
Beverly E. Walker -S
Date: 2022.05.25 12:00:55
-04'00'
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File Type | application/pdf |
File Modified | 2022-05-25 |
File Created | 2016-03-30 |