Pia

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Privacy Impact Assessment Form
v 1.21
Status

Form Number

Form Date

Question

Answer

1

OPDIV:

CDC

2

PIA Unique Identifier:

TBD

2a Name:

02/13/19

WISEWOMAN Reporting System
General Support System (GSS)
Major Application

3

The subject of this PIA is which of the following?

Minor Application (stand-alone)
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)?

8a Date of Security Authorization

No
Yes
No
Agency
Contractor
POC Title

Information Systems Security Off

POC Name

Cindy Allen

POC Organization CDC
POC Email

clallen@cdc.gov

POC Phone

770-488-5388
New
Existing
Yes
No

Mar 21, 2019

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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.

The system will now be used to document user credentials.
Otherwise, there have been no changes to the system or the
data collected.

11 Describe the purpose of the system.

The WISEWOMAN Reporting System is used by CDC funded
WISEWOMAN programs in States and tribal organizations to
submit Minimum Data Elements (MDEs) and other program
related data.

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.)

The system will maintain the email address of the awardee staff
member uploading data. MDEs include items relating to
screening and assessment, health coaching, and lifestyle
programs.
The email address is used for authentication to the system.
User credentials (emaill address and password) are maintained
temporarily until system access is no longer needed.

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?

MDEs are a set of standardized data variables maintained and
shared to ensure cardiovascular disease risk factor information
is collected for each participant. CDC does not require
awardees to collect direct participant-level identifying
information to be reported. MDEs serve the purposes of
describing, monitoring, and assessing individual and program
progress. MDEs are collected at the clinical provider level in
States and tribal organizations, among low-income, uninsured
and underinsured women ages 40 to 64. MDEs include
information about the screening site, client demographics, risk
factors and clinical assessment, and participation in health
coaching and lifestyle programs. Health outcome measures
assessed include, but are not limited to, systolic and diastolic
blood pressure readings, total cholesterol, weight, smoking
status, nutrition, and physical activity variables. The written
progress report, submitted annually, is primarily a narrative
description of the program's activities and accomplishments
and is a requirement for awardees as outlined in the Funding
Opportunity Announcement.
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

Other...

password

Other...

Other...

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

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
The primary purpose of using PII is to document user
authentication to the system.
Not applicable.

20 Describe the function of the SSN.

Not applicable.

20a Cite the legal authority to use the SSN.

Not applicable.

21

Identify legal authorities governing information use
Section 301 of the Public Health Service Act [42 U.S.C. 241]
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.

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.

OMB No. 0920-0612, Expired 12/31/2018
Yes

24 Is the PII shared with other organizations?

No
Within HHS
Other Federal
Agency/Agencies
State or Local
Agency/Agencies

Identify with whom the PII is shared or disclosed and
24a
for what purpose.

Private Sector
Describe any agreements in place that authorizes the
information sharing or disclosure (e.g. Computer
24b Matching Agreement, Memorandum of
n/a
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?

n/a
Awardees designate a data manager as a condition of the
cooperative agreement funding. The awardee data manager is
granted access to the WISEWOMAN Reporting System which
requires email address for authentication.
Voluntary
Mandatory

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Describe the method for individuals to opt-out of the
Awardee data managers may not opt-out of the collection of
collection or use of their PII. If there is no option to
27
their email address, since awardees must designate a data
object to the information collection, provide a
manager as a condition of the cooperative agreement funding.
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.
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.

Awardees will be notified by email of any major changes to the
system.

Users can contact the Centers for Disease Control and
Prevention (CDC) Information Systems Security Officer with
any concerns.
Reviews are conducted quarterly of all collected email
addresses. Those no longer involved with this information
collection are removed.
Users

Only specific CDC authorized
personnel have access to the email

Administrators
31

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

Developers
Contractors

CDC contractors have access to email
addresses for user and system support.

Others
Describe the procedures in place to determine which
Access is role based; users and contractors are granted access
32 system users (administrators, developers,
based on their roles and responsibilities with the program.
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).
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.

Role based access controls are in place to ensure the concept
of "least privilege" is implemented.

CDC staff and contractors complete annual Security Awareness
and Privacy training.

Not applicable.
Yes
No
CDC’s Records Control Schedule for Scientific and Research
Project Records, Significant and or Secondary Research
Records; authorized disposition is to maintain the data at least
eleven years, but no longer than twenty years, after the
retirement of the system.

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Administrative Controls: Access to PII is role-based and limited
to authorized staff only. Audits are conducted quarterly of PII
to ensure appropriate access. A security assessment of the
system is conducted annually.
Describe, briefly but with specificity, how the PII will
38 be secured in the system using administrative,
technical, and physical controls.

Technical Controls: All data is encrypted in transit. Access
controls (emaill address and password) are in place to restrict
access to authorized users. Continuous monitoring is in place
to detect security threats.
Physical Controls: CDC’s servers are located in a secure facility
with multiple layers of restricted access.

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

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Reviewer Questions
8

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

Answer
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

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

Jarell
Oshodi -S

Digitally signed by Jarell
HHS Senior
Oshodi -S
Agency Official
Date: 2019.03.26
for Privacy
08:57:22 -04'00'

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