ML20148M353

Case Management System Web (CMS-W) Pia

ML20148M353
Person / Time
Issue date:	05/27/2020
From:	Charles Brown NRC/OCIO
To:
References
Download: ML20148M353 (19)

Text

ADAMS ML20148M353 U.S. Nuclear Regulatory Commission Privacy Impact Assessment Designed to collect the information necessary to make relevant determinations regarding the applicability of the Privacy Act, the Paperwork Reduction Act information collection requirements, and records management requirements.

Case Management System Web (CMS-W)

Date: May 27, 2020 A. GENERAL SYSTEM INFORMATION

1. Provide a detailed description of the system:

The Case Management System (CMS-W) is an overarching subsystem hosted within BASS that provides an integrated methodology for planning, scheduling, conducting, reposting and analyzing allegations programs for the NRC. CMS-W is the umbrella title given to three separate applications;

• Enforcement Action Tracking System (EATS)- web application that allows authorized users to enter new or updated case information, query enforcement case information, report on enforcement case information, and update validation tables and user logon information.

• Allegation Management System (AMS)- database web application that is used to assist in the timely collection, storage and retrieval of key information on Allegations received by the NRC related to NRC regulated facilities. AMS was developed so that individual offices of the NRC could manage information regarding allegations related to NRC regulated facilities more effectively.

• Case Management System (CMS) - designed to assist the Office of Investigations (OI) meet their objectives by tracking all the different entities required for NRC investigations. This was previously called the Office of Investigations Management Information System (OIMIS). It has been renamed CMS.

2. What agency function does it support?

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CMS-W to tracks enforcement activities, allegations individuals and entities referred to in potential or actual investigations and matters of concern to the Office of Investigations.

3. Describe any modules or subsystems, where relevant, and their functions.

There ae no other modules or subsystems.

4. What legal authority authorizes the purchase or development of this system?

The collection of Privacy Information by applications hosted in the CMS-W environment has been authorized by the following statues:

• Privacy Act of 1974, as amended, 5 U.S.C. §552a

• Paperwork Reduction Act, as amended, 44 U.S.C. § 3501 et seq

• E-Government Act of 2002, Section 208 (Public Law 107-347)

• Records Management by Federal Agencies, 44 U.S.C. Chapter 31

5. What is the purpose of the system and the data to be collected?

CMS contains sensitive allegation, enforcement action, and investigation data involving actual or alleged criminal and civil/regulatory violations. CMS may include witness and subject names and personal identifiers as well as personal background information with address and phone numbers. These systems will contain detailed information on current and completed allegations, enforcement actions, and investigations with pre-decisional information for enforcement actions.

6. Points of

Contact:

Project Manager Office/Division/Branch Telephone Claire Robb OCIO/ITSDOD 301-287-0779 Business Project Manager Office/Division/Branch Telephone Claire Robb OCIO/ITSDOD 301-287-0779 Technical Project Manager Office/Division/Branch Telephone Natasha Harris OI 301-415-2374 ISSO Office/Division/Branch Telephone Consuella Debnam OCIO 301-287-0834 PIA Template (04-2019) Page 2 of 19

System Owner/User Office/Division/Branch Telephone Thomas Ashley OCIO/ITSDOD 301-415-0771

7. Does this privacy impact assessment (PIA) support a proposed new system or a proposed modification to an existing system?

a. New System X Modify Existing System Other

b. If modifying or making other updates to an existing system, has a PIA been prepared before?

(1) If yes, provide the date approved and ADAMS accession number.

ML13358A187 1/17/2013 (2) If yes, provide a summary of modifications or other changes to the existing system.

Updating to new PIA template

8. Do you have an NRC system Enterprise Architecture (EA)/Inventory number?

Yes

a. If yes, please provide Enterprise Architecture (EA)/Inventory number.

20050012

b. If, no, please contact EA Service Desk to get Enterprise Architecture (EA)/Inventory number.

B. INFORMATION COLLECTED AND MAINTAINED These questions are intended to define the scope of the information requested as well as the reasons for its collection. Section 1 should be completed only if information is being collected about individuals. Section 2 should be completed for information being collected that is not about individuals.

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1) INFORMATION ABOUT INDIVIDUALS

a. Does this system maintain information about individuals?

(1) If yes, identify the group(s) of individuals (e.g., Federal employees, Federal contractors, licensees, general public (provide description for general public (non-licensee workers, applicants before they are licenses etc.)).

Yes. CMS maintains personal information about Federal employees, licensees, and Federal contractors that work with nuclear materials inside and outside of NRC.

(2) IF NO, SKIP TO QUESTION B.2.

b. What information is being maintained in the system about an individual (be specific - e.g. SSN, Place of Birth, Name, Address)?

The information that resides within the three CMS-W applications (AMS, EATS and CMS) includes: Name, organization, witness and subject names, addresses, phone number, license type, certifications, title, Social Security Number, drivers license number, physical attributes (i.e., height, weight, hair color, eye color, ethnicity, scars or tattoos), citizenship, education, experience, training, and birth date.

c. Is information being collected from the subject individual?

To the greatest extent possible, collect information about an individual directly from the individual.

(1) If yes, what information is being collected?

Name Organization Education Training Certifications Experience Addresses Phone number License type Birth date Social Security Number PIA Template (04-2019) Page 4 of 19

Drivers license number Height Weight Hair Color Eye color Ethnicity Scars or tattoos Title

d. Will the information be collected from individuals who are not Federal employees?

YES (1) If yes, does the information collection have OMB approval?

N/A - OMB approval is not required for information collections during a Federal criminal investigation or prosecution, during a civil action to which the United States is a party, or during the conduct of intelligence activities. There is no OMB clearance needed (a) If yes, indicate the OMB approval number:

N/A

e. Is the information being collected from existing NRC files, databases, or systems?

Yes.

(1) If yes, identify the files/databases/systems and the information being collected.

The license information, witness/subject names, addresses, phone numbers, social security numbers, and physical attributes collected by the CMS-W application will come from existing hardcopy files (the information will be manually entered into the system)

f. Is the information being collected from external sources (any source outside of the NRC)?

Yes.

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(1) If yes, identify the source and what type of information is being collected?

The background information collected about individuals by CMS-W, including criminal history and individual business information, is from a background investigation with information obtained through the National Crime Information Center (NCIC). Also, through public records such as credit checks, property records, investment records, and Dun and Bradstreet Reports. These databases however, do originally collect their information from the subject individual and require periodic updates to verify the accuracy of the information.

g. How will information not collected directly from the subject individual be verified as current, accurate, and complete?

The individual will be pulled from other NRC databases and files.

Information will also be pulled through public records such as credit checks, property records, investment records, and Dun and Bradstreet Reports

h. How will the information be collected (e.g. form, data transfer)?

CMS-W will pull information from License files and from Replacement Reactor Program System (RRPS) which resides in BASS.

2. INFORMATION NOT ABOUT INDIVIDUALS

a. Will information not about individuals be maintained in this system?

No (1) If yes, identify the type of information (be specific).

N/A

b. What is the source of this information? Will it come from internal agency sources and/or external sources? Explain in detail.

N/A C. USES OF SYSTEM AND INFORMATION These questions will identify the use of the information and the accuracy of the data being used.

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1. Describe all uses made of the data in this system.

The system data collected by CMS-W applications will be used for the following activities:

Track individuals Track licensees and licensed materials Contact NRC personnel, as well as external personnel, involved in the use of nuclear materials Perform background checks and verification of personnel qualifications Verify employer information and personnel certifications Create, edit, track, and resolve allegations in the CMS-W application

2. Is the use of the data both relevant and necessary for the purpose for which the system is designed?

Yes

3. Who will ensure the proper use of the data in this system?

The BASS Information System Security Officer (ISSO) and the Application ISSO for each application in the BASS environment will be individually responsible for ensuring that the data collected by each application is used appropriately.

4. Are the data elements described in detail and documented?

a. If yes, what is the name of the document that contains this information and where is it located?

Yes. Privacy data elements collected by BASS applications are described at a high level in the BASS CMS-W System Security Plan (SSP) and in more detail in respective BASS Application administrator guides and user documentation for each application. These documents include the Case Management User Manual

5. Will the system derive new data or create previously unavailable data about an individual through aggregation from the information collected?

Some of the PII data stored in CMS-W will be encrypted in the database. Yes, the data may be used by OI personnel (or NRC personnel) for investigation purposes and when printed as a report, classified as aggregation of data. This information will be stored in locked cabinets if/when it is created as a report.

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Derived data is obtained from a source for one purpose and then the original information is used to deduce/infer a separate and distinct bit of information that is aggregated to form information that is usually different from the source information.

Aggregation of data is the taking of various data elements and then turning it into a composite of all the data to form another type of data (i.e. tables or data arrays).

a. If yes, how will aggregated data be maintained, filed, and utilized?

All output from CMS-W applications will be stored in locked file cabinets and available to authorized personnel only.

b. How will aggregated data be validated for relevance and accuracy?

This information will be validated for relevancy and accuracy by the cross-reference of the current data provided by the CMS-W applications.

c. If data are consolidated, what controls protect it from unauthorized access, use, or modification?

Consolidated data that is output in a report from the CMS-W applications are protected by physical access controls. This data is stored in locked file cabinets and only accessible to authorized individuals. Aggregated data will be created on an as-needed basis and will only be accessible to authorized personnel who have signed the necessary Rules of Behavior (ROB) documentation and have the appropriate clearance.

6. How will data be retrieved from the system? Will data be retrieved by an individuals name or personal identifier (name, unique number or symbol)? (Be specific.)

Yes, by individuals name or personal identifier

a. If yes, explain, and list the identifiers that will be used to retrieve information on the individual.

Data will be retrieved from the CMS-W databases using queries and data output created by CMS applications. Data can be retrieved by an individuals name or personal identifier and will be viewed on the system or printed out by authorized personnel.

7. Has a Privacy Act System of Records Notice (SORN) been published in the Federal Register?

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Yes

a. If Yes, provide name of SORN and location in the Federal Register.

CMS-W is covered under the Privacy Act system of records NRC 23, Office of Investigations Indices, Files and Associated Records.

8. If the information system is being modified, will the SORN(s) require amendment or revision?

No

9. Will this system provide the capability to identify, locate, and monitor (e.g.,

track, observe) individuals?

a. If yes, explain.

Yes. Monitoring information will be provided by the CMS-W applications.

The applications will store information that will include individual licenses, licensees, radioactive material, and allegation data, witnesses, and subjects. This data will provide monitoring support, allowing authorized application users to monitor and track individuals.

(1) What controls will be used to prevent unauthorized monitoring?

CMS-W applications will use access controls, including user rights and privilege enforcement through access control lists and ROBs acknowledgement documentation, to prevent unauthorized monitoring of personal information.

10. List the report(s) that will be produced from this system.

CMS-W applications reports:

CASE REPORTS Status Report Cases Initiated Open Cases Trend Report Open Cases Detail Trend Report Closed Cases Investigations Referred to DOJ By Allegation Method By Allegation Source By Received Date PIA Template (04-2019) Page 9 of 19

OI Violation Case Statistics Case Status ACTIVITY REPORTS Law Enforcement Tracking and Coordination Activities Chronology ISR Report Agent Activities Activity Certification CRIMINAL REPORTS Referrals Indictments Convictions Sentencing Declinations CIVIL REPORTS Referrals Filings Judgments Settlements Recoveries Declinations Annual Case Count Summary Performance Measure Performance Measure Annual Performance Measure Material Performance Measure High Level Waste Performance Measure Reactors Performance Measure New Reactors Case Count ALL Case Count Reactors Case Count Materials Case Count High Level Waste Case Count H & I Cases Case Count NON H & I Cases OI National Performance STATS SOL REPORT LEAP REPORTS Leap Report Pay Year Region 1 Pay Period Region 2 Pay Period PIA Template (04-2019) Page 10 of 19

Region 3 Pay Period Region 4 Pay Period Region HQ Pay Period Manpower Report Non Case Specific Investigative to the Mission Case Specific Investigative Activities Miscellaneous/Other Investigative Activities Records Retention Inactive Cases Recently Approved Docs.

Annual Report Details Annual Report Statistics Criminal Cases Performance Measures - Stats Performance Measures - Details Deadfiles Summary Sheet; Licensee History Regional Weekly Status Data Compilation Repot; Escalated Enforcement Actions Timeliness Report Statistical Summary Report Ad-Hoc Report

a. What are the reports used for?

These reports provide information used for investigation purposes.

b. Who has access to these reports?

CMS administrators, OI directors, Special Agents in Charge, assistant directors, investigation assistants, senior agents, and agents may have access to CMS information reports.

D. ACCESS TO DATA

1. Which NRC office(s) will have access to the data in the system?

Data in CMS-W is accessed by OI and OI offices in the regions.

(1) For what purpose?

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OI offices will access PII data and physical attributes on entities for investigation purposed.

(2) Will access be limited?

Access to CMS-W is limited to authorized personnel only. This is also enforced through access controls. The applications track users by LAN ID and date who add or update data. Audit trails will be reviewed periodically to minimize the impact of misuse.

2. Will other NRC systems share data with or have access to the data in the system?

(1) If yes, identify the system(s).

No. Only CMS-W will share data between the three applications (EATS, AMS and CMS)

(2) How will the data be transmitted or disclosed?

Data will be transmitted electronically on the NRC networks behind the NRC firewall. All data transfer will be internal and, on the infrastructure, only.

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3. Will external agencies/organizations/public have access to the data in the system?

No.

(1) If yes, who?

N/A (2) Will access be limited?

N/A (3) What data will be accessible and for what purpose/use?

N/A (4) How will the data be transmitted or disclosed?

N/A E. RECORDS AND INFORMATION MANAGEMENT (RIM) - RETENTION AND DISPOSAL The National Archives and Records Administration (NARA), in collaboration with federal agencies, approves whether records are temporary (eligible at some point for destruction/deletion because they no longer have business value) or permanent (eligible at some point to be transferred to the National Archives because of historical or evidential significance). These determinations are made through records retention schedules and NARA statutes (44 U.S.C., 36 CFR). Under 36 CFR 1234.10, agencies are required to establish procedures for addressing records management requirements, including recordkeeping requirements and disposition, before approving new electronic information systems or enhancements to existing systems. The following question is intended to determine whether the records and data/information in the system have approved records retention schedule and disposition instructions, whether the system incorporates Records and Information Management (RIM) and NARAs Universal Electronic Records Management (ERM) requirements, and if a strategy is needed to ensure compliance.

1) Can you map this system to an applicable retention schedule in NRCs Comprehensive Records Disposition Schedule(NUREG-0910), or NARAs General Records Schedules?

No. As an umbrella it is composed of 3 separate applications: Enforcement Action Tracking System (EATS); Allegation Management System (AMS); and Case Management System (CMS).

Most of the data/information in the system is covered by several schedules for these applications. However, some records/data in the system may need to be scheduled as PIA Template (04-2019) Page 13 of 19

they may not follow under any identified schedule; therefore, NRC records personnel will need to work with staff to develop a records retention and disposition schedule for records created or maintained. Until the approval of such schedule, these records and information are Permanent. Their willful disposal or concealment (and related offenses) is punishable by fine or imprisonment, according to 18 U.S.C., Chapter 101, and Section 2071. Implementation of retention schedules is mandatory under 44 U.S. 3303a (d), and although this does not prevent further development of the project, retention functionality or a manual process must be incorporated to meet this requirement.

a. If yes, please cite the schedule number, approved disposition, and describe how this is accomplished (then move to F.1).

• For example, will the records or a composite thereof be deleted once they reach their approved retention or exported to an approved file format for transfer to the National Archives based on their approved disposition?

b. If no, please contact the Records and Information Management (RIM) staff at ITIMPolicy.Resource@nrc.gov.

F. TECHNICAL ACCESS AND SECURITY

1. Describe the security controls used to limit access to the system (e.g.,

passwords).

CMS-W is accessed by user account and password verification assigned by the application administrators. Additionally, access to varying features of CMS-W is restricted by user roles. The BASS administrators and database administrators have high-level access to the CMS-W. Appropriate access must be requested by the user through project managers and application owners and then be granted by CMS-W administrators to ensure access is limited to authorized users only.

2. What controls will prevent the misuse (e.g., unauthorized browsing) of system data by those having access?

Access controls and identification and authentication controls are in place.

Specifically, account management and access enforcement are implemented to prevent the misuse of system data. Only authorized users who have been approved by project managers and applications owners and reviewed by CMS-W administrators are granted access. Furthermore, identification and authentication controls are used to enforce unique ID requirements and periodic password changes.

3. Are the criteria, procedures, controls, and responsibilities regarding access to the system documented?

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(1) If yes, where?

Yes. Criteria, procedures, controls, and responsibilities for CMS-W are documented in the CMS-W SSP and in the respective application user and administrator guides found in the BASS document repository.

4. Will the system be accessed or operated at more than one location (site)?

Yes

a. If yes, how will consistent use be maintained at all sites?

The CMS-W environment is located at NRC HQ. All users using CMS-W are behind the NRC firewall and on the NRC network. Consistent use will be maintained from all sites via agency approved methods (e.g., VPN, Citrix, mobility platforms). Because users will need to be on the NRC LAN to access CMS access authorization enforcement is facilitated.

5. Which user groups (e.g., system administrators, project managers, etc.)

have access to the system?

OI has access to CMS-W

6. Will a record of their access to the system be captured?

a. If yes, what will be collected?

Yes. CMS-W captures time of access and what changes have been made by which user for applications.

7. Will contractors be involved with the design, development, or maintenance of the system?

YES If yes, and if this system will maintain information about individuals, ensure Privacy Act and/or PII contract clauses are inserted in their contracts.

• FAR clause 52.224-1 and FAR clause 52.224-2 should be referenced in all contracts, when the design, development, or operation of a system of records on individuals is required to accomplish an agency function.

• PII clause, Contractor Responsibility for Protecting Personally Identifiable Information (June 2009), in all contracts, purchase orders, and orders against other agency contracts and interagency agreements that involve contractor access to NRC owned or controlled PII. - YES

8. What auditing measures and technical safeguards are in place to prevent misuse of data?

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Auditing measures in place include record keeping of system access, application logs of sign on and sign off activities, records of additions and deletions to databases, and Unix/Linux logs for administrator access. Technical safeguards include access authorization enforcement, periodic password changes, and account reviews.

9. Is the data secured in accordance with FISMA requirements?

Yes.

a. If yes, when was Certification and Accreditation last completed?

CMS-W is under BASS which was recommended to be placed into the systems ongoing authorization program on January 7, 2016 (ML15309A762).

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PRIVACY IMPACT ASSESSMENT REVIEW/APPROVAL (For Use by OCIO/GEMS/ISB Staff)

System Name: Case Management System (CMS-W)

Submitting Office: OCIO A. PRIVACY ACT APPLICABILITY REVIEW Privacy Act is not applicable.

X Privacy Act is applicable.

Comments:

CMS-W is covered under the Privacy Act system of records NRC 23, Office of Investigations Indices, Files and Associated Records.

Reviewers Name Title Date Sally A. Hardy Privacy Officer 06/11/2020 B. INFORMATION COLLECTION APPLICABILITY DETERMINATION X No OMB clearance is needed.

OMB clearance is needed.

Currently has OMB Clearance. Clearance No.

Comments:

OMB approval is not needed for information collections made:

• During the conduct of a Federal criminal investigation or prosecution, or during the disposition of a particular criminal matter;

• During the conduct of a civil action to which the United States or any official or agency thereof is a party, or during the conduct of an administrative action, investigation, or audit involving an agency against specific individuals or entities However, the requirements of the Paperwork Reduction would apply during the conduct of general investigations or audits undertaken with reference to a category of individuals or entities such as a class of licensees or an entire industry.

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Reviewers Name Title Date David Cullison Agency Clearance Officer 6/8/2020 C. RECORDS RETENTION AND DISPOSAL SCHEDULE DETERMINATION No record schedule required.

X Additional information is needed to complete assessment.

X Needs to be scheduled.

Existing records retention and disposition schedule covers the system - no modifications needed.

Comments:

Most of the data/information in the system is covered by several schedules for these applications. However, some records/data in the system may need to be scheduled as they may not follow under any identified schedule; therefore, NRC records personnel will need to work with staff to develop a records retention and disposition schedule for records created or maintained. Until the approval of such schedule, these records and information are Permanent.

Their willful disposal or concealment (and related offenses) is punishable by fine or imprisonment, according to 18 U.S.C., Chapter 101, and Section 2071. Implementation of retention schedules is mandatory under 44 U.S. 3303a (d), and although this does not prevent further development of the project, retention functionality or a manual process must be incorporated to meet this requirement.

Reviewers Name Title Date Marna B. Dove Sr. Program Analyst, Electronic Records Manager 06/05/2020 D. BRANCH CHIEF REVIEW AND CONCURRENCE This IT system does not collect, maintain, or disseminate information in identifiable form from or about members of the public.

X This IT system does collect, maintain, or disseminate information in identifiable form from or about members of the public.

I concur in the Privacy Act, Information Collections, and Records Management reviews:

/RA/ Date June 17, 2020 Clarissa L. Evans Brown, Chief Computer Security Branch Governance & Enterprise Management Services Division Office of the Chief Information Officer PIA Template (04-2019) Page 18 of 19

TRANSMITTAL OF PRIVACY IMPACT ASSESSMENT/

PRIVACY IMPACT ASSESSMENT REVIEW RESULTS TO: Thomas Asley, OCIO Name of System: Case Management System (CMS-W)

Date CSB received PIA for review: Date CSB completed PIA review:

May 27, 2020 June 11, 2020 Noted Issues:

Clarissa L. Evans Brown, Chief Signature/Date:

Computer Security Branch Governance & Enterprise Management /RA/ June 17, 2020 Services Division Office of the Chief Information Officer Copies of this PIA will be provided to:

Tom Ashley, Director IT Services Development & Operation Division Office of the Chief Information Officer Jonathan Feibus Chief Information Security Officer (CISO)

Governance & Enterprise Management Services Division Office of the Chief Information Officer PIA Template (04-2019) Page 19 of 19