ML22210A135

Government Retirement & Benefits (Grb) Platform Privacy Impact Assessment

ML22210A135
Person / Time
Issue date:	09/15/2022
From:	Natalya Bobryakova, Benjamin Partlow Governance & Enterprise Management Services Division
To:
Bobryakova N
References
Download: ML22210A135 (15)

Text

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.

Please do not enter the PIA document into ADAMS. An ADAMS accession number will be assigned through the e-Concurrence system which will be handled by the Privacy Team.

Government Retirement & Benefits (GRB) Platform Date: June 30, 2022.

A. GENERAL SYSTEM INFORMATION

1. Provide a detailed description of the system:

GRB is a web-based Software-as-a-Service (SaaS) Federal retirement and benefits solution provided to the Nuclear Regulatory Commission (NRC) by Government Retirement & Benefits, Inc. The NRC benefit specialists use GRB to prepare service histories and create retirement estimate reports as well as other related estimate reports. NRC employees use GRB to access and update employee benefits requests.

2. What agency function does it support?

GRB supports the Office of Chief Human Capital Officer (OCHCO) administration of the benefit programs, including the retirement processing.

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

GRB does not contain additional modules, subsystems, or functions beyond its primary function.

a. Provide Agencywide Documents Access and Management System (ADAMS) ML numbers for all Privacy Impact Assessments or Privacy Threshold Analysis for each subsystem.

N/A.

4. What legal authority authorizes the purchase or development of this system? ? (What law, regulation, or Executive Order authorizes the collection and maintenance of the information necessary to meet an official program mission or goal? NRC internal policy is not a legal authority.)

5 United States Code (U.S.C.) Titles 8415 and 83397.

PIA Template (07-2022)

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

Calculation of Federal employees retirement benefit estimates, disability and death benefit estimates, Service Computation Date calculation, Military/Civilian deposit and redeposit requirements, and retirement plan determination.

6. Points of

Contact:

(Do not adjust or change table fields. Annotate N/A if unknown. If multiple individuals need to be added in a certain field, please add lines where necessary.)

Project Manager Office/Division/Branch Telephone Sandra Labissiere OCHCO/ADHROP/WMBB 301-287-0551 Business Project Manager Office/Division/Branch Telephone Susan Salter OCHCO/ADHROP 301-287-0545 Technical Project Manager Office/Division/Branch Telephone John Shea OCHCO/HCAB 301-415-0246 Executive Sponsor Office/Division/Branch Telephone Susan Salter OCHCO/ADHROP 301-287-0545 ISSO Office/Division/Branch Telephone Natalya Bobryakova OCIO/ITSDOD/SOB/IAT 301-287-0671 System Owner/User Office/Division/Branch Telephone N/A N/A N/A

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

a. New System Modify Existing System X Other

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

Yes.

PIA Template (07-2022)

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

September 14, 2020; ADAMS ML20156A190.

(2) If yes, provide a summary of modifications or other changes to the existing system.

Update to the latest template and updates to Point of Contact (POC) list and to Question F.4 (GRB is not accessed at multiple sites).

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

Yes.

a. If yes, please provide the EA/Inventory number.

20120006.

b. If, no, please contact EA Service Desk to get the 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.

1. INFORMATION ABOUT INDIVIDUALS

a. Does this system maintain information about individuals?

Yes.

(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.)).

Federal employees and, if applicable, spouses, dependents, and designated beneficiaries of Federal employees.

PIA Template (07-2022)

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

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

Information about Federal employees: name, SSN, date of birth, marital status, gender, spouses name, spouses social security number, spouses date of birth, spouses gender, number of dependent children, address, telephone numbers, email addresses, banking information, salary, retirement benefits, and military service.

Information about spouses, dependents, and designated beneficiaries of a Federal employee, if applicable: name, SSN, date of birth, banking information for direct deposit.

c. Is information being collected from the subject individual? ? (To the greatest extent possible, collect information about an individual directly from the individual.)

Yes.

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

Information collected from Federal employees: name, SSN, date of birth, marital status, gender, spouses name, spouses social security number, spouses gender, number of dependent children, address, telephone numbers, email addresses, banking information for direct deposit, military service.

Benefits information collected (in the Application for Death Benefits for example) include applicants name, SSN, date of birth, banking information for direct deposit; spouses (including former spouses) name; dependent childs name, SSN, and date of birth.

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

Yes. Benefits information (within the Application for Death Benefits, the OPM Standard Form 3104A) is collected from individuals who are not Federal employees.

(1) If yes, does the information collection have the Office of Management and Budgets (OMB) approval?

Yes.

(a) If yes, indicate the OMB approval number:

OMB number 3206-0172. Application for Death Benefits (FERS)/Documentation and Elections in Support of PIA Template (07-2022)

Application for Death Benefits when Deceased was an Employee at the Time of Death (FERS).

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.

Data is imported from Federal Personnel Payroll System (FPPS) operated by Department of interior (DOI) and Interior Business Center (IBC).

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

No.

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

N/A.

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

Employees and benefit specialists verify the information for accuracy and completeness.

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

GRB is populated with information entered directly by employees and via electronic file transfer from FPPS.

In the event of a death in service, the benefit specialist collects information from the survivors and then manually enters the information in GRB to retrieve the applicable death benefit calculation and forms.

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.

PIA Template (07-2022)

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.

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

Calculation of Federal employees retirement benefit estimate, death benefit estimate, Service Computation Date calculation, deposit, and redeposit requirements, and retirement plan determination.

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?

Proper use of GRB will be ensured by OCHCO Professionals and System Administrators.

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

Yes.

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

GRB-Saas_RBS Data Dictionary located on the OCHCO G Drive Restricted Access for OCHCO only.

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

Yes. GRB does create and/or aggregate new data about the individual and dependents to calculate retirement benefits and dates.

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).

PIA Template (07-2022)

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

Data is housed in the GRB system.

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

The data is verified by HR specialists and employees.

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

Role-based access controls are implemented during the initial user account setup, limiting user access and privilege based on their respective roles. Access to the system is only granted once users have been authenticated through Identity, Credential, and Access Management (ICAM) services, preventing unauthorized access to and use of the data.

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.

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

Data will be retrieved from the system via the Employees Name.

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

Yes.

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

Government-wide SORN - OPM-GOVT-1, General Personnel 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?

No.

a. If yes, explain.

N/A.

PIA Template (07-2022)

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

N/A.

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

Retirement benefit estimate reports, Death benefit estimate reports, Service computation date reports, Military/Civilian deposit and redeposit reports.

a. What are the reports used for?

Estimating Federal employee retirement benefits and retirement contributions owed.

b. Who has access to these reports?

Universal access is limited to Human Resources (HR) specialists, managers, and system administrators. Additionally, NRC employees may generate and access reports that contain only their own information.

D. ACCESS TO DATA

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

NRC OCHCO Professionals and/or Contractor access and administer all employee data.

All NRC employees may access the system to review their own data.

(1) For what purpose?

NRC OCHCO Professionals and/or Contractors provide estimated retirement benefits reports to NRC employees.

Individual NRC employees may generate retirement benefits reports for themselves.

(2) Will access be limited?

Yes, universal access is limited to NRC Benefits Specialists and system administrators.

User-specific access is limited to ones own data.

PIA Template (07-2022)

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

No.

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

N/A.

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

N/A.

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

Yes.

(1) If yes, who?

Government Retirement & Benefits, Inc. (GRB).

(2) Will access be limited?

Access will be limited to NRC users and individuals providing technical assistance at GRB, Inc.

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

NRC users can access GRB to update and verify their own records and benefits requests.

Individuals providing technical assistance at Government & Retirement Benefits, Inc. can access NRC data within the system to facilitate the resolution of technical issues and ensure the platforms functionality.

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

NRC users access GRBs application online (https://platform.grbinc.com/)

through a secure Internet connection.

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 United States Code (U.S.C.), 36 Code of Federation PIA Template (07-2022)

Regulations (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 and NARAs Universal Electronic records management 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 (GRS)?

Yes.

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

GRS 2.5, item 020: Individual employee separation files.

It includes records not included in separating employees Electronic Official Personnel Folder (eOPF), documenting individual employees transfer to another Federal agency of office or voluntary or involuntary separation from career, disability, early retirement, death, political appointment service, and legal and financial obligations of government.

Retention is Temporary:

Destroy 1 year after date of separation or transfer, but longer retention is authorized if required for business use.

Additional Suggested Retention:

GRS 2.5, item 051: Phased retirement individual case files.

Case files of individual employee participation in phased retirement.

Retention is Temporary:

Destroy 1 year after employee participation concludes or the employee retires, but longer retention is authorized if required for business use.

(These records could be retained with the retirement file and should be retained as the GRS 2.5 item as above).

b. If no, please contact the 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).

Role-based access is limited through use of Agency ICAM authentication services and makes use of NRC-specific account, passwords, and multi-factor PIA Template (07-2022) authentication. Only users whose official duties require universal-record access are so assigned.

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

Role assignment and ICAM authentication services controls will be utilized to prevent unauthorized access to the system.

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

Yes.

(1) If yes, where?

Documentation related to access has been provided by GRB and is stored on the G Drive with limited access for OCHCO only.

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

No.

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

N/A.

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

have access to the system?

The OCHCO Professionals and System Administrators groups access the universal system. Members of NRCs All Employees group can access their own records.

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

Yes.

a. If yes, what will be collected?

Access to the system will be logged and collecting the following event data types:

User Logon/Logoff Account, Management Object, Access, Policy Change, Privilege Use Process, Tracking System, Events, Information, PIA Template (07-2022)

Date/Time, Component Event, Type, User or Process ID Success or Failure Result.

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

Yes. GRB, Inc. administrators will be involved in the troubleshooting of system related issues.

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

Federal Acquisition Regulation (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.

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

Audit records are reviewed weekly for suspicious activity and violations and findings are reported to the Chief Information Officer (CIO) or assignee.

Violations cause alert messages to be sent to administrators. Audit review will be increased during time of high risk.

9. Is the data secured in accordance with the Federal Information Security Management Act (FISMA) requirements?

Yes.

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

And what FISMA system is this part of?

GRB is listed in the OCHCO External Services (ES) Authorization to Operate and has been authorized by NRC as of December 20, 2018 (ML18354A944).

b. If no, is the Certification and Accreditation in progress and what is the expected completion date? And what FISMA system is this planned to be a part of?

N/A.

PIA Template (07-2022)

c. If no, please note that the authorization status must be reported to the Chief Information Security Officer (CISO) and Computer Security Offices (CSOs) Point of Contact (POC) via e-mail quarterly to ensure the authorization remains on track.

N/A.

PIA Template (07-2022)

PRIVACY IMPACT ASSESSMENT REVIEW/APPROVAL (For Use by OCIO/GEMSD/CSB Staff)

System Name: Government Retirement & Benefits (GRB) Platform Submitting Office: Office of the Chief Human Capital Officer A. PRIVACY ACT APPLICABILITY REVIEW Privacy Act is not applicable.

X Privacy Act is applicable.

Comments:

The information is covered by government-wide system of records notice - OPM GOVT General Personnel Records.

Reviewers Name Title Signed by Hardy, Sally on 08/11/22 Privacy Officer B. INFORMATION COLLECTION APPLICABILITY DETERMINATION No OMB clearance is needed.

OMB clearance is needed.

X Currently has OMB Clearance. Clearance No. 3206-0172.

Comments:

The OPM clearance covers the Application for Death Benefits (FERS)/Documentation and Elections in Support of Application for Death Benefits when Deceased was an Employee at the Time of Death (FERS).

Reviewers Name Title Signed by Cullison, David on 08/10/22 Agency Clearance Officer PIA Template (07-2022)

C. RECORDS RETENTION AND DISPOSAL SCHEDULE DETERMINATION No record schedule required.

Additional information is needed to complete assessment.

Needs to be scheduled.

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

Comments:

Reviewers Name Title Signed by Dove, Marna Sr. Program Analyst, Electronic Records on 08/10/22 Manager 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:

Signed by Partlow, Benjamin on 09/15/22 Acting Chief Cyber Security Branch Governance and Enterprise Management Services Division Office of the Chief Information Officer PIA Template (07-2022)

TRANSMITTAL OF PRIVACY IMPACT ASSESSMENT/

PRIVACY IMPACT ASSESSMENT REVIEW RESULTS TO: Susan Salter, Office of the Chief Human Capital Officer Name of System: Government Retirement & Benefits (GRB) Platform Date CSB received PIA for review: Date CSB completed PIA review:

June 30, 2022 August 11, 2022 Noted Issues:

Benjamin Partlow Acting Chief Signature/Date:

Cyber Security Branch Governance and Enterprise Management Signed by Partlow, Benjamin Services Division on 09/15/22 Office of the Chief Information Officer Copies of this PIA will be provided to:

Thomas G. Ashley, Jr.

Director IT Services Development and Operations Division Office of the Chief Information Officer Garo Nalabandian Acting Chief Information Security Officer (CISO)

Office of the Chief Information Officer PIA Template (07-2022)