ML23094A278

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Foiaxpress Privacy Impact Assessment
ML23094A278
Person / Time
Issue date: 03/31/2023
From: Colbert L
NRC/OCIO/GEMSD/FLICB
To:
Colbert L
References
Download: ML23094A278 (21)


Text

U.S. Nuclear Regulatory Commission Privacy Impact Assessment FOIAXpress OCIO Version 2 3/31/2023 Instruction Notes:

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 Template Version 2.0 (03/2023)

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 Document Revision History Date Version PIA Name/Description Author 3/31/2023 2.0 FOIAXpress Initial Release Lezlie Colbert

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 Table of Contents 1

Description 1

2 Authorities and Other Requirements 3

3 Characterization of the Information 4

4 Data Security 8

5 Privacy Act Determination 11 6

Records and Information Management-Retention and Disposal 12 7

Paperwork Reduction Act 15 8

Privacy Act Determination 16 9

OMB Clearance Determination 17 10 Records Retention and Disposal Schedule Determination 18 11 Branch Chief Review and Concurrence 19

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 1 The agency is subject to the requirements of the E-Government Act and is committed to identifying and addressing privacy risks whenever it develops or makes changes to its information systems. The questions below help determine any privacy risks related to the E-Government Act or later guidance by the Office of Management and Budget (OMB) and the National Institute of Standards and Technology (NIST).

Name/System/Subsystem/Service Name: FOIAXpress (subsystem of BASS).

Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) Cloud.

Date Submitted for review/approval: 3/31/2023.

Note: When completing this PIA do not include any information that would raise security concerns or prevent this document from being made publicly available.

1 Description 1.1 Provide the description of the system/subsystem, technology (i.e., Microsoft Products), program, or other data collections (hereinafter referred to as project).

Explain the reason the project is being created.

FOIAXpress supports the NRC Freedom of Information Act/Privacy Act (FOIA/PA) Program.

FOIAXpress is a cloud-based application managed by Opexus. The SaaS application can be securely accessed online through AINS FedRAMP, DISA Level II-certified cloud. FOIAXpress offers a centralized location for receiving Freedom of Information Act (FOIA) and Privacy Act (PA) requests, delivering responsive records, and communicating with requesters. The FOIAXpress application includes the Electronic Document Review (EDR), which will speed the review and redaction process by leveraging technology to quickly filter, de-duplicate, rank, and categorize responsive content in large volumes of emails, attachments, as well as other file types. FOIAXpress is also a workflow system and repository that will streamline FOIA request tracking and management to facilitate greater requester interaction. FOIAXpress also includes a records retention module that can quickly and easily remove case file data that are beyond their record retention period.

FOIAXpress stores FOIA requests and appeals, responsive records, notes, and other information related to the processing of a FOIA/PA request, appeal, or consultation from another federal agency. Members of the NRC FOIA team and other personnel with system access with a need to know, can assign, track, and monitor tasks; calculate fees; generate reports; and store responsive records. These functions streamline and help automate business processes associated with NRC FOIA responsibilities.

The FOIAXpress system includes the Public Access Link (PAL), a web portal that allows members of the public to electronically submit and track the status of their FOIA or PA requests.

PAL has a payment connector, Pay.gov, which enables the NRC to accept online payments for FOIA processing. Individuals can create a PAL account with a unique login ID and password and submit requests for information electronically through a link. Requesters may also attach supporting documentation to their request and directly download the documents through PAL

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 2 if/when the documents are released by the NRC. The PAL portion of FOIAXpress is publicly accessible online; however, requesters do not have the ability to directly access the FOIAXpress system or other data stored in the system. Only authorized NRC FOIA personnel have access to the data supplied by requesters via FOIAXpress.

Please mark appropriate response below if your project/system will involve the following:

PowerApps Public Website Dashboard Internal Website SharePoint None Other Remote, Shared Data Storage and Processing (cloud computing service) 1.2 Does this privacy impact assessment (PIA) support a proposed new project, proposed modification to an existing project, or other situation? Select options that best apply in table below.

Mark appropriate response.

Status Options

New system/project

Modification to an existing system/project.

If modifying or making other updates to an existing system/project, provide the ADAMS ML of the existing PIA and describe the modification.

The original PIA was submitted 7/13/2022 for FOIAXpress, this version updates the information.

Annual Review If making minor edits to an existing system/project, briefly describe the changes below.

Other (explain)

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 3 1.3 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 System Owner/Data Owner/Steward ISSO Business Project Manager Technical Project Manager Executive Sponsor Name Karen Danoff Stephanie Blaney Consuella Debnam Lezlie Colbert Lezlie Colbert N/A Office/

Division/

Branch OCIO/GEMS/

FLICB/FT OCIO/GEMS/

FLICB/

OCIO/GEMS/

CSB/IAT OCIO/GEMS/

FLICB/FT OCIO/GEMS/

FLICB/FT Telephone 301-415-5072 301-415-6975 301-287-0834 301-415-3722 301-415-3722 2 Authorities and Other Requirements 2.1 What specific legal authorities and/or agreements permit the collection of information for the project?

Provide all statutory and regulatory authorities for operating the project, including the authority to collect the information; NRC internal policy is not a legal authority. Please mark appropriate response in table below.

Mark with an X on all that apply.

Authority Citation/Reference

Statute

1. Freedom of Information Act (5 U.S.C. § 552, as Amended by Public Law No. 104-231, 110 Stat.

3048) and the FOIA Improvement Act of 2016 (P.L.

114-185 (June 30, 2016)) Memorandum for the Heads of Executive Departments and Agencies:

Open Government Directive, M10-06 (December 8, 2009)

2. Clinger Cohen (40 U.S.C. 11318)
3. The Economy Act (31 U.S.C. § 1535, 1536)

Executive Order

Federal Regulation Production or Disclosure of Material or Information, 28 C.F.R. Part 16 10 CFR Part 9, Subpart A: Freedom of Information Act Regulations 10 CFR Part 9, Subpart B: Privacy Act Regulations

Memorandum of Understanding/

Agreement

Other (summarize and provide a copy of relevant portion)

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 4 2.2 Explain how the information will be used under the authority listed above (i.e., enroll employees in a subsidies program to provide subsidy payment).

The FOIA allows members of the public to request access to records from federal agencies to learn about their government. Federal agencies are required to disclose any information requested under the FOIA unless it falls under one of nine exemptions which protect interests such as personal privacy, national security, privileged, commercial, financial and law enforcement information. The Privacy Act requests allow members of the public to request information held about themselves by the Federal Government. The FOIAXpress and PAL applications, which are used by the NRC to track FOIA and Privacy Act requests, collects Personally Identifiable Information (PII) from an individual Privacy Act requester for the purpose of identifying records contained within a NRC System of Records pertaining to that requester.

FOIA requesters are required to provide their home address and/or email address for the NRC FOIA team to respond directly to the requester. Additionally, for Privacy Act requests and Privacy Act amendments, to authenticate the individual requesters identity, the NRC may collect the social security number and date of birth. For either a FOIA or Privacy Act request, individuals can either create an account in PAL to request copies of records or send the FOIA team an email to FOIA.Resource@nrc.gov. Regardless of how the NRC FOIA team receives the FOIA or PA request, the requesters name, contact information, and any attached ID verification documents will also be entered in their requester profile in FOIAXpress. Requester profiles can only be viewed by the FOIAXpress authorized users who have a need to know.

Once the FOIA team receives the FOIA or PA request, it is assigned to a FOIA specialist who tasks the appropriate program office(s) so that they may conduct a search of their systems to identify any potentially responsive records.

If the project collects Social Security numbers, state why this is necessary and how it will be used.

The individual making the FOIA/PA request is required to provide NRC with their name and contact information, such as home address, business name, business address, home phone number, business phone number, cell phone number, fax number, home e-mail address, or business e-mail address. The person making the FOIA/PA request may voluntarily provide their social security number or date of birth as a means of identity verification, but it is not required. FOIA/PA team members redact the Personal Identifiable Information (PII) on the Incoming request to reduce the sensitivity of the information when sharing the incoming request with NRC office(s) who are tasked to locate responsive records to the FOIA/PA request.

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 5 3 Characterization of the Information In the table below, mark the categories of individuals for whom information is collected.

Category of individual

Federal employees (not in their official capacity)

Contractors (not in their official capacity)

Members of the Public

Licensees

Other In the table below, is a list of the most common types of PII collected. Mark all PII that is collected and stored by the project/system. If there is additional PII not defined in the table below, a comprehensive listing of PII is provided for further reference in ADAMS at the following link: PII Reference Table 2023.

Categories of Information

Name

Resume or curriculum vitae

Date of Birth (not required)

Driver's License Number (not required)

Country of Birth

License Plate Number

Citizenship

Passport number (not required)

Nationality

Relatives Information

Race

Taxpayer Identification Number

Home Address

Credit/Debit Card Number

Social Security number (Truncated or Partial) not required

Medical/health information

Gender

Alien Registration Number

Ethnicity

Professional/personal references

Spouse Information

Criminal History

Personal e-mail address

Biometric identifiers (facial images, fingerprints, iris scans)

Personal Bank Account Number

Emergency contact e.g., a third party to contact in case of an emergency

Personal Mobile Number

Accommodation/disabilities information

Marital Status

Children Information

Mother's Maiden Name

Other Work Address Work email Fax number Employer Identification Number

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 6 3.1 Describe how the data is collected for the project. (i.e., NRC Form, survey, questionnaire, existing NRC files/ databases, response to a background check).

FOIA/PA requests, appeals and consultations are required to be submitted in writing. The NRC accepts FOIA/PA requests, appeals and consultations by mail, fax, email to FOIA.Resource@nrc.gov, via the Public Access Link public site, or via DOJs National FOIA Portal (NFP). Requests that come to the NRC through the NFP are sent directly to FOIAXpress either by email or through PAL. ID verification and release authorization can also be sent to the NRC through the above methods. FOIA/PA requests and appeals that are submitted through the Public Access Link or through the National FOIA Portal collect data by completing either the public PAL form or the National FOIA Portal form. When requesters submit their initial request using PAL, and select that it is a Privacy Act Request, the system then requires you to upload proof of identity. The proof of identity is not required when submitting FOIA or Consultation requests. When requesters submit their initial request on FOIA.gov the system allows the requester to upload documentation to verify their identity. Once we receive the request in FOIAXpress, we then require the requester to fill out the Form 507.

To process the FOIA/PA request, the FOIAXpress system maintains copies of responsive records that have been received by NRC program offices and saved in the system. The system contains the various types of agency records that are generated, received, or maintained by the NRC. These documents consist of legal, investigatory, administrative, or similar nonpublic agency records, which may contain law enforcement-related or confidential commercial information, or other types of sensitive non-PII obtained from outside parties, investigatory subjects, or other individuals (e.g., witnesses, complainants, staff from other government entities or Congress, other consumers, or the requester), depending on the type and nature of the record.

3.2 If using a form to collect the information, provide the form number, title and/or a link.

Public Access Link - https://foia.nrc-gateway.gov/app/CreateRequest.aspx.

DOJs National FOIA Portal for NRC requests - https://www.foia.gov/?id=37b76626-93b8-44d1-bba7-2f756f39b9db&type=component#agency-search.

NRC 509 -Statement of Estimated Fees; OMB Number 3150-0043.

NRC 507 - Freedom of Information, Privacy Act Record Request Form; OMB 3150-0043.

NRC 629 - Authorization for Payment by Credit Card; OMB Number: 3150-0190.

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 7

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 8 3.3 Who provides the information? Is it provided directly from the individual or a third party.

FOIA and Privacy Act requests come directly from the individual seeking the information, or through their representative.

3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.

To validate personal information, the FOIA/PA team receives ID verification and release authorizations for third-party requesters.

3.5 Will PII data be used in a test environment? If so, explain the rationale.

No. For our testing purposes, we have no need to include PII.

3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous information?

Inaccuracies might be found by the FOIA Specialist in the FOIA team during the process of responding to a request and gathering the necessary documents. Privacy Act Request identity verification takes place at the initial stages of reviewing an incoming request. FOIA Specialists, as authorized users, can correct inaccurate or erroneous information in FOIAXpress.

4 Data Security 4.1 Describe who has access to the data in the project (i.e., internal NRC, system administrators, external agencies, contractors, public).

FOIAXpress access is limited to NRC users with a license. The only users are the OCIO FOIA Team, the OCIO GEMS Administrative Assistant (who assists with FOIA case intake and close-out tasks), and a few members of OCIO management. The FOIA Team includes contractors and government personnel. Those without a FOIAXpress license cannot access the FOIAXpress system. The PAL web portal only allows the public to create a user profile, submit, and track the status of only their own FOIA/PA requests.

4.2 If the project/system shares information with any other NRC systems, identify the system, what information is being shared and the method of sharing.

N/A. FOIAXpress does not share information with any other NRC systems.

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 9 4.3 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.

Identify what agreements are in place in the table below.

Agreement Type

Contract Provide Contract Number:

License Provide License Information:

Memorandum of Understanding Provide ADAMS ML number for MOU:

Other

None 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.

FOIAXpress access is limited to NRC users with a license. The only users are the OCIO FOIA Team, the OCIO GEMS Administrative Assistant (who assists with FOIA case intake and close-out tasks), and a few members of OCIO management. The FOIA Team includes contractors and government personnel. Those without a FOIAXpress license cannot access the FOIAXpress system. In addition, each NRC approved user with access to FOIAXpress has a Personal Identity Verification (PIV) Card, and either IT-II access, L, or Q level clearance.

4.5 Explain how the data is transmitted and how confidentiality is protected (i.e.,

encrypting the communication or by encrypting the information before it is transmitted).

The cloud platform for AINS eCase permits transport Layer Security 1.1.

4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).

Data is stored in the FedRAMP approved Cloud.

4.7 Explain if the project can be accessed or operated at more than one location.

Not applicable. NRC users can only access FOIAXpress using the NRC GFE laptop either on site or when teleworking.

4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?

Yes. The FOIA team has 4 vendor (Opexus) employees under the FOIA Support Services contract, all with FOIAXpress licenses to perform work under the contract. These contractor employees access the system via SSO with their PIV card credentials (the same access as federal staff users. Cleared Opexus personnel have an administrative account to access the system during configuration and implementation efforts.

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 10 4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.

FOIAXpress does have auditing reports built in the application to identify any misuse of the data. The FOIA team can review the auditing reports daily or weekly, as required. The objects that are available to be audited include administrative level, request level and file cabinet level.

FOIAXpress is only accessed by NRC authorized users with a license.

4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,

trace/track/observe) individuals.

N/A. FOIAXpress does not have the capability to identify, locate, and monitor individuals.

4.11 Define which FISMA boundary this project is part of.

BASS 4.12 Is there an Authority to Operate (ATO) associated with this project/system?

Authorization Status

Unknown

No If no, please note that the authorization status must be reported to the Chief Information Security Officer (CISO) and Computer Security Organization (CSOs)

Point of Contact (POC) via e-mail quarterly to ensure the authorization remains on track.

In Progress provide the estimated date to receive an ATO.

Estimated date: N/A

Yes-Short Term ATO extended to April 30, 2023 Indicate the data impact levels (Low, Moderate, High, Undefined) approved by the Chief Information Security Officer (CISO)

Confidentiality-Moderate Impact Level Integrity-Moderate Availability-Moderate 4.13 Provide the NRC system Enterprise Architecture (EA)/Inventory number. If unknown, contact EA Service Desk to get the EA/Inventory number.

[Emailed the EA service Desk and awaiting response.]

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 11 5 Privacy Act Determination 5.1 Is the data collected retrieved by a personal identifier?

Mark the appropriate response.

Response

Yes, the PII is retrieved by a personal identifier (i.e., individuals name, address, SSN, etc.)

List the identifiers that will be used to retrieve the information on the individual.

First Name, Last Name, Organization name, email address,

No, the PII is not retrieved by a personal identifier.

If no, explain how the data is retrieved from the project.

<Insert response here>

5.2 For all collections where the information is retrieved by a personal identifier, the Privacy Act requires that the agency publish a System of Record Notice (SORN) in the Federal Register. As per the Privacy Act of 1974, "the term 'system of records' means a group of any records under the control of any agency from which information is retrieved by the name of the individual or by some other personal identifier assigned to the individual.

Mark the appropriate response in the table below.

Response

Yes, this system is covered by an existing SORN. (See existing SORNs:

https://www.nrc.gov/reading-rm/foia/privacy-systems.html )

Provide the SORN name, number, (List all SORNs that apply):

NRC-10, Freedom of Information Act (FOIA) and Privacy Act (PA) Request Records

SORN is in progress

SORN needs to be created

Unaware of an existing SORN

No, this system is not a system of records and a SORN is not applicable.

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 12 5.3 When an individual is asked to provide personal data (i.e., form, webpage, survey), is a Privacy Act Statement (PAS) provided?

A Privacy Act Statement is a disclosure statement required to appear on documents used by agencies when an individual is asked to provide personal data. It is required for any forms, surveys, or other documents, including electronic forms, used to solicit personal information from individuals that will be maintained in a system of records.

Mark the appropriate response.

Options

Privacy Act Statement See: https://foia.nrc-gateway.gov/ and https://www.nrc.gov/reading-rm/foia/privacy-foia.html

Not Applicable

Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?

Submission of a FOIA/PA request is voluntary. However, depending on the request, the NRC FOIA team may not be able to process it without PII.

6 Records and Information Management-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). Records/data and information with historical value, identified as having a permanent disposition, are transferred to the National Archives of the United States at the end of their retention period. All other records identified as having a temporary disposition are destroyed at the end of their retention period in accordance with the NARA Records Schedule or the General Records Schedule.

These determinations are made through records retention schedules and NARA statutes (44 United States Code (U.S.C.), 36 Code of Federation Regulations (CFR)). Under 36 CFR, agencies are required to establish procedures for addressing Records and Information Management (RIM) requirements. This includes strategies for establishing and managing recordkeeping requirements and disposition instructions before approving new electronic information systems or enhancements to existing systems.

The following questions are intended to determine whether the records/data and information in the system have approved records retention schedules and disposition instructions, whether the

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 13 system incorporates RIM strategies including support for NARAs Universal Electronic Records Management (ERM) requirements, and if a mitigation strategy is needed to ensure compliance.

If the project/system:

Does not have an approved records retention schedule and/or,

Does not have an automated RIM functionality,

Involves a cloud solution,

And/or if there are additional questions regarding Records and Information Management

- Retention and Disposal, please contact the NRC Records staff at ITIMPolicy.Resource@nrc.gov for further guidance.

If the project/system has a record retention schedule or an automated RIM functionality, please complete the questions below.

6.1 Does this project map to an applicable retention schedule in NRCs Comprehensive Records Disposition Schedule (NUREG-0910), or NARAs General Records Schedules?

NUREG-0910, NRC Comprehensive Records Disposition Schedule

NARAs General Records Schedules 6.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.

System Name (include sub-systems, platforms, or other locations where the same data resides)

Records Retention Schedule Number(s)

GRS 4.2 Item 020: Access and disclosure request files.

GRS 4.2 Item 040: Records of accounting for and controlling access to records requested under FOIA, PIA, and MDR.

Approved Disposition Instructions Is there a current automated functionality or a manual process to support RIM requirements? This includes the ability to apply records retention and disposition policies in the system(s) to support records accessibility, reliability, integrity, and disposition.

Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?

The system maintains a record retention function that can identify records in the below-mentioned categories that are ready for disposal. The FOIA team will then manually delete the records.

Temporary. Destroy 6 years after

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 14 final agency action or 3 years after final adjudication by the courts, but longer retention is authorized if required for business use.

Temporary. Destroy 6 years after date of last entry of final action by agency, but longer retention is authorized if required for business use.

Disposition of Permanent Records Will the records be exported to an approved format and transferred to the National Archives based on approved retention and disposition instructions?

If so, what formats will be used?

NRC Transfer Guidance (Information and Records Management Guideline -

IRMG)

Note: Information in Section 6, Records and Information Management-Retention and Disposal, does not need to be fully resolved for final approval of the privacy impact assessment.

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 15 7 Paperwork Reduction Act The Paperwork Reduction Act (PRA) of 1995 requires that agencies obtain an Office of Management and Budget (OMB) approval in the form of a "control number"before promulgating a paper form, website, surveys, questionnaires, or electronic submission from 10 or members of the public. If the data collection is from federal employees regarding work-related duties, then a PRA clearance is not necessary.

7.1 Will the project be collecting any information from 10 or more persons who are not Federal employees?

Yes.

7.2 Is there any collection of information addressed to all or a substantial majority of an industry (i.e., Fuel Fabrication Facilities or Fuel Cycle Facilities)?

No.

7.3 Is the collection of information required by a rule of general applicability?

Yes, the collection of information using FOIAXpress is included in the clearance for 10 CFR Part 9 under OMB Control Number 3150-0043. FOIAXpress contains the online version of NRC Form 507.

The collection of fees using Pay.gov is covered by the clearance with OMB Control Number 3150-0190.

Note: For information collection (OMB clearances) questions: contact the NRCs Clearance Officer. Additional guidance can be found on the NRCs internal Information Collections Web page at: https://intranet.nrc.gov/ocio/33456.

STOP HERE - The remaining pages will be completed by the Privacy Officer, Records Management, and Information Collections Team.

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 16 Privacy Act Determination Project/System Name: FOIAXpress Submitting Office: FOIA Team Privacy Officer Review Review Results Action Items

This project/system does not contain PII.

No further action is necessary for Privacy.

This project/system does contain PII; the Privacy Act does NOT apply, since information is NOT retrieved by a personal identifier.

Must be protected with restricted access to those with a valid need-to-know.

This project/system does contain PII; the Privacy Act does apply.

SORN is required-Information is retrieved by a personal identifier.

Comments:

Information is covered under System of Records Notice NRC 10 - Freedom of Information Act (FOIA) and Privacy Act (PA) Request Records. See https://www.nrc.gov/docs/ML2230/ML22300A233.pdf Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 05/02/23

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 PIA Template (03-2023) 17 8 OMB Clearance Determination NRC Clearance Officer Review Review Results

No OMB clearance is needed.

OMB clearance is needed.

Currently has OMB Clearance. Clearance No. 3150-0043, 3150-0190 Comments:

The OMB clearance for 10 CFR Part 9 (3150-0043) needs to be revised to reflect all the information now be collected online and screenshots of all the online collection instruments.

Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 04/28/23

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 18 PIA Template (03-2023) 9 Records Retention and Disposal Schedule Determination Records Information Management Review Review Results

No record schedule required.

Additional information is needed to complete assessment.

Needs to be scheduled.

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

Comments:

Reviewers Name Title Sr. Program Analyst, Electronic Records Manager Williams, Lisa signing on behalf of Dove, Marna on 04/12/23

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 19 PIA Template (03-2023) 10 Branch Chief Review and Concurrence Review Results

This project/system does not collect, maintain, or disseminate information in identifiable form.

This project/system does collect, maintain, or disseminate information in identifiable form.

I concur with the Privacy Act, Information Collections, and Records Management reviews.

Chief Cyber Security Branch Governance and Enterprise Management Services Division Office of the Chief Information Officer Signed by Harris, Kathryn on 05/24/23

FOIAXpress Version 2.0 Privacy Impact Assessment 3/31/2023 20 PIA Template (03-2023)

ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System: FOIAXpress Date CSB received PIA for review:

March 31, 2023 Date CSB completed PIA review:

May 1, 2023 Action Items/Concerns:

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 Chief Information Security Officer (CISO)

Office of the Chief Information Officer