ML23117A210
| ML23117A210 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/2023 |
| From: | NRC/OIP |
| To: | |
| Freeman S | |
| References | |
| Download: ML23117A210 (15) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Office of International Program (OIP) Passports & Visa Registration Database OIP Version 1.1 4/20/2023 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)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 Document Revision History Date Version PIA Name/Description Author 4/20/2023 1.1 Converted to new PIA template OIP 3/7/2023 1.0 Office of International Program (OIP) Passport & OIP Visa Registration Database Initial Release
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 Table of Contents 1 Description 1 2 Authorities and Other Requirements 2 3 Characterization of the Information 3 4 Data Security 5 5 Privacy Act Determination 8 6 Records and Information Management-Retention and Disposal 9 7 Paperwork Reduction Act 12 8 Privacy Act Determination 13 9 OMB Clearance Determination 14 10 Records Retention and Disposal Schedule Determination 15 11 Branch Chief Review and Concurrence 15
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 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: Office of International Program (OIP) Passports &
Visa Registration Database.
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) SharePoint.
Date Submitted for review/approval: 4/20/2023.
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.
The list is a repository of the agencys passport and visa registrations needed to support the Nuclear Regulatory Commission (NRC) international travel consistent with U.S. government requirements. The site is in NRCs SharePoint Online and the list has need-to-know, limited/restricted access.
Please mark appropriate response below if your project/system will involve the following:
PowerApps Public Website Dashboard Internal Website SharePoint None Other 1
PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 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.
Annual Review If making minor edits to an existing system/project, briefly describe the changes below.
Other No modifications made and no need for annual reviews.
Converted to new PIA template 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 System ISSO Business Technical Executive Manager Owner/Data Project Project Sponsor Owner/Steward Manager Manager Name Stanley Freeman Julie Hughes Office/ OIP/IOB OCIO/GEMSD Division /CSB/IAT
/Branch Telephone 301-287-9064 301-287-9277 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.
2 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 Mark with an Authority Citation/Reference X on all that apply.
U.S.C. 3511, 3512, and 3523; 5 U.S.C.
Statute Chapter 57; and implementing Federal Travel Regulations (41 CFR Chapters 300-304).
Executive Order Federal Regulation Memorandum of Understanding/Agreement Other (summarize and This program is authorized under provide a copy of relevant Management Directive 5.13.
portion) 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 information is used to track the status of official passports for NRC travelers. This enables staff to receive reminders when their passports are nearing their expiration dates. It also enables management to maintain an awareness of which staff are capable of international travel.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
Not applicable.
3 Characterization of the Information In the table below, mark the categories of individuals for whom information is collected.
Category of individual Federal employees Contractors Members of the Public (any individual other than a federal employee, consultant, or contractor)
Licensees Other 3
PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 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 Driver's License Number Country of Birth License Plate Number Citizenship Passport number Nationality Relatives Information Race Taxpayer Identification Number Home Address Credit/Debit Card Number Social Security number (Truncated or Partial) Medical/health information Gender Alien Registration Number Ethnicity Professional/personal references Spouse Information Criminal History Biometric identifiers (facial images, Personal e-mail address fingerprints, iris scans)
Emergency contact e.g., a third party to Personal Bank Account Number contact in case of an emergency Personal Mobile Number Accommodation/disabilities information Marital Status Other Also collect passport issuance date, and passport expiration date. Issued Children Information visas (country name and expiration date Mother's Maiden Name only).
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).
Individuals must complete the Department of State form and provide the completed form to OIP.
OIP then sends the completed form by courier to the Department of State. The business passport numbers and visas are assigned by Department of State and then provided to OIP via courier. OIP uses the information provided by Department of State and inputs it into the OIP Database. Existing NRC files are updated with new passport numbers as renewals are processed.
4 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 3.2 If using a form to collect the information, provide the form number, title and/or a link.
Not applicable.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
The Department of States Special Issuance Agency issues the passports. OIP receives the passport and or Visa via Courier contracted by the NRC and then distributes to the employee.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
The information is entered into SharePoint by the International Program Specialist who confirms the passport information is accurate.
3.5 Will PII data be used in a test environment? If so, explain the rationale.
No - there are no test environments.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous information?
International Program Specialist has the ability to call out an error when discovered.
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).
Internal NRC staff within OIP/IOB with a need-to-know.
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.
NICE uses the SharePoint site to determine whether or not a traveler has a valid passport. The NICE database sends alerts to travelers when their passports are up for renewal.
5 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 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 with the external non-NRC partner or system 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.
Access control is managed by SharePoint security groups/permissions and limited to those personnel with a need-to-know.
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 OIP database in SharePoint communicates with the NRC International Cooperation and Engagement (NICE) SharePoint site. NRR-approved contractors authorized to manage the NICE system have linked NICE with the SharePoint page to have the sites communicate effectively. The OIP database will transmit only the staffs name and his/her passport/visa expiration dates with the NICE SharePoint. This information is not considered PII and is already available in NICE. There is a workflow to transmit the staffs name and passport and visa expiration date automatically.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
Data is stored in SharePoint Online which is cloud.
4.7 Explain if the project can be accessed or operated at more than one location.
Not applicable.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
Not applicable.
6 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
Ownership and viewing rights are limited to the necessary staff within OIP/IOB with a need-to-know.
4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
No.
4.11 Define which FISMA boundary this project is part of.
Information Technology Infrastructure (ITI).
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:
Yes Indicate the data impact levels (Low, Moderate, High, Undefined) approved by the Chief Information Security Officer (CISO)
20090005 (ITI EA Number).
7 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 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.
No, the PII is not retrieved by a personal identifier.
If no, explain how the data is retrieved from the project.
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):
SORN GSA/Govt-4 Contracted Travel Services Program 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.
8 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 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 Not Applicable A Department of State form is used to collect the information; not an NRC form.
Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
Official (business) passports are mandatory to support international travel on behalf of the NRC. Per YA-20-0056, these passports should be used as a form of identification instead of PIV cards, which cannot be used while on travel. DOS also require visas for certain countries. If information is not provided, the individual will not receive a business passport or Visa.
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.
9 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 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 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 Unscheduled 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 2.2 - Employee Management Records Approved Disposition Instructions GRS 2.2 item 010 - Employee management administrative records Temporary. Destroy when 3 years old, but longer retention is authorized if required for business use.
GRS 2.2 item 090 - Records related to official passports.
Application records.
10 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 Temporary. Destroy when 3 years old or upon employee separation or transfer, whichever is sooner; but longer retention is authorized if required for business use.
GRS 2.2 item 091 - Records related to official passports.
Official passport registers.
Temporary. Destroy when superseded or obsolete.
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 The information remains in the system until an administrator Will the records/data or a composite be automatically or deletes it. Staff have been manually deleted once they reach their approved known to return to the agency, retention? so their information is kept on the SharePoint page for several years after departure.
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.
11 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 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 more 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?
No.
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?
No.
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.
12 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 8 Privacy Act Determination Project/System Name: Office of International Program (OIP) Passports & Visa Registration Database.
Submitting Office: Office of International Programs (OIP)
Privacy Officer Review Review Results Action Items No further action is necessary for This project/system does not contain PII.
Privacy.
This project/system does contain PII; the Must be protected with restricted Privacy Act does NOT apply, since information is NOT retrieved by a personal access to those with a valid need-to-know.
identifier.
SORN is required- Information is This project/system does contain PII; the Privacy Act does apply.
retrieved by a personal identifier.
Comments:
OGC reviewed and confirm GSA/Govt-4 Contracted Travel Services Program does cover this information. If any changes are made to the information being maintain, the PIA would need to be updated and reviewed to determine if the changes create any new privacy concerns.
Reviewers Name Title Signed by Hardy, Sally on 05/22/23 Privacy Officer 13 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 9 OMB Clearance Determination NRC Clearance Officer Review Review Results No OMB clearance is needed.
OMB clearance is needed.
Currently has OMB Clearance. Clearance No.
Comments:
The collection of information that is housed in this system is exempt from the requirements of the Paperwork Reduction Act (5 CFR 1320.3(c)(4)).
Reviewers Name Title Signed by Cullison, David on 05/08/23 Agency Clearance Officer 14 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 10 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 Signed by Dove, Marna on 05/12/23 Sr. Program Analyst, Electronic Records Manager 11 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.
Signed by Harris, Kathryn on 05/24/23 Chief Cyber Security Branch Governance and Enterprise Management Services Division Office of the Chief Information Officer 15 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 16 PIA Template (03-2023)
Office of International Program (OIP) Passport Version 1.1
& Visa Registration Database Privacy Impact Assessment 4/20/2023 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System: Office of International Program (OIP) Passports & Visa Registration Database Date CSB received PIA for review: Date CSB completed PIA review:
April 20, 2023 May 19, 2023 Action Items/Concerns:
Copies of this PIA will be provided to:
Ledetria Beaudoin Director (Acting)
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 17 PIA Template (03-2023)