ML23216A199
| ML23216A199 | |
| Person / Time | |
|---|---|
| Issue date: | 07/25/2023 |
| From: | NRC/OCIO, Oasis Systems |
| To: | |
| References | |
| Download: ML23216A199 (19) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Information Technology Infrastructure (ITI)
Identity, Credential, and Access Management (ICAM)
Office of the Chief Information Officer (OCIO)
Version 1.0 07/25/2023 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)
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 Document Revision History Date Version PIA Name/Description Author 07/25/2023 1.0 Initial Release of ITI_ICAM PIA in new OCIO template Oasis Systems, LLC 07/13//2023 DRAFT Draft Release - Completed ICAM PIA in OCIO new template Oasis Systems, LLC
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 Table of Contents 1 Description 1 2 Authorities and Other Requirements 3 3 Characterization of the Information 3 4 Data Security 5 5 Privacy Act Determination 7 6 Records and Information Management-Retention and Disposal 9 7 Paperwork Reduction Act 11 8 Privacy Act Determination 14 9 OMB Clearance Determination 15 10 Records Retention and Disposal Schedule Determination 16 11 Branch Chief Review and Concurrence 17
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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:
Identity, Credential, and Access Management (ICAM).
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform):
Database Server.
Date Submitted for review/approval: August 3, 2023.
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.
ICAM is a robust set of credentialing services built on industry standard commercial off-the-shelf software running on the Nuclear Regulatory Commission (NRC) standard computing platforms.
ICAM delivers Public Key Infrastructure (PKI) and One-Time Password (OTP) credentials to internal staff, contractors, and external partners. In addition, it provides single sign-on (SSO),
identity management, and attribute synchronization services. ICAM includes processes for verifying the identity of certificate applicants, securely issuing certificates and keys, and revoking certificates in a timely manner. ICAM also escrows encryption keys of employees and contractors to prevent loss of data in the event a users data encryption key becomes unavailable. ICAM is a Privacy Act System of Records, identified as NRC-45, as defined by the Privacy Act of 1974.
Please mark appropriate response below if your project/system will involve the following:
PowerApps Public Website Dashboard Internal Website SharePoint Other (explain)
PIA Template (03-2023) 1
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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.
N/A Other (explain) 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 Busines Technica Executiv Manage Owner/Data ISSO s Project l Project e r Owner/Steward Manager Manager Sponsor Gwen Julie Hughes James Name TBD TBD TBD Hayden Branden Jarrell Peyton OCIO/GEMSD/CSB/I Office/ OCIO/
OCIO/ AT Division ITSDOD ITSDOD OCIO/GEMSD/CSB/I
/Branch /NSOB AT Telephon 301-287-9277 301-287-301-287-0761 e 301-415-4074 0701 PIA Template (03-2023) 2
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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 Authority Citation/Reference that apply.
Statute N/A Homeland Security Presidential Executive Order Directive 12 Federal Regulation N/A Memorandum of Understanding/Agreement N/A Other (summarize and provide a copy of relevant portion)
N/A 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 purpose of ICAM and the data it collects is to identify applicants and verify identity information provided by those applicants in support of a request for electronic credentials for access to federal facilities, networks, computer systems, and Internet-based e-Government applications.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
ICAM may require the use of Social Security Number (SSN) information for confirmation of applicant identity or for federal processing requirements. All SSN data is encrypted to applicable federal standards at rest and during transmission.
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 - N/A PIA Template (03-2023) 3
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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 - N/A Children Information Mother's Maiden Name 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).
For internal staff, information is collected from the PSATS and FPPS to ensure accuracy and consistency of information used for identity credentials. Information from the PSATS and/or FPPS is a data transfer.
Information is collected from online registration and paper submissions completed by the applicant.
For External Partner applicants, the provided identity information may be validated using an external service that accesses one or more authoritative repositories intended for identity verification.
In addition, External Partner company names are verified against Secretary of State business records and company affiliation is verified through a telephonic employment check.
PIA Template (03-2023) 4
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 3.2 If using a form to collect the information, provide the form number, title and/or a link.
N/A.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
Directly from the individual. For internal staff, information is collected from the PSATS and FPPS to ensure accuracy and consistency of information used for identity credentials.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
Directly from the individual.
3.5 Will PII data be used in a test environment? If so, explain the rationale.
N/A.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous information?
Users have access to EIH SailPoint IdentityIQ which allows them to update personal information such as name and home contact information, Office location & phone numbers, organizational information such as position and organization information, as well as the ability to update emergency contact information.
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).
System administrators 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.
NRC e-Government applications may have access to External Partner credential information when a controlled access mechanism is available.
PIA Template (03-2023) 5
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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 in the table below.
Agreement Type Contract Provide Contract Number:
License Provide License Information:
Memorandum of Understanding Provide ADAMS ML number for MOU:
Other
- Online searches for copies of an individuals public digital certificate using the Public Certificate Repository portion of the ICAM system; and
- Data transmitted to the Office of Personnel Management (OPM) as part of the vetting process for internal applicants. OPM has access only to the data transmitted; not to the system.
- The Public Certificate Repository is made available to all agencies, organizations, and the public. The Office of Personnel Management (OPM)
Fingerprint Transaction System receives transmitted applicant data.
4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
Data can only be accessed through privileged accounts and a PIV card.
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).
ICAM transmits content to staff over the NRCs ITI internal network. The data is encrypted and so is the communication.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
Stored at NRC database.
4.7 Explain if the project can be accessed or operated at more than one location.
Headquarters and all Regions.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
Yes, contractors possess a badge and PIV card.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
All privileged role holders must meet qualifications and sign special Rules of Behavior for Trusted Persons which are periodically renewed. Private Key recovery requires a minimum of two authorized administrators with administrator certificates and key recovery privilege. Defined system security events trigger email alerts. Viewing audit data requires administrator privileges.
PIA Template (03-2023) 6
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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.
ICAM is a subsystem of the Information Technology Infrastructure (ITI) boundary.
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)
Confidentiality- Moderate 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.
The ITI EA# is 20090005.
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.
Name No, the PII is not retrieved by a personal identifier.
If no, explain how the data is retrieved from the project.
PIA Template (03-2023) 7
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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, and link to the Federal Register Notice. (List all SORNs that apply):
NRC 45 - Electronic Credentials for Personal Identity Verification 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.
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 (insert link to PAS)
Privacy Advisory (insert link to Privacy Advisory)
Not Applicable Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
Mandatory.
PIA Template (03-2023) 8
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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 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 PIA Template (03-2023) 9
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 6.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.
System Name (include sub-systems, platforms, or ICAM other locations where the same data resides)
Records Retention Schedule Number(s) GRS 5.6 - Security Records, items 120, 121, and 130 GRS 3.1 - General Technology Management Records GRS 3.2 Information Systems Security Records Approved Disposition Instructions See table attached below for additional details on the schedules and disposition instructions.
Is there a current automated functionality or a manual No 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 TBD Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
Disposition of Permanent Records TBD 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)
PIA Template (03-2023) 10
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 Records Records Schedule - Description Retention/Disposition Instruction ICAM System GRS 3.1 item 051 - Data Temporary. Destroy 5 years after Architecture Design administration records. All the project/activity/transaction is Document documentation for temporary completed or superseded, or the electronic records and associated system is terminated, documentation not necessary for the or the associated data is migrated preservation of permanent records. to a successor system, but longer retention is authorized if required for business use.
System access GRS 3.2 item 030 - System access Temporary. Destroy when records records. Systems not requiring business use ceases.
special accountability for access.
System access GRS 3.2 item 031 - System access Temporary. Destroy 6 years after records records. Systems requiring special password is altered or user accountability for access. account is terminated, but longer retention is authorized if required for business use.
PKI administrative GRS 3.2 item 060 - PKI Temporary. Destroy/delete when records administrative records. FBCA CAs. 7 years 6 months, 10 years 6 months, or 20 years 6 months, based on maximum level of operation of the CA or when no longer needed for business, whichever is later.
PKI administrative GRS 3.2 item 061 - PKI Temporary. Destroy/delete when records administrative records. Other (non- 7 years 6 months to 20 years 6 FBCA et.al.) CAs. months old, based on the maximum level of operation of the CA, or when no longer needed for business, whichever is later.
PKI transaction- GRS 3.2 item 062 - PKI transaction- Temporary. Destroy/delete when 7 years 6 months to 20 years 6 PIA Template (03-2023) 11
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 specific records specific records. months old, based on the maximum level of operation of the (Not sure if these appropriate CA and after the records are information record the PKI is created/maintained in designed to protect and/or access ICAM; this schedule is destroyed according to an was included as it is authorized schedule, or in the case applicable to PKIs) of permanent records, when the record is transferred to NARA legal custody. Longer retention is authorized if the agency determines that transaction-specific PKI records are needed for a longer period.
Personal identification GRS 5.6 item 120 - Personal Temporary. Destroy 6 years after credentials and cards. identification credentials and cards. the end of an employee or Application and Application and activation records. contractors tenure, but longer activation records. retention is authorized if required for business use.
Personal identification GRS 5.6 item 121 - Personal Temporary. Destroy after credentials and cards. identification credentials and cards. expiration, confiscation, or return.
Cards. Cards.
Temporary and local GRS 5.6 item 130 - Temporary and Temporary. Destroy upon facility identification local facility identification and card immediate collection once the and card access access records. temporary credential or card is records. returned for potential reissuance due to nearing expiration or not to exceed 6 months from time of issuance or when individual no longer requires access, whichever is sooner, but longer retention is authorized if required for business use.
PIA Template (03-2023) 12
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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 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?
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.
PIA Template (03-2023) 13
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 8 Privacy Act Determination Project/System Name: Identity, Credential, and Access Management (ICAM).
Submitting Office: Office of the Information Officer.
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:
This system is covered by System of Records Notice (SORN) 45 Electronic Credentials for Personal Identity Verification and NRC 36 Employee Locator Records.
Reviewers Name Title Signed by Hardy, Sally on 08/29/23 Privacy Officer PIA Template (03-2023) 14
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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:
OCIO has committed to obtaining a clearance for this collection of information.
Reviewers Name Title Benney, Kristen signing on behalf of Cullison, David Agency Clearance Officer on 08/17/23 PIA Template (03-2023) 15
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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 08/17/23 Sr. Program Analyst, Electronic Records Manager PIA Template (03-2023) 16
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 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 09/06/23 Chief Cybersecurity Branch Governance and Enterprise Management Services Division Office of the Chief Information Officer PIA Template (03-2023) 17
Identity, Credential, and Access Management (ICAM) Version 1.0 Privacy Impact Assessment 07/25/2023 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System: Identity, Credential, and Access Management (ICAM)
Date CSB received PIA for review: Date CSB completed PIA review:
August 3, 2023 August 23, 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 PIA Template (03-2023) 18