ML23241A935
| ML23241A935 | |
| Person / Time | |
|---|---|
| Issue date: | 08/23/2023 |
| From: | NRC/OCFO |
| To: | |
| Howerton J | |
| References | |
| Download: ML23241A935 (20) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment HCM Cloud for Time and Labor System (HCMTL)
Office of the Chief Financial Officer (OCFO)
Version 1.0 8/23/2023 Template Version 2.0 (03/2023)
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 Document Revision History Date Version PIA Name/Description Author 8/23/2023 1.0 HCMTL PIA Initial Release. OCFO Oasis Systems, LLC 7/21/2023 DRAFT HCMTL PIA Draft Release. OCFO Oasis Systems, LLC
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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 7 6 Records and Information Management-Retention and Disposal 8 7 Paperwork Reduction Act 11 8 Privacy Act Determination 12 9 OMB Clearance Determination 13 10 Records Retention and Disposal Schedule Determination 14 11 Branch Chief Review and Concurrence 15
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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: HCM Cloud for Time and Labor System (HCMTL).
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): Cloud.
Date Submitted for review/approval: August 23, 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.
HCMTL captures time, attendance, and labor data, leveraging the Oracle Human Capital Management (HCM) cloud application. The HCM Time & Labor (T&L) and Absence modules require all employees to be self-reporters and to enter time taken for vacation, sick leave, jury duty, etc. It also tracks monthly leave accrual (vacation and sick hours earned each month vs.
hours taken).
HCMTL supports recording of employee activity-based hours to be used primarily for payroll and fee billing through the following modules:
Time and Labor - NRC employees can report, manage, and process time using the Time and Labor module. Time data can be transferred to global payroll, project costing, and external applications.
Absence Management - NRC employees can schedule and approve absences, maintain absences, and analyze absence data using Absence Management.
The purpose of HCMTL is to collect time and attendance data for payroll processing, formulating and executing budgets, operations planning, workload planning, labor data reporting, performance monitoring, reporting on resource expenditures, billing NRC licensees, and managing costs associated with collecting fees.
Please mark appropriate response below if your project/system will involve the following:
PowerApps Public Website Dashboard Internal Website SharePoint None Other:
PIA Template (03-2023) 1
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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.
The HCMTL system was renamed, previously known as the Human Resources Management System - Cloud (HRMS-C), as documented in the previous PIA.
ADAMS ML: ML21025A267 Annual Review If making minor edits to an existing system/project, briefly describe the changes below.
Other (explain) 1.3 Points of
Contact:
Project System ISSO Business Technical Executive Manager Owner/Data Project Project Sponsor Owner/Steward Manager Manager Name Abby Howard John Erikka N/A Howard Olarte Osborne Howerton LeGrand Osborne Office/ OCFO/ OCFO OCFO/ OCFO/ N/A OCFO Division/ DOC/FSB DOC/FSB DOC/FSOB Branch Telephone 301-415- N/A 301-415- 301-415- N/A N/A 6288 8170 7748 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 Authority Citation/Reference apply.
5 United States Code (U.S.C.) 6334; 5 Statute U.S.C. Part III, Subpart D; 31 U.S.C. 716; &
31 U.S.C. Chapters 35 and 37.
Executive Order 26 Code of Federation Regulations (CFR)
Federal Regulation 31.6011(b)(2), 31.6109-1.
Memorandum of Understanding/
PIA Template (03-2023) 2
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 Agreement Other (summarize and provide a copy of relevant 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).
Information in the system is used for data transmissions to the Department of the Interior (DOI) for paycheck and leave balances calculations, license fees billings, updates to the agencys core financial system, financial reporting, project management, salary and benefits modeling, cost accounting modeling, and strategic workforce planning.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
HCMTL uses employee information (first name, last name, SSN, etc.) to support management of salaries and benefits, leave balances, payroll data, time and attendance data, and activity-based work hours.
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:
PIA Template (03-2023) 3
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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 Children Information Other:
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).
Employee time and attendance information is collected directly from the individual. Employee information (name, DOB, SSN, etc.), salary and benefits, and payroll information comes from DOIs Federal Personnel Payroll System (FPPS) via daily file transfer to an intermediary file server.
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.
Employee timesheet data is collected directly from the individual; and employee information is collected from existing NRC systems and DOI FPPS, shared through an intermediary server.
PIA Template (03-2023) 4
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
Employee time and attendance data is verified through OCFO reconciliations, SF-52s, and Earnings and Leave statements. There are no data validations for employee information from DOI FPPS; HCMTL assumes that incoming data is accurate.
3.5 Will PII data be used in a test environment? If so, explain the rationale.
Yes, the HCMTL test environment uses PII to validate system enhancements and corrections.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous information?
HCMTL does not collect PII directly from the subject individual, it is provided by file transfer from DOI FPPS to an intermediary server. If employee information is inaccurate, this can be corrected by the subject individual through the Employee Express self-service portal, or by contacting an NRC Office of the Chief Human Capital Officer (OCHCO) Human Resource (HR) specialist.
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).
All NRC Offices have access to the system for the purposes of employee time entry, approvals, and reporting of activities. Access within the system is limited based on roles and responsibilities. There are need-to-know restrictions in place for access to PII required to perform official duties.
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.
HCMTL shares information with the following NRC systems:
Budget Formulation System (BFS) - HCMTL sends employee payroll information to BFS.
Financial Accounting and Integrated Management Information System (FAIMIS) -
HCMTL sends employee hour and payroll data to FAIMIS.
Cost Activity Code System (CACS) - HCMTL sends employee hour data to CACS.
CACS provides employee staff assignment information to HCMTL.
All information/file sharing between HCMTL and NRC systems use an intermediary server.
4.3 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.
A file from DOIs FPPS contains employee information, salary and benefits, leave balances, and payroll information, delivered to an intermediary server.
PIA Template (03-2023) 5
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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:
Interconnection Security Agreement Provide ADAMS ML number for ISA: ML21265A519 Service Level Agreement Provide ADAMS ML number for SLA: ML22277A714 None 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
NRC personnel access HCMTL from the NRC network, using Information Technology Infrastructure (ITI) Identity, Credential, and Access Management (ICAM) for Single Sign-On (SSO). User access and activity is monitored by service administrators. Audit trails track user access by User ID with date and time stamps, and logs are reviewed by the assigned Information System Security Officer (ISSO) designees.
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 data to and from HCMTL is transmitted to other NRC systems via batch file interfaces, using an intermediary server. All communications are encrypted, employing Tectia SSH and FIPS-mode.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
Data is stored in the cloud and temporarily on the intermediary server.
4.7 Explain if the project can be accessed or operated at more than one location.
HCMTL is hosted in the cloud and is accessible from the Internet.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
Yes, all NRC contractors supporting HCMTL have been through the NRC badging process.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
HCMTL has been configured to log user access activities and updates to system records.
PIA Template (03-2023) 6
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
N/A.
4.11 Define which FISMA boundary this project is part of.
HCMTL is included as a subsystem of the Financial Management Systems (FMS) FISMA 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.
EA Number: 20210005.
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.
Data is retrieved by a system-generated employee ID (employee identification number) and/or employee last name / first name.
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 PIA Template (03-2023) 7
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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):
US Federal Government-wide SORN OPM/GOVT General Personnel Records; NRC Official Personnel Training Records; NRC Payroll Accounting 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.
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 Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
NRC personnel are required to provide PII (name, address, SSN, banking information, etc.) to DOI FPPS for employee hours reporting, payroll, and benefits.
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 PIA Template (03-2023) 8
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 6.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.
System Name (include sub- HCMTL systems, platforms, or other locations where the same data resides)
Records Retention Schedule GRS 2.4 Item 010 - Records used to calculate Number(s) payroll, arrange paycheck deposit, and change previously issued paychecks.
GRS 2.4 Item 030 - Time and attendance records.
GRS 2.4 Item 040 - Agency payroll record for each pay period.
GRS 2.4 Item 050 - Wage and tax statements.
GRS 2.4 Item 060 - Payroll program administrative records. - Administrative correspondence between agency and payroll processor, and system reports used for agency workload and/or personnel management purposes.
GRS 2.4 Item 061 - Payroll program administrative records. - Payroll system reports providing fiscal information on agency payroll.
Approved Disposition Instructions GRS 2.4 Item 010:
Temporary. Destroy 3 years after paying agency or payroll processor validates data, but longer retention is authorized if required for business use.
GRS 2.4 Item 030:
Temporary. Destroy when 3 years old, whichever is sooner, but longer retention is authorized if required for business use.
GRS 2.4 Item 040:
Temporary. Destroy when 56 years old.
GRS 2.4 Item 050:
Temporary. Destroy when 4 years old, but longer retention is authorized if required for business use.
GRS 2.4 Item 060:
Temporary. Destroy when 2 years old, but longer retention is authorized if required for business use.
GRS 2.4 Item 061:
Temporary. Destroy when 3 years old or after Government Accountability Office (GAO) audit, whichever comes sooner, but longer retention is authorized if required for business use.
Is there a current automated Although HCMTL records map to the above functionality or a manual process to mentioned records retention schedules, data in support RIM requirements? This HCMTL is not deleted/destroyed. All records have PIA Template (03-2023) 10
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 includes the ability to apply records been retained to support inquiries from the Office of retention and disposition policies in General Counsel (OGC) regarding open the system(s) to support records investigations.
accessibility, reliability, integrity, and disposition.
Disposition of Temporary Records Records/data are not deleted from the system once they reach their approved retention. There are no Will the records/data or a composite plans to implement automated records retention be automatically or manually deleted functionality.
once they reach their approved retention?
Disposition of Permanent Records No.
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) 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.
PIA Template (03-2023) 11
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 8 Privacy Act Determination Project/System Name: HCM Cloud for Time and Labor System (HCMTL).
Submitting Office: Office of the Chief Financial Officer.
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 Must be protected with restricted Privacy Act does NOT apply, since access to those with a valid need-to-information is NOT retrieved by a personal know.
identifier.
This project/system does contain PII; the SORN is required- Information is Privacy Act does apply. retrieved by a personal identifier.
Comments:
Covered by Government-wide SORN OPM/GOVT General Personnel Records; NRC Official Personnel Training Records; NRC Payroll Accounting Records.
Reviewers Name Title Signed by Hardy, Sally on 09/20/23 Privacy Officer PIA Template (03-2023) 12
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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:
Information is only collected from Federal employees within the scope of their employment.
Reviewers Name Title Signed by Cullison, David on 09/11/23 Agency Clearance Officer PIA Template (03-2023) 13
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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 09/15/23 Sr. Program Analyst, Electronic Records Manager PIA Template (03-2023) 14
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 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 09/28/23 Chief Cybersecurity Branch Governance and Enterprise Management Services Division Office of the Chief Information Officer PIA Template (03-2023) 15
HCM Cloud for Time and Labor System (HCMTL) Version 1.0 Privacy Impact Assessment 8/23/2023 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
HCM Cloud for Time and Labor System (HCMTL).
Date CSB received PIA for review: Date CSB completed PIA review:
August 23, 2023 September 19, 2023 Action Items/Concerns:
Copies of this PIA will be provided to:
Ledetria 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) 16