ML23269A021
| ML23269A021 | |
| Person / Time | |
|---|---|
| Issue date: | 10/11/2023 |
| From: | NRC/ADM/PMAE |
| To: | |
| Katz T | |
| References | |
| EA H0008 | |
| Download: ML23269A021 (10) | |
Text
U.S. Nuclear Regulatory Commission Privacy Threshold Analysis PIV Peripherals System Subsystem of Automated Access Control and Computer Enhanced Security System (ACCESS)
Office of Administration (ADM)
EA Number H0008 Version 1.0 09/25/2023 Instruction Notes:
Please do not enter the PTA 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)
ACCESS PIV Peripherals Version 1.0 Privacy Threshold Analysis 09/25/2023 Document Revision History Date Version PTA Name/Description Author 09/25/2023 1.0 PIV Peripherals PTA - Initial Release ADM Oasis Systems, LLC 09/05/2023 DRAFT PIV Peripherals PTA - Draft Release ADM Oasis Systems, LLC
ACCESS PIV Peripherals Version 1.0 Privacy Threshold Analysis 09/25/2023 Table of Contents 1 Description 1 2 Characterization of the Information 2 3 Records and Information Management-Retention and Disposal 4 4 Privacy Act Determination 7
ACCESS PIV Peripherals Version 1.0 Privacy Threshold Analysis 09/25/2023 System/Project Name: PIV Peripherals.
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform)
None, PIV Peripherals stores no data.
Date Submitted for review/approval: 09/25/2023.
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.
The PIV Peripherals system consists of hardware peripherals such as fingerprint scanners and cameras used to support the PIV Card Issuance Process (the process itself is not within the ACCESS FISMA boundary).
Please indicate if your project/system will involve the following:
PowerApps Public Website Dashboard Internal Website SharePoint None Other 1.2 Does this privacy threshold analysis (PTA) support a proposed new project, proposed modification to an existing project, or other situation? Mark appropriate response in table below.
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 PTA and describe the modification.
Annual Review If making minor edits to an existing system/project, briefly describe the changes below.
Other (explain)
The ACCESS PIV Peripherals PTA is being split from the ACCESS consolidated PTA and updated to new template per NRCs Privacy Officers request.
PTA Template (03-2023) 1
ACCESS PIV Peripherals Version 1.0 Privacy Threshold Analysis 09/25/2023 1.3 Points of
Contact:
System Executive Project Manager Owner/Data ISSO Sponsor Owner/Steward Jennifer Name Denis Brady Jennifer Golder Tamar Katz Golder Office of Office of Administration Administration (ADM) / Program (ADM) / Division of Management, Office Office of Office of Facilities & Security Announcements, &
/Division Administration Administration (DFS) / Security Editing (PMAE) /
/Branch (ADM) (ADM)
Management and Budget &
Operations Branch Information (SMOB) Technology Team (BITT)
Telephone 301-415-5768 301-287-0741 301-415-2500 301-287-0741 2 Characterization of the Information Does this project collect, process, or retain information on: (Check all that apply)
Category of individual NRC Federal employees Other Federal employees Contractors working on behalf of NRC Members of the Public (non-licensee workers, applicants before they are licenses etc.)
Project/system does not collect any personally identifiable information Other 2.1 Is the project/system collecting information about an individual? If yes, provide a description of the information being collected.
N/A.
2.2 Please list the data fields/information being collected.
The ACCESS PIV Peripherals (Cameras and Fingerprint Scanners) do not store any information.
2.3 Does this project use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs, such as the last four.)
N/A.
PTA Template (03-2023) 2
ACCESS PIV Peripherals Version 1.0 Privacy Threshold Analysis 09/25/2023 2.4 Describe how the data is collected for the project. (i.e., NRC Form, survey, questionnaire, existing NRC files/ databases, response to a background check).
N/A.
2.5 If using a form to collect the information, provide the form number, title and/or a link.
N/A.
2.6 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.
2.7 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.
N/A.
Identify what agreements are in place with the external non-NRC partners or systems 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 2.8 Describe how the data is accessed (NRC network/remotely) and the access control mechanisms that prevent misuse.
N/A.
2.9 Define the FISMA boundary this project/system is part of.
PIV Peripherals is a part of the ACCESS FISMA boundary.
2.10 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 PTA Template (03-2023) 3
ACCESS PIV Peripherals Version 1.0 Privacy Threshold Analysis 09/25/2023 the Chief Information Security Officer (CISO)
Confidentiality-Moderate Integrity- Moderate Availability- Moderate 2.11 Provide the NRC system Enterprise Architecture (EA)/Inventory number. If unknown, contact EA Service Desk to get the EA/Inventory number.
The EA number is H0008.
3 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.
PTA Template (03-2023) 4
ACCESS PIV Peripherals Version 1.0 Privacy Threshold Analysis 09/25/2023 3.1 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 3.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.
System Name (include sub-systems, platforms, or PIV Peripherals System other locations where the same data resides)
Records Retention Schedule Number(s) Not applicable, PIV Peripherals is just peripheral hardware with no data or records that are maintained.
However, see suggested GRS 3.1 General Technology Management Records GRS 3.1 - 020 Information Technology Operations and Maintenance Records Approved Disposition Instructions *Note: Additional information/data/records kept in this system may need to be scheduled; therefore, NRC records personnel will need to work with staff to develop a records retention and disposition schedule for records created or maintained. Until the approval of such schedule, these records and information are Permanent. Their willful disposal or concealment (and related offenses) is punishable by fine or imprisonment, according to 18 U.S.C., Chapter 101, and Section 2071. Implementation of retention schedules is mandatory under 44 U.S. 3303a (d), and although this does not prevent further development of the project, retention functionality or a manual process must be incorporated to meet this requirement.
PTA Template (03-2023) 5
ACCESS PIV Peripherals Version 1.0 Privacy Threshold Analysis 09/25/2023 Is there a current automated functionality or a manual N/A 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 N/A Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
Disposition of Permanent Records N/A 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)
PTA Template (03-2023) 6
ACCESS PIV Peripherals Version 1.0 Privacy Threshold Analysis 09/25/2023 4 Privacy Act Determination Review Results Action Items No further action is necessary for This project/system does not contain PII.
Privacy.
A privacy impact assessment is This project/system does contain PII required Comments:
Reviewers Name Title Signed by Hardy, Sally on 10/11/23 Privacy Officer I concur with this analysis.
Signed by Harris, Kathryn on 10/11/23 Chief Cybersecurity Branch Governance and Enterprise Management Services Division Office of the Chief Information Officer PTA Template (03-2023) 7