ML23310A296
| ML23310A296 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/2023 |
| From: | Consuella Debnam NRC/OCIO |
| To: | |
| Debnam C | |
| References | |
| Download: ML23310A296 (21) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Regional Applications - Region I (RAPP-RI)
Subsystem of Business Application Support System (BASS)
Office of the Chief Information Officer (OCIO)
Version 1.0 10/02/2023 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 (08/2023)
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 Document Revision History Date Version PIA Name/Description Author 10/02/2023 1.0 Regional Applications - Region I (RAPP-RI) OCIO Initial Release Oasis Systems, LLC 09/13/2023 DRAFT Regional Applications - Region I (RAPP-RI) OCIO Draft Release Oasis Systems, LLC
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 Table of Contents 1 Description 1 2 Authorities and Other Requirements 3 3 Characterization of the Information 4 4 Data Security 5 5 Privacy Act Determination 8 6 Records and Information Management-Retention and Disposal 9 7 Paperwork Reduction Act 13 8 Privacy Act Determination 15 9 OMB Clearance Determination 16 10 Records Retention and Disposal Schedule Determination 17 11 Branch Chief Review and Concurrence 18
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 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: Regional Applications - Region I (RAPP-RI).
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): Microsoft SQL Server.
Date Submitted for review/approval: October 30, 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.
Regional Applications (RAPP) is a subsystem of BASS, and RAPP is comprised of 3 sets of applications: Region I (RAPP-RI), Region II (RAPP-RII), Region IV (RAPP-RIV)
The RAPP-RI, RAPP-RII, and RAPP-RIV applications reside on BASS virtual servers. Regional system administrators are only responsible for their applications. BASS provides centralized services and database administration.
Region I descriptions are provided below:
The Region I office oversees Resident Inspector Site Expansion (RISE) locations throughout the Northeastern United States. Applications that support the business functions are hosted on BASS.
RAPP-RI applications include:
Region I Data Warehouse: consolidates all Regional I databases into a single warehouse which will host all RI modernized databases.
Staff Profile Request System (SPRS): manages Emergency Response Staff information and the staff reporting system.
Request Tracking System (RTS): provides a purchase tracking system that tracks all of the RI form 30 purchase activities.
Government Vehicle Reservations System (GVRS): provides the interface for users to reserve government vehicles. This system allows users to interact with the vehicle management team to report and to maintain vehicle condition.
PIA Template (08-2023) 1
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 Emergency Responsibility Scheduling System (EROAS): provides a web access system that allows all emergency response members to log their availability through the ERO system. In addition to the logged availability, the system can generate EROAS reports based on management needs.
Ask Management Feedback System (AMFS): provides a web access system that regional staff use to communicate with the management team through a question-and-answer format.
The AMFS implements role-based security to provide question privacy (anonymous submission) and automates the AMS publication processes.
SPRS is the application that stores PII information. The other applications are fed from SPRS which is under the development of the Region I Enterprise Database Application Modernization (EDAM) project. The purpose of the SPRS is multifold. First, it replaces the Region I intranet legacy system, which used obsolete technologies and tools. SPRS has implemented many new features to automate and replace the manual processes of Region I staff information updated from HQ ICAM nightly jobs. SPRS provides Region I staff information with functions for searching, updating local profiles, and integrating with the HQ ICAM system. SPRS also generates specific staff contact reports for organizational needs. The SPRS is a subset of the EDAM application developed by using the Microsoft C# and ASPNet MVC frameworks with Microsoft SQL server as the backend data store.
Please mark appropriate response below if your project/system will involve the following:
PowerApps Public Website Dashboard Internal Website SharePoint None Other 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 (explain)
PIA Template (08-2023) 2
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 1.3 Points of
Contact:
Project System ISSO Business Technical Executive Manager Owner/Data Project Project Sponsor Owner/Steward Manager Manager Name Shihsing Gwen Hayden Consuella Michael Shihsing Michael Dean Chang Debnam Dean Chang Mary Walsh Office/ NRC R1 OCIO OCIO NRC R1 NRC R1 NRC R1 DRM Division/ DRM IRB DRM IRB DRM IRB IRB Branch Telephone 610-337- 301-287-0761 301-287- 610-337- 610-337- 610-337-5079 5221 0834 5079 5221 610-337-5351 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 Authority Citation/Reference X on all that apply.
Statute Executive Order Federal Regulation Memorandum of Understanding/Agreement Other (summarize and provide a copy TBD 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).
Localized and centralized staff Information allows emergency responders to easily access all emergency personnel contact information. In addition, SPRS gives the management group the capability of getting employee profile reports.
PIA Template (08-2023) 3
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 If the project collects Social Security numbers, state why this is necessary and how it will be used.
Social Security numbers are not collected.
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 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 PIA Template (08-2023) 4
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 Categories of Information Personal Mobile Number Accommodation/disabilities information Marital Status Other: Emergency contact name, phone Children Information number and address.
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).
SPRS does one-way pulling (data transfer) with read-only access by Region I employees unless a user has specific role with specific access rights.
3.2 If using a form to collect the information, provide the form number, title and/or a link.
There is no hard paper form used to feed the SPRS.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
Information is pulling only from the HQ ICAM view.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
The data comes directly from HQ ICAM where it is validated, and any updates would be made directly in HQ ICAM.
3.5 Will PII data be used in a test environment? If so, explain the rationale.
No.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous information?
The registrant/applicant cannot access their information once the form is submitted to OCIO management. If there needs to be a change to the information, the individual must notify the manager. The incorrect data must be corrected through the NRC ICAM interface.
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).
Region I applications implement a least-privilege RBAC that restricts data access to only authenticated personnel who have a need-to-access to perform their job function for the subsystem.
PIA Template (08-2023) 5
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 SPRS is role-based security application. Below is the matrix of role permissions.
Role Name Description Module Access RI EDAM This is an administrative access, which provides full ALL EDAM systems System right to manage the EDAM applications. and Admin Modules Admin SPRS - User Access rights to his/her own profile and view-only SPRS view module rights to the work information of other staff. and Edit/Save his/her own local fields SPRS - Access rights to all staff profile information and All SPRS modules Manager certain reports. including the reporting module SPRS - Access rights to all staff profile information and Full access to all the Admin certain reports. SPRS modules Access rights to the SPRS non-staff reference data.
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.
SPRS does not share any information with other NRC systems outside the Region I domain, except applications used specifically for Region I employees.
4.3 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 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 PIA Template (08-2023) 6
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
SPRS is accessed through the Region I intranet and uses the role-based access mechanism.
All privileged domain accounts are logged and recorded by Splunk. Region I application administrators receive Splunk reports daily. Region I application administrators are also able to run a report at the application level that shows privileged user actions.
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 staff information comes from the ICAM view and can only be accessed through internal application code. The code is also embedded with security logic to prevent unauthorized method calls. The security logics have been implemented to check the role-based access right to reveal authorized data.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
The data is stored in the Region I SQL server.
4.7 Explain if the project can be accessed or operated at more than one location.
The SPRS is only hosted by the Region I IIS server and the code only resides in the protected NRC server domain. It is the Region I intranet application.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
Yes, all contractors have gone through the security check and have been issued valid NRC badges.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
The Region I Data Warehouse used by the EDAM suite implements the following audit columns and is available for auditing purposes as needed.
CreatedDate, CreatedBy, LastModifiedDate, LastModifiedBy.
4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
Yes, the SPRS database table has implemented auditing fields such as CreateBy, ModifiedBy, CreateByTimestamp, and ModifyByTimestamp.
4.11 Define which FISMA boundary this project is part of.
BASS.
PIA Template (08-2023) 7
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 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.
20210011.
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.
Information from the Staff Profile Request System (SPRS) is retrieved by individual names.
No, the PII is not retrieved by a personal identifier.
If no, explain how the data is retrieved from the project.
PIA Template (08-2023) 8
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 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, (List all SORNs that apply):
SPRS is covered by NRC-36, Employee Locator 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?
This is not applicable because data comes from the ICAM view and has been approved and predefined.
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 PIA Template (08-2023) 9
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 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 RIM - 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 (08-2023) 10
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 6.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.
System Name (include sub-systems, platforms, or Region I (RAPP-RI) other locations where the same data resides)
Records Retention Schedule Number(s) See the table below for a listing of RAPP-RI modules and records retention schedules.
Approved Disposition Instructions See the table below for a listing of RAPP-RI modules and Disposition Instructions.
RAPP-RI Module Module Description Schedule Number Disposition Reg I Data Consolidates all RI *Reference Copy Retain until it is no Warehouse databases into a longer needed for single warehouse Data collections business use.
which will host all RI should be retained modernized according to the databases NUREG 0910 Part 25 (Regions) and NARAs GRS Staff Profile Request Manages Emergency GRS 5.3 item 020 - Temporary. Destroy System (SPRS) Response Staff Employee when superseded or information and the emergency contact obsolete, or upon staff reporting system information separation or transfer of employees Request Tracking Provides a purchase GRS 1.1 item 011 - Temporary. Destroy System (RTS) tracking system that Financial transaction when business use tracks all of the RI records related to ceases.
Form 30 purchase procuring goods and activities services, paying bills, collecting debts, and accounting. All other copies. Copies used for administrative or reference purposes.
(This assumes that OCFO holds the official copy.)
PIA Template (08-2023) 11
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 Government Vehicle Provides the GRS 5.4 item 010 - Temporary. Destroy Reservations System interface for users to Facility, space, when 3 years old or 3 (GVRS) reserve government vehicle, equipment, years after vehicles. The system stock, and supply superseded, as allows users to administrative and appropriate, but interact with the operational longer retention is vehicle management recordsrecords authorized if required team to report and scheduling and for business use.
maintain vehicle dispatching condition. vehicles GRS 5.4 item 090 - Temporary. Destroy Land vehicle and when 3 years old, but water vessel longer retention is inspection, authorized if required maintenance, and for business use.
service records. Transfer of extant records to new owns at sale or donation is authorized.
GRS 5.4 item 110 - Temporary. Destroy Vehicle and heavy 3 years after equipment operator separation of records. employee or 3 years after rescission of authorization to operate vehicles or equipment, whichever is sooner.
Emergency Provides a web GRS 5.3 item 020 - Temporary. Destroy Responsibility access system that Employee when superseded or Scheduling System allows all emergency emergency contact obsolete, or upon (EROAS) response members information separation or transfer to log their availability of employees through the ERO system. In addition to the logged availability, the system can generate EROAS reports based on management needs.
PIA Template (08-2023) 12
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 Ask Management Provides a web GRS 5.8 item 010 - Temporary. Destroy Feedback System access system that Technical and 1 year after resolved, (AMFS) regional staff use to administrative help or when no longer communicate with desk operational needed for business the management records use, whichever is team through a appropriate.
question-and-answer format. The AMFS implements role-based security to provide question privacy (anonymous submission) and automates the AMS publication processes.
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) 7 Paperwork Reduction Act The Paperwork Reduction Act (PRA) of 1995 requires that agencies obtain an 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.
PIA Template (08-2023) 13
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 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?
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 (08-2023) 14
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 8 Privacy Act Determination Project/System Name: Regional Applications - Region I (RAPP-RI).
Submitting Office: Office of the Chief Information Officer (OCIO).
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:
The Staff Profile Request System (SPRS) is covered by NRC-36, Employee Locator Records.
Reviewers Name Title Signed by Hardy, Sally on 12/06/23 Privacy Officer PIA Template (08-2023) 15
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 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:
An OMB clearance is not needed if the collection of information from contractors is within the scope of their contract.
Reviewers Name Title Signed by Cullison, David on 11/17/23 Agency Clearance Officer PIA Template (08-2023) 16
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 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 11/20/23 Sr. Program Analyst, Electronic Records Manager PIA Template (08-2023) 17
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 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 Feibus, Jonathan on 12/06/23 Chief Information Security Officer Chief Information Security Division Office of the Chief Information Officer PIA Template (08-2023) 18
Regional Applications - Region I (RAPP-RI) Version 1.0 Privacy Impact Assessment 10/02/2023 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System: Regional Applications - Region I (RAPP-RI)
Date CISD received PIA for review: Date CISD completed PIA review:
October 31, 2023 December 1, 2023 Action Items/Concerns:
Copies of this PIA will be provided to:
Caroline Carusone Director IT Services Development and Operations Division Office of the Chief Information Officer Garo Nalabandian Deputy Chief Information Security Officer (CISO)
Office of the Chief Information Officer PIA Template (08-2023) 19