ML23325A080
| ML23325A080 | |
| Person / Time | |
|---|---|
| Issue date: | 10/27/2023 |
| From: | Natalya Bobryakova NRC/OCIO/CISD, Oasis Systems |
| To: | |
| Bobryakova N | |
| References | |
| Download: ML23325A080 (20) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Electronic Official Personnel Folder (eOPF)
Office of the Chief Human Capital Officer (OCHCO) /
Office of the Chief Information Officer (OCIO)
Version 1.0 10/27/2023 Template Version 2.0 (08/2023)
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 Document Revision History Date Version PIA Name/Description Author 10/27/2023 1.0 eOPF - FINAL Release OCHCO / OCIO Oasis Systems, LLC 10/03/2023 DRAFT eOPF - DRAFT Release OCHCO / OCIO Oasis Systems, LLC
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 Table of Contents 1 Description 1 2 Authorities and Other Requirements 3 3 Characterization of the Information 5 4 Data Security 6 5 Privacy Act Determination 9 6 Records and Information Management-Retention and Disposal 10 7 Paperwork Reduction Act 13 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
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 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: Electronic Official Personnel Folder (eOPF).
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) Other Federal Government Agency; U.S. Office of Personnel Management (OPM).
Date Submitted for review/approval: November 8, 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 Electronic Official Personnel Folder (eOPF) system is owned by the U.S. Office of Personnel Management (OPM) Office of the Chief Information Officer Federal Data Solutions Data Warehouse Program. eOPF was developed by OPM for all Federal agencies as an e-Government initiative to manage and administer the official personnel files and to provide online access to personnel information for Human Resources (HR) staff, managers, and employees.
Each Federal employee has an Official Personnel Folder (OPF) which documents their entire period of Federal civilian service. The eOPF system maintains the electronic versions of the OPF for Federal employees and contains various official personnel files and human resource records used by the HR office. Each Federal employee has read only access to their individual folder in eOPF. The U.S. Nuclear Regulatory Commission (NRC) staff with assigned roles and responsibilities manage the NRCs users and data within the eOPF system.
Please mark appropriate response below if your project/system will involve the following:
PowerApps Public Website Dashboard Internal Website SharePoint None Other: Web-based system owned and operated by OPM PIA Template (08-2023) 1
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 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.
The PIA has been transferred into the latest template Other (explain) 1.3 Points of
Contact:
System Owner Business Technical Project Executive
/Data ISSO Project Project Manager Sponsor Owner Manager Manager
/Steward Mary Natalya Name Brendan Cain N/A Brendan Cain Mary Lamary Lamary Bobryakova Office of the Office of the Office of the Chief Human Chief Human Office of the Chief Capital Officer Capital Officer Office of the Chief Information Office (OCHCO) (OCHCO) / Chief Human Human Officer (OCIO)
/Division /Human N/A Human Capital Capital /Cyber and
/Branch Capital Capital Officer Officer Infrastructure Analysis Analysis (OCHCO)
(OCHCO) Security Branch Branch Division (CISD)
(HCAB) (HCAB) 301-415- 301-415-Telephone 301-287-0552 301-287-0671 N/A 301-287-0552 3300 3300 PIA Template (08-2023) 2
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 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 Authority Citation/Reference X on all that apply.
Statute 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). These determinations are made through records retention PIA Template (12-2020) 12 schedules and NARA statutes (44 United States Code (U.S.C.), 36 Code of Federation Regulations (CFR)). Under 36 CFR 1234.10, agencies are required to establish procedures for addressing records management requirements, including recordkeeping requirements and disposition, before approving new electronic information systems or enhancements to existing systems. The following question is intended to determine whether the records and data/information in the system have approved records retention schedule and disposition instructions, whether the system incorporates Records and Information Management and NARAs Universal Electronic Records Management requirements, and if a strategy is needed to ensure compliance.
Executive Order In general, OPM collects and maintains the information in eOPF pursuant to 5 United States Code (U.S.C.) §§ 1104, 1302, 2951, 3301, and 4315; E.O. 12107 (December 28, 1978), 3 CFR 1954-1958 Comp.; 5 U.S.C. 1104, and 1302; 5 CFR 7.2; Executive Orders 9830 and 12107; 3 CFR 1943-1948 Comp.; and 5 U.S.C. 2951(2) and 3301 authorize the maintenance of records the Government needs to make accurate employment decisions throughout an employees career.
5 CFR Chapter 1 Part 293 Personnel Records.
Federal 5 Code of Federation Regulations (CFR) 293.302 Regulation created the OPF to house paper records used by Federal government HR offices. These records establish an employment history that includes grades, occupations and pay, and records choices under Federal benefits PIA Template (08-2023) 3
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 Mark with an Authority Citation/Reference X on all that apply.
programs and were maintained as paper in agency HR offices until they were converted to digital images as part of an e-Government initiative established in response to the E-Government Act of 2002.
Memorandum of Understanding/
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).
The data is used by HR personnel for human resource functions. Each NRC employee can view their personnel forms and information in eOPF.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
Information in eOPF is indexed/filed using the Social Security Number (SSN) in combination with the employees full name and date of birth to validate the employees identity and assure correct filing of documents. Records can be retrieved by employee name and/or SSN.
PIA Template (08-2023) 4
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 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 Former NRC employees 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: Veterans preference status, tenure, minority group designator, Children Information physical handicaps, past and present salaries, grades, position titles, and Mother's Maiden Name employee locator information identifying work address and phone numbers.
PIA Template (08-2023) 5
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 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).
The NRC HR specialists submit forms to eOPF for filing in an employees eOPF. The information on the forms is completed by the individual or by the HR specialists.
3.2 If using a form to collect the information, provide the form number, title and/or a link.
The information maintained in eOPF is listed in the OPM/GOVT-1 SORN (General Personnel Records) published in the Federal Register.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
The information maintained in eOPF is provided by the individual and agencys HR specialists.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
Employees have access to their records to verify that they are relevant, timely, or complete in accordance with the Privacy Act. Employees can request an amendment, correction, or deletion of their records when the records are inaccurate.
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?
Employees have access to their records to verify that they are relevant, timely, or complete in accordance with the Privacy Act. Employees can request an amendment, correction, or deletion of their records when the records are inaccurate.
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).
NRCs Office of the Chief Human Capital Officer (OCHCO), the Office of the Inspector General (OIG), and employees have access to the 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.
N/A.
4.3 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.
The information in eOPF may be shared for background investigation purposes with Defense Counterintelligence and Security Agency (DCSA) investigators, who access OPF to perform work during investigations such as initial background checks and renewal of existing investigations.
PIA Template (08-2023) 6
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 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: DCSA is not authorized to conduct a background investigation unless a release, signed by the subject of the investigation is received.
None 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
eOPF employs role-based access controls, which categorize users as employee, Investigator, HR Specialist, or agency administrator, and permits access according to users role. Authorized users can authenticate to eOPF using a Personal Identity Verification (PIV) card credentials or Login.gov account.
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).
Data can be transmitted through a secure web connection (HTTPS) from FPPS to the eOPF server using Connect: Direct or Connect: Direct Secure + Option.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
eOPF is hosted by the Office of Personnel Management (OPM) in the Macon Data Center.
4.7 Explain if the project can be accessed or operated at more than one location.
No.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
Yes, eOPF can be accessed by a contractor. Any OCHCO contractors that might access eOPF are badged.
This system will maintain information about individuals, ensure Privacy Act and/or Personally Identifiable Information (PII) contract clauses are inserted in their contracts.
- Federal Acquisition Regulation (FAR) clause 52.224-1 and FAR clause 52.224-2 should be referenced in all contracts, when the design, development, or operation of a system of records on individuals is required to accomplish an agency function.
- PII clause, Contractor Responsibility for Protecting Personally Identifiable Information (June 2009), in all contracts, purchase orders, and orders against other agency contracts and interagency agreements that involve contractor access to NRC owned or controlled PII.
PIA Template (08-2023) 7
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
There are reports available for monitoring use of the system by each agency.
Additional reports can be generated if needed.
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.
NRCs eOPF is a component of Third-Party System (TPS) OCHCO External Services (OES)
Subsystem.
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 The OPM issued an Authority to Operate (ATO) for eOPF on July 8, 2019.
NRC issued an ongoing ATO for the TPS-OES subsystem on December 20, 2018, (ADAMS accession number ML18354A944).
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 TPS EA number is 20180002.
Guidance for retentions comes from the Office of Personnel Managements The Guide to Personnel Recordkeeping, OPM/GOVT-1 SORN and NARAs GRS 2.2 - Employee Management Records and GRS 5.2 - Transitory and Intermediary Records.
PIA Template (08-2023) 8
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 5 Privacy Act Determination 5.1 Is the data collected retrieved by a personal identifier?
Mark the appropriate response.
Response
Yes, the PII is retrieved by a personal identifier (i.e., individuals name, address, SSN, etc.)
List the identifiers that will be used to retrieve the information on the individual.
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 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):
Government-wide SORN: OPM/GOVT General Personnel 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.
PIA Template (08-2023) 9
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 5.3 When an individual is asked to provide personal data (i.e., form, webpage, survey), is a Privacy Act Statement (PAS) provided?
A Privacy Act Statement is a disclosure statement required to appear on documents used by agencies when an individual is asked to provide personal data. It is required for any forms, surveys, or other documents, including electronic forms, used to solicit personal information from individuals that will be maintained in a system of records.
Mark the appropriate response.
Options Privacy Act Statement Not Applicable Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
N/A.
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 PIA Template (08-2023) 10
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023
- 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) 11
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 6.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.
System Name (include sub- eOPF systems, platforms, or other locations where the same data resides)
Records Retention Schedule GRS 2.2 Item 040 Official Personnel Folder (Long Number(s) Term Records)
GRS 2.2 Item 041 Official Personnel Folder (Short Term Records)
GRS 5.2 Item 020 - Intermediary records Approved Disposition Instructions GRS 2.2 Item 040 Temporary. Destroy when survivor or retirement claims are adjudicated or when records are 129 years old, whichever is sooner, but longer retention is authorized if required for business use.
GRS 2.2 Item 041 Temporary. Destroy when superseded or obsolete, or upon separation or transfer of employee, whichever is earlier.
GRS 5.2 Item 020 Temporary. Destroy upon creation or update of the final record, or when no longer needed for business use, whichever is later. (Enterprise Human Resource Integration).
Transferring eOPF
- Serviced by a different personnel office in the same agency;
- In another agency when both offices transfer personnel and medical folders; and
- In an agency that does not transfer personnel and medical folders.
Transferring Records to the National Personnel Records Center (NPRC)
Under normal circumstances, the eOPF is transferred to NPRC 90 days after separation from Federal service.
Is there a current automated N/A functionality or a manual process to support RIM requirements? This includes the ability to apply records PIA Template (08-2023) 12
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 retention and disposition policies in the system(s) to support records accessibility, reliability, integrity, and disposition.
Disposition of Temporary Records Yes 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 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 (08-2023) 13
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 8 Privacy Act Determination Project/System Name: Electronic Official Personnel Folder (eOPF).
Submitting Office: Office of the Chief Human Capital Officer (OCHCO).
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-1(General Personnel Records)
Reviewers Name Title Signed by Hardy, Sally on 12/07/23 Privacy Officer PIA Template (08-2023) 14
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 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:
Reviewers Name Title Signed by Cullison, David on 11/27/23 Agency Clearance Officer PIA Template (08-2023) 15
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 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 12/06/23 Sr. Program Analyst, Electronic Records Manager PIA Template (08-2023) 16
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 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 12/07/23 Chief Information Security Officer Chief Information Security Division Office of the Chief Information Officer PIA Template (08-2023) 17
Electronic Official Personnel Folder (eOPF) Version 1.0 Privacy Impact Assessment 10/27/2023 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System: Electronic Official Personnel Folder (eOPF)
Date CISD received PIA for review: Date CISD completed PIA review:
November 21, 2023 December 6,2023 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) 18