ML24222A587
| ML24222A587 | |
| Person / Time | |
|---|---|
| Issue date: | 09/03/2024 |
| From: | Patrice Williams-Johnson NRC/OCFO |
| To: | |
| Williams-Johnson P | |
| References | |
| Download: ML24222A587 (1) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Summer Rise Office of the Chief Financial Officer (OCFO)
Version 1.0 07/18/2024 Template Version 2.0 (08/2023)
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 Document Revision History Date Version PIA Name/Description Author 07/18/2024 1.0 Initial Release Patrice Williams-Johnson
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 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 11 8
Privacy Act Determination 13 9
OMB Clearance Determination 14 10 Records Retention and Disposal Schedule Determination 15 11 Branch Chief Review and Concurrence 16
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 1 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: Summer RISE (Reimagining an Innovative Student Experience) Program Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) SharePoint online Date Submitted for review/approval: July 23, 2024 Note: When completing this PIA do not include any information that would raise security concerns or prevent this document from being made publicly available.
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.
There is no system associated with this program. The Office of the Financial Officer (OCFO) uses Microsoft Excel spreadsheet information provided by Montgomery County Public Schools (MCPS) Summer RISE Program Director. The information includes the contact information of high school students (or their parents) participating in the program. This program provides a pathway for Montgomery County Public School Students to explore and learn about career opportunities at the Nuclear Regulatory Commission (NRC). Rising MCPS juniors and seniors can participate in career-based learning opportunities during the summer and provided the opportunity to engage in hands-on learning opportunities related to their field of interest.
Please mark appropriate response below if your project/system will involve the following:
PowerApps Public Website Dashboard Internal Website SharePoint None Other <please explain >
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 2 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.
<Insert response here >
Annual Review If making minor edits to an existing system/project, briefly describe the changes below.
<Insert response here >
Other (explain) The program has been existing for several years but there has not been a Privacy Impact Assessment.
1.3 Points of
Contact:
(Do not adjust or change table fields. Annotate N/A if unknown. If multiple individuals need to be added in a certain field, please add lines where necessary.)
Project Manager System Owner/Data Owner/Steward ISSO Business Project Manager Technical Project Manager Executive Sponsor Name Patrice Williams-Johnson Office/Division
/Branch OCFO Telephone 301-415-5732
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 3 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 apply.
Authority Citation/Reference
Statute
Executive Order
Federal Regulation
Memorandum of Understanding/Agreement Summer RISE (is an initiative led by the Montgomery County Public Schools (MCPS) Department of Partnerships in collaboration with businesses, government agencies, higher education institutions, and nonprofit organizations through a MOU.
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 information collected allows the project manager and agency volunteers/hosts to communicate with students about program activities, scheduling, mentoring, etc.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
N/A
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 4 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 Students 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
Personal e-mail address
Biometric identifiers (facial images, fingerprints, iris scans)
Personal Bank Account Number
Emergency contact e.g., a third party to contact in case of an emergency
Personal Mobile Number
Accommodation/disabilities information
Marital Status
Children Information
Mother's Maiden Name
Other Note: Parental information for emergency contacts
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 5 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).
Data is collected from the MCPS Summer RISE Program Manager who shares information with the NRC Summer RISE Program Host. NRC Host completes the NRC Visitor Forms on behalf of the students.
3.2 If using a form to collect the information, provide the form number, title and/or a link.
The NRC Host completes the NRC Visitor Form with the students name and NRC Host contact information via the Visitors System.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
An individual (MCPS Summer RISE Program Director) provides the information to the NRC Summer RISE Program Host.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
MCPS collects the data from the students therefore the NRC assumes the information is accurate.
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 MCPS Summer RISE Program Director provides accurate information. If any issues, the NRC Summer RISE Host reaches out if needed.
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).
Specific internal NRC staff, IT contractors (to set up non-LAN accessible laptops) 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
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 6 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 - Group project information developed by students is shared with high school guidance counselors participating in program and attendees at closing ceremonies.
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 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
Students have NRC laptops that are not connected to NRC LAN. Additionally, the students do not have NRC email addresses and their communications on information they research using NRC laptops are done via their personal emails/phone numbers.
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).
N/A 4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
N/A 4.7 Explain if the project can be accessed or operated at more than one location.
N/A 4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
N/A 4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
Students are not allowed to remove the laptops from NRC premises. Laptops are locked up and assigned and distributed to the students when they are on physically at headquarters.
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 7 4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
Students do not have badges (only visitor passes) and are escorted. Hosts and volunteers stay with students throughout the day. At the end of the day, students turn in their visitor passes.
4.11 Define which FISMA boundary this project is part of.
N/A 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: <insert appropriate response>
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# - 20090005
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 8 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.
Students name and personal email
No, the PII is not retrieved by a personal identifier.
If no, explain how the data is retrieved from the project.
<Insert response here>
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):
<Insert response here>
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.
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 9 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?
Providing PII (name and email address) is required for participation in the program for communication purposes. The effect of a student not providing requested information may make them ineligible for participation.
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
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 10 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 6.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.
System Name (include sub-systems, platforms, or other locations where the same data resides)
Summer RISE (Reimagining an Innovative Student Experience)
Program (on a SharePoint Platform)
Records Retention Schedule Number(s)
The project does not have an approved records retention schedule.
GRS 2.2.110 Volunteer service case files Approved Disposition Instructions Temporary. Destroy 4 years after volunteer departs service, but longer retention is authorized if required for business use.
Is there a current automated functionality or a manual process to support RIM requirements? This includes the ability to apply records retention and disposition policies We need to communicate with the office for verification.
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 11 in the system(s) to support records accessibility, reliability, integrity, and disposition.
Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
We need to communicate with the office for verification.
Disposition of Permanent Records 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)
We need to communicate with the office for verification.
Note: Information in Section 6, Records and Information Management-Retention and Disposal, does not need to be fully resolved for final approval of the privacy impact assessment.
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?
Yes. However, the number of individuals may vary from year to year depending on the number of participants.
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)?
N/A 7.3 Is the collection of information required by a rule of general applicability?
Unknown 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.
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 12 STOP HERE - The remaining pages will be completed by the Privacy Officer, Records Management, and Information Collections Team.
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 13 8 Privacy Act Determination Project/System Name: Summer RISE Program Submitting Office: OCFO 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 Privacy Act does NOT apply, since information is NOT retrieved by a personal identifier.
Must be protected with restricted access to those with a valid need-to-know.
This project/system does contain PII; the Privacy Act does apply.
SORN is required-Information is retrieved by a personal identifier.
Comments:
SORN is required and is in the process of being established.
Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 08/30/24
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 14 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:
No clearance is needed if the information requested by the NRC from participants and their families does not exceed name, address, email address, and phone number. This includes any information collected by the Montgomery County Public Schools that is provided to the NRC.
Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 08/16/24
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 15 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 Sr. Program Analyst, Electronic Records Manager Signed by Dove, Marna on 08/22/24
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 16 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.
Director Chief Information Security Officer Chief Information Security Division Office of the Chief Information Officer Signed by Nalabandian, Garo on 09/03/24
Summer RISE Program Version 1.0 Privacy Impact Assessment 07/23/2024 PIA Template (08-2023) 17 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System: Summer RISE Program Date CISD received PIA for review:
July 23, 2024 Date CISD completed PIA review:
Action Items/Concerns:
Copies of this PIA will be provided to:
Gwen Hayden Director IT Services Development and Operations Division Office of the Chief Information Officer Katie Harris Deputy Chief Information Security Officer (CISO)
Office of the Chief Information Officer