ML24260A129
| ML24260A129 | |
| Person / Time | |
|---|---|
| Issue date: | 07/24/2024 |
| From: | NRC/OCFO, NRC/OCIO/CISD |
| To: | |
| Hardy S | |
| References | |
| Download: ML24260A129 (10) | |
Text
U.S. Nuclear Regulatory Commission Privacy Threshold Analysis Do Not Pay (DNP) Portal Office of the Chief Information Officer (OCIO)
Office of the Chief Financial Officer (OCFO)
Version 2.0 07/24/2024 Template Version 2.2 (05/2024)-ML091970114
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 Document Revision History Date Version PTA Name/Description Author 7/24/2024 2.0 Do Not Pay (DNP) - Annual Review Certification-Updated Points of Contact and transferred to the latest template OCIO/OCFO Oasis Systems, LLC 07/08/2024 DRAFT Do Not Pay (DNP) - Annual Review Certification-Updated Points of Contact and transferred to the latest template OCIO/OCFO Oasis Systems, LLC 08/22/2023 1.0 DNP PTA - Initial Release OCIO/OCFO Oasis Systems, LLC 08/02/2023 DRAFT DNP PTA - Draft Release OCIO/OCFO Oasis Systems, LLC
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 Table of Contents 1
Description 1
2 Characterization of the Information 3
3 Records and Information Management-Retention and Disposal 5
4 Privacy Act Determination 8
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 PTA Template (05/2024)-ML091970114 1
System/Project Name: Do Not Pay (DNP) Portal.
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): DNP is externally hosted by the U.S. Department of the Treasury (USDT) Bureau of the Fiscal Service.
Date Submitted for review/approval: July 24, 2024 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 Do Not Pay (DNP) Portal is operated by the U. S. Department of the Treasury (USDT)
Bureau of the Fiscal Service. This system was established to serve as a single point of entry through which agencies access relevant data in order to determine eligibility for a Federal award or payment. The Nuclear Regulatory Commission (NRC) is required to use the DNP Portal to verify eligibility for Federal payment recipients to reduce payment errors. USDT has created a Privacy Impact Assessment (PIA) for DNP that addresses the scope and uses PII stored and maintained within the system.
The NRC receives a secure vendor file via e-mail from the NRCs Financial Accounting and Integrated Management Information System (FAIMIS) and uploads the file to DNP to check against various USDT databases in the DNP Portal. When a match is made between the FAIMIS vendor file and the DNP databases, a report is generated in DNP and viewed by OCFO staff via the portal. Results from the file comparison are only viewed within DNP and require further investigation to determine any future actions.
The DNP Portal supports the NRCs payment function by verifying the accuracy of payments being made to vendors. The DNP Portal compares a list of NRC payees to the Treasury Departments list of parties that should not receive Federal payments.
Please indicate if your project/system will involve the following:
PowerApps Server/Database Design Dashboard Public Website SharePoint Internal Website Cloud Service Provider Other: Government Agency Website -
Nuclear Regulatory Commission (NRC) users can access the DNP application through Connect.gov.
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 PTA Template (05/2024)-ML091970114 2
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. PTA updated to the latest template and updated points of contact.
Other (explain) 1.3 Points of
Contact:
Project Manager System Owner/Data Owner/Steward ISSM Executive Sponsor Name Erikka LeGrand Owen Barwell Jonathan Butler N/A Office/Division
/Branch Office of the Chief Financial Officer (OCFO)
/Division of the Comptroller (DOC) /Financial Services &
Operations Branch (FSOB)
Chief Financial Officer/ Office of the Chief Financial Officer (OCFO)
Office of the Chief Information Officer (OCIO)/
Cyber and Infrastructure Security Division (CISD)
Information Assurance &
Oversight Branch (IAOB)
/Information Assurance Team (IAT)
N/A Telephone 301-415-7748 301-415-5059 301-415-2560
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 PTA Template (05/2024)-ML091970114 3
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 Please list the data fields/information being collected in the system.
The data being collected includes name, social security number, tax ID number, employer identification number, address, and banking information.
2.2 Is the project/system collecting information about an individual? If yes, provide a description of the information being collected.
Yes. The information available through the DNP Portal can relate to individuals as stated above.
Users can query the system to check and verify the eligibility of payment recipients.
2.3 Does this project use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs, such as the last four.)
Yes.
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).
The DNP database is maintained by the USDT. The NRCs vendor file received from FAIMIS collects and retains information about payment recipients. The FAIMIS vendor file is downloaded locally by the OCFO staff and immediately deleted once the file is uploaded to DNP.
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 PTA Template (05/2024)-ML091970114 4
2.5 If using a form (paper or web) to collect the information, provide the form number, title and/or a link.
The NRCs vendor file is received from FAIMIS.
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.
If so, 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: Interconnection Security Agreement (ISA) And Memorandum of Agreement (MOA) Between The Department of the Treasury Bureau of the Fiscal Service Treasury Web Application Infrastructure (TWAI) And The U.S. Nuclear Regulatory Commission Dated July 2022, ML22172A179.
None 2.8 Describe how the data is accessed (NRC network/remotely) and the access control mechanisms that prevent misuse.
USDT owns and manages DNP application and is responsible for user identification and authentication to the system. NRC relies completely on USDT to provide and manage unique credentials for NRC users. NRC users can authenticate via Personal Identity Verification (PIV) card to the DNP application via the Connect.Gov website. The NRC PIV cards are issued by ITI ICAM and are compliant with Federal Information Processing Standard (FIPS) 201-1, Personal Identity Verification (PIV) of Federal Employees and Contractors.
2.9 Define the FISMA boundary this project/system is part of.
DNP is a component of the NRCs Third-Party System (TPS) OCFO ES Subsystem.
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 PTA Template (05/2024)-ML091970114 5
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 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 TPS EA number is 20180002.
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
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 PTA Template (05/2024)-ML091970114 6
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.
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 other locations where the same data resides)
Do Not Pay (DNP) Portal.
FAIMIS Output (used as an input to DNP)
Records Retention Schedule Number(s)
DNP system is covered by the System of Records Notice - TREASURY/Fiscal Service
.023 - Do Not Pay Payment Verification Records.
FAIMIS Output - GRS 5.2 item 020 -
Intermediary records Approved Disposition Instructions 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.
Records created or collected by DNP are governed by the
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 PTA Template (05/2024)-ML091970114 7
National Archives and Records Administration (NARA) records schedule and are generally retained for a maximum of seven years after the end of the fiscal year in which the record was created.
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 in the system(s) to support records accessibility, reliability, integrity, and disposition.
USDT owns the DNP system and is responsible for the retention of its data.
Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
USDT owns the DNP system and is responsible for the retention of its data.
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)
USDT owns the DNP system and is responsible for the retention of its data.
Do Not Pay (DNP) Portal Version 2.0 Privacy Threshold Analysis 07/24/2024 PTA Template (05/2024)-ML091970114 8
4 Privacy Act Determination Review Results Action Items
This project/system does not contain PII.
No further action is necessary for Privacy.
This project/system does contain PII A privacy impact assessment is required
Other See comments section below for further details.
Comments:
Reviewers Name Title Privacy Officer I concur with this analysis.
Director Chief Information Security Officer Cyber Information Security Division Office of the Chief Information Officer Signed by Hardy, Sally on 10/28/24 Signed by Nalabandian, Garo on 11/01/24