ML24264A019
| ML24264A019 | |
| Person / Time | |
|---|---|
| Issue date: | 11/01/2024 |
| From: | Howerton J NRC/OCFO/DOC |
| To: | |
| Howerton J | |
| References | |
| Download: ML24264A019 (16) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Financial Management Systems (FMS) - Financial Management Data Mart (FMDM)
Office of the Chief Financial Officer (OCFO)
Version 1.2 09/12/2024 Template Version 2.2 (05/2024)
Financial Management Systems (FMS) -
Financial Management Data Mart (FMDM)
Version 1.2 Privacy Impact Assessment 09/12/2024 Document Revision History Date Version PIA Name/Description Author 09/12/2024 1.2 Final version updated to include additional ISSM comments/updates OCFO Oasis Systems, LLC 08/20/2024 1.1 FMS FMDM PIA Annual Update and transferred into new template OCFO Oasis Systems, LLC 08/06/2024 DRAFT of v1.1 FMS FMDM PIA Annual Update and transferred into new template OCFO Oasis Systems, LLC 07/17/2023 1.0 FMS FMDM PIA Initial Release OCFO Oasis Systems, LLC 06/23/2023 DRAFT FMS FMDM PIA Draft Release OCFO Oasis Systems, LLC
Financial Management Systems (FMS) -
Financial Management Data Mart (FMDM)
Version 1.2 Privacy Impact Assessment 09/12/2024 Table of Contents 1
Description 1
2 Authorities and Other Requirements 2
3 Characterization of the Information 4
4 Data Security 6
5 Privacy Act Determination 9
6 Records and Information Management-Retention and Disposal 10 7
Paperwork Reduction Act 12 8
Privacy Act Determination 14 9
OMB Clearance Determination 15 10 Records Retention and Disposal Schedule Determination 16 11 Review and Concurrence 17
Financial Management Systems (FMS) -
Financial Management Data Mart (FMDM)
Version 1.2 Privacy Impact Assessment 09/12/2024 PIA Template (05-2024)-ML050460335 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: Financial Management Systems (FMS) - Financial Management Data Mart (FMDM)
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) Database Server Date Submitted for review/approval: September 12, 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.
FMS is owned and managed by the Office of the Chief Financial Officer (OCFO). FMS provides the framework for managing cybersecurity compliance for OCFO financial services and systems used by the Nuclear Regulatory Commission (NRC). FMS is an umbrella system that is comprised of subsystems and services that support mission and business functions that OCFO provides for the agency. FMDM is a service under FMS that serves as a centralized repository of integrated data from the NRC's financial management systems. Its primary purpose is to provide timely, accurate financial data from authoritative data sources for the purpose of reporting and data analytics. The FMDM also feeds data to the NRC Enterprise Data Warehouse.
Information in the FMDM contains employee name, ID, location, position, and position ID; as well as pay amounts (salary and benefits), hours charged, and time codes used. Only the Legacy PAYPERS database (DB) contains personally identifiable information (PII). The PAYPERS DB stored and maintained Time & Attendance records and Earnings & Leave Statements for NRC employees between November 1998 and November 2001. After the frontend application was retired in 2002, the data collected by PAYPERS was put into the new Payroll Historical Database (PHDB) for historical purposes and later was migrated to the FMS Human Resources Management System (HRMS) subsystem. In 2021, the PAYPERS DB was moved to the servers repurposed for FMDM activities. The data originally stored in the PAYPERS DB has not been modified since the data was originally collected.
Please mark appropriate response below if your project/system will involve the following:
PowerApps Server/Database Design Dashboard Public Website SharePoint Internal Website
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Cloud Service Provider 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) 1.3 Points of
Contact:
Project Manager System Owner/Data Owner/Steward ISSM Business Project Manager Technical Project Manager Executive Sponsor Name Abby Olarte Owen Barwell John Howerto n
Susan Hayden Daniel Klein Owen Barwell Office/Division
/Branch OCFO/DO C/FSB OCFO OCFO/D OC/FSB OCFO/DO C/FSB OCFO OCFO Telephone 301-415-6288 301-415-5059 301-415-8170 301-415-6206 N/A 301-415-5059 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.
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Mark with an X on all that apply.
Authority Citation/Reference
Statute 5 United States Code (U.S.C.) 5101 et seq. & 5501 et seq.; 5 U.S.C. 5701 et seq.,
5525 et seq., & 6301 et seq.; 31 U.S.C.
716, 1104, 1105, 1108, 3325, 3511, 3512, 3701, 3711, 3717, & 3718; and Public Law 104-193, Personal Responsibility and Work Opportunity Reconciliation Act of 1996
Executive Order Executive Order (E.O.) 9397, Numbering System for Federal Accounts Relating to Individual Persons (Nov. 22, 1943)
Federal Regulation
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).
Information in the FMDM supports budget formulation and forecasting needs for the NRC across procurement spending, commitment planning, salaries, and benefits, Full Time Equivalent (FTE), and funding for employees.
Information stored in the FMDM is used for future funding considerations and decisions, financial reporting, and Tableau dashboard reporting.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
The Legacy PAYPERS DB contains employee name, date of birth, SSN, and address.
Please note, this information was collected from November 1998 through November 2001. The PAYPERS front end application has since been retired, and no further information was collected. This information is available based on need and in read-only view.
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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
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/Home Number
Accommodation/disabilities information
Marital Status
Children Information
Mother's Maiden Name
Other
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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 in the FMDM is not collected directly from the subject individual. Information is collected from existing NRC files/databases via direct connection (linked server, JDBC connections), or flat file:
HCM Cloud for Time and Labor System (HCMTL) & Office of the Chief Human Capital Officer (OCHCO) / Federal Personnel Payroll System (FPPS) - Salary/benefit amounts, employee duty location, employee pay grade/step, position title, employee and position ID, hours worked, and time codes charged.
Budget Formulation System (BFS) - Procurement spends planning, budget formulation, commitment planning.
Financial Accounting and Integrated Management Information System (FAIMIS) -
General financial information (commitments, obligations, expenditures).
Strategic Acquisition System (STAQS) - Contract information (ceiling, period of performance, COR) used for procurement spend planning.
Federal Planning and Architecture Support System (FEDPASS) - Transmission of pending IT changes between approvers and financial planners within BFSs commitment planning module.
As it relates to the data from the Legacy PAYPERS DB, data was transferred from the PAYPERS system to the PHDB in 2002, and from HRMS in 2021.
3.2 If using a form (paper or web) to collect the information, provide the form number, title and/or a link to the form.
N/A.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
Information in FMDM is not collected directly from subject individuals. Refer to section 3.1 regarding data sources (HCMTL, OCHCO/FPPS, BFS, FAIMIS, STAQS, FEDPASS, and Legacy PAYPERS DB).
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
Data is sourced from the respective systems of record at NRC. Data accuracy is verified by the respective systems in which the data is originally collected from the individual.
As it relates to the data from the Legacy PAYPERS DB, the information was verified in 2002 when the PHDB was tested and compared to the PAYPERS system from which it was derived.
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3.5 Will PII data be used in a test environment? If so, explain the rationale for this and how the PII information is protected.
N/A.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous privacy information?
No data used or maintained by the FMDM is collected from the subject individual. All information maintained by the service is from data transfers from other systems/services, as discussed in section 3.1 (HCMTL, OCHCO/FPPS, BFS, FAIMIS, STAQS, FEDPASS, and Legacy PAYPERS DB). If the individual wants to correct inaccurate PII, they must correct the PII in the source system/service.
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).
Access to the server hosting the FMDM is restricted to OCFO administrators. However, data stored on the servers for the purpose of the FMDM is available to NRC personnel with roles and responsibilities related to budget planning and reporting who have requested access to the budget formulation data set. Request forms must be reviewed and approved by OCFO.
Access controls exist on the application and associated Tableau data sets to ensure that only allowed individuals can access this 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.
Data in the FMDM is collected from existing NRC files/databases via direct connection (linked server, JDBC connections), or flat file:
HCMTL provides general employee information, employee salaries, as well as benefits, payroll, time and attendance, and activity-based work hour data via flat file for the BFS SALARY module.
FAIMIS provides financial transaction activity data via JDBC connection for BFS BUDGET and SPENDPLN module.
STAQS provides procurement contractual activity data via SQL server link for the BFS SPENDPLN module.
FEDPASS provides a view of all transactions received and their processing status via SQL server link BFS CPM module.
4.3 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.
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If so, 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.
Accounts for BFS administrators and FMDM users viewing budgeting data are restricted to NRC personnel with a LAN ID and a need-to-know. Accounts are integrated with the NRC Information Technology Infrastructure (ITI) Identity, Credential, and Access Management (ICAM) for Single Sign-On (SSO).
Users only have access to the data for which they have a need-to-know and have received approval from OCFO to access. Data sources themselves cannot be edited without stepped up access provisions, such as administrator provisions.
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 in the FMDM is collected from existing NRC files/databases via direct connection (linked server, JDBC connections), or flat file, as discussed above in section 4.2. Communications are encrypted and transmitted within the NRC firewall.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
Data is being stored on cloud servers. FMDM has successfully migrated to the cloud in the NRC ACS tenant.
4.7 Explain if the project can be accessed or operated at more than one location.
Access control is governed by URL; therefore, control can be consistently applied even across the different BFS URL links.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
Yes, all contractors supporting FMDM are, at minimum, NRC IT-I cleared, possessing NRC badges.
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4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
Auditing tools track user/administrator actions, such as data updates, calculations run, metadata updates, etc.
4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
N/A.
4.11 Define which FISMA boundary this project is part of.
FMDM operates as a service under the FMS FISMA boundary.
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.
The FMS EA number is 20190012.
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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, or other unique number, etc.)
List the identifiers that will be used to retrieve the information on the individual.
Users will not typically view data in this manner, but employee name/ID can be used to pull data for a specific individual.
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):
NRC-21, Payroll Accounting 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.
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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?
FMDM does not collect PII directly form the subject individuals, it is the responsibility of the source system/service to inform individuals whether or not PII disclosure is mandatory or voluntary.
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.
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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)
Financial Management Systems (FMS) - Financial Management Data Mart (FMDM)
Records Retention Schedule Number(s)
GRS 1.1 Financial Management and Reporting Records GRS 2.4 Employee Compensation and Benefits Records GRS 1.3 Budgeting Records Approved Disposition Instructions FMDM is Unscheduled; suggested disposition instruction for records in Masterfile: Temporary. Cut off records when no longer needed or when migrated to a successor system. Destroy/delete XXX after cutoff.
Additional information/data/records kept in this system may need to be scheduled; therefore, NRC records personnel will need to work with
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Until the approval of such schedule, these records and information are Permanent. Their willful disposal or concealment (and related offenses) is punishable by fine or imprisonment, according to 18 U.S.C., Chapter 101, and Section 2071. Implementation of retention schedules is mandatory under 44 U.S. 3303a (d), and although this does not prevent further development of the project, retention functionality or a manual process must be incorporated to meet this requirement.
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.
N/A Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
N/A 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) 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.
Financial Management Systems (FMS) -
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Version 1.2 Privacy Impact Assessment 09/12/2024 PIA Template (05-2024)-ML050460335 13 7.1 Will the project be collecting any information from 10 or more persons who are not Federal employees?
N/A.
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?
N/A.
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.
STOP HERE - The remaining pages will be completed by the Privacy Officer, Records Management, and Information Collections Team.
Financial Management Systems (FMS) -
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Version 1.2 Privacy Impact Assessment 09/12/2024 PIA Template (05-2024)-ML050460335 14 8 Privacy Act Determination Project/System Name: Financial Management Systems (FMS) - Financial Management Data Mart (FMDM)
Submitting Office: Office of the Chief Financial Officer 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:
Covered by NRC-21, Payroll Accounting Records.
Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 11/01/24
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Version 1.2 Privacy Impact Assessment 09/12/2024 PIA Template (05-2024)-ML050460335 15 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:
FMS-FMDM does not collect information directly from individuals or organizations and is not subject to the requirements of the Paperwork Reduction Act.
Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 10/28/24
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Version 1.2 Privacy Impact Assessment 09/12/2024 PIA Template (05-2024)-ML050460335 16 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:
Additional information/data/records kept in this system may need to be scheduled; therefore, NRC records personnel will need to work with staff to develop a records retention and disposition schedule for records created or maintained. Until the approval of such schedule, these records and information are Permanent. Their willful disposal or concealment (and related offenses) is punishable by fine or imprisonment, according to 18 U.S.C., Chapter 101, and Section 2071. Implementation of retention schedules is mandatory under 44 U.S. 3303a (d), and although this does not prevent further development of the project, retention functionality or a manual process must be incorporated to meet this requirement.
Reviewers Name Title Sr. Program Analyst, Electronic Records Manager Signed by Dove, Marna on 10/28/24
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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 Cyber Information Security Division Office of the Chief Information Officer Signed by Nalabandian, Garo on 11/01/24
Financial Management Systems (FMS) -
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Version 1.2 Privacy Impact Assessment 09/12/2024 PIA Template (05-2024)-ML050460335 18 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Financial Management Systems (FMS) - Financial Management Data Mart (FMDM)
Date CISD received PIA for review:
Date CISD completed PIA review:
Action Items/Concerns:
Copies of this PIA will be provided to:
Gwen Hayden Acting Director IT Services Development and Operations Division Office of the Chief Information Officer Katie Harris Acting Deputy Chief Information Security Officer (CISO)
Office of the Chief Information Officer