ML24264A027
| ML24264A027 | |
| Person / Time | |
|---|---|
| Issue date: | 11/01/2024 |
| From: | Sally Hardy NRC/OCIO/CISD, Oasis Systems |
| To: | |
| Hardy S | |
| References | |
| Download: ML24264A027 (16) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Invoice Processing Platform (IPP)
Office of the Chief Information Officer (OCIO)/
Office of the Chief Financial Officer (OCFO)
Version 1.0 September 18, 2024 Template Version 2.2 (05/2024)
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 Document Revision History Date Version PIA Name/Description Author 09/18/2024 1.0 IPP PIA - Initial Release OCIO/OCFO Oasis Systems, LLC 09/10/2024 DRAFT IPP PIA - Draft Release OCIO/OCFO Oasis Systems, LLC
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 Table of Contents 1
Description 1
2 Authorities and Other Requirements 3
3 Characterization of the Information 4
4 Data Security 6
5 Privacy Act Determination 8
6 Records and Information Management-Retention and Disposal 10 7
Paperwork Reduction Act 12 8
Privacy Act Determination 13 9
OMB Clearance Determination 14 10 Records Retention and Disposal Schedule Determination 15 11 Review and Concurrence 16
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 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: Invoice Processing Platform (IPP)
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): IPP is externally hosted by the U.S. Department of the Treasury (USDT) Bureau of the Fiscal Service.
Date Submitted for review/approval: September 18, 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 Invoice Processing Platform (IPP) is a web-based system that provides one integrated, secure system to simplify the management of vendor invoices. IPP assists Federal agencies in dealings with their vendors, some of which are sole proprietors. IPP helps Federal agencies avoid Prompt Payment penalties by supporting more efficient invoice processing while automating invoice collection, validation, and approval workflows. NRC commercial vendors log into the IPP application to submit invoices to the NRC, which are reviewed and approved by the NRC Contracting Officers (COs), Contracting Officer Representatives (CORs), and IT managers Please mark appropriate response below 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 - U.S.
Department of the Treasury
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 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.
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 John Howerton James Corbett Jonathan Butler N/A John Howerton James Corbett Office/
Division
/Branch Office of the Chief Financial Officer (OCFO)/
Division of the Comptroller (DOC)/
Financial Systems Branch (FSB)
Office of Administratio n (ADM)
Office of the Chief Information Officer (OCIO)
/Cyber and Infrastructur e Security Division (CISD) /
Information Assurance Team (IAT)
N/A Office of the Chief Financial Officer (OCFO)/
Division of the Comptroller (DOC)/
Financial Systems Branch (FSB)
Office of Administratio n (ADM)
Telephon e
301-415-8170 301-415-8725 301-415-2560 N/A 301-415-8170 301-415-8725
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 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 See 31 U.S.C. §§ 301, 321, 3325, and 33013343; see also 31 U.S.C. 3321 note, as amended. Pursuant to 12 U.S.C. § 391, the Fiscal Service has directed a Federal Reserve Bank, in its capacity as Treasurys fiscal agent, to operate IPP.
Executive Order
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).
The Fiscal Service offers IPP services pursuant to its statutory authorities to provide payment and cash management services to NRC/USDT.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
Tax ID information is stored in IPP, in which some Taxpayer Identification Number (TIN) for small businesses can be an individuals SSN. However, in IPP, NRC can view the last 4 digits of a Tax ID number in IPP, not a full TIN.
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 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 - NRC Commercial Vendors 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) Only last 4 digits, see section 2.2 for more details
Medical/health information
Gender
Alien Registration Number
Ethnicity
Professional/personal references
Spouse Information
Criminal History
Personal email address
Biometric identifiers (facial images, fingerprints, iris scans)
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 5
Categories of Information
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 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 IPP database is maintained by the USDT. The NRCs commercial vendors login into IPP to submit invoices to the NRC, which are reviewed and approved by NRC CORs and COs.
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.
The NRCs vendor invoice is directly entered by the vendor and accessed by the NRC user in the IPP application.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
Enrollment Data is entered into our system via XMVL download which is auto generated via our enrollment bot. Sometimes data is entered manually in the system by the OCFO staff.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
If an accuracy error occurs, the OCFO staff would email the agency requesting clarification.
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.
No.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous privacy information?
Vendors (including Sole Proprietors) may request to be enrolled through the Invoice Processing Platform website (www.ipp.gov). Data validation techniques, such as agency confirmation of their vendors, are used to verify the accuracy of the data.
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 6
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).
OCFO staff only have access to a subset of data based on the permissions assigned in the system. Vendors can only access information related to them.
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.
N/A.
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: 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 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
USDT owns and manages the IPP 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 to the IPP application via a Personal Identity Verification (PIV) card. 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.
Invoice Processing Platform (IPP)
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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).
IPP is a web-based system, VPN TCP/IP traffic to the Fiscal Service is IPSEC-encrypted using AES algorithms.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
Fiscal Service business applications run on the TWAI at the Federal Reserve Information Technology (FRIT) data centers in Richmond, VA, Dallas, TX, and East Rutherford, NJ (EROC).
4.7 Explain if the project can be accessed or operated at more than one location.
IPP is externally owned, therefore it can be accessed by the external provider.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
No.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
Users are provided credentials via the User Provisioning Services. IPP users are authenticated when requesting access to the IPP Application. A users ability to view information after authentication is further restricted based on the roles assigned to them in IPP by their agency on the principles of least privilege. All user and system to system transactions are logged and reviewed on a period basis by USDT. Users are also recertified on an annual basis to determine their need for continued access to IPP.
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.
IPP is a component of the NRCs Third Party System (TPS) OCFO ES Subsystem.
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 8
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 email quarterly to ensure the authorization remains on track.
In Progress provide the estimated date to receive an ATO.
Estimated date: Short Term ATO valid through 11/15/2024, approval #
Yes Indicate the data impact levels (Low, Moderate, High, Undefined) approved by the Chief Information Security Officer (CISO)
Confidentiality Integrity-Availability 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.
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.)
Data can be retrieved using a system-generated document number, Agency Location Code (ALC), vendor name, or vendor TIN/EIN.
List the identifiers that will be used to retrieve the information on the individual.
No, the PII is not retrieved by a personal identifier.
If no, explain how the data is retrieved from the project.
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 9
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):
IPP system is covered by the System of Records Notice - FMS SORN.002 -
Payment Records.
SORN is in progress
SORN needs to be created
Unaware of an existing SORN
No, this system is not a system of records and a SORN is not applicable.
5.3 When an individual is asked to provide personal data (i.e., form, webpage, survey), is a Privacy Act Statement (PAS) provided?
A Privacy Act Statement is a disclosure statement required to appear on documents used by agencies when an individual is asked to provide personal data. It is required for any forms, surveys, or other documents, including electronic forms, used to solicit personal information from individuals that will be maintained in a system of records.
Mark the appropriate response.
Options
Privacy Act Statement The Privacy Act Statement is in the Vendor Participation and Rules of Behavior Agreement, which is embedded in the collector module after access for reference.
Not Applicable
Unknown
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 10 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
Vendors must use Employer Identification Number (EIN) or Taxpayer Identification Number (TIN) to establish a payment relationship between an agency and vendor to associate a payment to an invoice, therefore PII is mandatory. If information is not provided, this may affect processing of payment.
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
- 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.
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 11 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)
Invoice Processing Platform (IPP)
Records Retention Schedule Number(s)
Use GRS 1.1 item 010 for the source records for approving the invoices.
Approved Disposition Instructions GRS 1.1 item 010 - Temporary. Destroy when 6 years after final payment or cancellation, 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 in the system(s) to support records accessibility, reliability, integrity, and disposition.
No. NRC does not apply retention to this IPP system.
Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
N/A - since the system is owned by Department of Treasury.
NRC is responsible for its source records.
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 12 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)
N/A 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.
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.
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 13 8 Privacy Act Determination Project/System Name: Invoice Processing Platform (IPP)
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:
Covered by SORN Treasury/FMS.002 - Payment Records, NRC Office of the Chief Financial Officer Financial Transactions and Debt Collection Management Records Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 10/31/24
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (05-2024)-ML050460335 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:
Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 10/10/24
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (03-2024)-ML050460335 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 10/25/24
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (03-2024)-ML050460335 16 11 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 Cyber Information Security Division Office of the Chief Information Officer Signed by Nalabandian, Garo on 11/01/24
Invoice Processing Platform (IPP)
Version 1.0 Privacy Impact Assessment September 18, 2024 PIA Template (03-2024)-ML050460335 17 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Invoice Processing Platform (IPP)
Date CISD received PIA for review:
September 18, 2024 Date CISD completed PIA review:
October 30, 2024 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