ML24330A240
| ML24330A240 | |
| Person / Time | |
|---|---|
| Issue date: | 09/20/2024 |
| From: | NRC/OCFO/DOC, Oasis Systems |
| To: | |
| Howerton J | |
| References | |
| Download: ML24330A240 (20) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Human Capital Management (HCM)
Office of the Chief Financial Officer (OCFO)
Version 1.0 09/20/2024 Template Version 2.2 (05/2024)
Human Capital Management (HCM)
Version 1.0 Privacy Impact Assessment 09/20/2024 Document Revision History Date Version PIA Name/Description Author 09/20/2024 1.0 Human Capital Management (HCM) - PIA Initial Release OCFO Oasis Systems, LLC 09/09/2024 Draft Human Capital Management (HCM) - PIA Draft Release OCFO Oasis Systems, LLC
Human Capital Management (HCM)
Version 1.0 Privacy Impact Assessment 09/20/2024 Table of Contents 1
Description 1
2 Authorities and Other Requirements 2
3 Characterization of the Information 3
4 Information Data Security 5
5 Privacy Act Determination 8
6 Records and Information Management-Retention and Disposal 9
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
Human Capital Management (HCM)
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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) - Human Capital Management (HCM).
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): Cloud - SaaS.
Date Submitted for review/approval: September 20, 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.
HCM Cloud is categorized as a moderate subsystem owned by the Office of the Chief Financial Officer (OCFO). HCM Cloud is NRCs instance of the FedRAMP authorized Software as a Service (SaaS) for Human Capital Management (HCM) product from Oracle.
The HCM Cloud is a cloud subsystem with web user access that complies with Federal systems standards and security requirements for major financial systems. The Oracle SaaS HCM product consists of numerous components comprising their Human Capital Management System. The HCM Cloud subsystem will utilize only the T&L module and will include historical human resources and payroll information.
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
Human Capital Management (HCM)
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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.
HRMS-C_Privacy_Impact_Assessment_ML21025A267
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/D ata Owner/S teward ISSM Business Project Manager Technical Project Manager Executive Sponsor Name Abby Olarte Owen Barwell John Howerton Susan Jones Abby Olarte Owen Barwell Office/Division
/Branch OCIO/SDO D/EAPSB/
WPT OCFO OCFO/D OC/FSB OCFO/DO C/FRB OCIO/SDO D/EAPSB/
WPT OCFO Telephone 301-415-6288 N/A 301-415-8170 301-415-6072 301-415-6288 N/A 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 26 Code of Federation Regulations (CFR) 31.6011(b)(2), 31.6109-1; 5 United States Code (U.S.C.) 6334; 5 U.S.C. Part III, Subpart D; 31 U.S.C. 716; 31
Human Capital Management (HCM)
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Mark with an X on all that apply.
Authority Citation/Reference U.S.C. Chapters 35 and 37.
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).
HCM supports recording of employee activity-based hours to be used primarily for payroll and fee billing.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
The purpose is to collect time and attendance data for payroll processing; formulating and executing budgets, operations planning, workload planning, labor data reporting, performance monitoring, reporting on resource expenditures, billing NRC licensees and managing costs associated with collecting fees.
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
Human Capital Management (HCM)
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Categories of Information
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 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 information is collected through data transfer using the Oracle HCM data loader tool.
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.
The source of this information comes from internal and external systems. Internal systems include CACS, OCIO, FAIMIS, BFS and the external system is DOI FPPS. The information is transferred via HCM data loader tool.
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3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
The accuracy of the data collected is validated through the source, which is the American Standard Code for Information (ASCII) text file from the Department of Interiors (DOI) Federal Payroll and Personnel System (FPPS). The types of information are employee demographics, SSN, salary and benefits, leave balances, and payroll.
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?
Data discrepancy reports have been created to ensure data integrity and internal controls are in place. Office of the Chief Human Capital Officer (OCHCO) and OCFO investigate any discrepancies that they discover or that are brought to their attention by employees. Agency policies on information integrity, security, and roles and responsibilities are documented in a series of Management Directives relating to personnel and financial.
4 Information Data Security 4.1 Describe who has access to the data in the project (i.e., internal NRC, system administrators, external agencies, contractors, public).
All NRC offices have access.
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.
OCFO FMS Budget Formulation System (BFS) - HCM Cloud transmits employee payroll information to BFS.
OCFO FMS Financial Accounting and Integrated Management Information System (FAIMIS) - HCM Cloud sends employees hour and payroll data to FAIMIS.
Office of the Chief Information Officer (OCIO) Business Application Support System Cost Activity Code System (CACS) -Employee staff assignment information.
Human Capital Management (HCM)
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4.3 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 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.
HCM users will be authenticated through the NRC Information Technology Infrastructure (ITI) /
Identity, Credential, & Access Management Authentication Gateway (ICAM).
Single Sign On (SSO) has been enabled for application and user access, and activity can be monitored by service administrators. Access will be monitored. Audit trails track user access by User ID with date and time stamps and will be periodically reviewed.
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).
The data to and from HCM will be transmitted to other systems via batch file interfaces.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
HCM produces time and labor related reports that are stored in the HCM Cloud Database.
HCM can also report on any other data element that is stored in HCM Cloud Database (via inbound feeds) along with time & attendance data.
4.7 Explain if the project can be accessed or operated at more than one location.
Yes.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
No, Federal NRC employees only.
Human Capital Management (HCM)
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4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
Oracle captures access logs. Single Sign On auditing mechanisms are put in place by Oracle to be able to identify activities and events of each authorized user. Users are authorized access based on their duties and assigned responsibilities.
4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
Access will be monitored. Audit trails track user access by User ID with date and time stamps and will be periodically reviewed by the assigned Information System Security Manager (ISSM).
4.11 Define which FISMA boundary this project is part of.
The HCM Cloud operates 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.
HCM is a subsystem of FMS. 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.
Data will not generally be retrieved at the individual employee level except in cases of data quality assurance (QA) or troubleshooting. In those cases, Employee ID will usually be used; however, name, SSN, bank account number, etc. can also be used.
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):
US Federal 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.
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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?
Data stored and processed by the server is not collected directly from the subject individual. It is the responsibility of the source systems to provide notice to individuals whether 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.
Human Capital Management (HCM)
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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)
FMS - HCM Records Retention Schedule Number(s)
GRS 2.4 Item 010 - Records used to calculate payroll, arrange paycheck deposit, and change previously issued paychecks.
GRS 2.4 Item 030 - Time and attendance records.
GRS 2.4 Item 040 - Agency payroll record for each pay period.
GRS 2.4 Item 050 - Wage and tax statements.
GRS 2.4 Item 060 - Payroll program administrative records. - Administrative GRS 2.4 Item 061: Payroll program administrative records. - Payroll system reports providing fiscal information on agency payroll.
Approved Disposition Instructions GRS 2.4 Item 010:
Human Capital Management (HCM)
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GRS 2.4 Item 030:
Temporary. Destroy after Government Accountability Office (GAO) audit or when 3 years old, whichever is sooner.
GRS 2.4 Item 040:
Temporary. Destroy when 56 years old.
GRS 2.4 Item 050:
Temporary. Destroy when 4 years old, but longer retention is authorized if required for business use.
GRS 2.4 Item 060:
Temporary. Destroy when 2 years old, but longer retention is authorized if required for business use.
GRS 2.4 Item 061:
Temporary. Destroy when 3 years old or after GAO audit, 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.
Records retention and disposition on the server is currently a manual process.
Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
Files are automatically deleted after successful transfer from the intermediary server to the destination system.
Human Capital Management (HCM)
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If so, what formats will be used?
NRC Transfer Guidance (Information and Records Management Guideline - IRMG)
No 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?
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.
STOP HERE - The remaining pages will be completed by the Privacy Officer, Records Management, and Information Collections Team.
Human Capital Management (HCM)
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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 OPM/GOVT General Personnel Records.
Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 12/18/24
Human Capital Management (HCM)
Version 1.0 Privacy Impact Assessment 09/20/2024 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:
No clearance is needed as the system does not collect information from non-Federal employees.
Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 12/06/24
Human Capital Management (HCM)
Version 1.0 Privacy Impact Assessment 09/20/2024 PIA Template (05-2024)-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 12/17/24
Human Capital Management (HCM)
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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 12/20/24
Human Capital Management (HCM)
Version 1.0 Privacy Impact Assessment 09/20/2024 PIA Template (05-2024)-ML050460335 17 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Human Capital Management (HCM)
Date CISD received PIA for review:
September 20, 2024 Date CISD completed PIA review:
December 18, 2024 Action Items/Concerns: