ML24338A264
| ML24338A264 | |
| Person / Time | |
|---|---|
| Issue date: | 11/21/2024 |
| From: | NRC/RES/DE/MEEB |
| To: | |
| Bayssie M | |
| References | |
| Download: ML24338A264 (18) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Hybrid Workshops Office of Nuclear Regulatory Research (RES)
Version 1.0 November 21, 2024 Template Version 2.3 (09/2024)
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 Document Revision History Date Version PIA Name/Description Author 11/24/2024 1.0 Initial Release RES
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 Table of Contents 1
Description 1
2 Authorities and Other Requirements 2
3 Characterization of the Information 3
4 Data Security 5
5 Privacy Act Determination 7
6 Records and Information Management-Retention and Disposal 8
7 Paperwork Reduction Act 10 8
Privacy Act Determination 11 9
OMB Clearance Determination 12 10 Records Retention and Disposal Schedule Determination 13 11 Review and Concurrence 14
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 PIA Template (09-2024)-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: Hybrid Workshops.
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) SharePoint.
Date Submitted for review/approval: December 3, 2024.
Note: When completing this PIA do not include any information that would raise security concerns or prevent this document from being made publicly available.
1 Description 1.1 Provide the description of the system/subsystem, technology (i.e., Microsoft Products), program, or other data collections (hereinafter referred to as project).
Explain the reason the project is being created.
RES holds workshops at various times during the year to bring a group of people together around a specific subject to encourage learning, collaboration, problem solving and/or the creation of new ideas depending on the subject matter. Unlike a traditional meeting or conference, a workshop is interactive and participative.
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 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.
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 PIA Template (09-2024)-ML050460335 2
Annual Review If making minor edits to an existing system/project, briefly describe the changes below.
Other (explain) These workshops have been going on for a number of years, but this is the first PIA that was developed.
1.3 Points of
Contact:
(Do not adjust or change table fields. Annotate N/A if unknown. If multiple individuals need to be added in a certain field, please add lines where necessary.)
Project Manager System Owner/Data Owner/Steward ISSM Business Project Manager Technical Project Manager Executive Sponsor Name Mekonen Bayssie Office/Division
/Branch MEB Telephone 2 Authorities and Other Requirements 2.1 What specific legal authorities and/or agreements permit the collection of information for the project?
Provide all statutory and regulatory authorities for operating the project, including the authority to collect the information; NRC internal policy is not a legal authority. Please mark appropriate response in table below.
Mark with an X on all that apply.
Authority Citation/Reference
Statute
Executive Order
Federal Regulation
Memorandum of Understanding/Agreement
Other (summarize and provide a copy of relevant portion)
This is an NRC workshop for the public to attend and share information.
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2.2 Explain how the information will be used under the authority listed above (i.e., enroll employees in a subsidies program to provide subsidy payment).
The information is used to register/process attendees for the meeting.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
N/A.
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 personally identifiable information (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)
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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 Note citizenship information only asked to determine if they will need to provide additional information to gain building access to attend workshop in person handled by OIP 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 data is collected through Links Microsoft Forms posted on the NRC Public Website. The information is then exported to an excel spreadsheet and stored in SharePoint, once exported the responses are deleted from Microsoft forms. The spreadsheet is maintained for approximately 2 months to create the summary report on who attended the meeting. Once summary report is finalized the data is deleted.
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.
https://forms.office.com/g/CHrZ2kagGX.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
The information was collected directly from the individual.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
The information is collected directly from the individual. There is no data validation. If the information entered by the individual is not correct, they will not get registered for the meeting.
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?
NRC does not validate the data entered by the individual in the registration form. If the e-mail is entered incorrectly, the individual will not receive the link to the meeting.
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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).
The information collected be accessed staff Materials Engineering Branch (MEB) & Structural Geotechnical & Seismic Engineering Branch (SGSEB) members.
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 for sharing with other systems. The data shared among branch members via Teams and SharePoint permissions.
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
None 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
The information is accessed in SharePoint.
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 is collected through Links Microsoft Forms posted on the NRC Public Website. The information is then exported to an excel spreadsheet and stored in SharePoint, once exported the responses are deleted from Microsoft forms. The spreadsheet is maintained for approximately 2 months to create the summary report on who attended the meeting. Once summary report is finalized the data is deleted.
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4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
The information is stored in SharePoint and shared with only branch members until deleted after 2 months. However, the summary report of the workshop lists the names and organizations of each attendee as this is a public meeting.
4.7 Explain if the project can be accessed or operated at more than one location.
N/A.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
No.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
Access is restricted to only those with a need-to-know and deleted once summary report has been completed.
4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
No.
4.11 Define which FISMA boundary this project is part of.
ITI.
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
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4.13 Provide the NRC system Enterprise Architecture (EA)/Inventory number. If unknown, contact EA Service Desk to get the EA/Inventory number.
ITI-20090005.
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.
Name
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 40 - Facility Security Access Control Records and NRC 38 - Mailing Lists
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 (Insert link to Privacy Act Statement (PAS) for each form, webpage or survey etc.)
Not Applicable
Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
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.
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 PIA Template (09-2024)-ML050460335 9
If the project/system:
Does not have an approved records retention schedule and/or Does not have an automated RIM functionality, Involves a cloud solution, And/or if there are additional questions regarding Records and Information Management
- Retention and Disposal, please contact the NRC Records staff at ITIMPolicy.Resource@nrc.gov for further guidance.
If the project/system has a record retention schedule or an automated RIM functionality, please complete the questions below.
6.1 Does this project map to an applicable retention schedule in NRCs Comprehensive Records Disposition Schedule (NUREG-0910), or NARAs General Records Schedules?
NUREG-0910, NRC Comprehensive Records Disposition Schedule
NARAs General Records Schedules
Unscheduled 6.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.
System Name (include sub-systems, platforms, or other locations where the same data resides)
Hybrid Workshops Records Retention Schedule Number(s)
GRS 6.4 020 Public correspondence and communications not requiring formal action Approved Disposition Instructions GRS 6.4 020 Temporary. Destroy when 90 days old, 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.
Manual Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
The records manually deleted after the workshop date and report summary completed.
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 PIA Template (09-2024)-ML050460335 10 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)
The information is collected for the workshop and the records follow the procedures how conference of attendees.
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 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)?
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.
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 PIA Template (09-2024)-ML050460335 11 8 Privacy Act Determination Project/System Name: Hybrid Workshops Submitting Office: Office of Nuclear Regulatory Research (RES)
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 40 - Facility Security Access Control Records and NRC 38 - Mailing Lists.
Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 01/07/25
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 PIA Template (09-2024)-ML050460335 12 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:
An OMB clearance is required if more than name, address, email address, and phone number is being collected from an individual.
Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 12/18/24
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 PIA Template (03-2024)-ML050460335 13 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 Records and Information Management Specialist Signed by Dove, Marna on 12/20/24 Signed by Williams, Lisa on 12/20/24
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 PIA Template (03-2024)-ML050460335 14 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 Feibus, Jonathan on 01/07/25
Hybrid Workshops Version 1.0 Privacy Impact Assessment November 24, 2024 PIA Template (03-2024)-ML050460335 15 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Hybrid Workshops Date CISD received PIA for review:
December 3, 2024 Date CISD completed PIA review:
January 7, 2025 Action Items/Concerns: