ML24358A037
| ML24358A037 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/2024 |
| From: | NRC/OCIO, Office of the Chief Human Capital Officer |
| To: | |
| Bobryakova N | |
| References | |
| Download: ML24358A037 (18) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Percipio Office of the Chief Information Officer (OCIO) /
Office of the Chief Human Capital Officer (OCHCO)
Version 1.0 December 03, 2024
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 Document Revision History Date Version PIA Name/Description Author December 03, 2024 1.0 Percipio Initial Release - Converted Percipio PTA to a PIA due to the addition of Conversation AI Simulator (CAISY) feature.
OCIO/OCHCO Oasis Systems, LLC November 7, 2024 DRAFT Percipio Draft Release - Converted Percipio PTA to a PIA due to the addition of Conversation AI Simulator (CAISY) feature.
OCIO/OCHCO Oasis Systems, LLC
Percipio Version 1.0 Privacy Impact Assessment December 03, 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 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
Percipio Version 1.0 Privacy Impact Assessment December 03, 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: Percipio.
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): Data resides within the Skillsoft Percipio cloud environment.
Date Submitted for review/approval: December 6, 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.
Percipio is Skillsofts next generation training content delivery and learning platform, which is delivered as a Software-as-a-Service (SaaS) cloud-based solution. Percipio provides skills-based learning paths and interactive, scenario-based content powered by artificial intelligence (AI). Percipio is a comprehensive suite of premium, original, and partner-authorized content, an extensive course library, more than 170 technical certifications programs, and a blend of virtual, on-demand and instructor-led training. The platform enables organizations to build and measure technical competencies as part of Skillsofts Aspire Journeys, which provide learners with customized learning paths to rapidly advance their proficiency in critical and on-demand technology and business skills.
Percipio supports the following NRC training programs:
New Supervisor Training Program Annual Supervisor Training Curriculum Supervisor Refresher Program New Employee/New Contractor Curriculum Proper Use of Government Charge Cards Nuclear Regulator Apprenticeship Network (NRAN)
Administrative Assistant Qualification Program Career Enhancement Skill-based Mentoring Program Cybersecurity Role-Based Training Program Reactor Inspector Qualification Program Federal Acquisition Certification for Program and Project Managers
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NRC Team Leader Training NRC Leaders at All Levels Certificate Program (LCP)
NRC Aspiring Leaders Certificate Program (ALCP)
Culture Change Series (5 curricula total)
Health, Safety, and Security (MC-1245)
NRC Writing Fundamentals Occupational Health and Safety (IMC-1248)
Onboarding and Retaining Employees Region II Health & Safety Training Suite (OSHA HAZWOPER)
Percipio supports the Nuclear Regulatory Commissions (NRCs) key strategic goal of fostering a healthy organization. Percipio enables the NRC to develop, and maintain a high performing, engaged, diverse and flexible workforce with the skills needed to carry out the NRCs mission now and in the future. In addition, the Percipio platform improves performance and productivity by investing in technical, professional and management training, accountability, and encourages leadership development.
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.
Annual Review If making minor edits to an existing system/project, briefly describe the changes below.
Other: Converted Percipio PTA to a PIA due to the addition of Conversation AI Simulator (CAISY) feature, which generates data that contain PII (e.g., interaction scores and grades).
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1.3 Points of
Contact:
Project Manager System Owner/Data Owner/
Steward ISSM Business Project Manager Technical Project Manager Executive Sponsor Name Carla Hopwood Jennifer Golder Natalya Bobryakova Carla Hopwood Carla Hopwood Jennifer Golder Office
/Division
/Branch Office of the Chief Human Capital Officer (OCHCO) /
Learning Innovation And Support Branch (LISB)
OCHCO Office of the Chief Information Officer (OCIO) /
Cyber and Infrastructure Security Division (CISD) /
Information Assurance and Oversight Branch (IAOB) /
Information Assurance Team (IAT)
OCHCO /
LISB OCHCO /
LISB OCHCO Telephone 301-415-3323 240-287-0741 301-287-0671 301-415-3323 301-415-3323 240-287-0741 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 Federal agencies are required to collect detailed information on training programs and needs, and to electronically report the data to the Office of Personnel Management (OPM) per 5 Code of Federation Regulations (CFR) 410 per; Regulation Identification Number (RIN) 3206-AK46; 71 Fed. Reg. 28,545.
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Mark with an X on all that apply.
Authority Citation/Reference
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).
OCHCO and NRC staff use the data collected by the system to provide learners with customized learning paths to rapidly advance their proficiency in critical and on-demand technology and business skills.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
Social Security numbers are not collected or stored in Percipio.
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
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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 email 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: NRC email address, user ID from the Talent Management System (TMS),
and CAISY AI users educational data such as interaction scores and grades.
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).
Users name, NRC email address, and Talent Management System (TMS) ID are collected through existing NRC files/databases provided by the Enterprise Identity Hub (EIH), a secure central repository for electronic identity information. The scores and grades are collected when users interact with the AI feature of Percipio within the application. Only users have access to their own scores and grades.
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.
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3.3 Who provides the information? Is it provided directly from the individual or a third party.
Information collected from EIH will be verified by the employee and an approving official, and the Identity, Credential, and Access Management System (ICAM).
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
Information collected from EIH will be verified by the employee and an approving official, and the Identity, Credential, and Access Management System (ICAM).
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?
Information collected from the EIH will be verified by the employee, an approving official and the ICAM. Administrators can also correct limited inaccurate information at the source.
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).
Employees, contractors, and supervisors across all NRC offices have access to information that pertains to them individually.
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.
The data from Percipio is being transmitted to TMS through the integration workflow between TMS and Percipio. The fields shared are TMS user ID, training title, completion date, completion status and scores.
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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.
Skillsoft, the Cloud Service Provider (CSP), maintains the application and has access to the TMS user ID, training title, completion date, completion status and scores.
If so, identify what agreements are in place with the external non-NRC partner or system in the table below.
Agreement Type
Contract # 47QTCA19D002B / 31310021F0014
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 NRC users access the Percipio web-based portal via the Internet. The users are authenticated through the NRCs ICAM Authentication Gateway, and they log in to Percipio using a Single Sign-on from the NRC network or two-factor authentication from outside of the NRC Network.
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).
Per the CSP System Security Plan (SSP), all external data in transit in and out of the environment is encrypted using TLS 1.2 or greater.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
Data resides within the Skillsoft Percipio cloud environment.
4.7 Explain if the project can be accessed or operated at more than one location.
No.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
Yes, NRC badged contractors have access to information that pertains to them individually.
The Skillsofts staff maintain the application and have access to the NRC Percipio data. Skillsoft recognizes the sensitivity of the data handled by its employees. To ensure the best security awareness and due diligence, Skillsoft performs background checks (subject to applicable local laws) with respect to pre-determined positions that require access to customer data. Skillsoft
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also checks references provided by candidates generally as part of the application process.
Additionally, all employees are required to review and sign a Security and Privacy Policy that details roles and responsibilities, escalation procedures and overall code of conduct within the organization. All employees are required to sign the policy annually, acknowledging their understanding and commitment to its guidelines.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse NRC relies on the CSP to secure all data in accordance with agencywide mandates and ensure that only authorized users can access the system. The CSP implements functional requirements into the technical design and implementation of the system and undergoes annual assessments to test the current safeguards.
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.
Percipio is a component of the NRCs Third-Party System (TPS) Talent Management (TM)
Subsystem.
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:
Yes Indicate the data impact levels (Low, Moderate, High, Undefined) approved by the Chief Information Security Officer (CISO)
Confidentiality-Low Integrity-Low Availability-Low 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.
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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.
Name, NRC Email address, and TMS user ID.
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 19 - Official Personnel Training Records 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.
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 PIA Template (09-2024)-ML050460335 10 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?
N/A.
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.
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 PIA Template (09-2024)-ML050460335 11 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)
Percipio Records Retention Schedule Number(s)
Unscheduled - Mission-related Training GRS 2.6 item 030 (superseded former GRS 1 item 29) Individual training records GRS 2.6 item 010 -Non-mission employee training program records Approved Disposition Instructions Unscheduled - Mission-related Training:
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
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 PIA Template (09-2024)-ML050460335 12 development of the project, retention functionality or a manual process must be incorporated to meet this requirement.
GRS 2.6 Item 030. Temporary. Destroy when superseded, 3 years old, or 1 year after separation, whichever comes first, but longer retention is authorized if required for business use.
GRS 2.6 Item 010. Temporary. Destroy when 3 years old, or 3 years after superseded or obsolete, whichever is appropriate, 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.
Skillsoft owns the Percipio system and is responsible for the retention of its data.
Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
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)
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.
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 PIA Template (09-2024)-ML050460335 13 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.
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 PIA Template (09-2024)-ML050460335 14 8 Privacy Act Determination Project/System Name: Percipio Submitting Office: Office of the Chief Information Officer (OCIO)
Office of the Chief Human Capital Officer (OCHCO)
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 19 - Official Personnel Training Records and OPM GOVT General Personnel Records Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 01/17/25
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 PIA Template (09-2024)-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:
No clearance is needed as long as contractors are not being requested to provide information outside the scope of their contract.
Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 01/08/25
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 PIA Template (03-2024)-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:
Reviewers Name Title Sr. Program Analyst, Electronic Records Manager Records and Information Management Specialist Signed by Dove, Marna on 01/16/25 Signed by Williams, Lisa on 01/10/25
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 PIA Template (03-2024)-ML050460335 17 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 01/17/25
Percipio Version 1.0 Privacy Impact Assessment December 03, 2024 PIA Template (03-2024)-ML050460335 18 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Percipio Date CISD received PIA for review:
December 19, 2024 Date CISD completed PIA review:
January 17, 2025 Action Items/Concerns: