ML25070A102
| ML25070A102 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/2025 |
| From: | Sanchez R NRC/OCIO/CISD |
| To: | |
| Debnam C | |
| References | |
| Download: ML25070A102 (20) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Telework Application Data App (TADA)
Office of the Chief Information Officer Version 3.0 3/7/2025 Template Version 2.4 (10/2024)
Telework Agreement Data Application (TADA)
Version 3.0 Privacy Impact Assessment 3/7/2025 Document Revision History Date Version PIA Name/Description Author 03/07/2025 3.0 Telework Agreement Data Application
- Major Feature/Workflow Updates Sanchez, Rachel 02/15/2024 2.0 Telework Agreement Data Application
- Major Feature Updates Sanchez, Rachel 08/11/2023 1.0 Telework Agreement Data Application
- Initial Release Stevens, Mackenzie
Telework Agreement Data Application (TADA)
Version 3.0 Privacy Impact Assessment 3/7/2025 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
Telework Agreement Data Application (TADA)
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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: Telework Agreement Data Application (TADA)
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) Microsoft Power Platform.
Date Submitted for review/approval: March 11, 2025.
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.
The NRC TADA application is designed to provide staff a secure, flexible, user friendly experience in the electronic submission and approvals of telework agreements which enable staff to leverage maximum telework flexibilities to the extent possible as recommended in MD 10.166, Telework and the Collective Bargaining Agreement, Article 7, Telework. The TADA empowers stakeholders with a secure, role based, flexible interface to view, submit, approve, and generate reports for analysis in future decision making via a standard web browser.
TADA is a canvas application developed on the Microsoft Power Platform. The application does not use any custom scripts.
Dataverse is the data storage behind the Power Platform that allows the secure management of data.
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
Telework Agreement Data Application (TADA)
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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.
TADA Version 1.0 ; Existing PIA (Accession No. ML23223A145)
TADA Version 3.0 will be including additional features and functionality to support the following telework agreement types:
Full-Time Telework Project-Based (Situational) Telework Reasonable Accommodations Special Circumstances Telework Non-standard Fixed Telework
Annual Review If making minor edits to an existing system/project, briefly describe the changes below.
Other (explain) 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 Rachel Sanchez Jon Feibus Lynn Sutton (Data Steward)
Consuella Debnam Lynn Sutton Rachel Sanchez Caroline Carusone Office/
Division
/Branch OCIO/SDOD/FO OCIO.SDOD/FO OCHCO
/ADHROP
/WMBB OCIO/CISD
/IAOB OCHCO/
ADHROP
/WMBB OCIO/SDOD/FO OCIO Telephone 301-415-2932 301-415-0717 301-287-0834 301-415-2932 301-415-1085
Telework Agreement Data Application (TADA)
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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)
The telework/alternate work address is captured on the NRC Form 624 in the existing telework approval process.
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 will be used to capture the telework/alternate work location of an NRC employee, as its currently captured on the NRC Form 624 in the existing telework approval process. This information will also help in automating the determination of the duty location of the employee.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
TADA does not collect social security numbers.
Telework Agreement Data Application (TADA)
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3 Characterization of the Information In the table below, mark the categories of individuals for whom information is collected.
Category of individual
Federal employees
Contractors
Members of the Public (any individual other than a federal employee, consultant, or contractor)
Licensees
Other In the table below, is a list of the most common types of PII collected. Mark all PII that is collected and stored by the project/system. If there is additional PII not defined in the table below, a comprehensive listing of PII is provided for further reference in ADAMS at the following link: PII Reference Table 2023.
Categories of Information
Name
Resume or curriculum vitae
Date of Birth
Driver's License Number
Country of Birth
License Plate Number
Citizenship
Passport number
Nationality
Relatives Information
Race
Taxpayer Identification Number
Home Address
Credit/Debit Card Number
Social Security number (Truncated or Partial)
Medical/health information
Gender
Alien Registration Number
Ethnicity
Professional/personal references
Spouse Information
Criminal History
Personal e-mail address
Biometric identifiers (facial images, fingerprints, iris scans)
Personal Bank Account Number
Emergency contact e.g., a third party to contact in case of an emergency
Personal Mobile Number/Home Number
Accommodation/disabilities information This is limited to identifying if the telework request is related to a reasonable accommodation. Details of any accommodation or disability is not to be entered into the system.
Marital Status
Other
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Categories of Information
Children Information
Mother's Maiden Name 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 in fields under the General Info tab of TADA for telework/alternate work location of an employee completing the request.
The additional features in the application are designed to support the capability for employees to provide detailed information (either through development of a template or by uploading document(s)) to accompany their telework request if it is outside of the standard, Fixed Telework agreement requirements (e.g. Full-Time, Special Circumstances, Reasonable Accommodations). This supporting information should not include details of medical or, health issues and/or accommodations/disabilities information related to themselves or regarding their immediate family (spouse/children) or relatives. This information is collected and provided to appropriate approving personnel to assist in their review and decision-making on the individuals telework agreement.
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 information that is currently collected on the NRC Form 624 for telework/alternate work location will be captured in TADA.
The information that is currently collected on the Full-Time Telework Plan, Special Circumstances Telework Plan, or non-standard Fixed Telework Memo will be captured in TADA.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
The NRC employee will provide their telework/alternate work location and reason for the specific telework request type.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
The street number and name of the address is not validated; however, the city and state are auto populated based on the zip code entered in the field. The street number and name of the address may be validated in a future release.
The reason for the request, if based on Reasonable Accommodation, is validated with the Reasonable Accommodation Coordinators. However, if not based on Reasonable Accommodation, the reason for the request is taken in good faith and may be validated depending on the nature of the request.
Telework Agreement Data Application (TADA)
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3.5 Will PII data be used in a test environment? If so, explain the rationale for this and how the PII information is protected.
No.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous privacy information?
Although the city and state are auto populated based on the zip code, all required fields for the telework/alternate work location are editable fields before a telework request is submitted.
The application offers spell check for any manual entries and the employee can remove and upload documents as needed if edits are needed to their attachment.
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 telework/alternate work location data is stored in a table in Dataverse secured by data loss prevention policies enabled on the platform (MS Power Platform). The tables are only accessible, via the Power Apps Studio, to application administrators within the security group.
Any personal information manually entered or uploaded is saved and stored securely in Dataverse. There will be no changes to the application administrators within the security group.
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.
TADA does not share information with any other NRC system.
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
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4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
The telework/alternate work address is accessed via a report run by authorized users in the Office of the Chief Human Capital Officer or Dataverse tables accessible by application administrators within the security group.
Manually entered personal information to include attached documentation are also limited to viewing only by authorized individuals as described above.
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 Microsoft, the following technologies are used for ensuring the secure transit of data:
Transport Layer Security/Secure Sockets Layer (TLS/SSL), which uses symmetric cryptography based on a shared secret to encrypt communications as they travel over the network.
Internet Protocol Security (IPsec), an industry-standard set of protocols used to provide authentication, integrity, and confidentiality of data at the IP packet level as its transferred across the network.
Advanced Encryption Standard (AES)-256, the National Institute of Standards and Technology (NIST) specification for a symmetric key data encryption that was adopted by the US government to replace Data Encryption Standard (DES) and RSA 2048 public key encryption technology.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
The data is stored in Dataverse, the native data repository for the MS Power Platform.
4.7 Explain if the project can be accessed or operated at more than one location.
TADA, as well as Power Platform environments, is only accessible to those within the NRC Government Commercial Cloud tenant who are in security groups authorized to access.
4.8 Can the project be accessed by a contractor? Have the contractors completed an IT-II investigation? Do they possess an NRC badge?
TADA can only be accessed by those who are in security groups which have been given access to TADA environments. The only contractors who are in these security groups are those who have a need to scan the app (SOC-AIR contractors).
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
The telework/alternate work location data is stored in a table in Dataverse secured by data loss prevention policies enabled on the platform (MS Power Platform). The tables are only
Telework Agreement Data Application (TADA)
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accessible, via the Power Apps Studio, to application administrators within the security group.
Additionally, Dataverse tables have columns to support auditing such as who and when a record was last modified. These controls place proper constraints on the accessibility and modification of the data.
4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
TADA does not identify, locate, and monitor individuals.
4.11 Define which FISMA boundary this project is part of.
TADA is an app under the Business Application Support System (BASS).
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.
20230004.
Telework Agreement Data Application (TADA)
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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
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):
Privacy data captured and stored in TADA is covered under the OPM/GOVT General Personnel Records and described at 77 Federal Register 73694 (December 11, 2012) and as subsequently modified as described in more recent Federal Register notices (most recent modification as of the date of this form: 87 Federal Register 5874 (February 2, 2022).
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.
Telework Agreement Data Application (TADA)
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A Privacy Act Statement is a disclosure statement required to appear on documents used by agencies when an individual is asked to provide personal data. It is required for any forms, surveys, or other documents, including electronic forms, used to solicit personal information from individuals that will be maintained in a system of records.
Mark the appropriate response.
Options
Privacy Act Statement (Privacy Statement in TADA (link included in the online web form in TADA)
Not Applicable
Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
Mandatory, otherwise their request may not be approved. The capture of the telework/alternate work address is required for accountability of the employee.
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
Telework Agreement Data Application (TADA)
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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)
Employee Compensation and Benefits Records Records Retention Schedule Number(s)
GRS 2.3 item 010 - Employee relations programs administrative records GRS 2.3 item 040 -Telework/alternate worksite program case files Approved Disposition Instructions GRS 2.3 - Item 010 -
Temporary. Destroy when 3 years old, but longer retention is authorized if required for business use.
GRS 2.3 - Item 040 -
Temporary. Destroy when superseded or obsolete or 1 year after end of employees participation in program, whichever is sooner, but longer retention is authorized if required for business use.
Is there a current automated functionality or a manual process to support RIM requirements?
Privacy Impact Assessment Telework Application Data App (TADA) will
Telework Agreement Data Application (TADA)
Version 3.0 Privacy Impact Assessment 3/7/2025 PIA Template (09-2024)-ML050460335 12 This includes the ability to apply records retention and disposition policies in the system(s) to support records accessibility, reliability, integrity, and disposition.
be assessed using the Records and Information (RIM) Certification process. The structured process will provide criteria aligned with the Suggested Rating to accurately reflect the system's ability to support records management requirements.
The initial release will not include an automated script for disposition but is planned for a future release.
Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
Privacy Impact Assessment Telework Application Data App (TADA) will be assessed using the Records and Information (RIM) Certification process. The structured process will provide criteria aligned with the Suggested Rating to accurately reflect the system's ability to support records management requirements.
A planned automated disposition will be scheduled for a future release.
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 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.
Telework Agreement Data Application (TADA)
Version 3.0 Privacy Impact Assessment 3/7/2025 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?
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.
Telework Agreement Data Application (TADA)
Version 3.0 Privacy Impact Assessment 3/7/2025 PIA Template (09-2024)-ML050460335 14 8 Privacy Act Determination Project/System Name: Telework Application Data App (TADA)
Submitting Office: Office of the Chief Information Officer (OCIO)
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 government-wide SORN - OPM/GOVT General Personnel Records.
Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 04/10/25
Telework Agreement Data Application (TADA)
Version 3.0 Privacy Impact Assessment 3/7/2025 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:
Comments: OMB approval is not needed since the information is being collected from current employees of the Federal government acting within the scope of their employment.
Reviewers Name Title Agency Clearance Officer Signed by Benney, Kristen on 03/20/25
Telework Agreement Data Application (TADA)
Version 3.0 Privacy Impact Assessment 3/7/2025 PIA Template (10-2024)-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 04/09/25 Signed by Williams, Lisa on 04/08/25
Telework Agreement Data Application (TADA)
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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 04/11/25
Telework Agreement Data Application (TADA)
Version 3.0 Privacy Impact Assessment 3/7/2025 PIA Template (10-2024)-ML050460335 18 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Telework Application Data App (TADA)
Date CISD received PIA for review:
March 11, 2025 Date CISD completed PIA review:
April 10, 2025 Action Items/Concerns: