ML25072A011
| ML25072A011 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/2025 |
| From: | Center J NRC/OCIO/CISD |
| To: | |
| Debnam C | |
| References | |
| Download: ML25072A011 (1) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Reasonable Accommodation (RA) System Office of the Chief Human Capital Officer (OCHCO)
Version 1.1 03/12/2025 Template Version 2.4 (10/2024)
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 Document Revision History Date Version PIA Name/Description Author 3/12/2025 1.1 RA Annual Review and Update Jessica Center/OCIO 06/262024 1.0 RA Initial Release Jessica Center
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 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 8
6 Records and Information Management-Retention and Disposal 9
7 Paperwork Reduction Act 11 8
Privacy Act Determination 13 9
OMB Clearance Determination 14 10 Records Retention and Disposal Schedule Determination 15 11 Review and Concurrence 16
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 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: Reasonable Accommodation (RA) System Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform)
RA is hosted in a FedRAMP authorized cloud owned/managed by Opexus through a software as a service (SaaS) workforce management suite called, eCASE. Data is stored on Opexus database servers.
Date Submitted for review/approval: March 12, 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.
This is a cloud-based system hosted by a third-party vendor (Opexus) on an NRC-external website created for the purpose. Access to the system is limited to NRC employees. This was created to streamline processes and tracking/reporting capabilities for those that need a modification or adjustment to a job or work environment.
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 FedRAMP authorized cloud Other <please explain >
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.
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 2
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.
Corrections to Categories of Information
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.)
Role Contact Information Name Office/Division/Branch Phone Number Project Manager(s)
Jessica Center OCHCO/HROP/PLERB 301-415-5888 System Owner/Data Owner or Steward Jessica Center ISSM Consuella Debnam OCIO 301-287-0834 Executive Sponsor N/A Other 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.
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 3
Mark with an X on all that apply.
Authority Citation/Reference
Statute
Executive Order Executive Order 13164
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).
Executive Order 13164 requires all agencies to track reasonable accommodations requests.
The eCase RA Module is used to track employee requests for reasonable accommodations, including identification of at least the following information as directed by the EO:
the number and types of reasonable accommodations that have been requested in the application process and whether those requests have been granted or denied; the jobs (occupational series, grade level, and agency component) for which reasonable accommodations have been requested; the types of reasonable accommodations that have been requested for each of those jobs; the number and types of reasonable accommodations for each job, by agency component, that have been approved, and the number and types that have been denied; the number and types of requests for reasonable accommodations that relate to the benefits or privileges of employment, and whether those requests have been granted or denied; the reasons for denial of requests for reasonable accommodation; the amount of time taken to process each request for reasonable accommodation; and the sources of technical assistance that have been consulted in trying to identify possible reasonable accommodations.
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.
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 4
Category of individual
Federal employees
Contractors
Members of the Public (any individual other than a federal employee, consultant, or contractor)
Licensees
Other <Insert response here>
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.
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
Marital Status
Children Information
Mother's Maiden Name
Other Religion/Religious Preference 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).
General information of an employees name and contact information is collected from the existing NRC Microsoft 365 Directory. Otherwise, data is collected directly from individuals.
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 5
Individuals may access the system directly to enter information; or the individual will provide their information to a processing representative in OCHCO who will add that information into the system as appropriate.
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.
Nonfederal employees will not be able to use the portal to submit a request, they will use NRC Form 726, Confirmation of Request for Reasonable Accommodation.
- Note that this information will be provided by the information via portal entry on the systems website.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
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 Reasonable Accommodation Coordinators (or their designee(s)) verify the accuracy and completeness of data.
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?
The individual will have direct edit access to their profile information and will be able to notify designated staff if any information is incorrect.
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).
Internal NRC users will have access to the system portal to enter and view their own information. Staff within OCHCO who process Reasonable Accommodation will have access.
- Non-NRC users do not have direct access to their information and will need to resubmit to correct or update information.
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 6
4.2 If the project/system shares information with any other NRC systems, identify the system, what information is being shared and the method of sharing.
N/A 4.3 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.
N/A If so, identify what agreements are in place with the external non-NRC partner or system in the table below.
Agreement Type
Contract Provide Contract Number:
License Provide License Information:
Memorandum of Understanding Provide ADAMS ML number for MOU:
Other
None 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
The system requires user account creation which includes providing an NRC email. The system is configured for SSO access by NRC staff. Access to data is limited based upon system roles set at account creation.
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).
Data may be transmitted from the system to individuals via email. The email will support encryption of PII or PHI.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
Data is stored at the Opexus FedRAMP data center.
4.7 Explain if the project can be accessed or operated at more than one location.
Yes. NRC users may access the system remotely via the NRC VPN. Users are required to adhere to NRCs policies for computer use.
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 7
4.8 Can the project be accessed by a contractor? Have the contractors completed an IT-II investigation? Do they possess an NRC badge?
Yes, a contractor with an NRC badge may access the system portal.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
System roles and permissions ensures that only approved users have access to the data and can only make modifications in line with their assigned system role. The system will have versioning tracking which will capture the user information and timestamp associated with modification to data.
4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
N/A 4.11 Define which FISMA boundary this project is part of.
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
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 8
4.13 Provide the NRC system Enterprise Architecture (EA)/Inventory number. If unknown, contact EA Service Desk to get the EA/Inventory number.
RA - 20200054 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.
<Insert response here>
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 11 - Reasonable Accommodation 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.
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 9
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 NRC 726.pdf
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. However, if the individual does not provide sufficient PII to establish their identity and their issue, their request may not be processed properly.
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.
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 10 The following questions are intended to determine whether the records/data and information in the system have approved records retention schedules and disposition instructions, whether the system incorporates RIM strategies including support for NARAs Universal Electronic Records Management (ERM) requirements, and if a mitigation strategy is needed to ensure compliance.
If the project/system:
Does not have an approved records retention schedule and/or Does not have an automated RIM functionality, Involves a cloud solution, And/or if there are additional questions regarding Records and Information Management
- Retention and Disposal, please contact the NRC Records staff at ITIMPolicy.Resource@nrc.gov for further guidance.
If the project/system has a record retention schedule or an automated RIM functionality, please complete the questions below.
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)
RA System eCase system; RA module Records Retention Schedule Number(s)
GRS 2.3 - Items 010, 020 Approved Disposition Instructions 010: Destroy 3 years old, but longer retention is authorized if required for business use.
020: Destroy 3 year after employee separation from the agency or all appeals are concluded whichever is later, 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 Manual. BASS Reasonable Accommodation (RA) will be assessed using the Records and
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 11 the system(s) to support records accessibility, reliability, integrity, and disposition.
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.
Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
Manual. BASS Reasonable Accommodation (RA) 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.
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 Records in this system will not be permanent records.
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?
Yes
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 12 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.
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-ML050460335 13 8 Privacy Act Determination Project/System Name: Reasonable Accommodation Submitting Office: 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 11 - Reasonable Accommodation Records.
Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 04/10/25
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (09-2024)-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: A clearance to cover the collection of information from members of the public on NRC Form 726 is currently being developed.
This clearance does not include medical information provided by non-Federal medical professionals. A clearance to collect medical information from non-Federal medical professionals is needed to comply with Federal law. Currently, no such clearance is being developed.
Reviewers Name Title Agency Clearance Officer Signed by Benney, Kristen on 03/27/25
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (10-2024)-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 Records and Information Management Specialist Signed by Dove, Marna on 04/09/25 Signed by Williams, Lisa on 04/08/25
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (10-2024)-ML050460335 16 11 Review and Concurrence Review Results
This project/system does not collect, maintain, or disseminate information in identifiable form.
This project/system does collect, maintain, or disseminate information in identifiable form.
I concur with the Privacy Act, Information Collections, and Records Management reviews.
Director Chief Information Security Officer Cyber Information Security Division Office of the Chief Information Officer Signed by Nalabandian, Garo on 04/14/25
Reasonable Accommodation (RA) System Version 1.1 Privacy Impact Assessment 03/12/2025 PIA Template (10-2024)-ML050460335 17 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
BASS - Reasonable Accommodation (RA) PIA Date CISD received PIA for review:
March 10, 2025 Date CISD completed PIA review:
April 9, 2025 Action Items/Concerns:
Due to a recent cybersecurity incident involving the deletion of a database that affected the Opexus Reasonable Accommodation SaaS, NRC is currently investigating the impacts on NRC-specific data and the potential implications for using this service. Once the investigation is concluded, this PIA should be reviewed again to ensure that the assessment accurately reflects the current situation.