ML25122A177

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Security Executive Agent Directive 3 (SEAD3) Pia
ML25122A177
Person / Time
Issue date: 03/13/2025
From: Nalabandian G
NRC/OCIO, Oasis Systems
To:
Katz T
References
PIA
Download: ML25122A177 (21)


Text

U.S. Nuclear Regulatory Commission Privacy Impact Assessment Security Executive Agent Directive 3 (SEAD3)

Office of Administration (ADM)

Version 1.1 03/11/2025

Security Executive Agent Directive 3 (SEAD3)

Version 1.1 Privacy Impact Assessment 3/11/2025 Document Revision History Date Version PIA Name/Description Author 3/11/2025 1.1 Update to include SEAD migration to cloud, portal access information for external users, and into new PIA template ADM Oasis Systems, LLC 1/15/2025 DRAFT of v1.1 Draft Release - Update to include SEAD migration to cloud and into new PIA template ADM Oasis Systems, LLC 04/23/2024 N/A ISSM Review - No Updates N/A 10/05/2023 1.0 SEAD3 PIA - Initial Release ADM Oasis Systems, LLC 9/15/2023 DRAFT SEAD3 PIA - Draft Release ADM Oasis Systems, LLC

Security Executive Agent Directive 3 (SEAD3)

Version 1.1 Privacy Impact Assessment 3/11/2025 Table of Contents 1

Description 1

2 Authorities and Other Requirements 2

3 Characterization of the Information 4

4 Data Security 6

5 Privacy Act Determination 8

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

Security Executive Agent Directive 3 (SEAD3)

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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: Security Executive Agent Directive 3 (SEAD3).

Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): Cloud: NRC Azure Cloud Services (ACS) tenant.

Date Submitted for review/approval: April 29, 2025.

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 Security Executive Agent Directive 3 is an executive security directive issued by the Office of the Director of National Intelligence (ODNI) in December 2016. It is applicable to all executive branch agencies and covered individuals, which includes all U.S. Nuclear Regulatory Commission (NRC) employees, consultants, experts, panel members, cleared contractors, cleared licensees, cleared licensee contractors, and other cleared persons designated by the Executive Director for Operations (EDO), such as individuals from the Organization of Agreement States. SEAD3 is designed to strengthen the safeguarding of national security equities and establishes the reporting requirements for covered individuals who have access to classified information or hold a sensitive position. These reporting requirements are generally consistent with the elements included in the Standard Form 86 (SF-86), "Questionnaire for National Security Positions", which is completed by NRC employment applicants and clearance holders during the initial and periodic reinvestigation processes, respectively.

Additionally, SEAD3 requires these elements to be reported by covered individuals prior to participation in certain activities or as soon as possible following the start of their involvement if prior reporting is not possible. In response to the Federal Government requirement to track employees, contractors, and licensees personal travel to foreign countries in the interest of national security, Security Executive Agent Directive 3 (SEAD3) was added to the Office of Administrations (ADM) Moderate ADM Support Systems (MASS) boundary as a module of the Personnel Security Adjudication Tracking System (PSATS). SEAD3 is a web portal used to report, record, and track foreign travel of NRC personnel who hold a security clearance.

Please note, licensees and other individuals who possess an NRC security clearance are required to use https://sead3portalext.nrc.gov/sead3portal/ to report personal foreign travel. In the event the portal cannot be accessed, then an e-mail can be sent to UnofficialTravel.Resource@nrc.gov to report unofficial foreign travel. Once access has been restored, then the information reported via e-mail must be entered into the portal.

Security Executive Agent Directive 3 (SEAD3)

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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.

Update to include PSATS migration to cloud and into new PIA template. Licensees shall use https://sead3portalext.nrc.gov/sead3portal/ to submit their unofficial foreign travel requests to NRC. This replaces the e-mail mechanism previously used.

ADAMS ML: ML23340A114

Annual Review If making minor edits to an existing system/project, briefly describe the changes below.

Other (explain) 1.3 Points of

Contact:

Project Manager System Owner/Data Owner/Steward ISSM Business Project Manager Technical Project Manager Executive Sponsor Name Michael England Eleni Jernell Tamar Katz N/A Denis Brady Bernie Thomson Office/

Division/

Branch ADM/DFS/

SMOB ADM ADM/

DRMA/BITT N/A ADM/DFS/

SMOB ADM/DFS Telephone 301-415-0178 301-415-8725 301-415-2500 N/A 301-415-5768 301-415-3657 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

Security Executive Agent Directive 3 (SEAD3)

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response in table below.

Mark with an X on all that apply Authority Citation/Reference

Statute 42 United States Code (U.S.C). 2011 et seq.; 42 U.S.C. 2165, 2201(i), 2201a, and 2284; and 42 U.S.C. 5801 et seq.

Executive Order Executive Order (E.O.) 9397, as amended by E.O. 13478; 10450, as amended; 10865, as amended; 12968, 13467, 13488, 13526, and 13587.

Federal Regulation 10 Code of Federal Regulation (CFR)

Parts 10, 11, 14, 25, 50, 73, 95; OMB Circular No. A-130, Revised; and 5 CFR Parts 731, 732.

Memorandum of Understanding/Agreement

Other (summarize and provide a copy of relevant portion)

Security Executive Agent Directive (SEAD) 3, Reporting Requirements for Personnel with Access to Classified Information or Who Hold a Sensitive Position 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).

Unofficial travel information collected by the SEAD3 portal (and e-mail correspondence for non-NRC personnel) is used to report, record, and track foreign travel of personnel who hold a security clearance. This portal was developed in response to the Federal Government requirement to track employee, contractor, and licensee personal travel to foreign countries in the interest of national security. Information collected becomes part of the individuals personnel security record and supports national security and the adjudication for continued access to classified information and systems.

The data will be used to track and catalog unofficial foreign travel as a part of the Continuous Evaluation (CE) process for covered individuals who have access to classified information or hold a sensitive position.

If the project collects Social Security numbers, state why this is necessary and how it will be used.

N/A.

Security Executive Agent Directive 3 (SEAD3)

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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.

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: Unofficial foreign travel dates, purpose, companion name/relationship, passport information, countries visited, travel itinerary, and lodging information

Security Executive Agent Directive 3 (SEAD3)

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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).

For NRC employees and contractors with a security clearance, the SEAD3 portal is used to complete the NRC Personal International Travel Form (https://sead3portal.nrc.gov/sead3portal/landing) prior to, or immediately after returning from unofficial foreign travel. For licensees and other individuals who possess an NRC security clearance, unofficial foreign travel requests are submitted to NRC through the UnofficialTravel.Resource@nrc.gov e-mail address. An external portal for non-NRC personnel use is planned to be developed within the next year to replace the current e-mail process.

Both forms of travel requests are reviewed by a limited number of ADM Division of Facilities and Securitys Security Management and Operations Branch (ADM/DFS/SMOB) personnel.

Requests are either approved or denied accordingly by SMOB. After a travel request has been reviewed and a decision has been made, the collected travel request information is retained in PSATS as part of the individuals personnel security file.

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.

NRC personnel use the SEAD3 portal to complete the NRC Personal International Travel Form (https://sead3portal.nrc.gov/sead3portal/landing).

Non-NRC personnel shall submit unofficial foreign travel requests via https://sead3portalext.nrc.gov/sead3portal/.

3.3 Who provides the information? Is it provided directly from the individual or a third party.

Information is entered into the portal (or sent via e-mail) directly by the individual subject.

3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.

There are limited information validation checks done by the SEAD3 portal. Information from travel request submissions can be cross-checked by SMOB with the individuals information in PSATS, if necessary.

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?

Individuals can retrieve their draft travel requests, correct submissions, and update requests with post-travel details in the SEAD3 portal. In the event a travel request is rejected because it requires additional information, the SMOB will correspond with the individual over e-mail to either go into the portal (for NRC personnel) and edit their request, or provide clarifying information in a follow up e-mail message (for non-NRC personnel).

Security Executive Agent Directive 3 (SEAD3)

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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 SEAD3 portal is an internal NRC-accessible website. All NRC employees and contractors with an NRC LAN ID can access the system from the NRC network. Within PSATS, a limited number of SMOB personnel have the ability to review and approve/reject/deny travel requests in the SEAD3 module. Finalized travel requests are accessible to the PSATS Administrator, Security Manager, Senior Adjudicator, Facilities Security Specialists, SMOB Elevated Reviewer, and Adjudicators.

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.

PSATS retains unofficial foreign travel information from SEAD3 in its databases as part of an individuals personnel security file. This information is also referred to for verification when an individual renews their clearance.

4.3 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.

The National Security Agency (NSA) occasionally sends NRC requests for information regarding the foreign travel of clearance-holding personnel. This request typically consists of asking how many NRC-cleared individuals traveled to a specific country/region, for the purpose of national security. No PII is shared with the NSA in response, only the number of individuals, and a list containing the names of individuals who traveled to the specific location during the timeframe requested.

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.

SEAD3 resides behind the NRC network firewall, authorized users must first gain access to the NRC network using valid authentication credentials. SEAD3 user accounts are integrated with the Information Technology Infrastructure (ITI) Identity, Credential, and Access Management (ICAM) for Single Sign-On (SSO) access. The system employs differing user access\privileges that keeps the data segregated within the system.

Security Executive Agent Directive 3 (SEAD3)

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Access to submitted travel requests awaiting approval are restricted to SMOB personnel with a need-to-know, based on roles and responsibilities, and with elevated permissions. An audit log tracks modification to applicable data fields within SEAD3.

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).

SEAD3 is accessible to NRC staff from the NRC VPN, using secure (HTTPS) Internet connections. E-mail correspondence from external clearance holders are encrypted if they contain PII.

4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).

SEAD3 data is stored in the NRC ACS tenant.

4.7 Explain if the project can be accessed or operated at more than one location.

The SEAD3 portal is a web-based system. User access is through authorized network connectivity. Login requirements and access levels remain the same no matter what location an approved user attempts to access the system.

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, all NRC contractors accessing and supporting SEAD3 are NRC badged personnel.

4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.

Audit logs track modifications to certain data fields within SEAD3. All access to data in SEAD3 is restricted to need-to-know based on roles and responsibilities. Audit logs are reviewed by system administrators to monitor activities and report any anomalies within the system. The date and time of the last login is captured.

4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,

trace/track/observe) individuals.

N/A - Although SEAD3 is used to observe unofficial travel data, it does not have a real-time tracking capability.

Security Executive Agent Directive 3 (SEAD3)

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4.11 Define which FISMA boundary this project is part of.

PSATS is included as a subsystem of the MASS FISMA boundary; SEAD3 is a module of PSATS.

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 - provides the estimated date to receive an ATO.

Estimated date:

Yes Indicate the data impact levels (Low, Moderate, High, Undefined) approved by the 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.

EA Number: 20110002.

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.

SMOB personnel with elevated privileges can retrieve information from SEAD3 by a keyword search (i.e., name, country of travel, and/or trip dates).

No, the PII is not retrieved by a personal identifier.

If no, explain how the data is retrieved from the project.

Security Executive Agent Directive 3 (SEAD3)

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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 Personnel Security Files and Associated 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.

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 Personal International Travel Form (https://sead3portal.nrc.gov/sead3portal/landing)

Not Applicable

Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?

Disclosure of PII elements (described above in section 3) is mandatory. Failure to report the information in a timely manner prior to travel and/or immediately upon return could result in disciplinary action and/or affect eligibility for a security clearance.

Security Executive Agent Directive 3 (SEAD3)

Version 1.1 Privacy Impact Assessment 3/11/2025 PIA Template (09-2024)-ML050460335 10 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.

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

Security Executive Agent Directive 3 (SEAD3)

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System Name (include sub-systems, platforms, or other locations where the same data resides)

SEAD3 Portal Records Retention Schedule Number(s)

Please note, after travel requests are submitted (either via the SEAD3 portal or over e-mail) and approved by ADM/DFS/SMOB, the collected information resides in PSATS, where it is retained as part of an individuals case file. Retention for the NRC Personal International Travel Form and licensee travel e-mail correspondence is documented in the PSATS PIA.

E-mail Records GRS 6.1 item 010 - E-mail and other electronic messages of Capstone officials GRS 6.1 item 11 - E-mail and other types of electronic messages of Non-Capstone officials.

All other except those in item 012.

Travel Records GRS 1.1 item 011 - Financial transaction records related to procuring good and services, paying bills, collecting debts, and accounting. All other copies used for administrative or reference purposes.

Approved Disposition Instructions E-mail Records GRS 6.1 item 010 - Permanent. Cut off and transfer in accordance with the Agencys approved NA-1005, Verification for Implementing GRS 6.1. This will be between 15 and 30 years, or after declassification review (when applicable), whichever is later.

For NRC Capstone officials, records are transferred after 15 years.

GRS 6.1 item 11 - Temporary. Delete when 7 years old, but longer retention is authorized if required for business use.

Travel Records GRS 1.1 item 011 - Temporary. Destroy when business use ceases.

Security Executive Agent Directive 3 (SEAD3)

Version 1.1 Privacy Impact Assessment 3/11/2025 PIA Template (09-2024)-ML050460335 12 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.

SEAD3 employs manual processes to support RIM requirements.

Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?

Active personnel security records are retained in SEAD3 for the duration of employment.

Inactive personnel security records in SEAD3 are archived.

Upon deletion of a SEAD3 user account, all reports generated by the user are deleted.

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 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?

For NRC employees and contractors with a security clearance, the SEAD3 portal is used to complete the NRC Personal International Travel Form (https://sead3portal.nrc.gov/sead3portal/landing) prior to, or immediately after returning from unofficial foreign travel. For licensees and other individuals who possess an NRC security clearance, unofficial foreign travel requests are submitted to NRC via the https://sead3portalext.nrc.gov/sead3portal/ portal address.

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.

Security Executive Agent Directive 3 (SEAD3)

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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.

Security Executive Agent Directive 3 (SEAD3)

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Submitting Office: Office of Administration (ADM)

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 Personnel Security Files and Associated Records.

Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 06/11/25

Security Executive Agent Directive 3 (SEAD3)

Version 1.1 Privacy Impact Assessment 3/11/2025 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.3150-0046 Comments:

The collection of SEAD 3 related information is covered by OMB Control Number 3150-0046.

The online portal for licensees is at OMB for approval as part of the renewal of the 10 CFR Part 25 clearance.

Reviewers Name Title Agency Clearance Officer Signed by Benney, Kristen on 05/29/25

Security Executive Agent Directive 3 (SEAD3)

Version 1.1 Privacy Impact Assessment 3/11/2025 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:

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 development of the project, retention functionality or a manual process must be incorporated to meet this requirement.

Reviewers Name Title Sr. Program Analyst, Electronic Records Manager Records and Information Management Specialist Signed by Dove, Marna on 06/10/25 Signed by Williams, Lisa on 05/22/25

Security Executive Agent Directive 3 (SEAD3)

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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 06/13/25

Security Executive Agent Directive 3 (SEAD3)

Version 1.1 Privacy Impact Assessment 3/11/2025 PIA Template (10-2024)-ML050460335 18 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:

Security Executive Agent Directive 3 (SEAD3)

Date CISD received PIA for review:

May 22, 2025 Date CISD completed PIA review:

June 13, 2025 Action Items/Concerns: