ML25139A486
| ML25139A486 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/2025 |
| From: | Natalya Bobryakova Office of the Chief Human Capital Officer, NRC/OCIO/CISD, Oasis Systems |
| To: | |
| Hardy S | |
| References | |
| Download: ML25139A486 (21) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Talent Management System (TMS)
Office of the Chief Information Officer (OCIO) /
Office of the Chief Human Capital Officer (OCHCO)
Version 2.0 04/21/2025 Template Version 2.5 (03/2025)
Talent Management System (TMS)
Version 2.0 Privacy Impact Assessment 04/21/2025 Document Revision History Date Version PIA Name/Description Author 04/21/2025 2.0 TMS PIA - PIA transferred to latest template. Updated section 4.2, and Points of contact OCIO/OCHCO Oasis Systems, LLC 04/02/2025 DRAFT of 2.0 TMS PIA - PIA transferred to latest template. Updated section 4.2, and Points of contact OCIO/OCHCO Oasis Systems, LLC 07/24/2024 1.0 TMS PIA - PIA transferred to latest template. Updated sections 1.2, 1.3, 2.1, 3, 3.6, 5.2.
OCIO/OCHCO Oasis Systems, LLC 07/08/2024 DRAFT TMS PIA - DRAFT Release - PIA transferred to latest template. Updated sections 1.2, 1.3, 2.1, 3, 3.6, 5.2.
OCIO/OCHCO Oasis Systems, LLC
Talent Management System (TMS)
Version 2.0 Privacy Impact Assessment 04/21/2025 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 13 8
Privacy Act Determination 15 9
OMB Clearance Determination 16 10 Records Retention and Disposal Schedule Determination 17 11 Review and Concurrence 18
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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: Talent Management System (TMS).
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): Data resides within a cloud service platform hosted by Cornerstone OnDemand, the Cloud Service Provider (CSP).
Date Submitted for review/approval: May 19, 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 Talent Management System (TMS) is a Software-as-a-Service (SaaS) cloud solution that provides the U.S. Nuclear Regulatory Commission (NRC) with an online learning platform and tools for the automation of performance management tasks and strategic workforce planning.
TMS is operated by Cornerstone OnDemand, Inc. (CSOD) on their cloud platform, the Cornerstone OnDemand - Unified Talent Management Suite (CUTMS).
TMS utilizes the CUTMS Learning Management and Performance Management modules to deliver web-based, instructor-led training and automation of performance management tasks.
The CUTMS Learning Management System assists the NRC in complying with e-Learning standards and provides a broad range of capabilities to enable program management and tracking relevant to training efforts, curriculum development, and delivery of a variety of training courses. The CUTMS Performance Management module assists the NRC in the development of employee performance appraisals and allows the use of competency models for skill management and strategic workforce planning.
TMS supports the following agency functions:
Storage of training records, course catalog, learning content management, course scheduling, and online course registration, Management and use of competency models to support the individual development plans and close skill gaps, Automation of performance management tasks, including development of employee performance appraisals and skill management.
TMS is comprised of the following modules:
Learning Management module to manage the development, delivery, and tracking of training completion,
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Performance Management module to automate performance, skill, and competency management tasks.
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.
Updated section 4.2, and Points of Contact information.
Other (explain) 1.3 Points of
Contact:
Role Contact Information Name Office/Division/Branch Phone Number Project Manager(s)
Hoai Vo Office of the Chief Human Capital Officer (OCHCO) /
Human Capital Analysis Branch (HCAB) 301-415-3955 System Owner/Data Owner or Steward Jennifer Golder Office of the Chief Human Capital Officer (OCHCO) 301-287-0741 ISSM Natalya Bobryakova Office of the Chief Information Officer (OCIO) / Cyber and Information Security Division (CISD) / Information Assurance and Oversight Branch (IAOB) / Information Assurance Team (IAT)
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Role Contact Information Name Office/Division/Branch Phone Number 301-287-0671 Executive Sponsor Jennifer Golder Office of the Chief Human Capital Officer (OCHCO) 301-287-0741 Other COR / Business Project Manager Andrey Korsak Office of the Chief Human Capital Officer (OCHCO) /
Human Capital Analysis Branch (HCAB) 301-287-0574 Technical Project Manager Hoai Vo Office of the Chief Human Capital Officer (OCHCO) /
Human Capital Analysis Branch (HCAB) 301-287-0574 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.
Performance Appraisal authority: 5 U.S.C.
§ 4301 - 4305; 5 U.S.C. § 4311 - 4315
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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).
The Office of the Chief Human Capital Officer (OCHCO) and NRC staff use the data collected by the system to:
Manage and track training efforts, including training and curriculum development, training delivery, administration, monitoring functions, and reporting requirements, Review the status of open and completed training, Analyze trends based on training activity, Prepare and submit standard reports, NRC-developed reports, ad-hoc query results as
- needed, Performance reviews and appraisals, Competency and skills management.
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 the TMS.
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: Agreement State employees, NRC authorized training attendees such as international training attendees, master material licensees 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.
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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
Sex (Male or Female)
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: office/organization, training related data, education history, Work email address, Course history, performance reviews, position, grade, training dates, course and session info, cost, approvals, and training facility, affiliation, work phone number, and course/session information.
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).
Information from NRC employees and contractors: TMS collects information about individuals from Federal Personnel Payroll System (FPPS) and Enterprise Identity Hub (EIH).
Information from Agreement State employees and external users (i.e., other Federal, international, Master Materials Licensee (MML) personnel): Name, affiliation, email address, work phone number, and course/session information.
Around October 1st each year, the Office of Nuclear Material Safety and Safeguards (NMSS) sends a memo to all Agreement States to notify them of the upcoming NRC training courses.
Agreement States that wish to participate in these courses must fill out a training application and submit the application to NMSS.
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NMSS gathers information regarding course participants and enters the information into TMS.
Agreement State information consists of student name and Agreement State abbreviation.
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.
Application for NRC-Sponsored Training for Agreement State Staff, ML23116A099 Application for NRC-Sponsored Training for MML Personnel, ML23116A103 3.3 Who provides the information? Is it provided directly from the individual or a third party.
Information is provided 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.
Information collected from FPPS, and EIH is verified by the employee and an approving official.
In addition, EIH data is validated by 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 FPPS, and EIH is verified by the employee and an approving official.
Users of the system can input and modify some limited data (e.g., performance reviews, development plans, training requests, and course surveys) as allowed by their access permissions. 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. Different roles exist within the system for various levels of privileged access.
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.
TMS offers an Application Programming Interface (API) that allows NRC systems to access its
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data. Most of the data fields that are stored in the TMS are potentially accessible through the API for direct reporting from TMS. The TMS data that are shared with other NRC systems include the following information about employees: Employee data (employee name, user ID, email address, employment history, job title, hire date, and other demographic or role-specific details), Organizational Unit, Learning, Performance, and Capability.
TMS shares information using an API connection with the Enterprise Identity Hub (EIH), NRC Enterprise eXecution and Utilization System (NEXUS), Strategic Workforce Planning (SWP) system, Microsoft PowerBI, Microsoft PowerAutomate, and Microsoft PowerApps. Additionally, TMS supports scheduled reports, which are delivered via email to the ICAM Support Resource mailbox at ICAMSupport.Resource@nrc.gov for Identity, Credential, and Access Management (ICAM).
4.3 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.
Yes, training completion data is transmitted to the OPM Enterprise Human Resources Integration Data Warehouse (EHRIDW) system owned by OPM.
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: ML24036A017
Other
None 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
TMS authentication is provided by the ICAM Authentication Gateway via the NRC enterprise authentication services to allow a Single Sign-On (SSO) authentication and Multifactor authentication for users.
4.5 Explain how the data is transmitted and how confidentiality is protected (i.e.,
encrypting the communication or by encrypting the information before it is transmitted).
The data is transmitted via secure encrypted connections.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
Data resides within a cloud service platform hosted by Cornerstone OnDemand.
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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? Have the contractors completed an IT-II investigation? Do they possess an NRC badge?
Yes, NRC badged contractors have access to information that pertains to them individually.
Different roles exist within the system for various levels of privileged access.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
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.
TMS is a component of the NRCs Third Party System - Talent Management (TPS-TM) subsystem. The TPS EA number is 20180002.
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 Authority To Operate (ATO) for Talent Management (TM) (ML19233A311)
Indicate the data impact levels (Low, Moderate, High, Undefined) approved by the Chief Information Security Officer (CISO)
Confidentiality-Moderate Integrity-Moderate Availability-Moderate
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4.13 Provide the NRC system Enterprise Architecture (EA)/Inventory number. If unknown, contact EA Service Desk to get the EA/Inventory number.
The TPS EA number is 20180002.
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.
Employee ID, LAN ID, Individuals 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): Official Personnel Training Records - NRC 19, OPM GOVT-1
SORN is in progress
SORN needs to be created
Unaware of an existing SORN
No, this system is not a system of records and a SORN is not applicable.
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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.
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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)
Talent Management System (TMS)
Records Retention Schedule Number(s)
Unscheduled - Records for Mission-related training which is included in TMS. See Note below in Disposition Instructions regarding requirements for unscheduled records.
GRS 2.6 item 010 - Non-mission employee training program records GRS 2.6 item 020 - Ethics training records GRS 2.6 item 030 - Individual training records GRS 2.2 item 070 - Employee performance file system records. Acceptable performance appraisals of non-senior executive service employees.
GRS 2.2 item 071-Employee performance file system records. Unacceptable performance appraisals of non-senior executive service employees.
GRS 2.2 item 072 - Employee performance file system records. Records of senior executive service employees.
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GRS 3.1 item 020 - Information technology operations and maintenance records.
Approved Disposition Instructions Unscheduled: Records for Mission-related training which is included in TMS:
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.
GRS 2.6 item 010; GRS 2.6 item 020: 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.
GRS 2.6 item 030: Temporary. Destroy when 6 years old or when superseded, whichever is later, but longer retention is authorized if required for business use.
GRS 2.2 item 070: Temporary. Destroy no sooner than 4 years after date of appraisal, but longer retention is authorized if required for business use.
GRS 2.2 item 071: Temporary. Destroy after employee completes 1 year of acceptable performance from the date of written advance notice of proposed removal or reduction-in-grade notice. This disposition instruction is mandatory; deviations are not allowed.
GRS 2.2 item 072: Temporary. Destroy no sooner than 5 years after date of appraisal, but longer retention is authorized if required for business use.
GRS 2.2 item 073: Temporary. Destroy when superseded. This disposition instruction is
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GRS 3.1 item 020: Temporary. Destroy 3 years after agreement, control measures, procedures, project, activity, or transaction is obsolete, completed, terminated, or superseded, 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.
CSOD owns the TMS 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?
CSOD owns the TMS system and is responsible for the retention of its data.
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)
CSOD owns the TMS system and is responsible for the retention of its data.
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.
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)?
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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.
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Submitting Office: 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, OPM GOVT-1 General Personnel Records Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 06/11/25
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Version 2.0 Privacy Impact Assessment 04/21/2025 PIA Template (03-2025)-ML050460335 16 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:
Currently the TMS does not need an OMB Clearance since it does not collect information directly but uses information on non-Federal employees provided by other sources. If changes are made to the system to directly collect information from non-Federal employees, the need for an OMB clearance will need to be revisited.
Reviewers Name Title Acting Agency Clearance Officer Signed by Benney, Kristen on 05/29/25
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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 06/10/25 Signed by Williams, Lisa on 06/10/25
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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.
Acting Director Chief Information Security Officer Cyber Information Security Division Office of the Chief Information Officer Signed by Nalabandian, Garo on 06/20/25
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Version 2.0 Privacy Impact Assessment 04/21/2025 PIA Template (10-2024)-ML050460335 19 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Talent Management System (TMS)
Date CISD received PIA for review:
5/29/2025 Date CISD completed PIA review:
6/11/2025 Action Items/Concerns: