ML25167A280
| ML25167A280 | |
| Person / Time | |
|---|---|
| Issue date: | 06/12/2025 |
| From: | NRC/OGC |
| To: | |
| Harris B | |
| References | |
| Download: ML25167A280 (19) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Tort Claims and Personal Property Claims Records Office of the General Counsel Version 1.0 06/12/2025 Instruction Notes:
Please do not enter the PIA document into ADAMS. An ADAMS accession number will be assigned through the e-Concurrence system which will be handled by the Privacy Team Template Version 2.5 (03/2025)
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 Document Revision History Date Version PIA Name/Description Author 06/06/2024 1.0 Tort Claims and Personal Property Claims Records Initial Release Brian Harris
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 Table of Contents 1
Description 1
2 Authorities and Other Requirements 3
3 Characterization of the Information 4
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
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 PIA Template (03-2025)-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: Tort Claims and Personal Property Claims Records.
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) SharePoint.
Date Submitted for review/approval: June 11, 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 Tort Claims and Personal Property Claims Records System on SharePoint is used by the Nuclear Regulatory Commission (NRC) Office of the General Counsel (OGC) to manage claims with the NRC under the Federal Tort Claims Act or the Military Personnel and Civilian Employees Claims Act. The SharePoint site allows electronic organizing of claims, associated documents and associates claim notes, contact information, documents, reminders, tasks, milestones, and other data in a secure environment.
The underlying infrastructure for SharePoint falls within the Information Technology Infrastructure (ITI) Azure Cloud Services (ACS) FISMA Boundary. ITI does not own, nor is it responsible for the management of this site including access controls or data stored within it.
This SharePoint site is fully owned and managed by the OGC staff.
Please mark appropriate response below if your project/system will involve the following:
PowerApps Artificial Intelligence (AI)
Dashboard Public Website SharePoint Internal Website Cloud Service Provider Server/Database Design Other
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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.
Annual Review If making minor edits to an existing system/project, briefly describe the changes below. Privacy Officer requested executive sponsor to create a PIA to align with the existing SORN.
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)
Yana Shnayder OGC/LHE/PSB 301-287-0706 System Owner/Data Owner or Steward N/A ISSM N/A Executive Sponsor Brian Harris OGC/LRAA/LECL 301-287-9120 Other N/A
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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 Federal Tort Claims Act, 28 U.S.C. 2671 et seq.; Military Personnel and Civilian Employees' Claims Act, 31 U.S.C. 3721; 44 U.S.C. 3101
Executive Order
Federal Regulation 28 CFR parts 14 and 15; 10 CFR part 14; 45 CFR part 34
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).
To process and track claims with the NRC under the Federal Tort Claims Act or the Military Personnel and Civilian Employees Claims Act.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
The project does not specifically collect Social Security numbers; however, Social Security numbers may be collected incidentally as part of the process. In particular, Social Security numbers may be included on documents or materials collected and used during claim review process.
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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
Sex (Male or Female)
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
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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).
The information may be collected directly from the employee, contractor, or member of the public.
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 436, Report of Work-Related Injuries and Illness; NRC 600, Employee Claim of Loss or Damage to Personal Property; SF 91, Motor Vehicle Accident (Crash) Report; SF 94, Statement of Witness; SF 95, Claim for Damage, Injury, or Death 3.3 Who provides the information? Is it provided directly from the individual or a third party.
Information may be collected directly from the individual or from a third party.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
The project does not check for accuracy as the individual would, in most circumstances, be able to address or contest the informations validity during the course of determining the validity of the claim.
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 would, in most circumstances, be able to address or contest the informations validity during the course of determining the validity of the claim.
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 Tort Claims and Personal Property Claims Records System SharePoint site will have limited access/permissions. Access is granted to only those staff in the Office of the General Counsel (OGC) who have authorization and a need to know. This includes OGC/LECL attorneys; the Deputy General Counsel for Legislation, Rulemaking and Agency Administration; authorized staff from OGC PSB and authorized administrative assistants within OGC. In
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addition, two NRC badged contractors have access to the SharePoint site to assist with future maintenance of the site.
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.
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.
NRC Cleared users authenticate via ICAM to the O365 environment (PIV login) and specific access to the SharePoint site is managed through SharePoint permissions set by the SharePoint owners. SharePoint owners are responsible for quarterly review of the permissions.
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).
Information will primarily be in documents (e.g.,.pdf,.doc,.msg, or.jpeg files) transferred via email (which is encrypted), downloaded from platforms supported by other administrative bodies, or that are in existing NRC records on the NRC IT systems.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
NRC SharePoint Site.
4.7 Explain if the project can be accessed or operated at more than one location.
No, the site is only accessed via the NRC production network.
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4.8 Can the project be accessed by a contractor? Have the contractors completed an IT-II investigation? Do they possess an NRC badge?
Two NRC badged contractors have access to the SharePoint site to assist with future maintenance of the site. They have completed an IT-II investigation.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
Updates, edits, and additional documents added to the site are tracked and date and time stamped with the username. In addition, site access is limited to those with a business need to access the system. Access permissions will be reviewed periodically.
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.
Information Technology Infrastructure (ITI) Azure Cloud Services (ACS) FISMA Boundary.
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.
The Tort Claims and Personal Property Claims Records System SharePoint site falls within Information Technology Infrastructure ACS boundary. The ITI EA number is 20090005.
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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.
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):
NRC-41: Tort Claims and Personal Property Claims Records DOL/GOVT-1 (Office of Worker's Compensation Programs, Federal Employees' Compensation Act File)
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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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 Privacy Act Statements are included on each of the NRC forms, which include NRC form 436 and 600.
Not Applicable
Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
It depends on the circumstances of the case. Not providing information may negatively impact the individuals claim.
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
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 PIA Template (03-2025)-ML050460335 10 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)
Tort Claims and Personal Property Claims Records System Records Retention Schedule Number(s)
GRS 1.1 ITEM 080 Administrative claims by or against the United States Approved Disposition Instructions GRS 1.1.080: Temporary. Destroy 7 years after final action, but longer retention is authorized if required for business 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.
No.
Tort Claims and Personal Property Claims Records 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 Temporary Records Manually deleted
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 PIA Template (03-2025)-ML050460335 11 Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
Tort Claims and Personal Property Claims Records 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 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. Information from the public may be collected on SF 94, Statement of Witness and SF 95, Claim for Damage, Injury or Death. The collection of this information is approved by OMB under clearance numbers 3090-0118 and 1105-0008.
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.
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 PIA Template (03-2025)-ML050460335 12 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.
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 PIA Template (03-2025)-ML050460335 13 8 Privacy Act Determination Project/System Name: Tort Claims and Personal Property Claims Submitting Office: Office of the General Counsel 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-41: Tort Claims and Personal Property Claims Records, DOL/GOVT-1 (Office of Worker's Compensation Programs, Federal Employees' Compensation Act File)
Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 07/10/25
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 PIA Template (03-2025)-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. 3090-0118 and 1105-0008 Comments:
Information from the public may be collected on SF 94, Statement of Witness and SF 95, Claim for Damage, Injury or Death. The collection of this information is approved by OMB under clearance numbers 3090-0118 and 1105-0008. These are government-wide standard forms (SF).
Reviewers Name Title Acting Agency Clearance Officer Signed by Benney, Kristen on 07/02/25
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 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 07/09/25 Signed by Williams, Lisa on 07/09/25
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 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 07/10/25
Tort Claims and Personal Property Claims Records Version 1.0 Privacy Impact Assessment 06/12/2025 PIA Template (10-2024)-ML050460335 17 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Tort Claims and Personal Property Claims Records.
Date CISD received PIA for review:
June 16, 2025 Date CISD completed PIA review:
July 10, 2025 Action Items/Concerns: