ML25198A217
| ML25198A217 | |
| Person / Time | |
|---|---|
| Issue date: | 07/15/2025 |
| From: | Office of the Chief Human Capital Officer, NRC/OCIO/CISD |
| To: | |
| Bobryakova N | |
| References | |
| Download: ML25198A217 (1) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Government Retirement and Benefits (GRB) Platform Office of the Chief Human Capital Officer (OCHCO) /
Office of the Chief Information Officer (OCIO)
Version 2.0 07/15/2025 Template Version 2.5 (03/2025)
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 Document Revision History Date Version PIA Name/Description Author 07/15/2025 2.0 Government Retirement and Benefits (GRB) - Updated into new template and Updated contacts OCIO / OCHCO Oasis Systems, LLC 06/27/2025 DRAFT of 2.0 Government Retirement and Benefits (GRB) - Updated into new template and Updated contacts OCIO / OCHCO Oasis Systems, LLC 12/20/2023 1.0 Government Retirement and Benefits (GRB) - FINAL Release OCIO / OCHCO Oasis Systems, LLC 12/01/2023 DRAFT Government Retirement and Benefits (GRB) - DRAFT Release OCIO / OCHCO Oasis Systems, LLC
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 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 8
6 Records and Information Management-Retention and Disposal 10 7
Paperwork Reduction Act 12 8
Privacy Act Determination 13 9
OMB Clearance Determination 14 10 Records Retention and Disposal Schedule Determination 15 11 Review and Concurrence 16
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 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: Government Retirement and Benefits (GRB)
Platform.
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): GRB is hosted by Government Retirement and Benefits, Inc., in a Government Community Cloud.
Date Submitted for review/approval: July 16, 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.
GRB Platform is a cloud-based Software-as-a-Service (SaaS) Federal retirement and benefits solution provided to the Nuclear Regulatory Commission (NRC) by Government Retirement and Benefits, Inc. The GRB Platform is authorized by the Federal Risk and Authorization Management Program (FedRAMP).
The NRC benefit specialists use GRB to prepare service histories and create retirement estimate reports as well as other related estimate reports. NRC employees use GRB to review their own compensation and benefits information and to submit employee benefits requests.
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
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-ML050460335 2
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.
The PIA has been transferred into the latest template and contacts were updated.
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 Richard Revzan Office of the Chief Human Capital Officer (OCHCO) /
Associate Director for Human Resources Operations and Policy (ADHROP)
ISSM Natalya Bobryakova Office of the Chief Information Officer (OCIO) / Cyber and Infrastructure Security Division (CISD) /
Information Assurance and Oversight Branch (IAOB) 301-287-0671 Executive Sponsor Richard Revzan Office of the Chief Human Capital Officer (OCHCO) /
Associate Director for Human Resources Operations and Policy (ADHROP)
Other Business Project Manager/ Technical Project Manager Hoai Vo Office of the Chief Human Capital Officer (OCHCO) /
Human Capital Analysis Branch (HCAB) 301-415-3955
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-ML050460335 3
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 5 United States Code (U.S.C.) Chapters 83 and 84
Executive Order Social Security numbers are collected and used in accordance with Executive Order 9397, as amended by Executive Order 13478.
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).
Information collected is used for calculation of Federal employees retirement benefit estimates, disability and death benefit estimates, Service Computation Date calculation, Military/Civilian deposit and redeposit requirements, and retirement plan determination.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
GRB uses Social Security numbers to identify employees and populate employees GRB profiles in order to maintain service information and to compute estimates of retirement benefits.
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-ML050460335 4
3 Characterization of the Information In the table below, mark the categories of individuals for whom information is collected.
Category of individual
Federal employees
Contractors
Members of the Public (any individual other than a federal employee, consultant, or contractor)
Licensees
Other In the table below, is a list of the most common types of PII collected. Mark all PII that is collected and stored by the project/system. If there is additional PII not defined in the table below, a comprehensive listing of PII is provided for further reference in ADAMS at the following link: PII Reference Table 2023.
Categories of Information
Name
Resume or curriculum vitae
Date of Birth
Driver's License Number
Country of Birth
License Plate Number
Citizenship
Passport number
Nationality
Relatives Information
Race
Taxpayer Identification Number
Home Address
Credit/Debit Card Number
Social Security number (Truncated or Partial)
Medical/health information
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: Information about spouses, dependents, and designated beneficiaries of a Federal employee, if applicable: name, SSN, date of birth, banking information for direct deposit.
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Categories of Information Information collected in the Application for Death Benefits include applicants name, SSN, date of birth, banking information for direct deposit; spouses (including former spouses) name; dependent childs name, SSN, and date of birth.
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).
GRB is populated with information entered directly by employees and via electronic file transfer from FPPS. In the event of a death in service, the benefit specialist collects information from the survivors and then manually enters the information in GRB to retrieve the applicable death benefit calculation and forms.
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.
Office of Personnel Management (OPM) Standard Form 3104, Application for Death Benefits, https://www.opm.gov/forms/pdf_fill/sf3104b.pdf.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
The information is provided by the individual. In the event of a death in service, the benefit specialists collect information from the survivors.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
Employees and benefit specialists verify the information for accuracy and completeness.
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.
N/A.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous privacy information?
Individuals cannot update information within GRB. The information used to populate GRB is from employees official personnel records. The employee should notify the benefit specialists if there are any discrepancies.
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-ML050460335 6
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).
NRC OCHCO staff and/or Contractor access and administer all employee data.
All NRC employees may access the system to review their own data.
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.
GRB employs role-based access controls and permits access according to users role.
Authorized users can access GRB by utilizing a Single Sign-on authentication service provided by the agencys Identity, Credential, and Access Management (ICAM) Authentication Gateway.
ICAM ensures that individuals who access NRC computer systems and services have been appropriately vetted for access.
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).
GRB allows only secure web connections via the Hypertext Transfer Protocol Secure (HTTPS)
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-ML050460335 7
that uses encryption for secure communication over the Internet.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
GRB is hosted by Government Retirement and Benefits, Inc., a Cloud Service Provider (CSP),
in a FedRAMP authorized cloud environment.
4.7 Explain if the project can be accessed or operated at more than one location.
N/A.
4.8 Can the project be accessed by a contractor? Have the contractors completed an IT-II investigation? Do they possess an NRC badge?
The NRC OCHCO contractors can access the data in GRB to provide authorized services to OCHCO. NRC contractors do possess NRC badges. The CSP staff can access the data in a cloud environment to support systems operations. The CSP staff undergo the Public Trust background investigations conducted by the U.S. Internal Revenue Service (IRS). The CSP staff do not possess NRC badges.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
The OCHCO administrators review auditable events, audit logs, and audit reporting records for indications of inappropriate or unusual activity on a weekly basis and report any suspicious activity to the NRC Computer Security and Incident Response Team (CSIRT).
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.
GRB is a component of the Third Party System (TPS) OCHCO External Services Subsystem (OES).
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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.
GRB is a component of TPS-OES. 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.
The information on the individual is retrieved by the employees name
No, the PII is not retrieved by a personal identifier.
If no, explain how the data is retrieved from the project.
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-ML050460335 9
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):
Government-wide SORN - OPM-GOVT-1, General Personnel 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 The required OPM forms contain Privacy Act Statements. Privacy Act Statements are provided on all retirement and benefit standard forms.
Not Applicable
Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
Yes, providing PII is mandatory. PII is needed to create an employees GRB profile in order to maintain service information and to compute an estimate of retirement benefits. The retirement benefit estimates cannot be calculated without access to employees PII.
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-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
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-ML050460335 11 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)
Government Retirement and Benefits (GRB)
Platform Records Retention Schedule Number(s)
GRS 2.5, item 020: Individual employee separation files. It includes records not included in separating employees Electronic Official Personnel Folder (eOPF), documenting individual employees transfer to another Federal agency of office or voluntary or involuntary separation from career, disability, early retirement, death, political appointment service, and legal and financial obligations of government.
GRS 2.5, item 051: Phased retirement individual case files.
Case files of individual employee participation in phased retirement.
Approved Disposition Instructions GRS 2.5 item 020: Temporary. Destroy 1 year after date of separation or transfer, but longer retention is authorized if required for business use.
GRS 2.5, item 051: Temporary. Destroy 1 year after employee participation concludes or the employee retires, but longer retention is authorized if required for business use. (These records could be retained with the retirement file and should be retained as the GRS 2.5 item 020 as above).
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.
Government Retirement and Benefits (GRB)
Platform 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 Will the records/data or a composite be The records/data is deleted manually.
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-ML050460335 12 automatically or manually deleted once they reach their approved retention?
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 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?
N/A.
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)?
N/A.
7.3 Is the collection of information required by a rule of general applicability?
N/A.
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.
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (03-2025)-ML050460335 13 8 Privacy Act Determination Project/System Name: Government Retirement and Benefits (GRB) Platform 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:
This system is covered by Government-wide SORN - OPM-GOVT-1, General Personnel Records.
Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 08/21/25
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 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. 3206-0156 and 3206-0172 Comments:
The listed control numbers are for SF-2800 and SF-3104b respectively.
Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 08/05/25
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 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 08/20/25 Signed by Williams, Lisa on 08/13/25
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 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 08/25/25
Government Retirement and Benefits (GRB) Platform Version 2.0 Privacy Impact Assessment 07/15/2025 PIA Template (10-2024)-ML050460335 17 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Government Retirement and Benefits (GRB) Platform Date CISD received PIA for review:
Aug 20, 2025 Date CISD completed PIA review:
Aug 21, 2025 Action Items/Concerns: