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**United States Department of Agriculture**

**National Agricultural Statistics Service**

**UNIX GSS**

**Privacy Impact Assessment**

**(PIA)**

**FINAL**

***version 2.2***

July 24, 2008

***[Prepared by:]{.underline}***

> DSD Laboratories
>
> 500 Interstate Park Drive, Suite 534
>
> Montgomery, Alabama 36109

[]{#__RefHeading___Toc207160545 .anchor}**[REVISION AND HISTORY
PAGE]{.smallcaps}**

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| 2.1     | 1         | Cosmetic  |           |           | RAC       |
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| 2.2     | July 24,  | Added     |           |           | RAC       |
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**[Table of Contents]{.smallcaps}**

Paragraph Page

[[REVISION AND HISTORY PAGE]{.smallcaps}
ii](#__RefHeading___Toc207160545)

[[1]{.smallcaps} [USDA Privacy Impact Assessment
Questionnaire]{.smallcaps}
4](#usda-privacy-impact-assessment-questionnaire)

[1.1 Data in the System 4](#data-in-the-system)

[1.2 Data Access 5](#data-access)

[1.3 Data Attributes 6](#data-attributes)

[1.4 Maintenance of Administrative Controls
7](#maintenance-of-administrative-controls)

[2 Summary 8](#summary)

# [USDA Privacy Impact Assessment Questionnaire]{.smallcaps}

## Data in the System

+-----------------------------------+-----------------------------------+
| 1\. Generally describe the        | Customer information --           |
| information to be used in the     | Information on all participating  |
| system in each of the following   | farmers and ranchers in the US    |
| categories: Customer, Employee,   | which include name, address,      |
| and Other.                        | phone number, size of operation,  |
|                                   | gender, race.                     |
|                                   |                                   |
|                                   | Other -- agribusiness -- Firm     |
|                                   | names, manager names, address,    |
|                                   | phone number, size of operation   |
|                                   | in various categories.            |
|                                   |                                   |
|                                   | All information collected and     |
|                                   | processed by this system,         |
|                                   | including personally identifiable |
|                                   | information, is protected by US   |
|                                   | Code: Title 7, 2276 --            |
|                                   | Confidentiality of Information.   |
+-----------------------------------+-----------------------------------+
| 2a. What are the sources of the   | The population of farmers,        |
| information in the system?        | ranchers, agri-businesses, and    |
|                                   | other federal agencies (FSA, IRS, |
|                                   | Census \[NPC\], FSIS) and         |
|                                   | InfoUSA.                          |
+-----------------------------------+-----------------------------------+
| 2b. What USDA files and databases | The NASS UNIX GSS utilizes both   |
| are used? What is the source      | transactional and analytical      |
| agency?                           | databases used in all Census,     |
|                                   | Survey, Support and Estimation    |
|                                   | and Dissemination applications    |
|                                   | used within the system.           |
|                                   |                                   |
|                                   | Source Agencies: NASS, FSA, FSIS  |
+-----------------------------------+-----------------------------------+
| 2c. What Federal Agencies are     | FSA, IRS, FSIS and Bureau of      |
| providing data for use in the     | Census                            |
| system?                           |                                   |
+-----------------------------------+-----------------------------------+
| 2d. What State and Local Agencies | None.                             |
| are providing data for use in the |                                   |
| system?                           |                                   |
+-----------------------------------+-----------------------------------+
| 2e. From what other third party   | InfoUSA, Universities             |
| sources will data be collected?   | (extension), commodity            |
|                                   | organizations, trade magazines.   |
+-----------------------------------+-----------------------------------+
| 2f. What information will be      | Refer to 1 above.                 |
| collected from the                |                                   |
| customer/employee?                |                                   |
+-----------------------------------+-----------------------------------+
| 3a. How will data collected from  | Criteria/Auditing questionnaire   |
| sources other than the USDA       | to the individual under review    |
| records and the customer be       | asking them to fill in the        |
| verified for accuracy?            | specifics for them.               |
|                                   |                                   |
|                                   | Name information is not verified  |
|                                   | by inference from a source.       |
|                                   | Instead that is used to start a   |
|                                   | questionnaire as identified       |
|                                   | above.                            |
+-----------------------------------+-----------------------------------+
| 3b. How will data be checked for  | Completeness is defined by the    |
| completeness?                     | individuals that fill out the     |
|                                   | questionnaires.                   |
+-----------------------------------+-----------------------------------+

## Data Access

  ----------------------------------- -----------------------------------
  1\. Who will have access to the     Access to data is limited only to
  data in the system (Users,          users authorized by NASS to modify,
  Managers, System Administrators,    maintain and review the data. This
  Developers, Other)?                 includes authorized managers,
                                      system administrators and
                                      developers. Each user also signs a
                                      pledge of confidentiality that
                                      carries severe legal penalties for
                                      violating the pledge.

  2\. How is access to the data by a  Business function managers define
  user determined? Are criteria,      the access need for the user based
  procedures, controls, and           on user requirements. Local manager
  responsibilities regarding access   verifies the authenticity and
  documented?                         veracity of the individual who is
                                      being approved for access. Access
                                      request as well as approval is
                                      documented accordingly by
                                      management and the Technical
                                      Services Branch. The Computer
                                      Security Staff audits access
                                      routinely.

  3\. Will users have access to all   See above. Users will only have
  data on the system or will the      access to data needed to carry out
  user's access be restricted?        their assignments. There are
  Explain.                            appropriate management controls for
                                      this purpose.

  4\. What controls are in place to   All authorized NASS users are
  prevent the misuse (e.g. browsing,  required to sign a pledge of
  unauthorized use) of data by those  confidentiality that carries severe
  having access?                      legal penalties for violating the
                                      pledge. NASS employs physical
                                      security controls, logical access
                                      controls, technological controls,
                                      auditing and monitoring of
                                      controls.

  5a. Do other systems share data or  FSA and FSIS provide data that are
  have access to data in this system? entered into the system. These are
  If yes, explain.                    done periodically through operator
                                      intervention.

  5b. Who will be responsible for     Read only interface so N/A
  protecting the privacy rights of    
  the customers and employees         
  affected by the interface.          

  6a. Will other agencies share data  The USDA FSA and ERS have limited
  or have access to data in this      access to some of the data stored
  system (International, Federal,     in the system and are controlled by
  State, Local, and Other)?           use of both hardware and software
                                      security controls.

  6b. How will the data be used by    It will only be used to support the
  the agency?                         Agency's mission of providing
                                      timely, accurate, and useful
                                      statistics in service to U.S.
                                      agriculture.

  6c. Who is responsible for assuring The NASS Deputy Administrator for
  proper use of the data?             Programs and Products.
  ----------------------------------- -----------------------------------

## Data Attributes

+-----------------------------------+-----------------------------------+
| 1\. Is the use of the data both   | Yes.                              |
| relevant and necessary to the     |                                   |
| purpose for which the system is   |                                   |
| being designed?                   |                                   |
+-----------------------------------+-----------------------------------+
| 2a. Will the system derive new    | No.                               |
| data or create previously         |                                   |
| unavailable data about an         |                                   |
| individual through aggregation    |                                   |
| from the information collected?   |                                   |
+-----------------------------------+-----------------------------------+
| 2b. Will the new data be placed   | No.                               |
| in the individual's record        |                                   |
| (customer or employee)?           |                                   |
+-----------------------------------+-----------------------------------+
| 2c. Can the system make           | No.                               |
| determinations about customers or |                                   |
| employees that would not be       |                                   |
| possible without the new data?    |                                   |
+-----------------------------------+-----------------------------------+
| 2d. How will the new data be      | N/A                               |
| verified for relevance and        |                                   |
| accuracy?                         |                                   |
+-----------------------------------+-----------------------------------+
| 3a. If data is being              | The same controls that are in     |
| consolidated, what controls are   | place for the raw data collected  |
| in place to protect the data from | from farmers and agri-businesses. |
| unauthorized access or use?       | In this case consolidation refers |
|                                   | to the normal process of          |
|                                   | aggregation of statistical data   |
|                                   | and not personally identifiable   |
|                                   | information.                      |
+-----------------------------------+-----------------------------------+
| 3b. If processes are being        | N/A.                              |
| consolidated, are the proper      |                                   |
| controls remaining in place to    |                                   |
| protect the data and prevent      |                                   |
| unauthorized access? Explain.     |                                   |
+-----------------------------------+-----------------------------------+
| 4a. How will the data be          | Yes. The GSS can use personal     |
| retrieved? Can it be retrieved by | identifiers to retrieve privacy   |
| personal identifier? If yes,      | info about an individual.         |
| explain.                          | Generally, retrieval is made      |
|                                   | possible by using a unique ID     |
|                                   | assigned to each respondent.      |
+-----------------------------------+-----------------------------------+
| 4b. What are the potential        | Our data providers have full      |
| effects on the due process rights | protection and due process rights |
| of customers and employees of:    | under US Code: Title 7, 2276 --   |
|                                   | Confidentiality of Information.   |
| -   consolidation and linkage of  | None of the items listed here can |
|     files and systems;            | be used to violate these rights   |
|                                   | to due process.                   |
| -   derivation of data            |                                   |
|                                   |                                   |
| -   accelerated information       |                                   |
|     processing and decision       |                                   |
|     making;                       |                                   |
|                                   |                                   |
| -   use of new technologies.      |                                   |
+-----------------------------------+-----------------------------------+
| 4c. How are the effects to be     | N/A.                              |
| mitigated?                        |                                   |
+-----------------------------------+-----------------------------------+

## Maintenance of Administrative Controls

  ----------------------------------- -----------------------------------
  1a. Explain how the system and its  The privacy and confidentiality of
  use will ensure equitable treatment all data providers are covered
  of customers and employees.         equally by US Code: Title 7, 2276.

  2a. If the system is operated in    N/A.
  more than one site, how will        
  consistent use of the system and    
  data be maintained in all sites?    

  2b. Explain any possibility of      Not possible to promote disparate
  disparate treatment of individuals  treatment based on the system
  or groups.                          processing. Any disparity would be
                                      applied at the human level devoid
                                      of the system or the system
                                      processing.

  2c. What are the retention periods  Data are retained as long as the
  of data in this system?             information are needed for list
                                      building. Census data are retained
                                      for ten to fifteen years in
                                      electronic form.

  2d. What are the procedures for     Data are expunged from electronic
  eliminating the data at the end of  systems, and paper questionnaires
  the retention period? Where are the are either sent to the National
  procedures documented?              Archives or shredded. The
                                      documentation for these procedures
                                      is stored in our policy and
                                      procedures manuals and
                                      instructions. They can be found in
                                      our HQ library and in our Field
                                      Offices.

  2e. While the data is retained in   Data are used only in support of
  the system, what are the            creating statistical information
  requirements for determining if the which are deemed accurate,
  data is still sufficiently          relevant, timely, and complete for
  accurate, relevant, timely, and     such purposes as are necessary for
  complete to ensure fairness in      the publication of statistical
  making determinations?              reports.

  3a. Is the system using             No.
  technologies in ways that the USDA  
  has not previously employed (e.g.   
  Caller-ID)?                         

  3b. How does the use of this        N/A.
  technology affect customer/employee 
  privacy?                            

  4a. Will this system provide the    No.
  capability to identify, locate, and 
  monitor [individuals]{.underline}?  
  If yes, explain.                    

  4b. Will this system provide the    No.
  capability to identify, locate, and 
  monitor [groups of                  
  people]{.underline}? If yes,        
  explain.                            

  4c. What controls will be used to   All NASS employees must sign a
  prevent unauthorized monitoring?    pledge of confidentiality that
                                      carries severe legal penalties for
                                      violating the pledge. Also the
                                      system has design features that
                                      allow only employees working on the
                                      particular subject area to gain
                                      access.

  5a. Under which Systems of Record   The system operates under
  notice (SOR) does the system        USDA/NASS-2, Agricultural Survey,
  operate? Provide number and name.   USDA/NASS-4, Agricultural Labor,
                                      USDA/NASS-5, List Sampling Frame
                                      and USDA/NASS-6, Farm Costs and
                                      Returns Survey.

  5b. If the system is being          If the scope of the personal data
  modified, will the SOR require      maintained is modified, the System
  amendment or revision? Explain.     of Record will be modified,
                                      accordingly.
  ----------------------------------- -----------------------------------

# [Summary]{.smallcaps}

This assessment describes the privacy concerns of the NASS UNIX GSS
system and its data. As privacy is one of the components of system
confidentiality this PIA must be considered anytime requirements are
being analyzed and decisions are being made about data usage, security
and system design**.**

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