**USDA PRIVACY IMPACT ASSESSMENT FORM**

**Agency:** National Agricultural Statistics Service

**     **

**System Name:** NASS Wide Area Network (WAN)

**     **

**System Type:** **Major Application**

**General Support System**

**Non-major Application**

**System Categorization (per FIPS 199):** **High**

**Moderate**

**Low**

**Description of the System:**

> The NASS Wide Area Network (WAN) serves as the default repository of
> data used and processed by various Agency desktop applications. The
> system provides NASS employees local access to file and print sharing
> services to the Agency enterprise network. It also provides client
> access to various desktop applications, including email.

**     **

**Who owns this system?** (Name, agency, contact information**)**

> Elvera Gleaton     
>
> National Agricultural Statistics Service
>
> 1400 Independence Ave., S.W.
>
> Washington, DC 20250
>
> Tel.No. (202)690-2352
>
> Paul Williams
>
> National Agricultural Statistics Service
>
> 1400 Independence Ave., S.W.
>
> Washington, DC 20250
>
> Tel.No. (202)720-7500

**     **

**Who is the security contact for this system?** (Name, agency, contact
information**)**

> Renato Chan     
>
> National Agricultural Statistics Service
>
> 1400 Independence Ave., S.W.
>
> Washington, DC 20250
>
> Tel.No. (202)720-4068

**     **

**Who completed this document?** (Name, agency, contact information**)**

> Renato Chan     
>
> National Agricultural Statistics Service
>
> 1400 Independence Ave., S.W.
>
> Washington, DC 20250
>
> Tel.No. (202)720-4068

### DOES THE SYSTEM CONTAIN INFORMATION ABOUT INDIVIDUALS IN AN IDENTIFIABLE FORM?

Indicate whether the following types of personal data are present in the
system

+------------------------------------------------------+------+-------+
| **QUESTION 1**                                       | Citi | Empl  |
|                                                      | zens | oyees |
| Does the system contain any of the following type of |      |       |
| data as it relates to individual:                    |      |       |
+------------------------------------------------------+------+-------+
| > Name                                               | **   | **    |
|                                                      | No** | Yes** |
+------------------------------------------------------+------+-------+
| > Social Security Number                             | **   | **    |
|                                                      | No** | Yes** |
+------------------------------------------------------+------+-------+
| > Telephone Number                                   | **No | **    |
|                                                      |      | Yes** |
|                                                      |   ** |       |
+------------------------------------------------------+------+-------+
| > Email address                                      | **No | **    |
|                                                      |      | Yes** |
|                                                      |   ** |       |
+------------------------------------------------------+------+-------+
| > Street address                                     | **No | **    |
|                                                      |      | Yes** |
|                                                      |   ** |       |
+------------------------------------------------------+------+-------+
| > Financial data (i.e. account numbers, tax ids,     | **No | **    |
| > etc)                                               |      | Yes** |
|                                                      |   ** |       |
+------------------------------------------------------+------+-------+
| > Health data                                        | **No | *     |
|                                                      |      | *No** |
|                                                      |   ** |       |
+------------------------------------------------------+------+-------+
| > Biometric data                                     | **No | *     |
|                                                      |      | *No** |
|                                                      |   ** |       |
+------------------------------------------------------+------+-------+
| **QUESTION 2**                                       | **No | **    |
|                                                      |      | Yes** |
| Can individuals be uniquely identified using         |   ** |       |
| personal information such as a combination of        |      |       |
| gender, race, birth date, geographic indicator,      |      |       |
| biometric data, etc.?                                |      |       |
|                                                      |      |       |
| NOTE: 87% of the US population can be uniquely       |      |       |
| identified with a combination of gender, birth date  |      |       |
| and five digit zip code[^1]                          |      |       |
+------------------------------------------------------+------+-------+
| Are social security numbers embedded in any field?   | **   | *     |
|                                                      | No** | *No** |
+------------------------------------------------------+------+-------+
| Is any portion of a social security numbers used?    | **   | *     |
|                                                      | No** | *No** |
+------------------------------------------------------+------+-------+
| Are social security numbers extracted from any other | **   | *     |
| source (i.e. system, paper, etc.)?                   | No** | *No** |
+------------------------------------------------------+------+-------+

**If all of the answers in Questions 1 and 2 are
NO,**![](media/image1.wmf){width="0.40555555555555556in"
height="0.38055555555555554in"}

You do not need to complete a Privacy Impact Assessment for this system
and the answer to OMB A-11, Planning, Budgeting, Acquisition and
Management of Capital Assets,

Part 7, Section E, Question 8c is:

If any answer in Questions 1 and 2 is YES, provide complete answers to
all questions below.

### DATA COLLECTION

3.  Generally describe the data to be used in the system.

     

> The NASS Wide Area Network (WAN) stores data used and processed by a
> number of desktop applications. Information stored includes data used
> for various administrative functions.

          

4.  Is the collection of the data both relevant and necessary to the
    purpose for which the system is designed? In other words, the data
    is absolutely needed and has significant and bearing on the system's
    purpose.

Yes

No. If NO, go to question 5

1.  Explain.

     

> Data collected are needed for the underlying application and systems
> to function properly.

     

5.  Sources of the data in the system.

    1.  What data is being collected from citizens and/or employees?

> Information on employees include: (1) name, (2) home address, (3)
> telephone number, (4) Social Security Number, (5) NASDA contract
> employee Bank Account Number, and (6) other administrative data.

          

2.  What USDA agencies are providing data for use in the system?

> NASS.     

     

3.  What government agencies (state, county, city, local, etc.) are
    providing data for use in the system?

     

> None.

     

4.  From what other third party sources is data being collected?

     

> None.

     

6.  Will data be collected from sources outside your agency? For
    example, citizens and employees, USDA sources (i.e. NFC, RD, etc.)
    or Non-USDA sources.

Yes

No. If NO, go to question 7

1.  How will the data collected from citizens and employees be verified
    for accuracy, relevance, timeliness, and completeness?

     

> N/A.     

     

2.  How will the data collected from USDA sources be verified for
    accuracy, relevance, timeliness, and completeness?

     

> N/A.

     

3.  How will the data collected from non-USDA sources be verified for
    accuracy, relevance, timeliness, and completeness?

     

> N/A.

     

### DATA USE

7.  Individuals must be informed in writing of the principal purpose of
    the information being collected from them. What is the principal
    purpose of the data being collected?

     

> To maintain a record of earnings for every NASS employee, and NASDA
> employees who work on NASS surveys to facilitate payment of payroll
> and travel expenses. Maintain records necessary to perform routine
> personnel actions.

     

8.  Will the data be used for any other purpose?

Yes

No. If NO, go to question 9

1.  What are the other purposes?

     

> N/A.

     

9.  Is the use of the data both relevant and necessary to the purpose
    for which the system is being used? In other words, the data is
    absolutely needed and has significant and demonstrable bearing on
    the system's purpose.

Yes

No. If NO, go to question 10

1.  Explain.

     

> Without the data, the underlying applications/systems will not
> function properly.

     

10. Will the system derive new data or create previously unavailable
    data about an individual through aggregation from the information
    collected (i.e. aggregating farm loans by zip codes in which only
    one farm exists.)?

Yes

No. If NO, go to question 11

1.  Will the new data be placed in the individual's record (citizen or
    employee)?

Yes

No

2.  Can the system make determinations about citizens or employees that
    would not be possible without the new data?

Yes

No

3.  How will the new data be verified for relevance and accuracy?

     

> N/A.

     

11. Individuals must be informed in writing of the routine uses of the
    information being collected from them. What are the intended routine
    uses of the data being collected?

     

> Information in the system for NASS employees are used routinely for
> administrative functions such as time and attendance, and travel
> reimbursements. Information in the system for NASDA employees are used
> routinely to process and disburse salary and travel checks.

     

12. Will the data be used for any other purpose (other than indicated in
    question 11)?

Yes

No. If NO, go to question 13

1.  What are the other purposes?

     

> N/A.

     

13. Automation of systems can lead to the consolidation of data --
    bringing data from multiple sources into one central location/system
    -- and consolidation of administrative controls. When administrative
    controls are consolidated, they should be evaluated so that all
    necessary privacy controls remain in place to the degree necessary
    to continue to control access to and use of the data. Is data being
    consolidated?

Yes

No. If NO, go to question 14

1.  What controls are in place to protect the data and prevent
    unauthorized access?

     

> Each LAN user is assigned a network account. Appropriate rights are
> assigned to these accounts which control what users can access within
> the system.

     

14. Are processes being consolidated?

Yes

No. If NO, go to question 15

1.  What controls are in place to protect the data and prevent
    unauthorized access?

     

> N/A.

     

### DATA RETENTION

15. Is the data periodically purged from the system?

Yes

No. If NO, go to question 16

1.  How long is the data retained whether it is on paper,
    electronically, in the system or in a backup?

     

> Retention of data follows schedules approved by the U.S. National
> Archives and Records Administration (NARA).

     

2.  What are the procedures for purging the data at the end of the
    retention period?

     

> Data that are expunged from the system are either sent to the NARA or
> shredded, whichever is applicable.

     

3.  Where are these procedures documented?

     

> The documentation for these procedures are stored in our policy and
> procedures manuals and instructions. They can be found in our HQ
> library and in our Field Offices.

     

16. While the data is retained in the system, what are the requirements
    for determining if the data is still sufficiently accurate,
    relevant, timely, and complete to ensure fairness in making
    determinations?

     

> Data are used only for administrative purposes and are deemed
> accurate, relevant, timely, and complete for such purposes as are
> necessary to maintain updated employee information.

     

17. Is the data retained in the system the minimum necessary for the
    proper performance of a documented agency function?

Yes

No

### DATA SHARING

18. Will other agencies share data or have access to data in this system
    (i.e. international, federal, state, local, other, etc.)?

Yes

No. If NO, go to question 19

1.  How will the data be used by the other agency?

     

> N/A.

     

2.  Who is responsible for assuring the other agency properly uses of
    the data?

     

> N/A.

     

19. Is the data transmitted to another agency or an independent site?

Yes

No. If NO, go to question 20

1.  Is there the appropriate agreement in place to document the
    interconnection and that the PII and/or Privacy Act data is
    appropriately protected?

          

> N/A.

     

2.  Where are those documents located?

     

> N/A.

20. Is the system operated in more than one site?

Yes

No. If NO, go to question 21

1.  How will consistent use of the system and data be maintained in all
    sites?

> The system operates in a distributed environment where majority of the
> data is located, administered and controlled at the NASS Headquarters
> location. To ensure data is consistent, the agency has an extensive
> set of policy memoranda, instructions, and technical review teams that
> make regular site visits.

     

     

### DATA ACCESS

21. Who will have access to the data in the system (i.e. users,
    managers, system administrators, developers, etc.)?

     

> Access to data is limited only to NASS users who have a need to
> modify, maintain and review the data. This includes authorized
> managers, system administrators and developers. Each user also signs a
> pledge of confidentiality that carries severe legal penalties for
> violating the pledge.

     

22. How will user access to the data be determined?

     

> Access to the data is determined by the system manager of the
> underlying application or system.
>
>      

1.  Are criteria, procedures, controls, and responsibilities regarding
    user access documented?

Yes

No. If NO, go to question 23

2.  Where are criteria, procedures, controls, and responsibilities
    regarding user access documented?

     

> Access request as well as approval is documented accordingly by
> management and the Technical Services Branch. The Computer Security
> Staff audits access routinely.

     

23. How will user access to the data be restricted?

     

> Users access are restricted by use of several logical and physical
> security controls. There are also appropriate management controls in
> place for this purpose.

     

1.  Are procedures in place to detect or deter browsing??

Yes

No

     

2.  Are procedures in place to detect or deter unauthorized user access?

Yes

No

24. Does the system employ security controls to make information
    unusable to unauthorized individuals (i.e. encryption, strong
    authentication procedures, etc.)?

Yes

No

### CUSTOMER PROTECTION

25. Who will be responsible for protecting the privacy rights of the
    citizens and employees affected by the interface (i.e. office,
    person, departmental position, etc.)?

     

> The responsible official can be reached at the following address:
>
> Deputy Administrator for Field Operations
>
> National Agricultural Statistics Service
>
> 1400 Independence Ave., S.W.
>
> Washington, DC 20250

     

26. How can citizens and employees contact the office or person
    responsible for protecting their privacy rights?

     

> A written request must be sent to the above official. The request must
> contain: name, address, and System of Record name.

     

27. A "breach" refers to a situation where data and/or information
    assets are unduly exposed. Is a breach notification policy in place
    for this system?

Yes - If YES, where is the breach notification policy located?

     

> NASS' breach notification policy is found on the Agency Intranet site.

     

No - If NO, please enter the POAM number with the estimated completion
date:

     

     

28. Consider the following:

-   Consolidation and linkage of files and systems

-   Derivation of data

-   Accelerated information processing and decision making

-   Use of new technologies

Is there a potential to deprive a citizens and employees of fundamental
rules of fairness (those protections found in the Bill of Rights)?

Yes

No. If NO, go to question 29

1.  Explain how this will be mitigated?

     

> N/A.

29. How will the system and its use ensure equitable treatment of
    citizens and employees?

     

> The system was not designed to give users the ability to treat
> citizens and employees unfairly.

     

30. Is there any possibility of treating citizens and employees
    differently and unfairly based upon their individual or group
    characteristics?

Yes

No. If NO, go to question 31

1.  Explain

> N/A.

     

### SYSTEM OF RECORD

31. Can the data be retrieved by a personal identifier? In other words,
    does the system actually retrieve data by the name of an individual
    or by some other unique number, symbol, or identifying attribute of
    the individual?

Yes

No. If NO, go to question 32

1.  How will the data be retrieved? In other words, what is the
    identifying attribute (i.e. employee number, social security number,
    etc.)?

     

> By use of a master employee file which is indexed by employee number
> assigned by NASS Headquarters and each NASS Field Office.

     

2.  Under which Systems of Record notice (SOR) does the system operate?
    Provide number, name and publication date. (SORs can be viewed at
    [www.access.GPO.gov](http://www.access.GPO.gov/))

     

> This system operates under the following SOR notices:
>
> USDA/NASS-1, Administrative Records Systems
>
> USDA/NASS-3, Personnel Data Base

     

3.  If the system is being modified, will the SOR require amendment or
    revision?

     

> This depends on the change being made. If required, NASS will make
> modifications to the SOR notices to comply with federal mandates.

     

### TECHNOLOGY

32. Is the system using technologies in ways not previously employed by
    the agency (e.g. Caller-ID)?

Yes

No. If NO, the questionnaire is complete.

1.  How does the use of this technology affect citizens and employees
    privacy?

     

> N/A.

     

Upon completion of this Privacy Impact Assessment for this system, the
answer to

OMB A-11, Planning, Budgeting, Acquisition and Management of Capital
Assets,

Part 7, Section E, Question 8c is:

**1. Yes.**

PLEASE SUBMIT A COPY TO

THE OFFICE OF THE ASSOCIATE CHIEF INFORMATION OFFICE/CYBER SECURITY

### ![](media/image2.png){width="5.997222222222222in" height="8.61111111111111in"}

### 

[^1]: Comments of Latanya Sweeney, Ph.D., Director, Laboratory for
    International Data Privacy Assistant Professor of Computer Science
    and of Public Policy Carnegie Mellon University To the Department of
    Health and Human Services On \"Standards of Privacy of Individually
    Identifiable Health Information\". 26 April 2002.