**USDA PRIVACY IMPACT ASSESSMENT FORM**

**Agency: U.S. Department of Agriculture, Farm Service Agency**

**     **

**System Name: Fingerprint Identification System (FIS)**

**     **

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

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

**Description of the System:**

**     **

> The Fingerprint Identification System (FIS) is a satellite system of
> the Department of Justice (DOJ) Civil Applicant System (CAS) that
> enables FSA staffs to electronically capture civil applicant
> fingerprints and biographical data and to transmit the data to the
> Federal Bureau of Investigation's (FBI) Integrated Automated
> Fingerprint Identification System (IAFIS) via the CAS satellite system
> as part of the background investigations of new Department employees,
> political appointees, and contractor personnel. The current estimate
> is that the agency processes 9252 fingerprint checks per year.
>
> CAS (main system) is located in the Justice Data Center, Washington,
> D.C. (JDC-W), and makes use of current network integration efforts to
> interconnect the DOJ and its components with other Federal Departments
> that utilize the CAS. CAS is operational 24 hours a day, 7 days a week
> with 99% availability to allow for regular scheduled maintenance.
>
> Since any response from IAFIS to a civil applicant submission may
> contain National Criminal Information Center (NCIC) data, FSA must
> comply with NCIC and USDA security policies as they relate to internal
> controls, information security, information dissemination, user
> security, and user training. These policies are described in more
> detail in the USDA certification and accreditation documents for the
> CAS satellite system.

**     **

**Who owns this system?**

> Kathy Williams
>
> Section Head, Operations Section
>
> USDA/FSA/DAM/HRD/KCHRO/OS
>
> U.S. Department of Agriculture
>
> Farm Service Agency
>
> 6501 Beacon Dr.
>
> Kansas City, MO 64133
>
> \(816\) 926-1392
>
> kathy.williams@kcc.usda.gov
>
> Susie Somuah-Gyamfi
>
> Section Head, Payroll/Personnel Operations Section
>
> USDA/FSA/DAM/HRD/PPOS
>
> U.S. Department of Agriculture
>
> Farm Service Agency
>
> 1280 Maryland Ave. 4^th^ Floor
>
> Washington, DC 20024
>
> \(202\) 401-0648
>
> susie.somuah-gyamfi@wdc.usda.gov

**Who is the security contact for this system?**

> Brian Davies
>
> Information System Security Program Manager (ISSPM)
>
> FSA/DAM/ITSD/OTC/ISO
>
> U.S. Department of Agriculture
>
> Farm Service Agency
>
> 1400 Independence Avenue SW
>
> Washington, D.C. 20250
>
> \(202\) 720-2419

brian.davies@wdc.usda.gov

**          **

**Who completed this document?**

> Kathy Williams
>
> U.S. Department of Agriculture
>
> Farm Service Agency
>
> 6501 Beacon Drive
>
> Kansas City, MO 64133
>
> Susie Somuah-Gyamfi
>
> U.S. Department of Agriculture
>
> 1400 Independence Ave.
>
> Stop 0594
>
> Washington, DC 20250-0594
>
> Sue Weis
>
> Information Security Office (ISO)
>
> FSA/DAM/ITSD/OTC/ISO
>
> U.S. Department of Agriculture
>
> Farm Service Agency
>
> 1400 Independence Avenue
>
> Washington, D.C. 20250
>
> \(202\) 690-4639
>
> sue.weis@wdc.usda.gov

**     **

### 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                                               | **Y  | **    |
|                                                      | es** | Yes** |
+------------------------------------------------------+------+-------+
| > Social Security Number                             | **Y  | **    |
|                                                      | es** | Yes** |
+------------------------------------------------------+------+-------+
| > Telephone Number                                   | **Y  | **    |
|                                                      | es** | Yes** |
+------------------------------------------------------+------+-------+
| > Email address                                      | **Y  | **    |
|                                                      | es** | Yes** |
+------------------------------------------------------+------+-------+
| > Street address                                     | **Y  | **    |
|                                                      | es** | Yes** |
+------------------------------------------------------+------+-------+
| > Financial data                                     | **   | *     |
|                                                      | No** | *No** |
+------------------------------------------------------+------+-------+
| > Health data                                        | **   | *     |
|                                                      | No** | *No** |
+------------------------------------------------------+------+-------+
| > Biometric data                                     | **Y  | **    |
|                                                      | es** | Yes** |
+------------------------------------------------------+------+-------+
| **QUESTION 2**                                       | **Y  | **    |
|                                                      | es** | 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?   | **Y  | **    |
|                                                      | es** | Yes** |
+------------------------------------------------------+------+-------+
| Is any portion of a social security numbers used?    | **Y  | **Ye  |
|                                                      | es** | s  ** |
+------------------------------------------------------+------+-------+
| Are social security numbers extracted from any other | **Y  | **Ye  |
| source (i.e. system, paper, etc.)?                   | es** | s  ** |
+------------------------------------------------------+------+-------+

**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:

**3. No, because the system does not contain, process, or transmit
personal identifying information.**

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.

     

     

     

     Fingerprint and Biographical Data

     

     

4.  Is the use of the data both relevant and necessary to the purpose
    for which the system is being designed? In other words, the data is
    absolutely needed and has significant and demonstrable bearing on
    the system's purpose as required by statute or by Executive order of
    the President.

Yes

5.  Sources of the data in the system.

    1.  What data is being collected from the customer?

     

     Name, home address, social security number, race, sex, gender and
fingerprint.

     

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

     

     None

     

3.  What state and local agencies are providing data for use in the
    system?

     

     N/A

     

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

     

     FBI system sending data back through CAS system

     

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

Yes

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

     

The information is verified by a driver's license, social security card
or a passport

     

     

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

     

     The information is verified against source documents as listed in
6.1

     

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

     

     The information being sent from the Department of Justice, we
assume it's correct

     

### 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 complete part of the pre-employment process for employees and
contractors.

     

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

No. If NO, go to question 9

1.  What are the other purposes?

     

     

     

9.  Is the use of the data both relevant and necessary to the purpose
    for which the system is being designed? In other words, the data is
    absolutely needed and has significant and demonstrable bearing on
    the system's purpose as required by statute or by Executive order of
    the President

Yes

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

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

Yes

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

No

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

     We assume the information is correct coming from the DOJ

     

     

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?

     

     Send information to Justice

     

12. Will the data be used for any other uses (routine or otherwise)?

No. If NO, go to question 13

1.  What are the other uses?

     

     

     

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?

No. If NO, go to question 14

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

     

     

     

14. Are processes being consolidated?

No. If NO, go to question 15

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

     

     

     

### DATA RETENTION

15. Is the data periodically purged from the system?

Yes

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

     

     Data will be retained up to 60 days electronically and then
manually deleted. Paper document is filed in the Official Personnel
Folder or personnel record and maintained indefinitely.

     

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

     

     Manual deletion in the CAS system

     

3.  Where are these procedures documented?

     

     The User Manual and Records Retention Regulations

     

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?

     

     The information is only used for the background investigation
process.

     

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

Yes

### 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

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

     

      Data will be shared with partner agencies via service level
agreements or

Memoranda of Agreements for Contractor security clearances.

     

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

> Each agency has a security officer or FOIA staff that will promulgate
> procedures for proper use of data.

     

     

     

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

Yes

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

> Yes

-   Service Level Agreement; DOJ and Farm Service Agency dated May 14,
    2007

-   Interconnection Security Agreement: DOJ and OCIO-ITS dated May 10.
    2007

     

     

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

Yes

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

     

     Sites will be independent of each other; however, both sites will
use the same User Manual and policies.

     

### DATA ACCESS

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

     

     Users and System Administrators

     

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

     

     By System Administrators

     

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

Yes

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

     

     Password protected and machine is in a locked room

     

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

Yes

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

Yes -- OCIO question

### CUSTOMER PROTECTION

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

> USDA/FSA/DAM/Human Resource Division

     

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

     

>       Kathy Williams - KC
>
>      Susie Somuah-Gyamfi - WDC

     

Both System Admistrators listed above may be contacted via telephone,
mail or email.

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, go to question 28

1.  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 customer of due process rights
(fundamental rules of fairness)?

Yes

1.  Explain how this will be mitigated?

> Due process procedures are submitted to each customer upon
> notification of decisions.

     

     

     

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

     

     Adjudicated on negative issues

     

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

No. If NO, go to question 31

1.  Explain

     

     

     

### 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

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

     

>      A Unique Id or the PIN of a person

     

2.  Under which Systems of Record notice (SOR) does the system operate?
    Provide number, name and publication date. (SORs can be viewed at
    http://www.defenselink.mil/privacy/govwide/)

     

OPM/GOVT-1

     

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

     

> Yes, if the system modification causes the system to deviate from what
> is permitted by the SORN.

     

### TECHNOLOGY

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

No. If NO, the questionnaire is complete.

1.  How does the use of this technology affect customer privacy?

     

     

     

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.jpeg){width="7.076388888888889in"
height="8.752777777777778in"}

[^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.