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**United States Department of Agriculture**

**National Agricultural Statistics Service**

**Market Sensitive Surveys (MSS)**

**Privacy Impact Assessment**

**(PIA)**

**FINAL**

***version 2.0***

July 26, 2007

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

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

[]{#__RefHeading___Toc189899583 .anchor}**[REVISION AND HISTORY
PAGE]{.smallcaps}**

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| **       | **Revision  | **Description**  | **Se        | ** | **In |
| Document | Date**      |                  | ction/Para. | Pa | itia |
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| \#**     |             |                  |             | \# |      |
|          |             |                  |             | ** |      |
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| 1.0      | 06/25/2007  | Initial Draft    |             |    | WCG  |
|          |             | Document         |             |    |      |
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| 2.0      | 07/26/2007  | Revised table    |             |    | RAC  |
|          |             | entries          |             |    |      |
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**[Table of Contents]{.smallcaps}**

Paragraph Page

[[REVISION AND HISTORY PAGE]{.smallcaps}
ii](#__RefHeading___Toc189899583)

[[1]{.smallcaps} [Introduction]{.smallcaps} 4](#introduction)

[1.1 Laws and Regulations 4](#laws-and-regulations)

[1.2 System Description 4](#system-description)

[1.3 Contact Information 5](#contact-information)

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

[2.1 Data in the System 7](#data-in-the-system)

[2.2 Data Access 8](#data-access)

[2.3 Data Attributes 8](#data-attributes)

[2.4 Maintenance of Administrative Controls
9](#maintenance-of-administrative-controls)

[3 Summary 11](#summary)

# [Introduction]{.smallcaps}

The Privacy Impact Assessment (PIA) is a process used to evaluate the
impact that the MSS system has on individuals. The PIA process is
designed to guide NASS MSS system developers and operators in assessing
privacy concerns and safeguards in computer application systems. The PIA
should be initiated in the early stages of the development of a system
and completed as part of the required System Life Cycle (SLC) and
security reviews. Privacy is one component of system confidentiality and
must be considered when requirements are being analyzed and decisions
are being made about data usage and system design. A PIA describes the
system and its data, any specific privacy concerns, and safeguards
established to meet privacy needs. The USDA Privacy Coordinator must be
involved in the PIA process.

## Laws and Regulations

-   Privacy act of 1974, as Amended (5 USC 552a);

-   Computer Security Act of 1987, Public Law 100-235, ss 3 (1) and (2),
    codified at 15 U.S.C. 272, 278 g-4 and 278 h;

-   Freedom of Information Act, as Amended (5 USC 552);

-   The E-Government Act of 2002, U.S.C. 3531 et seq.

## System Description

The MSS system is responsible for processing survey information to
provide timely, accurate, and useful statistics in service to U.S.
Agriculture. Market Sensitive Surveys include but are not limited to
those which cover commodities that are traded on the Futures exchanges
and production is concentrated in a small number of states. Knowledge of
sensitive data would allow a person to anticipate the NASS Agricultural
Statistics Board reports pertaining to the designated commodities.

**Function:**

> Agricultural statistical survey processing and reporting.

Market Sensitive Commodities (Corn, Soybeans, Cotton, Wheat, Rice, Oats,
Sugar Crops, Cattle and Hogs) are analyzed and summarized using NASS
systems and all are summarized using NASS's Survey Processing System
(SPS) on the Mainframe environment located at the National Information
Technology Center (NITC) in Kansas City.

**Platform:**

Data is stored on a NITC provided mainframe, which is an IBM 2064 linked
to the NASS LAN.

Data is analyzed and summarized using NASS's Survey Processing System
(SPS) on the Mainframe at NITC in Kansas City.

The mainframe system where the MSS system operates is logically
protected by NITC perimeter firewalls. The firewall is used to place
extra protection around a server, which is used to house data from the
Internal Revenue Service that helps measure coverage. A CISCO VPN
concentrator has been installed and there are test users, but this has
not made this a production system for all remote users. NASS uses RSA
tokens for users accessing the network remotely using their Internet
Service Provider. Policies and procedures for password control, rules of
behavior, data segmentation and security classification have been
developed for the system.

**Software:**

The software used for the bulk of the processing is SAS (base/AF). NITC
provides an IDS system for continual scanning of the system for
intrusions and unauthorized usage.

The underlying IBM Mainframe operating systems is MVS-OS. The operating
system of the NITC network support environment consists of CISCO IOS and
IPSO Checkpoint is installed.

**Systems/Applications supported:**

Data is stored on a NITC provided IBM 2064 mainframe. The software used
for the bulk of the processing is SAS (base/AF).

**User organizations:**

The reports of agricultural statistics and forecasts have a wide user
base and statistical reports of many types must be issued in a time
critical fashion. There are approximately 150 internal users of the
systems nationwide.

## Contact Information

**(1) Who is the person completing this document? (Name, title,
organization, and contact information).**

> Name: Renato Chan
>
> Title: Information System Security Program Manager (ISSPM)
>
> Organization: NASS
>
> Address: 1400 Independence Ave., S.W.
>
> City: Washington, DC 20250
>
> Phone: 202-720-4068
>
> Email: renato_chan@nass.usda.gov

**(2) Who is the system owner? (Name, organization and contact
information)**

> Name: Brian Lounsbury
>
> Title: Chief, Census and Survey Systems Branch
>
> Address: 1400 Independence Ave. S.W., Washington, DC 20250
>
> Phone: 202-720-7906
>
> Email: brian_lounsbury@nass.usda.gov

**(3) Who is the system manager for this system or application? (Name,
organization and contact information)?**

> Name: Debbie Williams
>
> Title: Head, Survey Processing Systems Section
>
> Address: 1400 Independence Ave. S.W., Washington, DC 20250
>
> Phone: 202-690-1401
>
> Email: deborah_williams@nass.usda.gov

**(4) Who is the IT Security Manager for this system and the contact
information?**

> Name: Renato Chan
>
> Title: ISSPM
>
> Address: 1400 Independence Ave., S.W., Washington, DC 20250
>
> Phone: 202-720-4068
>
> Email: renato_chan@nass.usda.gov

**(5) Who is the Department/Agency Privacy Act Officer/Coordinator who
reviewed this document? (Name, organization and contact information)**

> Name: Forest Chapman
>
> Title: Privacy Officer
>
> Address: 1400 Independence Ave., S.W., Washington, DC 20250
>
> Phone: 202-720-5221
>
> Email: forest_chapman@nass.usda.gov

**(6) Who is the Reviewing Official (DAA)?**

> Name: Jack Nealon
>
> Title: Director, Information Technology Division
>
> Address: Rm. 584, 1400 Independence Ave., S.W., Washington, DC 20250
>
> Phone: 202-720-2984
>
> Email: jack_nealon@nass.usda.gov

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

## Data in the System

+-----------------------------------+-----------------------------------+
| 1\. Generally describe the        | The NASS Survey Processing System |
| information to be used in the     | processes data that is collected  |
| system in each of the following   | from farmers and agri-businesses  |
| categories: Customer, Employee,   | under a strict pledge of          |
| and Other.                        | confidentiality. 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 and     |
| information in the system?        | agri-businesses.                  |
+-----------------------------------+-----------------------------------+
| 2b. What USDA files and databases | The NASS Market Sensitive Surveys |
| are used? What is the source      | uses secure SAS data sets,        |
| agency?                           | proprietary data files from our   |
|                                   | CATI system Blaisé, and FoxPro    |
|                                   | files to store and process the    |
|                                   | data.                             |
+-----------------------------------+-----------------------------------+
| 2c. What Federal Agencies are     | FSA.                              |
| providing data for use in the     |                                   |
| 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      | The data collected are updates to |
| collected from the                | existing personally identifiable  |
| customer/employee?                | information, such as name and     |
|                                   | address information, and data     |
|                                   | about their farms and             |
|                                   | agri-businesses, such as acres,   |
|                                   | economic data, and livestock      |
|                                   | numbers.                          |
+-----------------------------------+-----------------------------------+
| 3a. How will data collected from  | Criteria questionnaire to the     |
| sources other than the USDA       | individual under review asking    |
| records and the customer be       | them to fill in the specifics for |
| verified for accuracy?            | 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  | The NASS MSS System will be used  |
| completeness?                     | to perform these checks           |
+-----------------------------------+-----------------------------------+

## Data Access

  ----------------------------------- -----------------------------------
  1\. Who will have access to the     Data access is limited to only NASS
  data in the system (Users,          employees who have a need to review
  Managers, System Administrators,    the data for analytical purposes,
  Developers, Other)?                 and those system developers that
                                      support the system. Each employee
                                      must sign a pledge of
                                      confidentiality that carries severe
                                      legal penalties for violating the
                                      pledge.

  2\. How is access to the data by a  Access is determined by the above
  user determined? Are criteria,      signed pledge of confidentiality
  procedures, controls, and           and the subject area being
  responsibilities regarding access   analyzed, such as crops, livestock,
  documented?                         and economic areas of interest.
                                      Access is documented by our
                                      Technical Services Branch. Computer
                                      security staff shares access rights
                                      with business managers to ensure
                                      "need-to-know" access only.

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

  4\. What controls are in place to   All NASS employees must sign a
  prevent the misuse (e.g. browsing,  pledge of confidentiality that
  unauthorized use) of data by those  carries severe legal penalties for
  having access?                      violating the pledge. Also the
                                      system has design features that
                                      allow only employees working on the
                                      particular subject area to gain
                                      access.

  5a. Do other systems share data or  No.
  have access to data in this system? 
  If yes, explain.                    

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

  6a. Will other agencies share data  No.
  or have access to data in this      
  system (International, Federal,     
  State, Local, and Other)?           

  6b. How will the data be used by    It will only be used for
  the agency?                         statistical purposes.

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

## 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   | N/A.                              |
| 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 information is           |
| retrieved? Can it be retrieved by | processed, prior to statistical   |
| personal identifier? If yes,      | aggregation, at the personal      |
| explain.                          | identifier level. In the case of  |
|                                   | the NASS Survey Processing        |
|                                   | System, a unique ID is assigned   |
|                                   | to each respondent, and that ID   |
|                                   | is used to retrieve and analyze   |
|                                   | the data.                         |
+-----------------------------------+-----------------------------------+
| 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     | See above.                        |
| 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    This system operates in both a
  more than one site, how will        centralized mainframe environment
  consistent use of the system and    and a distributed LAN environment.
  data be maintained in all sites?    The NASS Survey Processing System
                                      is administered and controlled from
                                      our HQ site. Data processed in our
                                      Field Offices must meet the same
                                      rigor applied to our centralized
                                      mainframe environment. An extensive
                                      set of policy memoranda,
                                      instructions, and technical review
                                      teams that make regular site visits
                                      maintain the necessary consistency
                                      needed for statistical analysis and
                                      aggregation.

  2b. Explain any possibility of      This possibility does not exist
  disparate treatment of individuals  because of the statistical use of
  or groups.                          the data.

  2c. What are the retention periods  Data is retained as long as the
  of data in this system?             information is needed for survey
                                      data editing, analysis, estimation,
                                      and sampling. 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 for statistical
  the system, what are the            purposes and are deemed accurate,
  requirements for determining if the relevant, timely, and complete for
  data is still sufficiently          such purposes as are necessary for
  accurate, relevant, timely, and     the publication of statistical
  complete to ensure fairness in      reports.
  making determinations?              

  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   Only a few items on the survey
  notice (SOR) does the system        questionnaires qualify under the
  operate? Provide number and name.   Privacy Act of 1974 as systems of
                                      records. This system operates under
                                      USDA/NASS-1 Agricultural Survey
                                      Records.

  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 MSS system
and its data. As privacy is one 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**.**

### ![](media/image2.jpeg){width="6.127777777777778in" height="5.092361111111111in"}  {#section .unnumbered}