![](media/image1.jpeg){width="1.7395833333333333in"
height="1.1875in"}Privacy Impact Assessment

TIM/FACTS

***Version: 2.0***

USDA Forest Service

Date: March, 2008

# Document Information

  ----------------- -----------------------------------------------------
  Owner Details     

  Name              Sue Preece

  Contact Number    \(703\) 605-4643

  E-mail Address    spreece@fs.fed.us
  ----------------- -----------------------------------------------------

+---------+------------+----------------+-----------------------------+
| D       |            |                |                             |
| ocument |            |                |                             |
| R       |            |                |                             |
| evision |            |                |                             |
| and     |            |                |                             |
| History |            |                |                             |
+=========+============+================+=============================+
| R       | Date       | Author         | Comments                    |
| evision |            |                |                             |
+---------+------------+----------------+-----------------------------+
| 1.0     | December   | FS             | Initial FACTS document      |
|         | 5, 2005    |                | development.                |
+---------+------------+----------------+-----------------------------+
| 1.1     | February   | FS             | Updated to incorporate TIM  |
|         | 9, 2006    |                |                             |
+---------+------------+----------------+-----------------------------+
| 1.2     | August 7,  | FS (MSP)       | Periodic update.            |
|         | 2007       |                |                             |
+---------+------------+----------------+-----------------------------+
| 2.0     | February   | Xacta          | Updated format and          |
|         | 2008       |                | information based on        |
| Draft   |            |                | revised USDA Templates      |
+---------+------------+----------------+-----------------------------+
| 2.0     | March 2008 | FS (ARK)       | Made corrections to         |
|         |            |                | information throughout the  |
| Final   |            |                | draft document              |
+---------+------------+----------------+-----------------------------+
|         |            |                |                             |
+---------+------------+----------------+-----------------------------+

**Agency: USDA Forest Service**

**     **

**System Name: TIM/FACTS**

**     **

**System Type: X Major Application**

**General Support System**

**Non-major Application**

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

**X Moderate**

**Low**

**Description of the System:**

TIM/FACTS supports the Forest Service vegetation management program by
providing a business application that is used locally to collect
necessary data. TIM/FACTS provides data standards, corporate data
storage, and analytical tools for vegetation management efforts.
TIM/FACTS replaces many Regional and Forest level manual and
non-standard data storage and processing applications in the Forest
Service. The data are essential for managing the Special Forest Product
permits, Timber Sale Contracts, Vegetative Treatments as well as fiscal
items necessary to assure accountability and financial health for the
trust fund plans, collections, expenditures and balance on the National
Forests.

TIM/FACTS leverages the USDA eAuthentication Service in conjunction with
a commercial-off-the-self (COTS) Oracle Single Sign-On (SSO) application
called Oracle Internet Directory (OID), and a customized COTS Oracle
User Management Application (UMA) that automates and distributes account
management process including user registration and management approval,
oversight, and authorization processing to hosted application users and
managers.**     **

**     **

**System Owner**

Sue Preece

Acting/I-Web (Infra, TIM & FACTS) Program Manager

USDA Forest Service

1601 N Kent St 5^th^ floor

Arlington, VA 22209

703.605.4643

<spreece@fs.fed.us>

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

Michael Potts

TIM/FACTS ISSO

USDA Forest Service

201 14^th^ Street, SW 3SW

Washington, D.C. 20250

202-205-1305

mpotts@fs.fed.us

**     **

**Who completed this document?**

Ann Kronenberger

Alternate ISSO

USDA Forest Service

1601 N Kent St 5^th^ floor

Arlington, VA 22209

703-605-4794

<akronenberger@fs.fed.us>

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**                                | Citizens  | E        |
|                                               |           | mployees |
| Does the system contain any of the following  |           |          |
| type of data as it relates to individual:     |           |          |
+-----------------------------------------------+-----------+----------+
| > Name                                        | **Yes**   | **Yes**  |
+-----------------------------------------------+-----------+----------+
| > Social Security Number                      | **Yes**   | **No**   |
+-----------------------------------------------+-----------+----------+
| > Telephone Number                            | **Yes**   | **No**   |
+-----------------------------------------------+-----------+----------+
| > Email address                               | **No**    | **No**   |
+-----------------------------------------------+-----------+----------+
| > Street address                              | **Yes**   | **No**   |
+-----------------------------------------------+-----------+----------+
| > Financial data                              | **No**    | **No**   |
+-----------------------------------------------+-----------+----------+
| > Health data                                 | **No**    | **No**   |
+-----------------------------------------------+-----------+----------+
| > Biometric data                              | **No**    | **No**   |
+-----------------------------------------------+-----------+----------+
| **QUESTION 2**                                | **Yes**   | **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   | **Yes**   | **No**   |
| field?                                        |           |          |
+-----------------------------------------------+-----------+----------+
| Is any portion of a social security numbers   | **No**    | **No**   |
| used?                                         |           |          |
+-----------------------------------------------+-----------+----------+
| Are social security numbers extracted from    | **No**    | **No**   |
| any other source (i.e. system, paper, etc.)?  |           |          |
+-----------------------------------------------+-----------+----------+

**If all of the answers in Questions 1 and 2 are
NO,**![](media/image2.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.

> TIM: Data related to timber permits and sales including: region,
> forest, district, permit terms and conditions, bid date, award date,
> timber sale number, status and reason, purchaser name, financial
> address, vehicle data, contract number and type, contract species,
> cruise number, cruise type, cutting unit, bill amount, and bill date.
>
> FACTS: Data describing forest activities, including those accomplished
> under and to meet the Healthy Forest Initiative and the Healthy Forest
> Restoration Act, and data required for NEPA reporting.

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.

X Yes

No

5.  Sources of the data in the system.

    1.  What data is being collected from the customer?

> TIM: Customer name and unique identification number, ID type, ID
> state, ID expiration date, TIN, customer address, city, state, postal
> code, phone number, vehicle identification data.
>
> FACTS: None -- not applicable

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?

> 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, **customers**, USDA sources (i.e. NFC, RD, etc.) or
    Non-USDA sources.

X Yes

No. If NO, go to question 7

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

> In person, over-the-counter at the local unit where the transaction
> occurs

     

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?

     

     The principal purpose of the data is stated on the Permit or the
Permit/Bid Form

     

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

Yes

X No. If NO, go to question 9

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

X Yes

No

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

X No. If NO, go to question 11

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

Yes

No

2.  Can the system make determinations about customers 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?

     

     

     

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?

> The routine uses of the data are stated on the Permit or the
> Permit/Bid Form

     

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

Yes

X 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?

Yes

X 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?

Yes

X 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

X 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?

     

     

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

     

3.  Where are these procedures documented?

     

     

     

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?

Existing access controls prevent unauthorized modification of data, and
in some instances, data is no longer available for modification based on
process (it\'s locked). Additionally the data is encrypted in the
database and masked when displayed on a screen.

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

X 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

X No. If NO, go to question 19

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

     

     

     

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

     

     

     

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

X 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?

     

     Yes

     

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

Yes

X No. If NO, go to question 21

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

     

     

     

### DATA ACCESS

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

     

> FS users with Rules-of- Behavior Agreements and database
> administrators with signed Non-disclosure and Rules-of- Behavior
> Agreements

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

> TIM/FACTS uses an application called the User Management Application
> (UMA) to automate the process to request and approve access to
> TIM/FACTS. A user requests specific roles and org codes which allow
> access to specific subsets of data. The request is automatically
> forwarded to the requester's UMA Manager who approves or denies the
> request. The UMA manager is responsible for determining what level of
> access a given user requires to fulfill his/her job responsibilities.

     

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

X Yes

No

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

> Access is restricted via roles, org codes and fine-grained
> security.     

     

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

X Yes

No

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

X Yes

No

### 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.)?

> The business area Point of Contact, TIM/FACTS ISSO, and the TIM/FACTS
> System Owner           

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

> Phone, visit or email the Forest Service local unit where the original
> transaction occurred.

     

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?

X Yes. If YES, go to question 28

No

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

X No. If NO, go to question 29

1.  Explain how this will be mitigated?

     

          

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

     

     N/A

     

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

Yes

X 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?

X 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.)?

Data can be retrieved via a system-generated Control Number (CN), Name,
SSN, or TIN.

     

     

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/))

> USDA/FS-OFM-03, Administrative Billing and Collections

     

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

     N/A

     

     

### TECHNOLOGY

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

Yes

X 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

### Privacy Impact Assessment Authorization

### Memorandum

### 

### 

I have carefully assessed the Privacy Impact Assessment for the

TIM/FACTS Major
Application\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

(System Name)

This document has been completed in accordance with the requirements of
the EGovernment Act of 2002.

We fully accept the changes as needed improvements and authorize
initiation of work to proceed. Based on our authority and judgment, the
continued operation of this system is authorized.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

System Manager/Owner Date

OR Project Representative

OR Program/Office Head.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Agency's Chief FOIA officer Date

OR Senior Official for Privacy

OR Designated privacy person

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Agency OCIO Date

[^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.