Privacy Impact Assessment (PIA) 

for the 

FSA Partner Connect 

December 14, 2020 

For PIA Certification Updates Only: This PIA was reviewed on Enter date by Name of reviewer 

certifying the information contained here is valid and up to date. 

Contact Point 

Contact Person/Title: Corey Johnson / Information System Security Officer 

Contact Email: corey.johnson@ed.ov 

System Owner 

Name/Title: Samuel Aba / Senior IT Manager 

Principal Office: Samuel.Aba@ed.gov 

Please submit completed Privacy Impact Assessments to the Privacy Office at 

privacysafeguards@ed.gov 

FY 2020 
 

 

 

 

 

 

 

 

 

Please complete this Privacy Impact Assessment (PIA) on how personally identifiable 

information (PII) is collected, stored, protected, shared, and managed electronically by your 

system. You may wish to consult with your ISSO in completing this document. 

If a question does not apply to your system, please answer with N/A. 

1. Introduction 

1.1. Describe the system including the name, acronym, and a brief description of the program 

or purpose for the system. 

The FSA Partner Connect platform (Partner Connect) is a major application whose 

infrastructure is hosted on the FSA Cloud. Partner Connect is a unified digital website 

for school partners, financial institution partners, FSA staff, and contractors involved in 

the administration of Title IV financial aid for postsecondary education. 

Partner Connect will serve as the foundational platform for FSA’s partners, including 

more than 5,500 postsecondary institutions, as they navigate their participation in the 

Title IV student aid programs. FSA Partner Connect will feature— 

• Knowledge Center – The Knowledge Center will replace the Information for 

Financial Aid Professionals (IFAP) website. The redesigned site will offer a new 

look and feel, streamline information, and improve search capabilities and feature 

an updated FSA Handbook that will be presented in a more user-friendly format, 

including both a digital version and a downloadable PDF version. 

• Partner Dashboard – This feature will allow authenticated users to view a 

summary dashboard with snapshots of data related to their school or organization. 

The dashboard will include partner metrics, important communications, 

notifications, news, and high-level operational data tailored to users based on their 

role. 

• Partner Search and Profile – This feature will allow authenticated users to easily 

search and view comprehensive and consolidated information from FSA systems 

for a school. 

• Student, Parent, Borrower Accounts – This feature will provide authenticated 

users with a comprehensive and consolidated view of account information for 

students, parents, and/or borrowers. Authentication and role-based access are used 

to ensure that users have access only to information they are authorized to view. 

• Partner Role Management – This feature will allow Account Administrators to 

easily manage access to Partner Connect for individuals within their organization. 

Once an individual user has been granted access, the user will be able to view and 

manage his or her access through the Account Access Management Center. 

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1.2. Describe the purpose for which the personally identifiable information (PII)1 is collected, 

used, maintained, or shared. 

To enable Partner Connect functionality, Partner Connect obtains PII (via encrypted 

Application Programming Interface) sourced from other connected FSA systems for 

display to authenticated users (see explanation of Partner Dashboard above). The PII 

processed by the system includes information that has been collected by FSA for 

borrower identity verification, financial aid eligibility, or Title IV program participation 

eligibility. This information has been processed and maintained by other FSA back-end 

systems responsible for various Title IV functions throughout FSA. Specifically, 

information provided through Partner Connect is sourced from National Student Loan 

Data System (NSLDS), Common Origination and Disbursement (COD), and Student 

Aid Internet Gateway Enrollment (SAIG) / Participation Management (PM). For more 

information on how records are handled from these respective systems, please refer to 

those individual PIAs and system of records notices, available at www.ed.gov/privacy. 

The PII collected via Partner Connect enables access to privileged system data available 

in FSA back-end systems responsible for various Title IV functions throughout FSA. 

The PII collected in this system is used for the following purposes: 

• To enable access and login to Partner Connect for FSA staff and contractors as 

well as partners, specifically: postsecondary institutions, third-party servicers, 

state agencies, accrediting agencies, software providers, guaranty agencies, 

federal loan servicers, Federal Family Education Loan (FFEL) Lenders, lender 

servicers, and private collection agencies (PCAs); 

• To associate individual partner users with the appropriate partner organizations; 

detailed institutional information is provided to users with the appropriate system 

relationships; and 

• To provide postsecondary institutions and FSA staff with the ability to view 

comprehensive account information for FSA customers (students, parents, or 

borrowers). 

While Partner Connect collects PII to enable Partner Connect accounts, Partner Connect 

has established a service with FSA’s existing Access and Identity Management System

(AIMS) application for identity authentication and access services. For most partners 

1 The term “personally identifiable information” refers to information which can be used to distinguish or trace an 

individual's identity, such as their name, social security number, biometric records, etc. alone, or when combined 

with other personal or identifying information which is linked or linkable to a specific individual, such as date and 

place of birth, mother's maiden name, etc. OMB Circular A-130, page 33 

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(external users), the relationship with AIMS has already been established and the initial 

point of collection of PII is the SAIG Enrollment PM web site where partners enter – last 

name, first name, email, address, phone number, date of birth, and last four digits of 

Social Security number (SSN). The account information collected in PM is then passed 

to AIMS to generate a unique user ID in AIMS for user authentication and authorization 

to provide access to FSA applications. This is not a probabilistic match; all information 

submitted must match the AIMS ID information exactly in order to be authenticated. For 

most FSA staff or contractors (internal users), the relationship with AIMS has already 

been established and the collection of PII occurs by completing the FSA application 

security access form provided by the Application ISSO on behalf of the internal 

Department employee. If an account is not found, the user will receive either an email or 

be redirected to AIMS to obtain an account. 

Partner Connect collects the minimal PII needed by AIMS – first name, last name, date of 

birth, and last four digits of the SSN to create Partner Connect accounts and integrate 

with AIMS ID to enable a consistent authentication experience for users. User credentials 

for Partner Connect accounts are stored in a linked database, maintained separately from 

the AIMS ID database. User information collected (as described above) as well as a ‘user 

authentication’ flag are stored indefinitely. 

Once a Partner Connect account is established, users with appropriate permissions can 

view detailed institutional information or comprehensive account information for FSA 

customers to facilitate the administration of student aid. As stated previously, this data is 

sourced from other FSA back-end systems responsible for various Title IV functions and 

Partner Connect enables a consolidated view of information that is available in FSA 

systems today. 

Please see 3.1 for the complete list of PII collected, used, maintained, or shared. 

1.3. Is this a new system, or one that is currently in operation? 

New System 

1.4. Is this PIA new, or is it updating a previous version? 

New PIA 

1.5. Is the system operated by the agency or by a contractor? 

Contractor 

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1.5.1. If the system is operated by a contractor, does the contract or other acquisitionrelated documents include privacy requirements? 

N/A

Yes 

2. Legal Authorities and Other Requirements 

If you are unsure of your legal authority, please contact your program attorney. 

2.1. What specific legal authorities and/or agreements permit and regulate the collection and 

use of data by the system? Please include name and citation of the authority. 

• The Higher Education Act of 1965 (HEA), as Amended, section 441 and 461 

Title IV, section 401; 

• Executive Order 13478—Amendments to Executive Order 9397 Relating to 

Federal Agency Use of Social Security Numbers 

• 31 U.S.C 7701, Taxpayer Identifying Number 

SORN 

2.2. Is the information in this system retrieved by an individual’s name or personal identifier 

such as a Social Security Number or other identification? 

Yes 

2.2.1. If the above answer is YES, this system will need to be covered by Privacy Act 

System of Records Notice(s) (SORN(s)).2 Please provide the SORN name, number, 

Federal Register citation and link, or indicate that a SORN is in progress. 

N/A

Student Aid Internet Gateway (SAIG), Participant Management System (18-11-

10). March 1, 2018. 83 FR 8855. 

https://www.federalregister.gov/documents/2018/03/01/2018-04141/privacy-act-of1974-system-of-records 

Common Origination and Disbursement System (18-11-02). August 16, 2019. 84 

FR 41979-41987. 

https://www.federalregister.gov/documents/2019/08/16/2019- 17615/privacy-act-of1974-system-of-records 

2 A System of Records Notice (SORN) is a formal notice to the public that identifies the purpose for which PII is 

collected, from whom and what type of PII is collected, how the PII is shared externally (routine uses), and how to 

access and correct any PII maintained by ED. https://connected.ed.gov/om/Documents/SORN-Process.pdf 

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National Student Loan Database System (18-11-06). September 9, 2018. 84 FR 

47265-47271. 

https://www.federalregister.gov/documents/2019/09/09/2019- 19354/privacy-act-of1974-system-of-records 

2.2.2. If the above answer is NO, explain why a SORN was not necessary. For 

example, the information is not retrieved by an identifier, the information is not 

maintained in a system of records, or the information is not maintained by the 

Department, etc. 

N/A

Click here to enter text. 

Records Management 

If you do not know your records schedule, please consult with your records liaison or send 

an email to RMHelp@ed.gov 

2.3. What is the records retention schedule approved by National Archives and Records 

Administration (NARA) for the records contained in this system? Please provide all 

relevant NARA schedule numbers and disposition instructions. 

The records maintained or transmitted through Partner Connect follow the records 

disposition schedule for each back-end system. The applicable records schedules are as 

follows: 

• ED Records Schedule No. 051 – National Student Loan Data System (DAA0441-2017-0004) (ED 051). Records are destroyed 30 years after cutoff. Cutoff is 

annually when an applicable account is paid in full. 

• ED Record Schedule No. 072 – FSA Application, Origination, and Disbursement 

Records (DAA-0441-2013-0002) (ED 072). This records schedule is being amended and 

pending approval by the NARA. Applicable records will be held indefinitely until the 

applicable NARA approved amendments are in effect. 

2.4. Is the PII contained in this system disposed of appropriately, and in accordance with the 

timelines in the records disposition schedule? 

Yes 

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3. Characterization and Use of Information 

Collection 

3.1. List the specific PII elements (e.g., name, email, address, phone number, date of birth, 

Social Security, etc.) that the system collects, uses, disseminates, or maintains. 

Partner Connect collects, uses, disseminates, or maintains each of the following: 

General Information 

• Full name 

• Username 

• Social Security number 

• Taxpayer Identification Number 

• Student loan account number 

• Driver license number and issuing state 

• Citizenship status 

• Date of birth 

• Contact information 

• Home address; 

• Home, work, alternate, and mobile telephone 

• Email address 

Household Information 

• Family size, dependency status, marital status, spousal identifiers, estimated family 

contribution 

Financial Information 

• IRS Data for Income Based Repayments, (adjusted gross income, tax filing status and 

year, and exemptions), yearly income, credit report information 

Employment Information 

• Name, Employer Identification Number, address, phone number, website, begin and end 

date of employment 

Loan/Grant Information 

Dollar amount, payment milestones from origination through final payment 

Promissory note information and eligibility information 

3.2. Does the system collect only the minimum amount required to achieve the purpose 

stated in Question 1.2? 

Yes 

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Partner Connect collects the minimal PII needed by AIMS – first name, last name, date 

of birth, and last four digits of the SSN -- to create Partner Connect accounts and 

integrate with AIMS ID to enable a consistent authentication experience for users. This 

information is the minimum necessary to create the accounts and enable authentication. 

Once accounts are established, users with appropriate permissions view detailed 

institutional information or comprehensive account information for FSA customers to 

facilitate the administration of student aid. The information is the minimum necessary to 

provide a consolidated view of the information that is available in the FSA systems 

listed above. 

3.3. What are the sources of PII collected (e.g., individual, school, another agency, 

commercial sources, etc.)? 

To enable accounts access and login to Partner Connect, individuals will provide 

their PII which will then be sent to AIMS to see if an account has been created. If 

an account is located, Partner Connect creates an account to match the AIMS 

account for that individual. If an account is not found, the user will receive either 

an email or be redirected to AIMS to obtain an account. 

Once Partner Connect establishes a service with FSA’s existing AIMS application 

for identity authentication and access services, the authenticated users with the 

appropriate permissions will be able to conduct specific searches and view 

the specified data that is processed and maintained by FSA back-end systems 

responsible for various Title IV functions throughout FSA. 

These searches can result in the display of information regarding FSA 

customers (students, parents, borrowers) as well as Title IV institution specific 

information. This information is retrieved from the following FSA back-end 

systems using application programming interfaces (APIs): 

• National Student Loan Data System (NSLDS) 

• Common Origination and Disbursement (COD) 

• Student Aid Internet Gateway (SAIG), Participant Management (PM) System 

3.4. How is the PII collected from the stated sources listed in Question 3.3 (e.g., paper form, 

web page, database, etc.)? 

The PII collected via Partner Connect at fsapartners.ed.gov is provided directly from the 

individual or Title IV organizations when creating a Partner Connect account. 

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Postsecondary institutions and FSA staff users with the ability to access and view 

account information for FSA customers (students, parents, or borrowers) retrieve these 

records using one of the established PII data elements identified in 3.1. This information 

is retrieved from the listed FSA back-end systems (see question 3.3) using APIs. 

3.5. How is the PII validated or confirmed to ensure the integrity of the information 

collected?3 Is there a frequency at which there are continuous checks to ensure the PII 

remains valid and accurate? 

Data is collected directly from individuals, who are responsible for self-validating the 

correctness of the information. All information submitted must match the AIMS ID 

information exactly in order to be authenticated within Partner Connect. All other 

validation of records is the responsibility of the back-end system. Please consult the 

PIAs for the back-end systems to understand the validation process for the information 

maintained in those systems. 

Use 

3.6. Describe how the PII is used to achieve the purpose stated in Question 1.2 above. 

PII is used for identification verification and throughout the student aid lifecycle and for 

Title IV aid administration purposes. 

3.7. Is the system using PII for testing/researching new applications or information systems 

prior to deployment or for training employees? 

No 

3.7.1. If the above answer is YES, what controls are in place to minimize the risk and 

protect the data? 

N/A

Click here to enter text. 

Social Security Numbers 

It is the Department’s Policy that, in order to collect Social Security Numbers, the System Owner 

must state the collection is: 1) authorized by law, 2) necessary for an agency purpose, and 3) 

there is no reasonable alternative. 

3 Examples include restricted form filling, account verification, editing and validating information as it’s collected, 

and communication with the individual whose information it is. 

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3.8. Does the system collect Social Security Numbers? Note that if the system maintains 

Social Security Numbers but does not explicitly collect them, answer 3.8.1 to address the 

purpose for maintaining them. 

Yes 

3.8.1. If the above answer is YES, explain the purpose for its collection, and how the 

SSN will be used. 

N/A

The SSN is the unique identifier for Title IV, HEA programs and is required by 

program participants and their trading partners to satisfy borrower identification, 

borrower eligibility, loan servicing, and loan status reporting requirements under 

law and regulations. The SSN is the required identifier for numerous business 

processes. 

3.8.2. Specify any alternatives considered in the collection of SSNs and why the 

alternatives were not selected. 

N/A

The SSN is the unique identifier for Title IV, HEA programs and is required by 

program participants and their trading partners to satisfy borrower identification, 

borrower eligibility, loan servicing, and loan status reporting requirements under 

law and regulations. The SSN is first collected on the FAFSA and is the required 

identifier for numerous FSA business processes. The collection of SSNs of student, 

parent or borrower is required and authorized by 31 U.S.C. 7701 and Executive 

Order 9397 (November 22, 1943), as amended by Executive Order 13478 

(November 18, 2008). No alternatives currently exist for SSN collection. 

4. Notice 

4.1. How does the system provide individuals with notice about the collection of PII prior to 

its collection (e.g., direct notice, such as a Privacy Act Statement (if applicable) or 

public notice, such as a SORN, PIA,)? If notice is not provided, explain why not. 

The information in each system that Partner Connect accesses is covered by a SORN, 

which provides notice to individuals. For FSA customers (students, parents, or 

borrowers), direct notice, prior to collection, is provided during the Free Application for 

Federal Student Aid (FAFSA) process at studentaid.ed.gov. for FSA customers 

(students, parents, or borrowers) A Privacy Act Statement is provided to users at the 

point of collection. 

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4.2. Provide the text of the notice or the link to the webpage where the notice is posted if 

notice is provided other than by SORN or PIA. 

N/A

Please refer to the following systems’ PIAs to obtain the most current and accurate notice 

information: 

• COD PIA • SAIG PIA 

• NSLDS PIA • AIMS PIA 

4.3. What opportunities are available for individuals to consent to uses (including new uses 

of previously collected PII), decline to provide PII, or opt out of the project? 

For external users, please refer to the PIAs listed in question 4.2 for what opportunities 

are available for users to consent to uses, decline to provide PII, or opt out. 

Internal users may decline to have an account created on their behalf. However, access 

to Partner Connect and various FSA applications requires an account. 

4.4. Is the notice referenced in Question 4.1 reviewed and revised when there are changes in 

the practice, policy, or activities that affect the PII and privacy to ensure that individuals 

are aware of and can consent to, where feasible, these changes? 

Yes 

5. Information Sharing and Disclosures 

Internal 

5.1. Will PII be shared internally with other ED principal offices? If the answer is NO, please 

skip to Question 5.4. 

No 

5.2. What PII will be shared and with whom? 

N/A

Click here to enter text. 

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5.3. What is the purpose for sharing the specified PII with the specified internal 

organizations? 

N/A

Click here to enter text. 

External 

5.4. Will the PII contained in the system be shared with external entities (e.g. another agency, 

school district, the public, etc.)? If the answer is NO, please skip to Question 6.1. 

No 

Authenticated users may view information available within Partner Connect but Partner 

Connect does not provide any of the data within the system to any external entities via email, 

data exchanges, etc. 

5.5. What PII will be shared and with whom? List programmatic disclosures only.4 

Note: If you are sharing Social Security Numbers externally, please specify to 

whom and for what purpose. 

N/A

Click here to enter text. 

5.6. What is the purpose for sharing the PII with the specified external entities? 

N/A

Click here to enter text. 

5.7. Is the sharing with the external entities authorized? 

N/A

Click here to select. 

5.8. Is the system able to provide and retain an account of any disclosures made and make it 

available upon request? 

N/A

Click here to select. 

4 If this information is covered by Privacy Act System of Records Notice (SORN) please list only relevant 

programmatic disclosures listed under the Routine Uses section. 

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5.9. How is the PII shared with the external entity (e.g. email, computer match, encrypted 

line, etc.)? 

N/A

Click here to enter text. 

5.10. Is the sharing pursuant to a Computer Matching Agreement (CMA), 

Memorandum of Understanding (MOU), or other type of approved sharing agreement 

with another agency? 

N/A

Click here to select. 

5.11. Does the project place limitation on re-disclosure? 

N/A

Click here to select. 

6. Redress 

6.1. What are the procedures that allow individuals to access their own information? 

All users have access to their account information through the Account Access 

management center built into FSA Partner Connect. 

Borrowers may access their information as stated in the following systems’ PIAs: 

• COD PIA • SAIG PIA 

• NSLDS PIA • AIMS PIA 

6.2. What procedures are in place to allow the subject individual to correct inaccurate or 

erroneous information? 

Please refer to the following systems’ PIAs to obtain the most current and accurate 

redress information: 

• COD PIA • SAIG PIA 

• NSLDS PIA • AIMS PIA 

Internal users can modify and update demographic information in the Account Access 

management center built into Partner Connect. 

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6.3. How does the project notify individuals about the procedures for correcting their 

information? 

Please refer to the following systems’ PIAs to obtain the most current and accurate notice 

information: 

• COD PIA • SAIG PIA 

• NSLDS PIA • AIMS PIA 

The system does not notify internal users on the procedures for correcting their 

information as there is an area within the system that allows for modifications. 

7. Safeguards 

If you are unsure which safeguards will apply, please consult with your ISSO. 

7.1. Does the principal office work with their CSO/ISSO to build privacy & security into the 

system and build privacy extensions to the extent feasible? 

Yes 

7.2. Is an Authority to Operate (ATO) required? 

Yes 

7.3. Under NIST FIPS Pub. 199, what is the security categorization of the system: Low, 

Moderate, or High? 

N/A

Moderate 

7.4. What administrative, technical, and physical safeguards are in place to protect the 

information? 

In accordance with the Federal Information Security Management Act of 2002 

(FISMA), as amended by the Federal Information Security Modernization Act of 2014, 

every FSA system must receive a signed Authorization to Operate (ATO) from a 

designated FSA official. The ATO process includes a rigorous assessment of security and 

privacy controls, a plan of actions and milestones to remediate any identified 

deficiencies, and a continuous monitoring program. The Partner Connect system is 

currently undergoing ATO activities and an ATO is scheduled to be received on March 

26, 2021. 

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The security and privacy controls that are implemented for the system comprise a 

combination of management, operational, and technical controls, and include the 

following control families: access control, awareness and training, audit and 

accountability, security assessment and authorization, configuration management, 

contingency planning, identification and authentication, incident response, maintenance, 

media protection, physical and environmental protection, planning, personnel security, 

privacy, risk assessment, system and services acquisition, system and communications 

protection, system and information integrity, and program management. 

Access to the Partner Connect system is available only to users who have been 

authenticated to the Department of Education network using their Department-issued PIV 

and/or PIV-I card. Access to all privileged roles is controlled through processes that 

enforce formal requests and approvals for access on a need-to-know and least-privilege 

basis. 

Additional examples of specific controls include multifactor authentication, encryption of 

data at rest and in transit, firewalls, Intrusion Prevention and Intrusion Detections 

Systems (IPS/IDS), event monitoring systems, penetration testing, system audits, user 

recertification, and threat management. Finally, all privileged users are provided a copy 

of the Rules of Behavior and are required to complete the annual Cybersecurity and 

Privacy Awareness training. 

7.5. Is the information in the system appropriately secured in accordance with the IT 

security requirements and procedures as required by Federal law and policy? 

Yes 

7.6. Has a risk assessment been conducted where appropriate security controls to protect 

against that risk have been identified and implemented? 

Yes 

7.7. Please describe any monitoring, testing or evaluation conducted on a regular basis to 

ensure the security controls continue to work properly at safeguarding the PII. 

Once this system becomes operational, the monitoring will begin to ensure the security 

and privacy controls work properly at safeguarding PII. Continuous monitoring, 

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scanning, and testing will commence once the Partner Connect enters the Ongoing 

Security Authorization (OSA) Program. 

8. Auditing and Accountability 

8.1. How does the system owner assess and ensure that the PII is used in accordance with 

stated practices in this PIA? 

The system owner ensures that records are maintained in accordance with the provisions 

of the Federal Records Act, Departmental policies, and the Privacy Act, ensuring 

appropriate security and privacy controls are implemented to restrict access, and to 

properly manage and safeguard PII maintained within the system. 

The system owner participates in all major security and privacy risk briefings, meets 

regularly with the information system security officer (ISSO), and participates in FSA's 

Lifecycle Management Methodology (LMM), which addresses security and privacy risks 

throughout the system’s life cycle. Additionally, the system owner regularly reviews 

signed agreements that govern data use between organizations, such as system of records 

notices, memorandum of understanding, interconnection security agreement, etc. 

8.2. Does the system owner continuously monitor and audit the privacy controls to ensure 

effective implementation? 

Yes 

8.3. What are the privacy risks associated with this system and how are those risks 

mitigated? 

The main privacy risks are the unauthorized access, use, or loss or control of the data 

which can result in identity theft or other forms of fraud. These risks are mitigated 

through various safeguards such as access controls, configuration management and 

anomaly detection, strict password rule and two-factor authentication capabilities, and 

continuous monitoring of intrusion detection and firewall alerts. 

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