Privacy Impact Assessment (PIA) 

for the 

National Center for Homeless Education (NCHE) 

April 1, 2021 

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: Brandon Dent 

Contact Email: brandon.dent@ed.gov 

System Owner 

Name/Title: Metasebia Belachew 

Principal Office: OESE 

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 National Center for Homeless Education (NCHE) is the U.S. Department of 

Education (Department) funded technical assistance center that supports the 

implementation of the Education for Homeless Children and Youth’s (EHCY) 

grant program. The NCHE website (https://nche.ed.gov/) provides visitors with 

information about the EHCY grant program and related programs, including links 

to relevant Federal resources (including the statutory text of the McKinney-Vento 

Homeless Assistance Act and non-regulatory guidance authored by the 

Department) and NCHE-produced technical assistance resources designed to 

support grantee implementation (including tip sheets, research publications, and 

training materials). The NCHE website publishes non-identifiable data about 

students experiencing homelessness—the data are provided in multiple ways, 

including data aggregated at the national level and data that are state-specific— 

and includes resources to support grantees in collecting, reporting, and analyzing 

student data, activities which are all required by the Department and statute. 

NCHE maintains a help line (via both email and phone) for use by grantees, 

stakeholders, and students and families experiencing homelessness, and the 

center’s website provides information about contacting the help line and NCHE 

staff directly. 

Primary users of the system are state education agencies (SEAs), which receive 

EHCY program grants from the Department. Secondary users of the website 

include local educational agencies (which receive subgrants from SEAs), schoolbased personnel, service providers, parents, students, and other interested 

stakeholders. The secondary users access resources on the website to help ensure 

that children and youth experiencing homelessness can enroll and succeed in 

school. The website displays contact information for state homeless education 

coordinators and NCHE staff. The system also maintains login credentials for 

NCHE website administrators. The system is hosted in the ADTI-GSS hosting 

environment, a shared service hosting provider for the Department. 

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

used, maintained or shared. 

Information collected is used to disseminate information about state coordinators for the 

education of children and youth experiencing homelessness. The Department allocates 

McKinney-Vento funding annually to states based on the state’s proportion of the Title I, 

Part A federal allocation. States must subgrant funds competitively to school districts 

within the state to be used for program implementation at the district level. Information 

provided on the website allows the users to contact the state coordinators and NCHE 

staff personnel. 

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

Currently Operating System 

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

New PIA 

A recent review of the system determined that the system maintains PII (i.e., contact 

information for state homeless education coordinators and NCHE staff, as well as login 

credentials for NCHE website administrators). 

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

Contractor 

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

N/A 

Yes 

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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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 program is authorized Title I, Part A of the Elementary and Secondary Education 

Act (20 U.S.C. 6301 et seq.), as amended. The program regulations are in the U.S. Code 

of Federal Regulations at 34 CFR 222. These authorities allow for the establishment and 

maintenance of the program, including determining Local Education Agency (LEA) 

eligibility and for auditing eligible LEAs. 

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? 

No 

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 

Click here to enter text. 

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 

A SORN is not required because the information is not retrieved by a name or 

other identifier. 

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 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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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. 

GRS 3.2, item 030 – Information Systems Security – Records are destroyed 10 years 

after last action is taken on the file, but longer retention is authorized if required for 

business use. 

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

timelines in the records disposition schedule? 

Yes 

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. 

• State homeless education coordinators 

o Name of the Coordinator 

o Organization address 

o Organization phone number 

o Organization fax 

o Organization email 

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

stated in Question 1.2? 

Yes 

State coordinator information and NCHE staff information is collected to allow website 

visitors to contact them for assistance and information. Only the minimum necessary 

information required to identify and contact the coordinators and staff is collected. 

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

commercial sources, etc.)? 

State coordinator information is provided by state coordinating offices. NCHE staff 

information is provided by NCHE staff. 

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

web page, database, etc.)? 

Program officers directly contact state coordinating offices to collect information on 

state coordinators and add it to the webpage. NCHE staff send contact information 

directly to the website administrators to be posted. This information is reviewed on an 

annual basis or when staff turnover occurs and NCHE staff are notified of the change. 

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? 

The program office directly contacts the state coordinating offices to verify the contacts 

as required for managing a Title I, Part A program. The program office is responsible for 

making updates and ensuring the data on the website are correct. NCHE staff send the 

information directly. As it is their own contact information, it is likely to be correct. 

Use 

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

Coordinating office and point of contact information for both state coordinators and 

NCHE staff is posted on the website to allow coordination and collaboration with local 

agencies and to assist in providing comprehensive services to homeless children and 

youths and their families. 

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 

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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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. 

3.8. 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. 

No 

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

SSN will be used. 

☒ N/A 

System does not collect SSN 

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

alternatives were not selected. 

☒ N/A 

Click here to enter text. 

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. 

Website visitors do not submit any information using the website. NCHE staff and state 

coordinators provide their contact information explicitly so that it can be publicly 

displayed. They are notified of this purpose when the information is collected as 

specified under the contract between the Department of Education and the state in 

question. Additionally, this Privacy Impact Assessment provides notice. 

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. 

Click here to enter text. 

☒ N/A 

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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? 

The coordinating officers are required to submit the information as a requisite for taking 

part in the program. NCHE staff voluntarily provide this information so that they can be 

contacted to provide assistance and information. 

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. 

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 

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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. 

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? 

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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State coordinators and NCHE staff can access the website to view their information. 

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

erroneous information? 

State coordinators must contact the Federal program officer to make changes to the 

information they provided. NCHE staff may contact the website administrator. 

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

information? 

Federal program officer will notify the state coordinator by email about the procedures 

for correcting their information as specified under the contractual arrangement between 

the Department of Education and the state in question.. NCHE staff provide the 

information directly to the website administrators, and so would be aware to reach out if 

changes are needed. 

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 

Low 

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

information? 

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User access is managed NCHE Center program office. NCHE only supports 

communication using the latest secured Transport Layer Security protocols. The system 

does not collect data from other systems or share data with other systems. All personnel 

working with NCHE have to agree to established rules of behavior. Personnel in system 

administration and support roles must complete personnel background screening and 

complete additional training including role-based, incident response, and disaster 

recovery training. 

Physical security is inherited and maintained by the ADTI-General Support System. 

NCHE technical and administrative controls comply with the Federal Information 

Security Modernization Act requirements and with National Institute of Standards and 

Technology (NIST) standards. 

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. 

The system undergoes monthly scans and annual security assessment reviews and is 

continuously monitored using endpoint protection tools. 

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 NCHE system owner ensures that the information is used following stated practices 

in this PIA through several methods. One method is completing the Department’s Risk 

Management Framework process and receiving an authorization to operate (ATO). 

Under this process, a variety of controls are assessed by an independent assessor to 

ensure the NCHE application and the data residing within are appropriately secured and 

protected. One third of all NIST security controls are tested each year, and the entire 

system’s security is re-evaluated every three years. The PIA is reviewed and updated on 

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an as-needed basis and, at a minimum, biennially. These methods ensure that the 

information is used within the stated practices outlined in this PIA. 

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? 

This PIA details the privacy controls and safeguards implemented for this system to 

mitigate privacy risk. These controls and safeguards work to protect the data from 

privacy threats and mitigate the risks to the data. Additionally, privacy risks have been 

reduced by only collecting the minimum PII necessary and by not collecting any 

sensitive PII. 

Role-based access controls are implemented to ensure access to data are restricted to 

authorized users only. Access to monitoring and auditing related documents are limited 

to Department employees with appropriately approved access authorization. 

The privacy risk associated with the system is minimal, as the system only stores state 

coordinator names, office email addresses, office phone numbers and address and NCHE 

staff name and phone numbers. 

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