Privacy Impact Assessment (PIA)

for the

The LINCS Technology Project

January 11, 2022

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: Mary Jo Maralit

Contact Email: maryjo.maralit@ed.gov

System Owner

Name/Title: Mary Jo Maralit

Principal Office: Office of Career, Technical, and Adult Education (OCTAE)

Please submit completed Privacy Impact Assessments to the Privacy Office at

privacysafeguards@ed.gov

FY 2022
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 Literacy Information and Communications System (LINCS) provides evidencebased resources for adult educators at the state and local level to enable them to design

and deliver learning opportunities for adults so they can successfully transition to and

complete college career pathways leading to 21st century jobs.

The LINCS Technology Project is a system, comprised of public-facing websites with

the following components:

● LINCS (https://lincs.ed.gov) – Main site for the LINCS Technology Project.

Allows open access to a searchable collection of vetted resources for adult

education practitioners, resources for teachers and program managers, and links

to other LINCS system components. Does not support user registration.

● LINCS Community (https://community.lincs.ed.gov) – Open-access community

of practice (forum) where adult educators can discuss effective instructional

practices and strategies in content-based groups. Requires user registration to

access some site content.

● LINCS Learning Portal (https://courses.lincs.ed.gov) – Open-access learning

platform with over 20 self-paced courses that support professional development

for adult education practitioners. Requires user registration to access most site

content.

● LINCS Learner Center (https://learner.lincs.ed.gov) – Public resources for

adult learners that include Federal resources to help them achieve their goals and

continue their studies outside the classroom. Does not support user registration.

● Student Achievement in Reading (STAR) (https://star.lincs.ed.gov) –

Resources and discussion forum for instructors teaching intermediate-level adult

learners (grade level equivalent 4.0 – 8.9). Requires user registration to access

site content.

● Adult Education and Family Literacy Act (AEFLA) (https://aefla.ed.gov) –

Public resources to support the AEFLA program, which helps adults get the basic

skills they need to be productive workers, family members, and citizens,

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including reading, writing, math, English language proficiency, and problemsolving. Does not support user registration.

Each LINCS system component (listed above) is built using a virtual computing

“instance” within the Amazon Web Services (AWS) Elastic Computer Cloud (EC2).

LINCS exists in a virtual private cloud (VPC) that provides logical isolation from the

rest of the AWS cloud.

LINCS Learning Portal and LINCS Community are running the following:

● Red Hat Enterprise Linux (RHEL) with SELinux enabled

● Drupal Content Management System (CMS) engine for dynamic website content

and web services

● Moodle Learning Management System (LMS) which provides the courses

The CMS and LMS applications enable site users to access content stored within a

backend MySQL database for display within dynamically generated web pages. LINCS

components are hosted on virtual machine instances located in the FedRAMP-certified,

US-East (N. Virginia) AWS cloud.

With regard to LINCS database connectivity, each LINCS instance has an internal

database. LINCS does not connect to any other databases.

To continually improve the user experience, the LINCS Technology Project periodically

conducts user research. Research involves the use of a screener survey to identify

potential participants, and user interviews to gather data on the user experience.

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

used, maintained or shared.

The LINCS Technology Project collects PII from three sources:

1. LINCS Community, a community of practice

2. LINCS Learning Portal, a learning platform

3. User research

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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LINCS COMMUNITY AND LINCS LEARNING PORTAL

These sites collect the minimum PII that is required for user registration, and the PII data

is for internal system use only. The LINCS Community and LINCS Learning Portal

instances each maintain local records of its registered users. LINCS Community

provides single sign-on (SSO) for both sites.

The PII for user registration includes the following attributes:

● Email address

During registration, the user provides an email address, which can be personal or

work-related. The system sends a confirmation message to the email address, and

when the user clicks the link in the message to confirm the registration, the

system activates the registered user account.

The email address is always stored on the LINCS Community instance because it

is the SSO provider, and if the user registered for the LINCS Learning Portal, the

email address is also stored locally on that instance to create the registered user

account.

The registered user’s email address is not visible to other users. The registered

user chooses a display name so that the email address remains private.

When logging in to the LINCS Community or LINCS Learning Portal, the

registered user must provide the email address.

In addition to authentication, the system uses the email address to send password

reset requests, add the user to courses in the LINCS Learning Portal, and send

various email notifications based on user activity and notification preferences.

● Single sign-on password

During registration, the user chooses a password, and LINCS Community, the

SSO provider, stores the password for authentication to LINCS Community and

LINCS Learning Portal.

● First name, last name

The system uses first and last names to address registered users and provide a

personalized learning experience. The registered user provides first and last

names, but names are not validated for authenticity.

● LINCS Community display name

When registering, users choose a display name so that their email address

remains private. The display name is similar to a social media handle in that it

does not need to be a realistic name.

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Optional profile data

Both LINCS Community and LINCS Learning Portal allow registered users to populate

and manage (add/edit/delete) profile data. Each site stores user profiles locally. Profile

data is not shared across sites or services. Profile data is not validated for authenticity.

● LINCS Community: Profile data is visible only to other registered users, and

includes fields for organizational affiliation, interests, “about me”, and social

media links. While profile data remains restricted to registered users, posts in

LINCS Community are public, and post authors are identified using their display

names.

● LINCS Learning Portal: Profile data is visible only to other registered users

who are enrolled in the same course, and includes a profile photo and time zone,

as well as a toggle control for showing/hiding the user’s email address.

USER RESEARCH

LINCS is also beginning research to better understand our users’ experience. This will

consist of two parts - a screener survey to identify potential users willing to talk about

their experiences with LINCS, and a set of user interviews to better understand users’

experiences.

Screener survey

A screener survey is used to identify current and prospective LINCS users as potential

participants for one-on-one interviews. When a user research project is being conducted,

a link to the screener survey is posted in a discussion forum, in an informational bar on

the site, and on social media. Participation is completely voluntary.

The screener survey collects the following information:

● Email address

Users are informed up front in the introductory text that this survey, through

Microsoft Forms, is for users who are interested in participating in 25-minute

interviews. If they are interested in participating, they can choose to share their

email address in the Microsoft Forms survey created by the System Owner’s U.S.

Department of Education account. All data will be handled through the U.S.

Department of Education account and will also be provided as a “responses

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spreadsheet” that will be accessible by only the System Owner and the User

Experience Design and Research Lead (Contractor).

● First name, last name

If they are interested in participating, they can choose to share their first name and

last name in the Microsoft Forms survey created by the System Owner’s U.S.

Department of Education account. All data will be handled through the U.S.

Department of Education account and will also be provided as a “responses

spreadsheet” that will be accessible by only the System Owner and the User

Experience Design and Research Lead.

User interviews

The purpose of the interviews is that we will use the insights collected from users and

potential users of the LINCS site in order to improve user experience and to better

understand the features and functionalities that our users would find useful.

During the user interviews, interviewees will be informed that any information they

share will be recorded in notes format and as a video recording, and that these interviews

will not have their names attached to them. We will, for example, be asking them some

version of “Tell me about yourself.”, so information shared by the interviewee might

include job title, job role, and geographic location. These recordings and interview notes

will be stored using a randomized User Interview ID# and will not include their name.

The recordings and interview notes will be accessible only by the System Owner and the

User Experience Design and Research Lead (Contractor). The User Interview ID# is

necessary for the validity of the work, in case in the future, we want to follow-up with

someone (for example, to better understand something they said about a particular

feature, or to ask them to clarify the context in which they mentioned a particular

challenge when it comes to website usage).

The spreadsheet containing User Interview ID#s will be kept only by the System Owner

for the duration of the contract (another 4.5 years). The purpose for keeping this data is

in support of future research efforts (in case we want to follow up with the same set of

participants as the website changes, or in case we want to make sure not to reach out

again and overburden people we have already talked to).

After the interviews, the data will be summarized in presentation form, and the summary

presentation will be shared with the contractor (IT and UX), OCTAE (Department of

Education), and our site content partners. All summary information will only be shared

internally to the project team, and we have no plans to share to a broader audience.

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

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Currently in operation

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

This PIA is being updated to include user research projects. The LINCS Technology

Project is beginning research to better understand our users’ experience and will be

introducing screener surveys to identify participants for user interviews. Surveys will be

administered using Microsoft Forms. Interviews will be conducted over a secure Zoom

account.

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

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.

Under Title II of the Workforce Innovation and Opportunity Act, Public Law 113-128,

Section 242, the Office of Career, Technical, and Adult Education (OCTAE) carries out

a program of national leadership activities to enhance the quality and outcomes of adult

education and literacy activities and programs nationwide. OCTAE uses these funds to

provide technical assistance and professional development to programs, and to

contribute to research and evaluations of adult education programs and activities.

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

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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

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

The system does not retrieve information by name or 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

2.3. 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.

● Login information: GRS 3.2, item 030: System access records, systems not

requiring special accountability for access.

Retention: Temporary. Destroy when business use ceases.

Covers: Records created as part of the user identification and authorization

process to gain access to systems. Includes: user profiles, log-in files, password

files, etc.

● LINCS Community information: GRS 6.4, item 020: Public correspondence

and communications not requiring formal action.

Retention: Temporary. Destroy when 90 days old, but longer retention is

authorized if required for business use.

Covers: Records related to correspondence and communication, including

comments, to and from the public that require no formal response or action.

Includes: personal opinions on current events or personal experiences and

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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comments posted by the public on an agency website that do not require response

or that the agency does not collect for further use.

● LINCS Learning Portal information: ED 091, item a3: Printed and

electronic publications and print materials produced or funded by the

Department for internal or external distribution.

Retention: Permanent. Cut off at the end of the fiscal year. Transfer to NARA in

5 year blocks when the most recent records are 5 years old.

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.

For LINCS Community and LINCS Learning Portal, the system collects the following

information for internal system use.

● Email address

o During user registration: The user provides an email address (personal or

work-related) for registration, and the system uses the email address to

send a confirmation message and register the user.

o After initial registration: The system uses the email address to

authenticate the user, send password reset requests, add the user to

courses, and send various email notifications based on user activity and

notification preferences.

● LINCS Community password

During registration, the user chooses a login password, and the system

stores the password and email address as authentication credentials.

● First name, last name

The system uses names to address registered users and provide a

personalized learning experience. Names are not validated for authenticity.

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Optionally, registered users can populate profile data, such as organizational affiliation,

interests, about me, and social media links. Registered users manage their own profile

data while logged in to the system, and can add/edit/delete profile data at will.

The LINCS Community component allows Community users to populate their user

profiles to enhance the user experience, and as part of online coursework. When

registered users add data to their user profiles, the data become visible to other

Community users, but are never disclosed or disseminated. Profile data are not validated

for authenticity.

While access to user profile data are restricted to registered Community users, posts are

public.

Current and prospective LINCS users who volunteer to participate in user research

provide their names and email addresses in the screener survey.

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

stated in Question 1.2?

Yes

The LINCS Technology Project collects PII from three sources:

1. LINCS Community, a community of practice

2. LINCS Learning Portal, a learning platform

3. User research

LINCS sites collect the minimum PII that is required for user registration, and the PII

data is for internal system use only. During user research, the researcher collects the

minimum PII required to contact participants by email and coordinate interviews.

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

commercial sources, etc.)?

● Registered users: Registered users enter their own account and profile data on

the LINCS site. There are no external data sources.

● Privileged users: LINCS site administrators provide the names, email addresses,

and temporary passwords for new privileged user accounts. Privileged users are

either agency employees or contractors and have been approved by the LINCS

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management team for privileged user access.

(All privileged users take annual security training and agree to U.S. Department

of Education Standard PR.AC: User-Notification Warning Banner Terms and

Conditions. Privileged users are reviewed on a quarterly basis.)

● Research participants: Current and prospective LINCS users who volunteer to

participate in user research provide their names and email addresses in the

screener survey.

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

web page, database, etc.)?

● Registered users: Users enter their information into a webform on the LINCS

site when registering for an account or profile.

● Privileged users: LINCS site administrators enter the names, email addresses,

and temporary passwords of privileged users directly into the system. Privileged

users are either agency employees or contractors and have been approved by the

LINCS management team for privileged user access.

● Research participants: Current and prospective LINCS users who volunteer to

participate in user research provide their names and email addresses in the

screener survey. Participants may also share non-sensitive PII during interviews,

such as job titles and roles, but all data is anonymized for privacy and objectivity.

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?

● Registered users: The email address is confirmed during user registration.

During registration, the user provides an email address, which can be personal or

work-related. The system sends a confirmation message to the email address, and

when the user clicks the link in the message to confirm the registration, the

system activates the registered user account.

The email address is always stored on the LINCS Community instance because it

is the SSO provider, and if the user registered for the LINCS Learning Portal, the

email address is also stored locally on that instance to create the registered user

account.

The registered user’s email address is not visible to other users. The registered

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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user chooses a display name so that the email address remains private.

When logging in to the LINCS Community or LINCS Learning Portal, the

registered user must provide the email address.

In addition to authentication, the system uses the email address to send password

reset requests, add the user to courses in the LINCS Learning Portal, and send

various email notifications based on user activity and notification preferences.

No other information is confirmed or validated for authenticity.

● Privileged users: Privileged users are either agency employees or contractors.

Before privileged users can be added to the system, the LINCS management

team must approve them and identify them for LINCS site administrators who

create user accounts.

● Research participants: PII is not validated or confirmed. However, the email

address that the user provides must be correct in order for the researcher to

contact the participant and coordinate the interview.

Use

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

The following response duplicates the response to Question 1.2.

The LINCS Technology Project collects PII from three sources:

1. LINCS Community, a community of practice

2. LINCS Learning Portal, a learning platform

3. User research

LINCS COMMUNITY AND LINCS LEARNING PORTAL

LINCS sites collect the minimum PII that is required for user registration, and the PII

data is for internal system use only. The LINCS Community and LINCS Learning Portal

instances each maintain local records of its registered users. LINCS Community

provides single sign-on (SSO) for both sites.

The PII for user registration includes the following attributes:

● Email address

When logging in to the LINCS Community or LINCS Learning Portal, the

registered user must provide the email address.

In addition to authentication, the system uses the email address to send password

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reset requests, add the user to courses in the LINCS Learning Portal, and send

various email notifications based on user activity and notification preferences.

● Single sign-on password

During registration, the user chooses a password, and LINCS Community, the

SSO provider, stores the password for authentication to LINCS Community and

LINCS Learning Portal.

● First name, last name

The system uses first and last names to address registered users and provide a

personalized learning experience.

● LINCS Community display name

When registering, users choose a display name so that their email address

remains private. The display name is similar to a social media handle in that it

does not need to be a realistic name.

USER RESEARCH

During user research, the researcher collects the minimum PII required to contact

participants by email and coordinate interviews.

Screener survey

A screener survey is used to identify current and prospective LINCS users as potential

participants for one-on-one interviews. When a user research project is being conducted,

a link to the screener survey is posted in a discussion forum, in an informational bar on

the site, and on social media. Participation is completely voluntary.

The screener survey collects the following information:

● Email address

Users are informed in the introductory text that the survey is for users who are

interested in participating in 25-minute interviews. If they are interested in

participating, they can choose to share their email address in the Microsoft Form

created using the U.S. Department of Education account. All survey data is

contained in the U.S. Department of Education Microsoft Form account and is

also provided as a “responses spreadsheet” that is accessible only to selected

project team members.

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● First name, last name

If users are interested in participating in the survey, they can choose to share their

first name and last name in the Microsoft form created by the U.S. Department of

Education account. All survey data is contained in the U.S. Department of

Education account and is also provided as a “responses spreadsheet” that is

accessible only to selected project team members.

User interviews

During interviews, participants are informed that any information they share will be

recorded in notes format and as a video recording, and that these interviews will not

have their names associated with them. The interview will include a question like “Can

you tell me about yourself”, so the participant’s response might include job title, job

role, and geographic location.

Recordings and interview notes are stored using a User Interview ID# so as to keep

names private. Data is accessible only to selected project team members.

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.

3.8. 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

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

SSN will be used.

N/A

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

alternatives were not selected.

N/A

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.

● A link to the website privacy policy appears in the site footer.

● Privacy Impact Assessment is posted on the Department’s Notices page for

public reference.

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

https://lincs.ed.gov/privacy-policy

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?

Opportunities to consent to uses:

● During login, registered users must review the U.S. Department of Education

Standard PR.AC: User-Notification Warning Banner Terms and Conditions.

When registered users accept the terms and conditions, they are opting in.

● During registration, users are automatically subscribed to email announcements.

Registered users can opt out of receiving announcement by updating the

subscription settings in their profile.

● Registered users in LINCS Community must explicitly opt in to receive email

messages with group content for the groups they join.

Opportunities to decline to provide PII:

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● Users may opt out of LINCS services if they want to provide PII. When

accessing the LINCS system as anonymous users, they can view the posts in

LINCS Community, but they are not able to participate or engage with LINCS

Community members. As anonymous users in LINCS Learning Portal, they

cannot enroll in courses.

Registration is separate for LINCS Community and LINCS Learning Portal.

Registered users are not required to register for both services.

● Registered users can decline to provide profile data. It is optional and does not

impact their access to LINCS features.

Opportunities to opt out of the project:

● Registered users can opt out of the project by closing their accounts. When

registered users close their accounts, the accounts are blocked. On the LINCS

Community, any discussions or posted content from blocked users remains. For

the LINCS Learning Portal, blocked users become invisible to other users;

however their course progress is saved. The only information about these users

that remains visible is their chosen display name.

● Registered users can request to have their accounts and created content

permanently deleted.

● By default, registered users in LINCS Community are subscribed to email

announcements. To opt out, registered users can modify the subscription setting

in their user profile.

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

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

organizations?

N/A

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

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

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

N/A

5.7. Is the sharing with the external entities authorized?

N/A

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

available upon request?

N/A

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

line, etc.)?

N/A

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

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

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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with another agency?

N/A

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

N/A

6. Redress

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

Registered users manage their own account and profile data, and they access the data

when they log in to their accounts. (The system uses the user-supplied email address to

retrieve account and profile data from the application database.)

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

erroneous information?

Registered users manage their own account and profile data. To correct information, a

registered user must log in, and then access, update, and save the user profile settings

with the corrected information.

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

information?

After registered users add profile data, they follow the same process to access it again

and update it, so no special instructions are required.

Users may contact the LINCS Help Desk for direct user support if needed. The LINCS

Help Desk collects email addresses for internal use only. The email address is not

required to be the same one used to register for LINCS Community or LINCS Learning

Portal.

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

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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?

LINCS is built using virtual computing “instances” within the AWS Elastic Computer

Cloud (EC2). The instance data storage volumes make use of the Amazon Elastic Block

Store (EBS) that provides encryption for data at rest. LINCS exists in a virtual private

cloud (VPC) that provides logical isolation from the rest of the AWS cloud. Frontline

firewall protection for instances is provided at the VPC network boundary by a

collection of “security groups” in which the protocols, ports, and source IP ranges are

defined and blocked/allowed as needed.

The entire AWS EC2 “availability zone” in which the LINCS instances reside (us-east1) has been certified as FedRAMP compliant. FedRAMP is a U.S. Government-wide

program that delivers a standard approach to security assessment, authorization, and

continuous monitoring for cloud products and services.

System and application security updates are applied twice monthly. System

administrators are trained in PII awareness. Their access is restricted to an as-needed

basis, and their privileges are revoked when not needed.

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

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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.

● On an ongoing basis, Advanced Intrusion Detection Environment (AIDE) and

Open-Source Security Host-based Intrusion Detection System (OSSEC HIDS)

monitor system files and logs for anomalies and known issues.

● On a monthly basis, the LINCS team assesses the system using vulnerability

scans.

● On a monthly basis, the LINCS team assesses the system using Open Security

Content Automation Protocol (OpenSCAP) and Open Vulnerability and

Assessment Language/ Common Vulnerability Enumeration (OVAL/CVE).

● On a quarterly basis, the LINCS team audits privileged users.

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 Drupal platform strongly enforces a set of roles and permissions to ensure that

general users do not have access to the PII of others without their explicit permission.

Drupal core features allow LINCS site administrators to control which content is visible

to each designated user role. Email addresses are visible only to site administrators. For

registered users, only display names and information they choose to share is visible to

other registered users.

The LINCS management team ensures that the privileged users take annual security and

privacy awareness training and agree to U.S. Department of Education Standard PR.AC:

User-Notification Warning Banner Terms and Conditions.

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

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sensitive PII. Role-based access controls are implemented to ensure access to data is

restricted to authorized users only. Access to monitoring and auditing related documents

is limited to Department employees with appropriately approved access authorization.

Privacy risks include unauthorized access to PII in the LINCS system. Access to LINCS

privileged user credentials is limited to system administrators only. To protect registered

user account information and profile data, which are stored in the application database,

the LINCS system has the following safeguards:

● Firewalls

● All applicable safeguards prescribed by the National Institute of Standards and

Technology (NIST) Special Publication 800-53 Rev. 4

● Trained system administrators

● Restricted access to production data

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