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AmeriCorps

Privacy Impact Assessment (PIA)

1- GENERAL SYSTEM INFORMATION

1-1

Name of the information technology (IT) 

system:

AmeriCorps Child Care Benefit System 

1-2 System Identifier (3 letter identifier): ACB

1-3 Unique Investment Identifier (Exhibit 53): 485-000000020

1-4 Office or entity that owns the system: AmeriCorps

1-5 Office or entity that manages the system: GAP Solutions, Inc. (GAP)

1-6

State if the system is operational or 

provide the expected launch date:

Operational

1-7 System’s security categorization: Moderate

1-8

Date of most recent Security Assessment 

and Authorization (SA&A) or why one is 

not required:

August 30, 2022

1-9

Approximate number of individuals with 

personally identifiable information (PII) 

in the system

7,334

3- SIGNATURES (ORIGINAL MAINTAINED BY CHIEF PRIVACY OFFICER)

Role *Signature* *Date*

3-1 Information System Owner:

3-2 Office of General Counsel:

3-3 Chief Privacy Officer:

3-4

Chief Information Security 

Officer:

3-5

Senior Agency Official for 

Privacy:

250 E Street SW

Washington, D.C. 20525

202-606-5000/ 800-942-2677
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4- PIA HISTORY

4-1 State whether this is the first PIA for the system or an update to a signed PIA.

This is an update to a signed PIA.

4-2 If this is an update, describe any major system changes since the last PIA.

If this is the first time a PIA is being completed, write Not Applicable.

• Operating System (OS) upgraded to Window Server 2016

• Adobe ColdFusion 2021

5- SYSTEM PURPOSE

5-1 Describe the purpose of the system.

AmeriCorps offers childcare benefits to AmeriCorps State and National, VISTA, 

NCCC, and FEMA Corps members who meet the eligibility requirements. The 

AmeriCorps Childcare Benefits System (ACB) is designed to help AmeriCorps 

members and their families successfully apply for childcare benefits that are part of 

a package of benefits for members performing public service. The program 

website is located at https://americorpschildcare.com where the authorized 

members can access and complete a standardized enrollment form, which then 

allows payments to be processed and made to the AmeriCorps Members’ childcare 

providers. 

The ACB system is run by GAP Solutions, Inc. (GAP) that manages almost all 

aspects of the program. The system is located in a datacenter under an 

Infrastructure as a Service (IaaS) contract administered by Rectitude 369, which is 

FedRAMP Authorized as the VMware vCloud® Government Service (VCGS).

6- INVENTORY OF PII

6-1 Provide a list of all the PII included in the system.

The elements of PII in the system include:

• Name

• Gender

• Date of birth and age

• Birth Certificate 

• Home, cellular, and fax number

• Email address

• Mailing and physical address

• National Service Participant ID (NSPID) number

• HIPPA Mental Health Information (when applicable)

• Social Security and Tax ID Number
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• Child Care License and Business License Number

• Driver’s License and/or State ID Number

7- CATEGORIES OF INDIVIDUALS IN THE SYSTEM

7-1 Describe the categories of individuals whose PII is in the system and state 

approximately how many individuals are in each category.

The categories of individuals whose PII is in the system include:

1. AmeriCorps Service Member (Member) who apply for childcare benefits.

2. The Member’ children (generally one or two), supervisor, spouse, and 

anyone else who lives in their household.

3. Child Care Provider (Provider) who wants to care for a member’s child and 

receive a reimbursement

• 4826 Members are registered in ACB.

• 2508 Providers are registered in ACB.

8- INFORMATION IN THE SYSTEM

8-1 For each category of individuals discussed above:

a. Describe the information (not just PII) collected about that category.

b. Give specific details about any PII that is collected.

c. Describe how the information is used.

ACB includes information about Members who voluntarily enroll to receive 

childcare benefits. 

When a State and National or VISTA Member enrolls or receives childcare, ACB 

may collect the following information about that Member to validate their identity, 

establish their eligibility to participate, and process the approved subsidies:

• their name, date of birth, NSPID number, program affiliation, dates of 

service, worksite, home and cell phone number, email address, and current 

address

• their supervisor’s name and contact information

• their children who require childcare’s names, school enrollment 

information, child custody agreements or court orders, and birth certificates

• their spouse’s name, home phone number, email address, current address, 

employment status and, if the spouse is:

o unemployed, information about their last job including the name and 

phone number of their supervisor

o enrolled in a job training or educational program, information about 

that training or program

o self-employed, their business license and a business profit/loss 

statement
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• the name, age, and gender of other persons in the Member’s household and 

their relationship to the Member

• information of other persons in the member’s household who is 18 or older, 

including:

o total monthly income, where it comes from (e.g., child support,

scholarships), and proof of that income

o federal tax returns (which include social security numbers (SSNs)), 

in addition, paystubs of a whole month, a description of their current 

academic pursuits, or information showing whether they are seeking 

work

When a NCCC or FEMA Corps Member enrolls or receives childcare, ACB may 

collect the following information about that Member to validate their identity, 

establish their eligibility to participate, and process the approved subsidies:

• their name, date of birth, NSPID number, program affiliation, dates of 

service, worksite, home and cell phone number, email address, and current 

address

• their supervisor’s name and contact information

• their children who require childcare’s names, school enrollment 

information, child custody agreements or court orders, and birth certificates

• their spouse’s name, home phone number, email address, current address, 

employment status and, if the child is living with a spouse who is:

o unemployed, information about their last job including the name and 

phone number of their supervisor

o enrolled in a job training or educational program, information about 

that training or program

o self-employed, their business license and a business profit/loss 

statement

NCCC and FEMA Corps Members do not provide information about other 

household members because they live on a campus apart from anyone who could 

provide childcare. They only need to provide their spouse’s employment 

information if a child is living with that spouse because the eligibility requirements 

are different under this circumstance.

ACB also includes information about Providers who take care of Members’ 

children and then request payment for their service. An individual who applies for 

or becomes a Provider provides their name, business name and type, email address, 

current mailing address, address where care is provided, phone and fax number, 

Tax ID or Social Security Number (SSN), any relationship between the child and 

Provider, W-9 tax form, bank account information (e.g., name of bank and account 

number), cost of care, and money earned. Licensed Providers must also provide a 

State Child Care License while unlicensed Providers must also provide a copy of a 

current driver’s license or valid state ID and signed Social Security Card.

When organizations apply or become a Provider, all the above information is about 

the organization. At most, an organization may name an employee and provide 
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their business contact information. GAP uses this information to establish that the

Provider is qualified, confirm what care they provided, pay for their services, and

report the total payment amounts to the Internal Revenue Service (IRS) at the end

of the year

The exact information collected by GAP is documented in the forms located at: 

https://americorpschildcare.com/index.cfm?tab2

9- COLLECTIONS OF PII INTO THE SYSTEM

9-1 Describe for each source of PII in the system:

1- The source.

2- What PII comes from that source.

3- How the PII enters the system.

GAP staff use the My AmeriCorps Member Support Portal (part of the Electronic 

System for Programs, Agreements & National Service Participants or eSPAN) to 

verify that each applicant is eligible for childcare and to find their NSPID number 

and copy it into ACB.

All other PII in ACB comes from Members and Providers. They can type and 

upload information directly into ACB, or send documents to GAP to upload into 

ACB. As part of the overall Child Care Benefits Program, there is a helpdesk that 

will address questions and help facilitate the entry of data if Members or Providers 

are having difficulty updating/entering their information.

9-2 If any PII comes directly from the individual, describe the privacy controls in 

place. If all PII comes from a secondary source, write Not Applicable.

Members receive a Privacy Act Statement (PAS) at or before they provide PII 

collected into ACB. The PAS is located on the contact, login, and registration page 

of americorpschildcare.com, individuals must see one of these pages before they 

can access the parts of the website that collect their PII. The PAS is also included 

on all the forms that collect information from Members. In addition, the 

AmeriCorps Child Care Program Fact Sheet lists the childcare eligibility 

requirements, which explains why PII is requested beyond just contact and 

membership information.

The collection of PII into ACB is secured via a secure website directly into the 

database. The applicant also has the option to use a secure HIPPA compliant fax 

number through eFax or an encrypted email, then the information is manually 

entered into the application by the AmeriCorps Gap representative.

The website includes a PAS located at: 

https://americorpschildcare.com/index.cfm?tab7. The login page for the website 

invites all individuals to review that PAS before logging in.
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9-3 If PII about an individual comes from a source other than the individual, 

describe:

a. Why the PII is collected from the secondary source.

b. Why the PII from the secondary source is sufficiently accurate.

c. If/how the individual is aware that the secondary source will provide their 

PII.

If all PII about an individual comes directly from the individual, write Not 

Applicable.

My AmeriCorps Member Support Portal is part of the AmeriCorps system that 

tracks all Member information by using NSPID number. The essential PII in the 

system should be accurate so that the tracking processes can proceed further.

Members may provide information about their supervisor, their spouse, their 

children, and other persons in their household. This information is directly related 

to the childcare benefits that the Member applies and should be accurate so that the 

processing of benefits application can be done smoothly. GAP may require 

additional documentation such as a tax return when the information is key to a

decision such as childcare eligibility.

When an organization Providers designates an employee to complete the 

documents, the employee may provide business contact information of another 

employee and this information should be accurate so that the payments can be 

processed properly. These individuals should be aware that they represent the 

company, and their name and business contact information will be 

shared accordingly.

9-4 If any collections of PII into the system are subject to the Paperwork Reduction 

Act (PRA), identify the Office of Management and Budget (OMB) Control 

Number for the collection. If the system does not implicate the PRA, write Not 

Applicable.

The OMB Control Number is 3045–0142, its expiration date is 03/31/2025.

9-5 If any collections of PII into the system are subject to an agreement, describe 

those agreements. If no agreements are relevant, write Not Applicable.

Not Applicable; ACB does not link to any other systems.

10- SYSTEM ACCESS

10-1 Separately describe each category of individuals who can access the system along 

with:

a. What PII they can access (all or what subset).

b. Why they need that level of access.

c. How they would request and receive that access.
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d. How their access is reduced or eliminated when no longer necessary.

ACB is supported by a team of GAP employees and contractors providing differing 

roles within the environment. The level and type of access is based on the role of 

the user and all users comply with the CNCS rules of privacy. For example:

• the Project Manager, Lead Child Care Coordinator, and two Child Care 

Coordinators have read/write access to ACB and program documents that 

include PII

• the IT Administrator has read/write access to all ACB system and 

application data to include PII

• the System Security Officer/System Privacy Officer and developer do not 

have access to the ACB production system or any PII about Members or 

Providers (i.e., no access to PII).

GAP manages all user accounts through the ACB Change Configuration Control 

Policy and Procedure. All access requests must be reviewed and approved by the 

ACB Change Control Board (CCB) before they are made by the IT Administrator. 

When anyone leaves the project, the notification is submitted and tracked via the 

CCB process, the account is disabled on the off-boarding date, and all IT 

equipment which may contain PII is collected. The full suite of policies and 

procedures are reviewed, approved, and maintained by the AmeriCorps

Cybersecurity Team. 

AmeriCorps staff do not have direct access to ACB.

11- PII SHARING

11-1 Separately describe each entity that receives PII from the system and:

a. What PII is shared.

b. Why PII is shared.

c. How the PII is shared (what means/medium).

d. The privacy controls to protect the PII while in transit.

e. The privacy controls to protect the PII once received.

f. Any agreements controlling that PII.

If PII is not shared outside the system, write Not Applicable.

Each year, GAP sends to the IRS the name of each Provider, their Tax ID or SSN, 

and the amount GAP paid them that year. The IRS uses this information to confirm 

that the Provider paid taxes on those earnings.

GAP may share PII from ACB with the AmeriCorps staff who are responsible for 

overseeing the childcare program. When the contract with GAP ends, those 

AmeriCorps staff will receive all information stored in ACB. This information is 

provided to AmeriCorps via a secure connection. 
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12- PRIVACY ACT REQUIREMENTS

12-1 If the system creates one or more systems of records under the Privacy Act of 

1974:

a. Describe the retrieval that creates each system of records.

b. State which authorities authorize each system of records.

c. State which system of records notices (SORN) applies to each system of 

records.

If the system does not create a system of records, write Not Applicable.

The Childcare Coordinators and Managers search for Members using the

names and email addresses of the Members.

The legal authorities authorizing this system of records include:

• The National and Community Service Act of 1990 as amended (42 USC 

12501 et seq.)

• The Domestic Volunteer Service Act of 1973 as amended (42 USC 4950 et 

seq.)

• E.O. 9397 as amended - Numbering System for Federal Accounts Relating 

to Individual Persons

Childcare benefits may not exceed applicable payment rates as established in the 

state in which the childcare is provided under the Child Care and Development 

Block Grant Act of 1990 (42 U.S.C. 9858c(4)(A)).

The SORN that applies to the records in ACB is CNCS-06-CPO-ACB -

AmeriCorps Child Care Benefit System (ACB). A Privacy Act Statement, 

developed from the SORN, is provided to Members when they provide information 

captured in ACB:

Authorities – This information is requested pursuant to the National and 

Community Service Act of 1990 as amended (42 USC 12501 et seq.), the 

Domestic Volunteer Service Act of 1973 as amended (42 USC 4950 et seq.), 

and E.O. 9397 as amended. 

Purposes – It is requested to manage, administer, and evaluate the 

childcare benefits program offered to eligible AmeriCorps Service 

Members. 

Routine Uses – Routine uses of this information may include disclosure to 

(1) contractors to assist with administering the childcare benefit, (2) 

individuals and organizations providing childcare, and (3) federal, state, or 

local agencies pursuant to lawfully authorized requests. 

Effects of Nondisclosure – This request is voluntary, but not providing the 

information will likely affect your ability to receive childcare benefits.
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13- SAFEGUARDS

13-1 Describe the technical, physical, and administrative safeguards that protect the 

PII in the system.

The ACB system is safeguarded by multiple layers of controls to ensure the 

security and confidentiality of the PII collected through ACB. GAP Solutions 

follows AmeriCorps Childcare Benefits Policies, Procedures and authorization and 

issues GAP policies and procedures accordingly to ensure its employees receive 

required trainings and sign-off on the Rules of Behavior before they are authorized 

to access and perform works on ACB. From controls implemented via the 

FeRAMP Authorized Infrastructure as a Service (IaaS) to the GAP headquarter 

where the program is administered, all data is stored on hardened servers that are 

scanned and patched to ensure maintenance and implementation of all security and 

privacy controls. In addition, all access to ACB and the associated PII is via 

encrypted tunnels that use AES-256 encryption and enforce mandatory access 

control (MAC). All computers used in the operation of ACB have full disk 

encryption implemented. Notices are also posted on the ACB website advising the

individuals to securely upload their application documents and encrypt their emails. 

ACB performs logging at multiple layers; the logs identify all sources, destination 

IP addresses, and ports used. The system also performs system level logging that 

captures the user and computer name along with details of the event. These logs are 

monitored by the GAP ACB IT Support team and action is taken as appropriate.

No PII from ACB is permitted to be saved to removable media. Attendance sheets 

that include the name and age of the child are printed and stored in a controlled 

facility that only the authorized GAP personnel have access to. Roles that have 

oversight and responsibility to ensure the proper use of the PII within the ACB 

program and system are assigned, which include the Child Care Coordinators who

are responsible for the daily operations of the ACB program and system and 

safeguarding PII throughout the process, the Child Care Program Manager who is

responsible for the oversight of the Child Care Coordinators, and the Information 

System Security Officer/System Privacy Officer who is responsible for the overall 

program and system handling of PII data. All these individuals must sign an 

AmeriCorps Privileged User Rules of Behavior and receive privacy and security 

training annually which is documented as a performance metric monitored by 

AmeriCorps to ensure adequate information security and privacy compliance 

posture, 

14- DATA ACCURACY, ACCESS, AMENDMENT, AND CONTROL

14-1 Describe the steps taken to ensure PII is sufficiently accurate, relevant, current, 

and complete.

All PII within the system is current. Childcare Coordinators work with Members 

and Providers daily, to update and/or correct information in the 
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system as part of the application submission, evaluation, and maintenance 

processes based on paper records (W-2, Tax Records, etc.) which are all also stored

in electronic format at the Secured Data Center. This ensures the PII is accurate, 

and complete. ACB only collects PII that is relevant and required for processing the 

Childcare benefits.

All Members and Providers must reapply every year if they want to participate in 

the program, which provides an opportunity for them to update any outdated 

information.

14-2 Describe how an individual could view, correct, update, or ask to amend their PII.

Members and Providers can update their PII at any time; the helpdesk will address 

questions and/or help/facilitate the entry of data if the Members or Providers are 

having difficulty updating/entering their information through the website.

GAP provides each Provider an IRS 1099 tax form which shows what GAP 

reported to the IRS about that Provider. The providers can correct, update or ask to 

amend the information they provide if they find any discrepancy. 

14-3 Describe how an individual could control what PII about themselves is included in 

the system or how it is used. Also describe how those decisions could affect the 

individual.

Members and Providers do not have the option to provide only some of the PII or 

limit usage of their PII once included in the system. If they do not provide 

necessary information, then their application to receive or provide childcare cannot

be reviewed and is closed.

15- DATA RETENTION AND DESTRUCTION

15-1 Identify the National Archives and Records Administration (NARA) provided 

retention schedule for the system and provide a summary of that schedule.

Due to the business needs, AmeriCorps is working to assign retention schedules to 

the records in ACB system. These details have yet to be determined.

16- SOCIAL SECURITY NUMBERS (SSNs)

16-1 If the system collects truncated or full social security numbers (SSNs):

a. Explain why the SSNs are required.

b. Provide the legal authority for the usage of the SSNs.

c. Describe any plans to reduce the number of SSNs.

If the system does not collect any part of an SSN, write Not Applicable.

The IRS requires GAP to collect and provide the Tax ID associated with every 

Provider who receives payment. Some Providers use their SSN as their Tax ID. 
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The documents which may be collected from Members, their spouses, and 

individuals within their household to confirm a member’s eligibility may also 

include SSNs (e.g., tax documents and business documents). The official 

documents such as the IRS tax forms and instructions appropriately provide

Privacy Act Notice of its PII collection and handling activities. 

AmeriCorps only collects and uses SSN for the purposes as identified above. 

AmeriCorps creates alternative members ID to be used in daily operations.

17- WEBSITES

17-1 If the system includes a website which is available to individuals apart from 

AmeriCorps personnel and contractors, discuss how it meets all AmeriCorps and 

Federal privacy requirements. If the system does not include a website, write Not 

Applicable.

The ACB website uses what is known as a Java session cookie. This session cookie 

is only valid while the session is valid and only contains the Java session identifier 

and no other information. It does not use any cookies that stores anything about

AmeriCorps program, data, logic, or otherwise beyond the session cookie.

The website includes a privacy statement located at: 

https://americorpschildcare.com/index.cfm?tab7. A link is in the footer of every 

page of the website.

18- OTHER PRIVACY RISKS

18-1 Discuss any other system privacy risks or write Not Applicable.

Not Applicable