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AmeriCorps

Privacy Impact Assessment (PIA)

1- GENERAL SYSTEM INFORMATION

1-1

Name of the information technology (IT)

system:

The Electronic-System for Programs, 

Agreements and National Service 

Participants

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

1-3 Unique Investment Identifier (Exhibit 53): 485-000000004

1-4 Office or entity that owns the system: Office of Information Technology

1-5 Office or entity that manages the system: Office of Information Technology

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:

July 2022

1-9

Approximate number of individuals with 

personally identifiable information (PII)

in the system:

eSPAN contains information on over 2 

million individuals.

3- SIGNATURES (ORIGINAL MAINTAINED BY CHIEF PRIVACY OFFICER)

Role *Signature* *Date*

3-1 Information System Owner:

Signatures on file with Privacy Office

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/ 800-942-267

202-606-5000/ 800-942-2677

20525

202-606-5000/ 800-942-2677

treet S250 E Street SW
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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 an existing system with a prior 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.

The system was upgraded to Oracle19c since the last PIA was signed on June 2, 

2016.

5- SYSTEM PURPOSE

5-1 Describe the purpose of the system.

The Electronic-System for Programs, Agreements and National Service 

Participants (eSPAN) application system is a set of modules built on the Oracle 

database management system developed and maintained by AmeriCorps. The

primary purpose of eSPAN is to process, maintain, transit, manage and report on 

the information that AmeriCorps collects from its grantees and members, its

institution users, and the general public to support its member functions (i.e., 

recruit, apply, serve, payment, award, cost share) and grant functions (i.e., apply,

review, award, administer, reporting, evaluation, close out).

eSPAN uses and stores information about the current and former AmeriCorps 

Service Members (Members), the public individuals who apply to become 

Members (Applicants) or peer reviewers (Peer Reviewer), the organizations that 

receive Members from AmeriCorps (Project Sponsors) and the associated 

Memorandum of Agreements, and the organizations that receive financial resources 

from AmeriCorps (Grantees) and the associated grants (Grants).

Specifically, eSPAN is comprised of a centralized database and seven modules that 

interact with different section of the database designed to serve various member 

and grant management functions. These modules include Members Portal and 

eGrants Phase 2/Grantee Portal which are public-facing, AmeriCorps Staff Portal, 

eGrants Classic, eSPAN, Indicium, and the Data Warehouse which are used 

internally by AmeriCorps staff members. 

The Member Portal is a publicly available module where:

o Individuals of the public (Applicants) apply to serve and become 

members of an AmeriCorps program.

o Members obtain their tax information, manage their Segal 

AmeriCorps Education Awards (Education Awards), and complete 

other functions related to their service
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o Personal and professional references (References) complete a form 

about Applicants

o Staff working for institutions eligible to receive payment from a

Member’s Education Award (Educational and Lending Institutions) 

input the information that AmeriCorps needs to pay their Institution.

• eGrants Phase 2/Grantee Portal is a publicly available module where:

o Staff working for prospective and current Project Sponsors and 

Grantees (1) apply for Grants, and manage and provide status 

reports on their Grants and (2) apply for grants, recruit, manage, and 

provide status reports on their Members

o Individuals review application forms from prospective Project 

Sponsors and Grantees (Peer Reviewer) and apply for positions

o Peer Reviewers complete their employment profiles and submit their 

reviews

o AmeriCorps employees and contractors (AmeriCorps staff) review 

application forms from prospective and current Project Sponsors and 

Grantees and help them troubleshoot the Portal.

• The AmeriCorps Staff Portal is an internal module where:

o AmeriCorps staff view Applicant and Member information and 

manage their designated functions

o AmeriCorps’ Office of the National Service Trust (Trust) staff 

manage and pay Education Awards.

• eGrants Classic is an internal module where AmeriCorps staff review and 

select applications from prospective Project Sponsors and Grantees, manage 

current Project Sponsors and Grantees, and select and manage Peer 

Reviewers.

• eSPAN module is an internal module where AmeriCorps staff complete a 

range of functions which cannot be completed in the other modules. For 

example, AmeriCorps staff use this module to process Members’ living 

allowance, calculate tax withholdings, and create tax documents.

• Indicium is an internal module where AmeriCorps staff store a broad range 

of documents about Applicants, Members, Project Sponsors, and Grantees 

that is not collected in the other modules.

• The Data Warehouse is an internal module that AmeriCorps staff use to 

analyze the data in eSPAN. It contains a copy of everything in the other 

modules and some additional non-PII information such as maps of 

congressional districts.

6- INVENTORY OF PII

6-1 Provide a list of all the PII included in the system.
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The list of PII in eSPAN include username, name, email addresses (personal and 

work), mailing addresses (e.g., home, work, permanent, temporary), phone numbers 

(personal and work), social security number (SSN), passport number, demographics 

(e.g., gender, race, ethnicity, marital status), birth date and birth location, bank 

account number, National Service Participation ID number (NSPID), license plate 

number, driver’s license number, insurance policy number, employer, and job title. 

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.

eSPAN currently maintains PII about individuals of the following groups: 

• Applicants and Members, currently around 1.2 million and that number 

may increase by approximately 80,000 individuals each year

• Emergency contacts, one or more for each Member

• References for each VISTA and NCCC Applicant, two for each Applicant

• Death beneficiary for each VISTA and NCCC Member, one for each 

Member

• Individuals who worked for a prospective, current, or former Project 

Sponsor or Grantee, approximately 20,000 in total

• Current and former Peer Reviewers, approximately 8,000 in total

• Individuals who applied to become a Peer Reviewer and were not selected, 

approximately 9,500 in total

• Individuals who work for an Educational or Lending Institution, 

approximately 24,500 in total

Although eSPAN maintains PII about staff working for Grantees who requested or 

received a Senior Corps Grant, it does not maintain PII about individuals who 

served in Senior Corps.

8- INFORMATION IN THE SYSTEM

8-1 For each category of individuals discussed above:

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

• Give specific details about any PII that is collected.

• Describe how the information is used.

eSPAN’s modules collect and use different sets of information for different 

functions.

Member Portal Main Page

https://my.americorps.gov
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Member Portal Profile Creation -

https://my.americorps.gov/mp/recruit/registration.do

Applicants and Members use the Member Portal to manage their own information

and complete functions related to their service. NCCC and VISTA Applicants and 

Members generally submit more information into the Member Portal because 

AmeriCorps has a greater role in managing their services.

For these individuals who want to become a VISTA or NCCC Member, they first 

access the Member Portal to make application. They complete an application form

that requests their name, email, phone number, current and permanent mailing 

address, SSN, gender, birth date and location, citizenship, highest level of 

education and school, military status of self and family, status of registration to 

vote, known languages and proficiency, skills, and status of ownership of driver’s 

license. Each page of the application form includes an Office of Management and 

Budget (OMB) Control Number in the footer (3045-0054). A note under the 

gender question states that information is used to assure AmeriCorps provides 

opportunities to all groups, is only used for data analysis and is kept confidential. 

Those who complete the application form receive an email with a link to the page 

where they can create their Member Portal username and password.

Other individuals access the Member Portal after they become Member and intend 

to have account in the Member Portal. They are required to complete a form that 

requests their name, date of birth (DOB), SSN, and email address. If that 

information matches their record in eSPAN, the Portal creates their account and 

sends them an email with instructions on how to set their username and password.

Interested Applicants may use the Member Portal to search and apply for VISTA

and NCCC opportunities. The VISTA and NCCC application forms are slightly 

different, but both collect from an Applicant a motivational statement, the 

information about the Applicant’s skills, community service experiences, race, 

ethnicity, and References (name, email, title, employer, address, and phone 

number), the Applicant’s educational history and employment history 

(organization, location, dates, supervisor’s name and contact information, title, 

duties, and reason for leaving, and a reason for employment or educational gaps 

longer than six months), the Applicant’s current certifications and their expiration 

dates, and any information about adult or juvenile criminal offenses excluding 

speeding or parking tickets (date, place, charge, actions, court/probation/parole 

officer, and phone number) that the Applicant might have committed. All the pages 

of the application form (AmeriCorps Member Application, Enrollment, and Exit 

Form) include an OMB Control Number in the footer (3045-0054). Additional 

notices about the information being requested are also specifically provided in three 

pages of these forms:

• The page with questions about the Applicant’s criminal history explains 

why AmeriCorps conducts a criminal background check.
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• The page with questions about the Applicant’s race and other demographic 

information explains that the information is only used for data analysis to 

assure AmeriCorps provides opportunities to all groups and would be kept 

confidential.

• The page with questions about the Applicant’s References explains that the 

References will be contacted via email.

When an application form is submitted, the following functions may occur:

• The Member Portal automatically emails the References a link to the 

reference form in the Member Portal. It instructs each Reference to confirm 

their information and their relationship to the Applicant, and provide 

information about the Applicant’s work performance and emotional 

maturity and their recommendation if the Applicant shall serve with

AmeriCorps. Each Reference selects whether the Applicant may see their 

responses. The Reference is not provided a username, so the information

must be provided in one online session.

• The Member Portal automatically sends the Applicant’s name and SSN to 

the Social Security Administration (SSA) to confirm that the Applicant

meets the citizenship requirement. This process is further explained in the 

associated Computer Matching Agreement (CMA) between AmeriCorps 

and SSA. If the automatic process is unsuccessful, AmeriCorps may 

instruct the Applicant to provide their social security card or other

documents to verify their citizenship.

• AmeriCorps staff may, depending on the program, manually check if the 

Applicant is listed on the Department of Justice Dru Sjodin National Sex 

Offender Public Website. AmeriCorps staff use eSPAN to record only the 

information of whether the Applicant has a criminal sex offense record or 

not.

• AmeriCorps staff may, depending on the program, manually check if the 

Applicant has a criminal record in an FBI database. If so, AmeriCorps staff

evaluate the gravity of the criminal offense. If AmeriCorps decides the 

Applicant is still eligible to serve, an AmeriCorps staff member documents

the justification in a form which is stored in eSPAN, which is not provided 

to the Applicant.

Members may complete additional functions in the Member Portal depending on 

their status and branch of service (NCCC, VISTA, and State & National (S&N)), 

including

(1) . These Thcompleting a form if the Member drives a vehicle that is involved 

in an automobile accident, with information about the vehicle insurance 

carrier and coverage, vehicle information and license plate number, and the 

purpose of travel.
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(2) submitting travel request forms which may request Member’s emergency 

contact’s name and phone number, information of Member’s special needs 

(e.g., vegetarian, smoker, translations), and the purpose of travel.

(3) completing the VISTA Future Plans Form with a description of Member’s 

duties and accomplishments, and the rating of work by the Member’s

supervisor.

(4) completing an exit form with information about the Member’s disabilities 

status, special needs, etc.

(5) completing a comprehensive Member Exit Survey just before or after the 

Member’s service exit to answer survey questions about the Member’s 

service experience and its benefit to the growth of the Member, and the

Member’s future plan. The contents of the answers might be shared with a 

very limited number of AmeriCorps staff and vendors to research and 

evaluate the AmeriCorps programs.

Staff working for the Educational and Lending Institutions also use the Member 

Portal. After they provide their name and business contact information and 

AmeriCorps verifies that they do work for the Institution, the staff member can 

login to provide the information their Institutions needs to receive an Education 

Award and see what Education Awards have been sent to their Institution.

eGrants Phase 2/Grantee Portal

For these prospective Project Sponsors and Grantees that want to become Project 

Sponsor and/or Grantee (see https://www.nationalservice.gov/build-your-capacity

on how to become a Project Sponsor and/or Grantee) and the current Project 

Sponsors and Grantees, their Staff need to obtain eGrants Phase 2/Grantee Portal 

accounts to request and manage their AmeriCorps application. To register, the staff

must first of all provide an email, a phone number, an username and password, and 

their organization’s contact information and agree to the eGrants Rules of Behavior

which states that they will securely handle and appropriately use the information in 

eGrants Phase 2/Grantee Portal.

To become Project Sponsor and/or Grantee, the staff account holders submit SF424 Family application form to the portal on behalf of their organization. The PII

collected in the portal is limited to the staff contact information and the resumes for 

the project/grant. Once an application to become a Project Sponsor and/or Grantee

is selected or declined, AmeriCorps would notify the applicants. The application

form which includes the names of some staff of the applicant would become public. 

AmeriCorps announces decision on each application through a Notice of Federal 

Funding Opportunity. The notice includes a section entitled Transparency in 

Grantmaking which explains what information becomes public after the 

competition ends.
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Staff working for Project Sponsors and Grantees use the eGrants Phase 2/Grantee 

Portal to manage and submit reports, receive messages from AmeriCorps staff, and 

request modifications to their agreement with AmeriCorps. Some staff working for 

each Projects Sponsor also use the portal, to create service listings for their 

organization which generally include a staff member’s name and contact 

information, to search and view a limited profile of Applicants who have not 

applied to their program and send an invitation to apply (Applicants use the 

Member Portal to select whether Project Sponsors may view their limited profile)

to the Applicants, to view application forms and decide which Applicants should 

receive a slot, and to transfer Members between programs and assign job 

descriptions.

Project Sponsors also use the Portal to view, create, and update the profile of 

Member. S&N Members apply directly to the organization where they want to 

serve through the organization’s own hiring process. If selected, the Member or the 

Project Sponsor add to the profile of the Member the same PII that eSPAN would 

collect from a VISTA or NCCC Applicant.

The VISTA Member screens are somewhat different from the S&N screens 

because AmeriCorps’ role in Member management is different. For example, only

Project Sponsors requesting a VISTA Member must complete an evaluation of the 

Members they want to hire. The evaluation covers the Member’s strengths and 

weaknesses, the type of supervision the Member needs, and a rating of the 

Member’s potential success as a VISTA Member.

Other individuals access and apply through eGrants Phase 2/Grantee Portal to

become a Peer Reviewer. The application form requests their name, address, email

address, phone number, DOB, optional ethnicity and race information, need for 

special accommodations, education and job history, and a record of publications.

Individuals selected to become Peer Reviewers use eGrants Phase 2/Grantee Portal

to access and work on the Project Sponsor and Grantee application forms assigned 

to them for evaluation, and to provide their bank account information and SSNs to 

receive payment for the work assignment.

AmeriCorps Staff Portal:

The AmeriCorps Staff Portal is an AmeriCorps staff-only module that centers 

around Member management and processing Education Awards. For example, 

depending on their level of access, AmeriCorps staff may be able to:

• View and modify the information that Applicants and Members entered 

through the public-facing Portals and elsewhere

• Upload documents about Applicants and Members (e.g., oath of office, 

emergency contacts, drivers’ license, citizenship confirmation, criminal 

history checks, leave requests, disciplinary issues, and health assessments)
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• Review application forms and select who should become VISTA and 

NCCC Members

• Manage requests from Members to receive and spend their Education 

Awards, resolve payment concerns, pay for travel and training, and transfer 

to a different project

• Send messages to Project Sponsors, Grantees, and Members (they cannot 

respond through eSPAN module) and

• Create a broad range of reports about the Applicants and Members (e.g., 

which Members lists what skills, demographics, and disabilities in order to 

determine if AmeriCorps’s outreach activities are successful).

eGrants Classic:

eGrants Classic is an AmeriCorps staff-only module that centers around selecting 

and managing Project Sponsors, Grantees, and Peer Reviewers. For example, 

depending on their level of access, AmeriCorps staff may be able to:

• Create and manage user accounts for all eSPAN modules

• View application forms from Project Sponsors and Grantees 

• Select and manage Project Sponsors and Grantees

• Review application forms from Peer Reviewers, assign them to a panel, and 

receive their comments

• Access and modify the information needed to pay the Peer Reviewers

• View and document whether using a prospective or current Project Sponsor

or Grantee raises any major concerns (e.g., ongoing Office of Inspector 

General audit) and the remediation strategy. This information does not 

generally include PII unless someone lost the right to contract with the 

Federal government.

eSPAN

eSPAN is an AmeriCorps staff-only module used for a range of functions not built 

into the other modules. For example, depending on their level of access, 

AmeriCorps staff may be able to:

• View all information found in the modules listed above

• Fix data discrepancies and override limits in the other modules

• Complete most functions related to the Education Awards (e.g., list who 

received an Education Award or has an Education Award about to expire, 

record what Educational and Lending Institution should receive what funds, 

approve extension requests, track the amount of each Education Award)

• Create a broad range of reports.

Indicium

AmeriCorps staff use this module to capture a broad range of files needed to 

manage Applicants, Members, Project Sponsors, and Grantees. For example:
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• When an Applicant’s citizenship is not automatically confirmed through the 

CMA with SSA, AmeriCorps staff use this module to store copies of the 

documents needed to verify citizenship (e.g., SSN card, birth certificate, 

passport, legal permanent resident card).

• The Trust uses this module to capture the documents needed to justify 

paying an Education Award (e.g., proof that the Member attended the 

school, the cost of attendance, where the payment should be sent).

• The information written on paper forms used years ago when Member was 

in service would be uploaded into this module

The Data Warehouse

This database contains a duplicate of the information in eSPAN and some publicly

available information like congressional and school districts. AmeriCorps staff use 

it for a broad range of data analysis activities like budget forecasting and 

determining the effectiveness of a program.

9- COLLECTIONS OF PII INTO THE SYSTEM

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

• The source.

• What PII comes from that source.

• How the PII enters the system.

The sources of the PII in eSPAN includes Individuals, Members, Applicants, 

Project Sponsors, Grantees, Peer Reviewers, staffs of both AmeriCorps and the 

Project Sponsors/Grantees, References and the third parties.

The name, email, phone number, current and permanent mailing address, SSN, 

gender, birth date and location, citizenship, driver’s license information, vehicle 

information, criminal history, performance rating and other personal information of 

the Individual, Applicant and Member necessary for AmeriCorps to use to evaluate

applications in line with all compliance requirements and make payment for 

Member and Peer Review service are collected directly from these individuals

through eSPAN public web page. The name and business contact information of 

the staff are collected directly from these staff members which is necessary for 

account registration and management. The name and contact information of the 

references and emergency contact are collected directly from the Members or 

Individuals via eSPAN for reference checking or emergency contact purpose. The

name, address, email address, phone number, DOB, voluntary ethnicity and race

information, and special accommodation information of the Peer Reviewer are 

collected directly from the Peer Reviewer candidates via eSPAN which are 

essential for AmeriCorps to use to evaluate their candidacy. The reference

comment on the Applicants is collected from the Reference as a 3

rd party. 

AmeriCorps staff also manually check if the Applicant is listed on the 3

rd party 
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website - Department of Justice Dru Sjodin National Sex Offender Public Website or has 

a criminal record in a third-party database - FBI database, then document the results

in eSPAN system. The information collected from the third-party sources are used 

to evaluate the overall suitability for the AmeriCorps’ service positions.

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.

The eSPAN webpages available to the public include a link in the footer labeled

Privacy which direct the user to AmeriCorps privacy webpages where they are

informed of AmeriCorps’s privacy policy and AmeriCorps’ privacy program, the 

AmeriCorps System of Records Notices including SORN CNCS-04-CPO-MMFMember Management Files (MMF) that covers eSPAN system, the AmeriCorps 

eSPAN PIA which provides sufficient details of the collection, use, maintain, 

disclosures and disposal of PII in eSPAN, and the information about how the PII 

and data privacy rights of the individuals are protected. AmeriCorps signed CMA 

with SSA to ensure all the exchanges of data including PII with SSA strictly follow 

established protocol and are in compliance with all the applicable regulations and 

laws. 

The eSPAN webpages available to the public also include a link in the footer 

labeled Contact Us which direct the user to the National Service Hotline (NSH) 

Contact Us Page. It instructs the individuals how to request information about any

aspect of eSPAN via phone, live chat, or a messaging service.

The eSPAN webpages that collect PII from the individual generally (1) indicate 

that the collection is voluntary, (2) explain the general purpose of the collection, (2)

state what PII should be provided, (4) generally provides a separate text box for 

each item of PII, and (5) transmit the PII via a secure internet connection.

The eSPAN webpages that collect PII from Applicants and Members cannot be 

accessed unless the individual confirms and acknowledges the Privacy Act 

Statement first. When the demographic information is requested, a notice would 

pop up which explains the reason for the collection and assures the information 

would remain confidential and be used solely for data analysis. When eSPAN

instructs Applicants to provide information about their criminal history, a notice

would pop up to explain that AmeriCorps will complete a criminal background 

check, the opportunities of the Applicants may be limited if they have a criminal

record, and not providing their criminal history may impact whether they are 

selected to serve. Members who complete the Member Exit Survey are informed

that their responses will remain private to the extent permitted by law. The eSPAN

webpage that collects responses from References displays a Privacy Act Statement. 

References are provided the option to decide if they want the Applicant to see their 

responses or not. The eSPAN webpage that requests Peer Reviewers to provide 

their ethnicity or race information also explains that their responses are not 
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mandatory. The Notice of Federal Funding Opportunity that AmeriCorps publishes 

has a section titled Transparency in Grantmaking which explains what PII from

each application form will be made public after the competition ends.

AmeriCorps also put in place a series of administrative, technical and physical 

measures to safeguard eSPAN and the PII, more information in this regard is 

provided in the following sections. 

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.

Most of the PII in eSPAN is collected directly from the individuals, but there are 

situations where eSPAN reasonably collects PII from another party. AmeriCorps

notifies the individuals when these collections could negatively affect them. For 

example:

• eSPAN collects PII from third parties to confirm that Applicants do not 

have a criminal or sex offender record that renders them ineligible to serve. 

This is reasonable because Applicants (1) may not fully disclose something 

that could compromise their application and (2) are informed this will be 

collected into eSPAN and used to assess their application.

• eSPAN collects References’ assessment of Applicants and Project 

Sponsors’ assessment of their Members. This is reasonable because (1)

AmeriCorps is seeking a third-party perspective and (2) Applicants and 

Members are informed that this PII will be collected into eSPAN and used 

to assess their application form or performance.

• eSPAN requests that Members provide emergency contact information and 

does not confirm that PII with the emergency contact. This is reasonable 

because it is about someone who should be close to the Member, the PII is 

limited to contact information, and the Member may correct the information

at any time via eSPAN.

• When Project Sponsors enter PII on behalf of their Members, the Members

have access to update that PII as needed.

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 front page of the Members Portal and eGrants Phase 2/Grantee Portal display 

OMB Control Number 3045-0187 and the expiry date.
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Several forms in eSPAN displays an OMB Control Number, but are not required to 

show an expiration date:

• The Member Application, Enrollment and Exit Form with OMB Control 

Number 3045-0054

• The Member Exit Survey with OMB Control Number 3045-0094

The Project Sponsor and/or Grantee application form in the eGrants Phase 

2/Grantee Portal does not display an OMB Control Number because that is 

included in the instructions document, the staff receives the form and instruction 

then enter information into the Portal accordingly.

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.

Before eSPAN connects to other systems to receive PII about the public, 

AmeriCorps executes an agreement describing what PII will be received and how it 

will be protected. Currently there are agreements with:

• AmeriCorps’ financial management system (Momentum) to receive PII

from eSPAN to process payments and send eSPAN a confirmation notice

and

• SSA so AmeriCorps can automatically send PII about Applicants to SSA

and receive confirmation of their citizenship (see associated CMA).

10- SYSTEM ACCESS

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

with:

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

• Why they need that level of access.

• How they would request and receive that access.

• How their access is reduced or eliminated when no longer necessary.

Approximately 350 AmeriCorps staff have authorized access to all the eSPAN 

modules, but their access to the specific screens and PII within those eSPAN 

modules depends on their role and authorized rights. A very limited number of 

users have authorized access to see full SSNs and even fewer users have authorized 

access to see personal information such as health information, disability 

information, or the Member Exit Survey results. To request eSPAN access, a

supervisor or contract representative submits a request explaining the business 

needs for the user’s access, then the eSPAN administrator would select and grant

an appropriate level of access. There are quarterly audits when those supervisors

and contract representatives must confirm that the staff member still needs that 

level of access. When AmeriCorps staff separate from AmeriCorps, they lose all 

access to eSPAN.
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A staff member may set up an eGrants Phase 2/Grantee Portal account on behalf of 

their organization and apply to become a Project Sponsor or Grantee. If the 

application is approved by AmeriCorps, the staff becomes the account 

administrator for the Project Sponsor or Grantee organization and has 

administrator’s right to control who may access information about their 

organization or access PII about their Applicants/Members and what PII can be 

assessed, and remove an use’s access if the user separates from the organization.

Anyone may use the eGrants Phase 2/Grantee Portal to apply to become a Peer 

Reviewer and input their payment information if selected. They may then access 

and update their PII retained in eSPAN. They may only access an application form

from a potential Project Sponsor or Grantee if AmeriCorps staff assign them to 

review it.

Applicants and Members who create an account in the Member Portal may later 

access the Member Portal and view some of the PII eSPAN retains on them.

However, they cannot access the documents they provided containing PII.

Staff working for Educational and Lending Institutions may create an account in 

the Member Portal and later access that account to view all the PII eSPAN retains 

on them.

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.

eSPAN shares PII with the following other systems:

• Momentum: eSPAN collects information about several activities that 

should result in payment (e.g., who was a NCCC Member during a 

particular pay period, who should be reimbursed for work-related travel) 

along with the banking information needed to provide the payment. eSPAN 

sends these PII to a second AmeriCorps system called Momentum which 

manages the payments and then sends eSPAN a confirmation notice. There 

is an Interconnection Service Agreement (ISA) and Memorandum of 

Understanding (MOU) in place between eSPAN and Momentum.

• SSA: When an Applicant applies for service, a Member is transferred to a 
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new program, or a Member reenrolls in a different project, AmeriCorps

needs to confirm that the Applicant/Member meets the citizenship 

requirement. To do that, eSPAN sends the Applicant/Member’s SSN, 

name, and DOB to SSA and receives the citizenship information in return. 

This process is covered by a CMA, ISA, and MOU with SSA.

• AmeriCorps Health Benefits System (AHB): All VISTA and NCCC

Members may enroll in a health benefits plan that reimburses some of 

their health care costs. AHB tracks and manages the PII needed to 

provide this benefit. Every workday, eSPAN sends AHB an encrypted 

file containing each VISTA and NCCC Member’s name, DOB, gender, 

payment address, current address, permanent address, phone numbers, 

start and end date of service, member type and role, and NSPID. AHB 

uses these PII to confirm that the Member is eligible and establish initial 

contact. The vendor operating AHB has a contract with AmeriCorps

which includes privacy and security provisions consistent with 

AmeriCorps’ respective internal requirements.

• U.S. Department of Treasury: Once the Trust confirms that a former 

Member’s request to spend their Education Award is accurate and meets 

all requirements, the payment information is sent from eSPAN to Treasury 

via a vendor’s secure server; the file includes each Educational and 

Lending Institutions’ contact information, amount to be paid, name of the 

Member, and their SSN. Similarly, once eSPAN compiles the monthly 

allowance for each VISTA and NCCC Member, the payment information

is sent from eSPAN to Treasury via a vendor’s secure server within the 

boundary of Momentum; the file includes the Member’s name, NSPID, 

amount to be paid, address, and bank account information. The privacy 

and security provisions consistent with AmeriCorps’ respective internal

requirements are included in the contracts with vendors.

• Mail Vendor: eSPAN sends Education Award letters, Education Award

extensions, tax documents, and other Member documents to a vendor who 

mails them to Members. The privacy and security provisions consistent 

with AmeriCorps’ respective internal requirements are included in the 

contracts with vendors.

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.
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eSPAN operates under the following legal authorities:

• Domestic Volunteer Service Act, as amended 2009

• National and Community Service Act, as amended 2009

• Serve America Act (Pub. L. No.111-13)

• National and Community Service Trust Act of 1993 

• Budget and Accounting Procedures Act of 1950, as amended

• Accounting Procedures Act of 1950, as amended

• Chief Financial Officer Act of 1990

• Debt Collection Improvement Act of 1996

• Privacy Act of 1974, as amended by the Computer Matching and Privacy 

Protection Act of 1988

Information on Applicants and Members may be searched by NSPID, name, DOB, 

SSN, email address, phone numbers, and addresses.

Applicants, Members, and References are provided the following Privacy Act 

Statement before eSPAN requests their PII.

13- SAFEGUARDS

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

PII in the system.

AmeriCorps’ administrative policies and procedures, technical controls, and 

physical controls help ensure the PII in eSPAN is safeguarded adequately and

handled appropriately. 

To ensure eSPAN is appropriately managed, AmeriCorps developed several written 

procedures and processes, which include a process to approve and document all 

configuration changes, a breach response plan, and processes for user access 

managements per least privilege and need-to-know principles subject to regular 

auditing. All AmeriCorps employees with authorized access are required to receive 

annual security and privacy training and sign the AmeriCorps Cybersecurity Rules 

of Behavior with instructions about how to properly handle PII. All AmeriCorps

contractors have security and privacy provisions in their contracts and each 

contractor employee are required to sign the AmeriCorps Cybersecurity Rules of 

Behavior.

AmeriCorps developed and follows a privacy policy that governs all aspects of 

AmeriCorps’ privacy practices and PII handling processes, and a cybersecurity 

policy that governs all of AmeriCorps’ electronic information. The specific 

safeguard controls implemented include but are not limited to, that all access to 

eSPAN is encrypted using Transport Layer Security and removable media (e.g., 

tape backups) are encrypted using FIPS 140-2 compliance standards, all electronic 

media used to store PII in eSPAN is properly erased before it is decommissioned, 
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the PII about actual individuals is never used to test the system, and each year

eSPAN undergoes a SA&A by an independent third party. eSPAN also creates a 

broad range of audit logs that capture the time, date, and username of everyone who 

changes one’s system access, accesses eSPAN, or creates or modifies a record. 

Those audit logs are closely monitored, and unauthorized activity is referred to the 

appropriate official for action. Any PII captured in the audit logs is used solely for 

information security management purpose. Meanwhile, all the safeguards of the 

hosting environment of eSPAN also apply to eSPAN, with reinforced assurance.

14- DATA ACCURACY, ACCESS, AMENDMENT, AND CONTROL

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

and complete.

The steps taken to assure PII in eSPAN is sufficiently accurate, relevant, current, 

and complete are based on the needs of the function requiring that PII.

AmeriCorps has different responsibilities when managing NCCC, VISTA, and 

S&N Applicants and Members, and designed eSPAN to only collect the PII

necessary for those responsibilities. For example, eSPAN does not automatically

collect banking details from S&N Members because AmeriCorps does not process 

their living allowance.

eSPAN collects some PII directly from the individual through webpages. These 

webpages generally (1) request for each item of PII in a separate question, (2)

provide a separate text box to receive each item of PII, and (3) warn or stop users if 

the response is in an unlikely format (e.g., flagging a blank textbox or a phone 

number that is less than ten digits). The NSH is available to help anyone with

questions about how to correctly enter their PII.

eSPAN is designed in a way that more sensitive decisions involving an individual 

would require additional levels of approval, which lowers the chance of a mistake. 

For example, removing a Member from service may require one user to document 

the removal in eSPAN and a second user to approve that removal.

The accuracy and timeliness of PII in eSPAN primarily depends on whether 

individuals provide accurate information and update it as needed. The response to 

question 14-2 below discusses how individuals may provide and update most part 

of their PII.

The IT security controls discussed above also help ensure that PII is protected from 

malicious or accidental changes.

14-2 Describe how an individual could view, correct, update, or ask to amend their PII.
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AmeriCorps works to inform all individuals how they may access PII about 

themselves if their PII are maintained within eSPAN:

• eSPAN and some of AmeriCorps’ other websites have notices about the 

NSH; the NHS can explain what PII about an individual may be in eSPAN,

if/how they may navigate to it, and if/how they may update it.

• The bottom of each form includes a link to AmeriCorps’ privacy webpage; 

that webpage lists a point of contact who will respond to privacy concerns 

raised by the individual. 

• The SORN CNCS-04-CPO-MMF-Member Management Files (MMF)

(Federal Register :: Privacy Act of 1974; System of Records) provides 

notice to the public about the records maintained and processed in eSPAN.

Two of eSPAN’s modules give individuals the ability to access and update their 

own PII if the PII are maintained within eSPAN:

• Applicants and Members may access their PII via the Member Portal.

• Staff working for Educational and Lending Institutions may access their PII

via the Member Portal.

• Staff working for Project Sponsors and Grantees may access their PII via 

the eGrants Phase 2/Grantee Portal.

• Prospective and current Peer Reviewers may access their PII via the eGrants 

Phase 2/Grantee Portal.

There are some limitations such as:

• Individuals must contact AmeriCorps staff to request paper forms with their 

PII which were scanned and saved in Indicium (this module is not 

connected to the Member Portal)

• Individuals who apply to AmeriCorps for any reason may not be able to 

change their PII after the application deadline and

• Members with criminal records are not given access to the form that 

AmeriCorps staff completed with justification of the Members’ eligibility.

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.

eSPAN has the feature that enables the users to control what PII about themselves

should be included in eSPAN or how it is used, depends on the purpose for 

collection. When eSPAN requests PII from the individuals, they can usually 

decline to provide it, but that choice may affect their ability to receive payment, 

become a Member, or enjoy another benefit.

There are some situations where individuals are given some control over how their 

PII is used or accessed, Applicants decide if they want Project Sponsors to access

part of their application form before they apply to that service listing.
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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.

The current record retention and disposition schedule numbers for records of 

National Service Trust are:

• DAA-0362-2018-0003-0001. The final deposition is temporary. The time of

cutoff is at the end of fiscal year the voucher was processed. The records 

will be destroyed 12 years after cutoff.

• DAA-0362-2018-0003-0002. The final deposition is temporary. The time of 

cutoff is at the end of fiscal year the form was processed. The records will 

be destroyed 12 years after cutoff.

• DAA-0362-2018-0003-0003. The final deposition is temporary. The time of

cutoff is at the end of fiscal year the form was adjudicated. The records will 

be destroyed 12 years after cutoff.

• DAA-0362-2018-0003-0004. The final deposition is temporary. The time of 

cutoff is at the end of fiscal year the form was received. The records will be 

destroyed four years after cutoff.

• DAA-0362-2018-0003-0005. The final deposition is temporary. The time of 

cutoff is at the end of fiscal year the extension request was adjudicated. The 

records will be destroyed four years after cutoff.

• DAA-0362-2018-0003-0006. The final deposition is temporary. The time of 

cutoff is at the end of fiscal year the award was transferred. The records will 

be destroyed four years after cutoff.

• DAA-0362-2018-0003-0007. The final deposition is temporary. The time of 

cutoff is at the end of fiscal year from the date the member earns their

education award. The records will be destroyed four years after cutoff.

• DAA-0362-2018-0003-0008. The final deposition is temporary. The time of 

cutoff is at the end of fiscal year from the date the reissue is processed. The 

records will be destroyed four years after cutoff.

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

other records in eSPAN system. Currently, most records in eSPAN system are

maintained for an indefinite period of time.

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.
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SSNs are collected only when it is legally required from

• Applicants to confirm their citizenship since that is an AmeriCorps 

eligibility requirement

• Members if they receive a payment that must be reported to the Internal 

Revenue Service and

• Peer Reviewers to send a record of their payments to the Internal Revenue 

Service

Depending on the user’s authorized level of access, eSPAN displays either the full 

SSN, or only the first 5 digits, or none of it.

Authorities for these functions include the National and Community Service Act of 

1990 as amended (42 U.S.C. 12501 et seq.) and the Domestic Volunteer Service 

Act of 1973 as amended (42 U.S.C. 4950 et seq.)

Members are provided the following Privacy Act Notice before the Member Portal

requests their SSN:

This page of the form requests your SSN to (a) confirm your citizenship status for 

eligibility purposes and/or (b) send you a payment that must also be reported to the 

Internal Revenue Service using your SSN. This request is voluntary, but not 

providing your SSN may affect your ability to become a Member and/or receive 

payments. It is requested pursuant to 42 U.S.C. Chapter 129 - National and 

Community Service, 42 U.S.C. Chapter 66 - Domestic Volunteer Services, and 

Executive Order 9397, as amended.

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

reduce the number of SSN, 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 eSPAN modules accessed by the public are the Member Portal and eGrants

Phase 2/Grantee Portal.

Neither of those modules utilize persistent cookies or similar tracking mechanisms.

The Member Portal has a link in the footer of every webpage labeled Privacy which 

sends the user to https://www.nationalservice.gov/privacy; that webpage includes 

AmeriCorps’ privacy policy and an email address where individuals can inquire
21

about the privacy ramifications of eSPAN. The main page also includes the 

following statement:

This is a United States Government computer system. This computer system, 

including all related equipment, networks, software, and data, is provided 

only for authorized U.S. government use. Unauthorized use of this system is 

strictly prohibited and may be subject to criminal prosecution. AmeriCorps

may monitor or audit any activity or communication on the system and 

retrieve any information stored within the system. By accessing and using 

this computer, you are consenting to such monitoring and information

retrieval for law enforcement and other purposes. Unauthorized use or 

policy infractions should be reported to AmeriCorps.

The eGrants Phase 2/Grantee Portal has the link to 

https://www.nationalservice.gov/privacy. The main page also includes the 

statement:

AmeriCorps actively monitors this system and software activity to maintain 

system security, availability, and to ensure appropriate and legitimate 

usage. Any individual who intentionally accesses a Federal computer or 

system without authorization, and who alters, damages, makes unauthorized 

modifications to, or destroys information in any Federal interest computer, 

or exceeds authorized access, is in violation of the Computer Fraud and 

Abuse Act of 1986 (Public Law 99-474). Any evidence of possible violations 

of proper use or applicable laws found as a result of this monitoring may be 

turned over to Corporation Management and law enforcement. Any 

individual found to be in violation of the system proper use rules or law 

could be punished with loss of system access, fines and imprisonment. By 

proceeding, you hereby acknowledge your agreement with these terms and 

the system's rules of behavior and consent to such monitoring and 

informational retrieval for law enforcement and other official purposes.

Apart from links that go to other Federal agency websites, individuals who click a 

link from an AmeriCorps website to a non-Federal agency owned website would 

see the following notice:

The website you are about to visit is not part of the AmeriCorps domain and 

may or may not be under AmeriCorps' management or control, and its 

privacy and security practices and policies may differ from AmeriCorps. 

AmeriCorps is not responsible for the link nor does it endorse the content of 

the third-party website (Read more).

Click here or on the Continue button to proceed to the external website, 

otherwise click cancel to stay on NationalService.gov.

18- OTHER PRIVACY RISKS

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

Not applicable.