Version: 1.4

Date: March 4, 2020

Prepared for: USDA OCIO-Policy, 

E-Government and Fair Information 

Practices (PE&F)

Policy, E-Government and Fair Information Practices

Privacy Impact Assessment 

Template
Privacy Impact Assessment – Guidance and Template

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Privacy Impact Assessment for the

NCAH on Azure Platform (NAP)

March 2020

Contact Point 

Robert Hazen

APHIS Marketing and Regulatory Programs (MRP)

United States Department of Agriculture

(515) 337-6329

Reviewing Official 

Tonya Woods

Director, Freedom of Information and Privacy Act Staff

United States Department of Agriculture

(301) 851-2487
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Abstract 

The purpose of the NCAH on APHIS Platform (NAP) system security plan is to assess and 

authorize all of the National Centers for Animal Health (NCAH) mission capabilities residing 

on the Animal and Plant Health Inspection Service (APHIS) Enterprise Infrastructure (AEI) 

general support system (GSS). The NCAH is located in Ames, IA and Plum Island, NY.

NAP supports the following mission capabilities:

The NCAH Quality Management (NQM) system is owned the by Animal and Plant Health 

Inspection Service (APHIS), Veterinary Service (VS), Science Technology and Analysis 

Services (STAS), National Veterinary Services Laboratories (NVSL). NQM is a quality 

management system (QMS) that provides a software suite of compliance focused tools that 

supports the NVSL requirement to maintain compliance to applicable regulations and 

standards. This Privacy Impact Assessment (PIA) is being conducted as part of maintenance, 

assessment, and authorization.

The Warehouse, Inventory Management and Procurement System (WIMPS) is an enterpriselevel electronic information management system managing two warehouses in Veterinary 

Services (VS). These warehouses store routine office supplies and consumables used by 

investigative, scientific and support staff conducting research, investigative activities, animal 

disease and biologic testing. The users of this system rely heavily on having a quick response 

when disease outbreaks are observed. This information system allows VS to: 

• Receive packages 

• Report costs 

• Maintain and rotate inventory 

• Shipping supplies for diagnostic testing of animal disease, animal health emergencies and 

routine livestock surveillance. 

• Ship veterinary supplies necessary for animal health to stakeholders inside and external to 

USDA 

This privacy impact assessment is being conducted to assess the storage of PII for stakeholders 

external to the USDA who contribute to the nation-wide animal health programs.

Overview 

NCAH Quality Management (NQM) supports the regulatory compliance needs of the APHIS 

Veterinary Services (VS) Science Technology and Analysis Services (STAS), National Veterinary 

Services Laboratories (NVSL) and its scientific laboratory activities. NQM is an industry leading 

quality management system (QMS) that provides a software suite of compliance focused tools. As a 

web based (internal facing) and paperless system NQM supports the NVSL requirement to maintain 

compliance to applicable regulations and standards.

The NQM provides automated, streamlined management of:

• Product and compliance documents control • Product customer complaints

• Process change control • Process corrective and preventive action (CAPA)
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• Training (non-AgLearn based) • Other quality management business processes

• Audits

Information in the system includes procedures, standard operating procedures (SOPs), policies, work 

instructions (WI), references, manuals, and forms. NQM is used to ensure the most current version of 

a document is used for internal work processes, from scientific laboratory procedures to administrative 

procedures. Procedural training records, technical corrective actions, and auditing information will be 

stored in NQM. Additionally, the NQM is to ensure the compliant operation, maintenance, and repair 

of NVSL owned laboratory equipment with the purpose of maintaining the Laboratories' certificates. 

This includes tracking the training accomplishments of NVSL, which are needed to operate the NVSL 

owned laboratory equipment, laboratory processes and administrative processes.

Information is manually share from VS Laboratory Information Management System (VS LIMS) 

when a customer complaint potentially identifies a technical process in need of corrective or 

preventative action. The VS LIMS information will include PII on the animal owner or private citizen 

acting in a complimentary role to the owner. 

Corrective and preventative action (CAPA) is the only portion of NQM that contains PII.

The NQM is a child of NCAH Azure Platform (NAP) and categorized as a “Moderate” system.

The Warehouse, Inventory Management and Procurement System (WIMPS) is an enterpriselevel electronic information management system managing two warehouses in Veterinary 

Services (VS). These warehouses store routine office supplies and consumables used by 

investigative, scientific and support staff conducting research, investigative activities, animal 

disease and biologic testing. The users of this system rely heavily on having a quick response 

when disease outbreaks are observed. Additionally, the facilities store routine office supplies and

consumables. 

The information system stores information necessary to identify items, identify the package 

recipient inside of USDA, and non-USDA employee ship-to information. Ship-to information is 

shared with UPS and FedEx to deliver vaccines and other animal health emergency supplies. 

During a typical transaction, office or laboratory supplies are order from the supplier and received 

at the warehouse to be transferred to the final recipient. The entire lifecycle is support to ensure 

the paper and printer ink are received by the office worker, and that gloves, solvents and pipettes 

are received by the laboratory worker. The second typical transaction is when USDA identifies 

and ships to suitable recipients supplies for diagnostic testing of animal disease, animal health 

emergencies, and routine livestock surveillance. Recipients are both USDA and external to 

USDA. Ship-to information is share with FedEx and UPS to successfully deliver the USDA 

supplies. 

WIMPS is operated under the authority of Homeland Security Presidential Directive 9 and Animal 

Health Protection Act.

Section 1.0 Characterization of the Information 
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The following questions are intended to define the scope of the information requested and/or 

collected as well as reasons for its collection as part of the program, system, rule, or technology 

being developed. 

1.1 What information is collected, used, disseminated, or maintained in 

the system? 

NCAH Quality Management:

Information maintained includes laboratory and administrative documents, 

procedures, policies, instructions, references, manuals, forms, audits, calibration 

results, and reports. Specific information about individuals may include:

Diagnostic sample information

• Wildlife/ Zoo/ owner

• If owner then:

o Owner Name

o Owner City

o Owner State

o Owner Zip

o Owner Country

• Location of Animal

• Total Numbers of Animals

• Herd or Flock size

• Herd or Flock affected

• Herd or Flock Dead

• Date collected

• Collected by 

• Authorized by

• Preservation

• Purpose

• Country origin

• Country destination 

• FAD Number

• Referral Number

• National Poultry Improvement plan 

(Y/N)

• Specimen

• Species

• O-Group

• Serotype

• Culture Number

• Clinical Role

• Contract number

• Comments

Slaughtering Establishment Information:

• Establishment ID 

• Establishment Name

• Establishment Address

• Establishment City

• Establishment State

• Establishment Zip

• Establishment Country

• Establishment email

• Establishment Fax

• Establishment Phone
Tuberculosis Sample Information: 

• Food Inspector Name

• Veterinarian Name

• Market Buyer Name

• Market Buyer Address 

• Market Buyer City

• Market Buyer State

• Market Buyer Zip

• Market Buyer Country

• Lot number

• Number in Lot

• Number with Lesions

• Slaughter Date

• Dressed Weight

• Live Weight

• Post Mortem Report

• Tissue

• Condition

Diagnostic testing (animal) information

• Tests requested

• Disease

• Concentration

• Sex

• Sample ID

• Animal ID

• Age

• Age Unit

• Age Classification

USDA Government Employee:

• Employee Name

• Employee Business E-mail

• Employee Organizational Group

• Employee’s Supervisor

Employee information is maintained to determine current contact information as well 

as access requirements. A history of this information is maintained via the COTS 

Master Control audits. Employee information contained in the database is only jobrelated (e.g. name, position, job email).

WIMPS:

This information system maintains the following information: 

• Shipping Address 

• Contact Name 

• Contact Phone Number 

• Contact e-mail 

• Order Information 

• Premises Identification Number 

• USDA Employee Name 

• USDA Phone Number 

• USDA e-mail 

• USDA Component, Agency, & Office 

• Ship-to-USDA Address 

• USDA Employee Signature 

• USDA Employee’s Supervisor 

• USDA Employee’s Supervisor USDA e-mail
1.2 What are the sources of the information in the system? 

NVSL sources of information in the NQM include:

Laboratory and administrative documents, standard operating procedures (SOPs), 

policies, work instructions (WI), references, manuals, forms, laboratory audits 

(internal audits of laboratory activities, administrative procedures, calibration), and 

corrective action & preventive action (CAPA) reports.

NVSL Employee information is provided by the individual’s supervisor, APHIS 513 

form, internal APHIS organizational charts, and LDAP account creation 

documentation.

PII collected in VS LIMS can be moved to NQM when a complaint is submitted and 

follows the CAPA process. NVSL employees manually upload or manually enter 

information from VS LIMS to NQM may include information from State and private 

veterinary diagnostic laboratories, private veterinary practitioners, Federal meat 

inspectors, Federal field veterinarians, and others. In addition, VS LIMS information 

includes laboratory samples from other countries for import cases and for cases where 

diagnostic assistance is requested.

The sources of information in the WIMPS include:

• USDA employee 

• USDA supervisor 

• USDA active directory 

• USDA/APHIS District office directors

1.3 Why is the information being collected, used, disseminated, or 

maintained? 

NCAH Quality Management:

The information is maintained in NQM to maintain compliance with the Laboratories’ 

accreditation. Collecting the information listed in Sections 1.1 and 1.2 of this 

document helps automate, streamline, and manage the following under a single web 

based platform: 

• document control

• document change control

• training control (non-Aglearn related training certificates)

• audits (internal audits of laboratory activities, administrative procedures, 

calibration, management systems compliance)

• CAPA (Corrective Action & Preventive Action)

• other quality management business processes
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Laboratory and administrative documents, SOP, policies, WI, references, manuals, 

forms, laboratory audits, and CAPA are maintained through subsequent revisions for 

the benefit of document owners and knowledge retention.

Non-PII animal or sample information is disseminated to DHS, DHS contractors, 

State, university, international, or other collaborating laboratories consistent with the 

support of safeguarding animal health.

Any information, to include PII, may be included in the artifacts submitted to the 

accreditation bodies in order to continue the government’s accreditation of NVSL.

Information may also be disseminated in response to a Freedom of Information Act 

(FOIA) request.

WIMPS:

The information is being maintained in WIMPS to ensure the successfully receipt and 

delivery of packages, and to track the funding for those packages.

1.4 How is the information collected? 

NQM:

Employee information is provided by the individual’s supervisor, APHIS 513 form, 

internal APHIS organizational charts, and LDAP account creation documentation. 

Information as described in Sections 1.1 and 1.2 is APHIS employee generated/created 

within the NQM application. The Sample, Establishment, and Testing information 

listed in Section 1.1 is collected from VS LIMS when a customer submits a complaint 

to the NVSL.

WIMPS:

USDA employee information is collected from the supervisor, USDA active directory.

Non-USDA ship-to information is collected from the APHIS District offices.

1.5 How will the information be checked for accuracy? 

NQM:

Employee information is validated by the individual’s supervisor through the use of an 

APHIS 513 form, digitized in the User Management System (UMS).

Information as described in Sections 1.1 and 1.2 is checked for accuracy via peer 

review (subject matter experts), quality and document managers, and the employee’s 

supervisor. After the employee’s supervisor approves the document, the document is 

then sent to the appropriate Program quality manager for final review/authorization.

WIMPS:

USDA information is validated by the supervisor and through periodic review of the 

USDA active directory. Non-USDA ship-to information is validated by the APHIS 

District offices.
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1.6 What specific legal authorities, arrangements, and/or agreements 

defined the collection of information? 

Specific legal authorities for both NQM and WIMPS include:

NVS was established under the authority of the Homeland Security Presidential Directive 

9 (HSPD-9) which established the NVS in 2004. 

CVB enforces the Virus-Serum –Toxin Act (21 USC §151-159 et.seq.) 

NVSL provides testing under: 9 CFR 53 (Foot-And-Mouth Disease, Pleuropneumonia, 

Rinderpest, and Certain other communicable Diseases of Livestock or Poultry); 9 CFR 56 

(Control of H5/H7 Low Pathogenic Avian Influenza); 9 CFR 82 (Exotic Newcastle 

Diseases and Chlamydiosis) and 9 CFR 94 (Rinderpest, Foot-and-Mouth Disease, Exotic 

Newcastle Disease, African Swine Fever, Classical Swine Fever, Swine Vesicular 

Disease, and Bovine Spongiform Encephalopathy: prohibited and restricted importations) 

Under the authority of the Animal Health Protection Act (7 USC Chapter 109), Animal 

Welfare Act (7 USC 54), Homeland Security Presidential Directives (HSPD) 5 

(Management of Domestic Incidents); HSPD 7 (Critical Infrastructure Identification, 

Prioritization, and Protection); HSPD 8 (National Preparedness); HSPD 9 (Defense of 

United States Agriculture and Food) & HSPD 12 (Policies for a common Identification 

Standard for Federal Employees and Contractors) 

NADC (ARS) as authority under: 

The Organic Act of 1862 (7 U.S.C. 2201 note), Agricultural Research Act of 1935 (7 U.S.C. 

427), Research and Marketing Act of 1946 (Pub. L. 79-733), as amended (7 U.S.C. 427, 

1621 note), Food and Agriculture Act of 1977 (Pub. L. 95- 113), as amended (7 U.S.C. 1281 

note), Food Security Act of 1985 (Pub. L. 99-198) (7 U.S.C. 3101 note), Food, Agriculture, 

Conservation, and Trade Act of 1990 (Pub. L. 101-624) (7 U.S.C. 1421 note), Federal 

Agriculture Improvement and Reform Act of 1996 (Pub. L. 104-127), Agricultural 

Research, Extension, and Education Reform Act of 1998 (Pub. L. 105-185), and Farm 

Security and Rural Investment Act of 2002 (Pub.L. 107-171).

1.7 Privacy Impact Analysis: Given the amount and type of data 

collected, discuss the privacy risks identified and how they were 

mitigated. 

Unauthorized access to this data is the privacy risk. This is mitigated by using capabilities 

common to USDA and the commercial products used. This includes: 

• System access control by USDA domain credentials 

• User based role access

• Separation of duties 

• Limiting web access 

• Audit logging 
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Improper disclosure of privacy data is mitigated through approved system access that 

is limited to NVSL Quality Assurance employees. User access is requested, reviewed, 

and documented on APHIS form 513. User access is recertified annually. Access is 

limited to USDA employees, and contractor access is not provided.

Section 2.0 Uses of the Information 

The following questions are intended to delineate clearly the use of information and the 

accuracy of the data being used. 

2.1 Describe all the uses of information. 

National Centers for Animal Health (NCAH) on Azure Platform (NAP) is a moderate 

system and contains NQM and WIMPS.

NQM:

information is used to maintain compliance with ISO accreditation. Additionally, the 

information is used to help automate, streamline and manage the following under a 

single web based platform:

• document control, change control

• training control (non-Aglearn related training certificates)

• audits (internal audits of laboratory activities, administrative procedures, 

calibration, management systems compliance)

• CAPA (Corrective Action & Preventive Action)

• customer complaints

• other quality management business processes

The PII maintained in the system is used to correct processes and prevent future 

actions that may be the root cause of future complaints.

WIMPS:

Information is used by APHIS VS to order, track, ship, and manage warehouse inventory 

distribution to both USDA and non-USDA customers.

2.2 What types of tools are used to analyze data and what type of data 

may be produced? 

NQM:

NQM commercial off the shelf (COTS) software Master Control contains pre-defined 

and customized reports. The data contained in the reports is used to automate and 

streamline document and change control. This includes (but is not limited to): 
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outstanding training, ownership of documents, documents assigned to 

individuals/groups, pending CAPA reports/review, etc.

WIMPS:

Contained within the WIMPS, the Integrated Sales Analysis Tool (Business Intelligence 

module) integrates IBM Cognos to generate reports from the data contained in the system. 

Reporting consists of cost and logistical data for supplies of high volume biologic testing. 

Other reports can be created to determine usage metrics for users, storage information, 

processing, historical order information, and inventory preparation based on previous 

needs.

2.3 If the system uses commercial or publicly available data please 

explain why and how it is used. 

NQM:

The system uses publicly available ISO accreditation requirements (to maintain ISO 

accreditation), A2LA (an accrediting body with additional requirements that is used 

for clarification/guidance of ISO requirements), equipment manuals and vendor 

websites (for instrumentation), and also scientific journal articles for scientific test 

validation.

WIMPS:

The WIMPS does not use commercial or publicly available data.

2.4 Privacy Impact Analysis: Describe any types of controls that may be 

in place to ensure that information is handled in accordance with the 

above described uses. 

Privacy rights of the customer and employees will be protected by USDA APHIS VS 

STAS NVSL management. NQM COTS Master Control also has security controls to 

address access to and security of information.

• Access to the data in the system is controlled and documented by formal 

authorization

• All access to the system is limited by account identification and password

• Users have formal training in how to use the system

• Users have formal training on how to properly manage PII

• A warning banner must be acknowledged at login

Section 3.0 Retention 

The following questions are intended to outline how long information will be retained after the 

initial collection. 
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3.1 How long is information retained? 

NQM:

Paper records are retained indefinitely for COOP purposes. Electronic data is 

maintained varies based on the information source and guiding directive (ISO, 

Federal, USDA Policy, etc).

WIMPS:

Electronic information is maintained for 25 years. The data is archived at 5 years intervals.

3.2 Has the retention period been approved by the component records 

officer and the National Archives and Records Administration 

(NARA)? 

No. Data retention periods have been submitted and aware awaiting final approval by 

NARA. NQM and WIMPS have separate scheduled submitted.

3.3 Privacy Impact Analysis: Please discuss the risks associated with the 

length of time data is retained and how those risks are mitigated. 

Risks associated with data retention are minimal and include the possibility of the data 

being accessed by unauthorized personnel. NQM uses role based access to mitigate 

this risk. The Login interface reminds users of their responsibility every time they log 

in. In addition, given the length of time data is retained in the information system 

(WIMPS specifically), unauthorized access to this data is the privacy risk. This is 

mitigated by using capabilities common to USDA and the commercial products used. 

This includes: 

• System access control by USDA domain credentials 

• User based role access 

• Separation of duties 

• Limiting web access 

• Audit logging

Section 4.0 Internal Sharing and Disclosure 

The following questions are intended to define the scope of sharing within the United States 

Department of Agriculture.

4.1 With which internal organization(s) is the information shared, what 

information is shared and for what purpose? 

NQM:

Information is shared with USDA ARS employees. Agricultural Research Service 

(ARS) employees can login to NQM but cannot access PII. PII data extractions are 

not shared with ARS employees.
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Animal procedures, work instructions, and forms are shared with USDA ARS 

employees located at the USDA NCAH in Ames, IA. Information is also shared with 

USDA ARS employees co-located with NVSL at the Foreign Animal Disease 

Diagnostic Laboratory (FADDL) in Plum Island, NY. PII contained within NQM is 

not accessible by USDA ARS employees and this is enforced by their user role. 

WIMPS:

No information is shared internally. The system is used by APHIS and ARS to conduct 

business. ARS and APHIS employees have access and access controls are in place.

4.2 How is the information transmitted or disclosed? 

NQM:

Requested information or forms are sent in hard-copy or digital format via e-mail. 

ARS employees can alternatively login to NQM based on their need but cannot access 

PII.

WIMPS:

No data is transmitted or disclosed. 

4.3 Privacy Impact Analysis: Considering the extent of internal 

information sharing, discuss the privacy risks associated with the 

sharing and how they were mitigated. 

Privacy rights of the NQM customer and employees will be protected by USDA 

APHIS VS STAS NVSL management. Target systems also have security controls to 

address access to and security of information.

• All information sharing with internal systems is done manually over the internal 

APHIS network. (VS LIMS data is manually added to NQM.)

• Access to the data in the systems (NQM and USDA email) is controlled and 

documented by formal authorization

• All access to the system is limited by account identification and eAuthentication. 

The eAuthentication makes uses of Personal Identification Verification (PIV) 

cards using associated certificates.

• Users have formal training in how to use the system

• A warning banner must be acknowledged at login

Section 5.0 External Sharing and Disclosure 

The following questions are intended to define the content, scope, and authority for information 

sharing external to USDA which includes Federal, state and local government, and the private sector. 
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5.1 With which external organization(s) is the information shared, what 

information is shared, and for what purpose? 

NQM:

Information is shared with the following external entities. When information is shared 

that contains PII, the PII shared is listed in Section 1.1:

• Contractor or DHS employees located at PIADC (Plum Island Animal Disease 

Center) in Plum Island, NY. This group does not have access to QM and does 

not receive PII data extractions.

• Contracted vendors for ISO accreditation and registration. Information shared 

includes SOPs, work instructions, CAPAs, etc. for the purpose of ISO 

accreditation. This group does not have access to NQM. Artifacts used to 

document accreditation related to customer complaints may contain PII data 

extractions.

• State and international laboratories, universities, and other entities for 

collaborative purposes and cooperative agreements. This group does not have 

access to NQM and does not receive PII data extractions.

• International entities to establish testing capacity in other countries. This enables 

consistent processes/procedures to support the mission of safeguarding animal 

health. This group does not have access to NQM and does not receive PII data 

extractions.

WIMPS:

Information is shared with FedEx and UPS. Name, address, and phone number is shared. 

This information is shared for package delivery to the ship-to address.

5.2 Is the sharing of personally identifiable information outside the 

Department compatible with the original collection? If so, is it 

covered by an appropriate routine use in a SORN? If so, please 

describe. If not, please describe under what legal mechanism the 

program or system is allowed to share the personally identifiable 

information outside of USDA. 

NQM:

The PII information shared outside of the Department is compatible with the original 

collection. The PII accompanies the customer’s complaint with the intent of resolving 

the issue and avoid reoccurring issues for the customer. The NVSL quality manager's

validate this outcome; the ISO accreditation organization ensures NCAH are following 

the procedures we have set forth to maintain accreditation. This organization is named 

contracted activity cleared for access to USDA data and are bound by a confidentiality 

agreement.
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Department contractors who are vendor employees can be provided access to NQM for 

troubleshooting purposes and maintenance. This vendor is named contracted activity 

cleared for access to USDA data and are bound by a confidentiality agreement.

APHIS SORN 19 is being updated to clearly make notification of the movement of PII 

from VS LIMS to NQM as described in this assessment.

WIMPS:

The sharing of information is compatible with the reason it was collected. Animal owners 

and others share this information in order to receive no-cost animal disease and biologic 

testing material. These animal owners and others rely heavily on having a quick response 

when disease outbreaks are observed.

5.3 How is the information shared outside the Department and what 

security measures safeguard its transmission? 

NQM:

The contracted vendors for ISO accreditation and registration described in Section 5.1 

must pass through NCAH campus’ physical security, are covered by a non-disclosure 

agreement, and are only provided escorted access to view records potentially 

containing PII. Vendor specific technical support may potentially view records 

containing PII during the investigation of a technical incident or software defect. 

Vendor technical support is covered by a non-disclosure agreement and secure email is 

used to transmit information and communicate back and forth in order to resolve the 

technical issue.

WIMPS:

The information is printed on the outside of each box. The information is transmitted to 

FedEx or UPS when the package pick-up is requested.

5.4 Privacy Impact Analysis: Given the external sharing, explain the 

privacy risks identified and describe how they were mitigated. 

NQM:

Uses of information are in accordance with the stated purpose and use of the original 

collection of a customer complaint by VS LIMS. The privacy risks are limited to the 

minority of customer complaints that originate from an incident in VS LIMS and also 

contain PII. The other uses of information listed in Section 1.3 do not contain PII. The 

privacy risk is the mishandling of PII in customer complaints. To mitigate this access 

to NQM must be explicitly authorized and the application is protected by the following 

measures:

• All access to the system is limited by username and password.

• Application limits access to relevant information by assigned application 

functions to roles. Additionally, NQM has areas within the application (called 

“vaults”) where specific documents, information, and processes can be 
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controlled at a user-specific level. This prevents access to unauthorized 

information.

• Access to NQM is internal to USDA APHIS staff.

• The USDA warning banner must be acknowledged at application login.

WIMPS:

The information is printed on the outside of each box. The information is transmitted to 

FedEx or UPS when the package pick-up is requested. This shared information must be 

provided to successfully deliver the animal disease and biologic testing material. This 

cannot be mitigated.

Section 6.0 Notice 

The following questions are directed at notice to the individual of the scope of information collected, 

the right to consent to uses of said information, and the right to decline to provide information. 

6.1 Does this system require a SORN and if so, please provide SORN 

name and URL.

NQM:

Yes. APHIS SORN-19. https://www.ocio.usda.gov/sites/default/files/APHIS-19.txt.

Updates to the SORN are being processed, found under POAM 30015, under CSAM 

ID 2464 (VS LIMS).

WIMPS:

Yes, NAP POA&M 29876 has been created to document this deficiency.

6.2 Was notice provided to the individual prior to collection of 

information? 

NQM:

Yes. The information shared from VS LIMS was included in SORN APHIS-19 

Laboratory Information Management System, 

https://www.federalregister.gov/articles/2013/10/01/2013-23868/privacy-act-systemsof-records-labware-laboratory-information-management-system

WIMPS:

A SORN will be developed and published and a Privacy Notice will be created.

6.3 Do individuals have the opportunity and/or right to decline to provide 

information? 

NQM:

No, individuals external to NVSL that submit samples to be tested at the laboratory 

must submit all data required by VS LIMS to assign appropriate test and report results. 

Individuals are not compelled to submit samples to the laboratory, however if an 
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individual does choose to submit samples, required information to include personal 

information must be included. Individuals do not have the opportunity to decline to 

have their information shared outside of VS LIMS should their submitted information 

be moved to a complaint in NQM.

WIMPS:

No. If individuals do not provide the information then they will not receive the supplies 

requested.

6.4 Do individuals have the right to consent to particular uses of the 

information? If so, how does the individual exercise the right? 

NQM:

No, the NQM submitters’ data are treated uniformly. Only information that is cleared 

through the Freedom of Information Act is available for use.

WIMPS:

No. The information is used for only one purpose within the WIMPS

6.5 Privacy Impact Analysis: Describe how notice is provided to 

individuals, and how the risks associated with individuals being 

unaware of the collection are mitigated. 

NQM:

Information is not collected with NQM. Data are collected using VS LIMS with the 

individual’s knowledge, and data are voluntarily submitted to the laboratory along 

with test samples.

WIMPS:

At this time a SORN is pending for the WIMPS. Once the SORN is published a Privacy 

Notice will be created.

Section 7.0 Access, Redress and Correction 

The following questions are directed at an individual’s ability to ensure the accuracy of the 

information collected about them. 

7.1 What are the procedures that allow individuals to gain access to their 

information? 

Any individual may obtain information from a record in the system that pertains to 

him or her. All inquiries should be addressed in one of the following manners:

VIA MAIL:

Animal and Plant Health Inspection Service

Director, Freedom of Information and Privacy Act Staff
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4700 River Road, Unit 50

Riverdale, MD 20737

VIA FACSIMILE: 301-734-5941

VIA E-MAIL: foia.officer@aphis.usda.gov

(NOTE: While e-mail attachments are often an important and legitimate means of 

conducting business, they also have the potential to cause great harm to our e-mail 

infrastructure, as well as to individual workstations. Please place the text of your 

FOIA request into the 'body' of the email message.)

VIA Web Request Form: Located at the following link 

https://www.aphis.usda.gov/aphis/resources/foia/ct_how_to_submit_a_foia_request

7.2 What are the procedures for correcting inaccurate or erroneous 

information? 

NQM:

If an employee discovers inaccurate information in NQM, they can contact the NVSL 

Quality Management (QM) unit.

WIMPS:

Persons listed as the ship-to address can correct their information any time through the 

USDA District Office.

7.3 How are individuals notified of the procedures for correcting their 

information? 

All USDA employees are notified of the procedures to correct information by their 

human resource department.

WIMPS:

Persons listed as the ship-to address are typically in contact with USDA throughout the 

entire disease outbreak. Persons listed as the ship-to address can contact the USDA district 

office at any time to address shipping concerns or correct their information.

7.4 If no formal redress is provided, what alternatives are available to the 

individual? 

A formal process is available to correct any data inaccuracies. See section 7.3 for more 

information.

7.5 Privacy Impact Analysis: Please discuss the privacy risks associated 

with the redress available to individuals and how those risks are 

mitigated. 
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APHIS has a formal redress procedure in place and there is minimum risk.

Section 8.0 Technical Access and Security 

The following questions are intended to describe technical safeguards and security measures. 

8.1 What procedures are in place to determine which users may access 

the system and are they documented? 

Both systems utilize the User Management System (UMS) to assist in the submission 

and tracking of users. A Supervisor can submit an employee for access to the system. 

Once the application is reviewed the applicable NQM and WIMPS administrators are 

notified of additions. Every Quarter one quarter of the accounts are reviewed for 

accuracy.

NQM:

Access is based on the need to do business and is determined by USDA APHIS VS 

management. All access to the NQM application is authorized and documented by an 

APHIS 513 form.

WIMPS:

At NCAH, user access is initiated by an USDA employee’s supervisor request, is 

approved by the system owner in NVSL, or the NVS Logistics Chief, and is recorded on 

APHIS form 513. Ordering clerks at district offices must first have an eAuth account 

prior to requesting access for placing orders.

8.2 Will Department contractors have access to the system? 

NQM:

Department contractors can be provided access to NQM for troubleshooting purposes 

is that need arises. The contractor’s access will be evaluated during the user 

certification process for NQM.

WIMPS:

No contractors have access.

8.3 Describe what privacy training is provided to users either generally 

or specifically relevant to the program or system? 

Currently, all individuals provided access to NQM and WIMPS are required to 

complete annual Information Technology (IT) Security Awareness Training and must 

sign APHIS Rules of Behavior form prior to receiving access to the information 

system. The standard USDA warning banner must also be acknowledged and 

accepted before logging in to the system.
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8.4 Has Certification & Accreditation been completed for the system or 

systems supporting the program? 

Yes. The NAP system established an Authority to Operate (ATO) on May 10, 2017 

and is categorized as a “Moderate” system. The system re-accreditation is set to 

renew the ATO in May 2020.

8.5 What auditing measures and technical safeguards are in place to 

prevent misuse of data? 

NQM:

Technical safeguards and auditing measures are in accordance with FIP 199/200 

Moderate Baseline Security Controls. Some of the technical safeguards for NQM are 

a security model that includes auditing, role-based views, field-level security, and 

division of security. This means any events, such as create, modify, soft deletion, and 

user login activity are audited at the field level. In addition, the audit history on 

individual record and/or audit history summary is also tightly controlled with separate 

security settings to protect the integrity of the log. The security model for access to 

the data within NQM is through role-based access and data restriction configurations. 

Furthermore, views and field-level access are role-based, preventing users from 

seeing, accessing, and/or making changes to individual fields or records they do not 

have access to. NQM users must be validated against APHIS Active Directory for 

authentication.

• All access to the data in the system is controlled by formal authorization 

using UMS.

• All access to the system is limited by account identification and 

eAuthentication. The eAuthentication makes uses of PIV cards using 

associated certificates.

• Warning banner must be acknowledged before logging in.

• All information sharing with internal systems is done over the internal 

APHIS network.

• Auditing is enabled both at the application and database level.

WIMPS:

USDA Active Directory (AD) provides authentication and identity services for this 

information system. All users must have active AD accounts, and AD provides a technical 

safeguard to WIMPS. This information system includes an Oracle database for data storage 

as well as auditing. All objects in the information system are audited, normal and privileged 

user actions are audit, and all audit logs written to the database are analyzed and archived.

8.6 Privacy Impact Analysis: Given the sensitivity and scope of the 

information collected, as well as any information sharing conducted 
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on the system, what privacy risks were identified and how do the 

security controls mitigate them? 

NQM:

The privacy information collected and stored in NQM is at risk from improper 

handling during transit. This risk is mitigated through user training and limiting use 

to Federal owned networks. Users are trained at least annually. Information is 

limited to APHIS, ARS, or DHS systems.

WIMPS:

All of the information stored in this information system is available outside of this 

information system. The integrity of the data is protected to ensure all transaction are 

complete and all items shipped successfully. All data objects, transactions, and ship-to 

data are protected by the available USDA technology and services (Oracle and Active 

Directory). Audit logs are available for all transactions.

Section 9.0 Technology 

The following questions are directed at critically analyzing the selection process for any technologies 

utilized by the system, including system hardware and other technology. 

9.1 What type of project is the program or system? 

NQM:

Is quality management system (QMS) commercial, off the shelf software (COTS) 

that provides a software suite of compliance focused tools that supports the NVSL 

requirement to maintain compliance to applicable regulations and standards.

WIMPS:

Is a supply chain solution COTS provided by Tecsys software.

9.2 Does the project employ technology which may raise privacy 

concerns? If so please discuss their implementation. 

N/A – Neither NQM or WIMPS employ technology that may raise privacy concerns.

Section 10.0 Third Party Websites/Applications 

The following questions are directed at critically analyzing the privacy impact of using third 

party websites and/or applications.

10.1 Has the System Owner (SO) and/or Information Systems Security 

Program Manager (ISSPM) reviewed Office of Management and 

Budget (OMB) memorandums M-10-22 “Guidance for Online Use of 
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Web Measurement and Customization Technology” and M-10-23 

“Guidance for Agency Use of Third-Party Websites and 

Applications”?

The ISSPM and system owner have reviewed the OMB memorandums listed above.

10.2 What is the specific purpose of the agency’s use of 3rd party websites 

and/or applications?

N/A

10.3 What personally identifiable information (PII) will become available 

through the agency’s use of 3rd party websites and/or applications.

N/A

10.4 How will the PII that becomes available through the agency’s use of 

3rd party websites and/or applications be used?

N/A

10.5 How will the PII that becomes available through the agency’s use of 

3rd party websites and/or applications be maintained and secured?

N/A

10.6 Is the PII that becomes available through the agency’s use of 3rd party 

websites and/or applications purged periodically? 

N/A

10.7 Who will have access to PII that becomes available through the 

agency’s use of 3rd party websites and/or applications?

N/A

10.8 With whom will the PII that becomes available through the agency’s 

use of 3rd party websites and/or applications be shared - either 

internally or externally?

N/A

10.9 Will the activities involving the PII that becomes available through 

the agency’s use of 3rd party websites and/or applications require 
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either the creation or modification of a system of records notice 

(SORN)?

N/A

10.10 Does the system use web measurement and customization technology?

N/A

10.11 Does the system allow users to either decline to opt-in or decide to 

opt-out of all uses of web measurement and customization 

technology?

N/A

10.12 Privacy Impact Analysis: Given the amount and type of PII that 

becomes available through the agency’s use of 3rd party websites 

and/or applications, discuss the privacy risks identified and how they 

were mitigated. 

N/A
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Agency Approval Signature 

________________________________ 

Karl J. Hochstein

NAP System Owner

NVSL Associate Director

Animal Plant Inspection and Service

________________________________ 

Preston Griffin

Acting MRP CISO

Marketing and Regulatory Programs

United States Department of Agriculture

________________________________ 

Tonya Woods

APHIS Privacy Act Officer

Animal and Plant Health Inspection Service

United States Department of Agriculture