Version: 1.4

Date: December 4, 2019

Prepared for: USDA OCIO-Policy,

E-Government and Fair Information 

Practices (PE&F)

Policy, E-Government and Fair Information Practices

Privacy Impact Assessment 

MRP Azure Cloud GSS
Privacy Impact Assessment – MRP Azure Cloud GSS

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Privacy Impact Assessment for the

MRP Azure Cloud

General Support System 

December 9, 2019

Contact Point 

Marco A. Munoz

MRP Azure Cloud System Owner

USDA/APHIS/MRP-IT

970-494-7140

Reviewing Official 

Tonya G. Woods

APHIS/MRP Privacy Act Officer

(301)-851-4076
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Abstract 

This Privacy Impact Assessment (PIA) is for the USDA, Marketing and Regulatory Programs 

(MRP) Azure Cloud General Support System (GSS). The MRP Azure Cloud GSS provides 

cloud based information technology services for the MRP agencies for compliance 

requirements and information technology modernization efforts. This PIA was conducted 

because the MRP Azure Cloud GSS has the potential to store personally identifiable 

information within the system.

Overview 

The Animal and Plant Health Inspection Service (APHIS) is charged with protecting and 

promoting U.S. agricultural health, regulating genetically engineered organisms, 

administering the Animal Welfare Act and carrying out wildlife damage management 

activities. These efforts support the overall mission of USDA, which is to protect and promote 

food, agriculture, natural resources and related issues. APHIS is charged with supporting the 

information technology needs for the USDA MRP mission area agencies which includes 

APHIS and the Agricultural Marketing Service (AMS). AMS is charged with administering 

programs that create domestic and international marketing opportunities for U.S. producers of 

food, fiber, and specialty crops, and delivering services to the agriculture industry that ensure 

the quality and availability of wholesome food for consumers across the country.

The purpose of this system is to provide supporting information technology services to 

employees Marketing and Regulatory Programs that facilitates domestic and international 

marketing of U.S. agricultural products and ensures the health and care of animals and plants. 

The MRP Azure Cloud is a mission area GSS for cloud based infrastructure and platform 

services for the AMS and APHIS agencies. 

The APHIS MRP Information Technology (IT) organization established an infrastructure 

cloud environment through the use of the Microsoft Azure Government cloud services. 

Connectivity to these services is through a private network connection between the USDA 

network and Microsoft datacenters used for government customers. The system is comprised 

of major components providing a multitude of services to MRP agency employees and 

program units from AMS and APHIS. The services include machine virtualization, storage, 

networking, application platforms and other cloud based services from Microsoft. The cloud 

service provider, Microsoft, is responsible for and provides the physical and cloud service 

foundation that the system components are built on. For a complete list of components in the 

GSS, please see the narratives in the SSP.

The Azure Cloud GSS has components which process, collect, or retain information on 

USDA employees, contractors or other entities working on behalf of USDA. The system 

provides the infrastructure and services for MRP agency program units that store information 

that may contain PII and/or privacy data. 
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Section 1.0 Characterization of the Information 

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? 

The GSS stores data used and processed by a number of MRP agency programs in 

the course of fulfilling their mission for USDA. It is expected to hold any type of 

data AMS and APHIS uses for applications or general services. The boundary of the 

data stored is the responsibility of the application/investment including the SORNs 

and privacy impacts. The GSS maintains the data and is responsible for the security 

of the stored data.

1.2 What are the sources of the information in the system? 

The source of information that resides within the GSS will be from users and other 

major applications for which a PTA/PIAs has been written. In addition, the stored 

information is for AMS and APHIS employees/contractors in support of the mission 

of the MRP agencies.

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

maintained? 

It is for the mission work of MRP agencies that include internal and external sources. 

This includes contractor numbers, employee name, and home telephone numbers. It 

may also include the potential for users or systems to store documents and/or data that 

is extracted from other applications to support the purpose or function of their 

application or system operating in the GSS boundary. An example of this is data being 

transferred from another authorized system existing in a different data center to a 

resource provisioned in the GSS where it is process by a program unit’s application 

for a particular business function. 

1.4 How is the information collected? 

The information is obtained through the course of fulfilling the mission of the MRP 

agencies. MRP agencies and program units operate applications and/or systems which 

may collect information. Those applications are managed as a separate system, as a 

separate security boundary, that would detail how information is collected for their

specific need. This includes establishing a separate PTA and PIA. These applications 

can operate within the boundary of the GSS and run using offered services. 

1.5 How will the information be checked for accuracy? 
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The data is checked for accuracy by the MRP agency employees collecting the 

information. The GSS maintains information through the storage components and 

applications maintained on the system. Each application system owner is responsible 

for documenting the data about their system within their own boundary documents. In 

some cases, applications developed or used can provide assistance with data validation 

and accuracy checking. The GSS maintains the security of the data and applications 

servers or services. The GSS does not collect information instead it maintains the 

information needed to support the mission of the agency.

1.6 What specific legal authorities, arrangements, and/or agreements 

defined the collection of information? 

The GSS does not collect information. However, the legal authorities defined in the 

collection of information by MRP agencies’ program units operating applications and 

systems include, but are not limited to the following:

Agriculture Improvement Act (Farm Bill);

Animals and Animal Products (CFR Title 9);

Animal Damage Control Act;

Animal Health Protection Act; 

Animal Welfare Act; 

Defense of United States Agriculture and Food (HSPD-9);

Food and Drugs (Title 21 U.S.C)

Plant Protection Act; 

Public Health Security and Bioterrorism Preparedness and Response Act; and

Virus Serum Toxin Act.

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

collected, discuss the privacy risks identified and how they were 

mitigated. 

Risks are identified via findings, audits & incidents (see below). Once identified, they 

are mitigated based on the vulnerability criticality. If the timeline exceeds 30 days, a 

cost worksheet and Plan of action & milestone (POA&M) are approved by the system 

owner.

Since FY18, no privacy risks were identified for the Azure system. If a privacy risk is 

identified in the future, Azure stakeholders, will work with various teams, and the 

Privacy Office, to remediate vulnerabilities. If the risk has been identified as a PII 

breach, it will be reported within one hour of the incident, to USDA Cyber Security 

Officials.
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Risk Source Findings

• OIG Audit

• GAO Audit

• FFMIA/FMFIA

• FDCC/USGCB

• Incident (privacy breach)

• DHS Finding

• Cyber Stat/PIV

• FISMA A&A

Possible Privacy Risks

RISK Mitigating Factors

Integrity and 

availability of data

The risks are mitigated through the use of 2 factor 

authentication. Azure cloud services have storage 

redundancy, geo-regional duplication, security access 

controls and encryption to protect GSS data from 

corruption and loss of access. 

Privacy rights of 

customer/employees

All access to the system would require authentication by 

authorized personnel only.

Application access limits access to relevant information 

and prevents access to unauthorized information.

Any privacy information and information in general will 

have multiple layers of security protecting 

customers/employees if data is stored.

Data encryption Use of DLP technology, firewalls, IDP/IPS technology, 

proxy servers is used for data protection. Azure cloud 

services enable the GSS to encrypt data at rest while 

additional means for operating systems and databases will 

add further encrypting capabilities using Bitlocker for 

storage and Transparent Data Encryption.

 

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. 
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2.1 Describe all the uses of information. 

The information stored is used to carry out the mission of MRP agencies.

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

may be produced? 

Not Applicable. However, based on requirements of work to be performed by the 

MRP agencies, employees and contractors, the use of varying tools, applications and 

cloud services may be deployed to work with data stored in the GSS. Agency 

programs may generate additional work product data based on their needs and 

requirements to address the mission of MRP agencies.

2.3 If the system uses commercial or publicly available data please 

explain why and how it is used. 

Not Applicable. The system itself does not use commercial or publicly available data. 

However, the GSS enables agency programs to store data that may originate from 

commercial or public suppliers to perform the mission of MRP agencies.

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. 

The GSS does not collect. However, it is a platform used to save data. The 

infrastructure has implemented controls to secure the data stored locally for the 

support of the MRP agencies. 

The GSS uses two-factor authentication to access and use role based access controls to 

operate and manage the system. Any application operating within or use the GSS will 

conform to access, authentication and authorization requirements meeting security and 

configuration standards and mandates. The degree of information handling compliance 

will be based on program, application and compliance requirements. The GSS enables 

the proper handling of information based on specified requirements (see below).

• Authority & Purpose

• Accountability, Audit Risk Management 

• Data Quality and Integrity

• Data Minimization and Retention

• Individual Participation and Redress

• Security

• Transparency

• Use Limitation

The GSS has capabilities to automatically protect data of the GSS by default include 

automatically encrypting data at rest and denying access by default. The storage 
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system automatically encrypts data stored. Access controls are enabled. They include 

such items as firewalls denying all traffic by default at three different key points in the 

network before there is access to the applications and their data storage. Additional 

means for locking down application resources for further protections are possible. In 

cases such as this, it is dependent on a program unit’s application or system specified 

requirements. 

Section 3.0 Retention 

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

the initial collection. 

3.1 How long is information retained? 

Items are retained per the General Records Schedule 24: Information Technology 

Operations and Management Records, records are destroyed based on the subject 

matter. 

3.2 Has the retention period been approved by the component records 

officer and the National Archives and Records Administration 

(NARA)? 

Each of the program offices that collect data will schedule the records as required.

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

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

As of FY20, no risk have been identified.

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? 

This is based on the programs use of the data and this would be documented in their 

appropriate PIA and/SORN.

4.2 How is the information transmitted or disclosed? 

This is based on the programs use of the data and this would be documented in their 

appropriate PIA and/or SORN.
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The GSS offers means of protection for program unit data. This comes in the form of 

encrypted transmission, encrypted storage, support for encryption protocols and access 

controls. 

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. 

Not Applicable.

The GSS enables information sharing or has components being used by program units 

for their business needs, systems or application. Privacy risks are mitigated use of 

security controls for authentication, authorization functionality, segregation for data 

and network access controls.

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. 

5.1 With which external organization(s) is the information shared, what 

information is shared, and for what purpose? 

This is based on the programs use of the data and this would be documented in the 

appropriate PIA and/or SORN.

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. 

Not Applicable. Each program will create and publish a SORN for the data they are 

responsible for.

5.3 How is the information shared outside the Department and what 

security measures safeguard its transmission? 

This is based on the programs use of the data and this would be documented in the 

appropriate PIA and/or SORN.
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5.4 Privacy Impact Analysis: Given the external sharing, explain the 

privacy risks identified and describe how they were mitigated. 

Not Applicable.

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.

No. SORNs are the responsibility of the programs. Each program will create and 

publish a SORN for the data they are responsible for.

6.2 Was notice provided to the individual prior to collection of 

information? 

No PII is collected by the GSS. The infrastructure stores the information collected by 

the programs. Notice is the responsibility of the programs.

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

information? 

Not Applicable.

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

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

Not Applicable.

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. 

There is no risk identified with individuals not being unaware of the collection of data.
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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? 

The procedures to allow individuals to gain access to their information is documented 

in the appropriate PIA and or SORN. That is the responsibility of the programs.

7.2 What are the procedures for correcting inaccurate or erroneous 

information? 

Procedures are established within the programs.

7.3 How are individuals notified of the procedures for correcting their 

information? 

The information is provided in the appropriate PIA and/or SORN. This is the 

responsibility of the programs.

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

individual? 

Not Applicable.

7.5 Privacy Impact Analysis: Please discuss the privacy risks associated 

with the redress available to individuals and how those risks are 

mitigated. 

There are no identified risks associated with the redress.

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? 

Rules of Behavior (ROB) is implemented for which all GSS users, including 

privileged users, must consent prior to being granted system credentials for access. 

The GSS inherits the USDA implementation of User Security Awareness training 

which is provided annually by the Department. MRP IT has created access control lists 
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(ACLs) and uses role based access controls (RBAC) for the GSS that determine who 

within agencies can access system resources. Authorization for access to these secured 

resources must be obtained before a user is granted access.

8.2 Will Department contractors have access to the system? 

Yes.

8.3 Describe what privacy training is provided to users either generally 

or specifically relevant to the program or system? 

The Department’s IT Security Awareness Training Program is provided on an annual 

base and is mandatory for all MRP employees. All users are required to sign a ROB 

that addresses privacy related responsibilities. Employees also have to take privacy 

training, to ensure they know how to address PII, breaches, and retention. 

8.4 Has Certification & Accreditation been completed for the system or 

systems supporting the program? 

Yes. The system received an approval to operate (ATO) 11/23/2018. The FISMA 

A&A will be conducted on an annual basis, until the ATO expires 11/23/2021. 

8.5 What auditing measures and technical safeguards are in place to 

prevent misuse of data? 

All users are required to have an individual user account to access the GSS. Firewalls 

and intrusion detection systems prevent unscrupulous parties from accessing the GSS.

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

information collected, as well as any information sharing conducted 

on the system, what privacy risks were identified and how do the 

security controls mitigate them? 

Not Applicable.

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? 

The system is a General Support System (GSS).
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9.2 Does the project employ technology which may raise privacy 

concerns? If so please discuss their implementation. 

No, the GSS does not employ technology which 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 

Web Measurement and Customization Technology” and M-10-23 

“Guidance for Agency Use of Third-Party Websites and 

Applications”?

Yes.

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

and/or applications?

Not Applicable. The GSS does not use third party websites or applications.

10.3 What personally identifiable information (PII) will become available 

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

Not Applicable. The GSS does not use third party websites or applications.

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

3rd party websites and/or applications be used?

Not Applicable. The GSS does not use third party websites 

or applications.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?

Not Applicable. The GSS does not use third party websites or applications.

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

websites and/or applications purged periodically? 
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Not Applicable. The GSS does not use third party websites or applications.

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

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

Not Applicable. The GSS does not use third party websites or applications.

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?

Not Applicable. The GSS does not use third party websites or applications.

10.9 Will the activities involving the PII that becomes available through 

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

either the creation or modification of a system of records notice 

(SORN)?

Not Applicable. The GSS does not use third party websites or applications.

10.10 Does the system use web measurement and customization technology?

Not Applicable. The GSS does not use web measurement and customization.

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?

Not Applicable. The GSS does not use web measurement and customization.

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. 

Not Applicable. The GSS does not use third party websites or applications.
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Approval Signature 

________________________________ 

Tonya Woods

APHIS/MRP Privacy Act Officer (PAO)

Animal and Plant Health Inspection Service

United States Department of Agriculture

________________________________ 

Preston Griffin

MRP IT –Information System Security Program Manager (ISSPM)

Animal and Plant Health Inspection Service

United States Department of Agriculture

________________________________ 

Marco A. Munoz

MRP IT – MRP Azure Cloud GSS System Owner

Animal and Plant Health Inspection Service

United States Department of Agriculture