Version: 1.3

Date: March 7, 2019

Prepared for: USDA APHIS

Privacy Impact Assessment 

APHIS eFile

Technology, Planning, Architecture, & E-Government
Privacy Impact Assessment 

APHIS eFile

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Privacy Impact Assessment for the

APHIS eFile System

March 7, 2019

Contact Point 

John Golden

Animal and Plant Health Inspection Service

301 851-2688

Reviewing Official 

Tonya Woods, APHIS Privacy Act Officer

United States Department of Agriculture

(301) 851-4076

Danna Mingo, MRP Privacy Compliance Officer 

United States Department of Agriculture

(301) 851-2487
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Abstract 

This Privacy Impact Assessment (PIA) is for the USDA, Animal and Plant Health Inspection 

eFile System. The APHIS eFile system provides a web-based tool that enables the public to 

apply for, check status of application(s), and receive APHIS permits on-line. This PIA is being 

conducted to determine the potential impact of the data which is collected via APHIS eFile.

Overview 

The Animal and Plant health Inspection Services (APHIS) of the United States Department of 

Agriculture (USDA) is charged with protecting the health and value of American agriculture 

and natural resources from the introduction of destructive plant and animal diseases and pests. 

These efforts support the overall mission to protect and promote agriculture and natural 

resources. 

APHIS eFile consist of a set of secure Web-based interfaces on the SalesForce platform, 

which include permit application interface that supports the entry, update, submission, and 

tracking of APHIS permit applications by the public. It also contains an interface that 

supports regulatory processing and issuance of said permits by APHIS staff.

This PIA is being created for the APHIS eFile which is a cloud provided solution. 

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? 

Customer – Customers enter permit application information, check the status of permit 

applications, and view permit responses. Customers also collaborate with the APHIS 

Permit Staff to verify accuracy of the permit and to ensure all requirements are met. 

The system uses the following information about customers: 

• Name (including full name, mother’s maiden name, maiden name of the 

individual, nickname or alias, business name)

• Telephone number (including work, Fax and home numbers)

• Address Information (include mailing address, email address, and organization 

name and job function)

• Date/Place or birth
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• Name, quantity, country of origin and intended use of regulated articles 

(organisms and materials) to be imported.

• Photographic image/identifying characteristics

• Proposed Articles to be permitted

• Risk mitigation requirements

• Compliance agreements and inspection reports

• Shipment Information (including country of origin)

• Handwriting or an image of the signature

• Destination addresses for shipments of regulated articles, including contact 

name and phone number.

• Miscellaneous identification numbers (national accreditation number and state 

license numbers.

• Planned dates and ports of entries for shipments, planned quantities of 

permitted articles in shipments.

• For Biotechnology Regulatory Service (BRS) permit applications, the 

applicant may declare that some permit application information is Confidential 

Business Information (CBI), a designation allowed under Section (b)(4) of the 

Freedom of Information Act, which exempts from disclosure certain types of 

information related to trade secrets and commercial or financial information.

The system uses the following information about employees:

• Name, address (including mailing address), telephone number (including work, 

FAX and home numbers), email address, and organization name and job 

function.

• For APHIS permits staff who signs permits, the system uses a digital image of 

the handwritten employee signature for printing on the permit.

Other - State regulatory agencies review permit applications, and enter comments 

about draft permit conditions. Agricultural Inspectors from the U.S. Customs and 

Border Protection use APHIS eFile to view permits and confirm the validity of 

permits.

The system uses the following information about other: 

• Name, address (including mailing address), telephone number (including work, 

FAX and home numbers), email address, and organization name and job 

function.

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

Permit applications submitted by permit applicants (importers, import brokers, and 

researchers). Comments provided by APHIS permits staff and state officials in order 

to issue a permit.
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1.3 Why is the information being collected, used, disseminated, or 

maintained? 

The principle purpose of collecting data in APHIS eFile is to collect information 

related to the application of a permit, fees associated with permits, and to track status 

information relating to issuance of a permit and the final outcome. 

1.4 How is the information collected? 

The information is collected through an online application. 

The decision-making process is an online series of steps followed by the APHIS

customer (applicant), APHIS employee, and other government agency staff who are 

required to review the information regarding permit issuance. 

1.5 How will the information be checked for accuracy? 

The system includes required fields where the applicant must enter data before 

proceeding to the next page of the application. The applicant has an opportunity to 

review their information and must certify that the information was entered correctly 

prior to submission.

APHIS employees, and other government agency officials are required to review the 

information regarding permit issuance. Manual verification involves the following 

steps:

• The APHIS reviewer confirms in APHIS eFile that all information was 

received and is complete.

• If information is missing, they can use APHIS eFile to request more 

information as required.

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

defined the collection of information? 

Dog permitting is covered under The Animal Welfare Act (AWA). The BRS permits 

are covered under The Plant Protection Act.

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

collected, discuss the privacy risks identified and how they were 

mitigated. 

The information collected (when obtained as a whole) could identify individuals and 

their activities with regards to APHIS permitting. This information is protected through 

various levels of security and policy. The system itself is protected by role-based access 

layers and positive identification techniques to ensure that only people authorized can 
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view information. [Note: Due to the level of development customization in the cloud 

platform, identified PII cannot be encrypted.] Auditing is being performed and system 

audit logs are being reviewed for suspicious activity.

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. 

The principle purpose of collecting data from an individual is to collect information 

related to the application of a permit, fees associated with permits, and to track status 

information relating to issuance of a permit and the final outcome.

Data will also be used to manage and issue permits and notifications; perform 

inspections, investigations, and permit-related activities; prepare permits, letters, and 

other documents; generate reports to evaluate quality control and effectiveness of the 

program (These reports may include privacy data such as name and address); 

determine if the action requested in the permit application would be additionally 

subject to other Federal or State authorities; and facilitate and account for payments.

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

may be produced? 

Inherent Salesforce platform tools are used.

2.3 If the system uses commercial or publicly available data please 

explain why and how it is used. 

Not Applicable. The system 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. 

This information is protected through various levels of security and policy. The system 

itself is protected by role-based access layers and positive identification techniques to 

ensure that only people authorized to view and act upon information about others can 

do so.
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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? 

Dog Permitting:

Paper and electronic records will be retained in accordance with disposition authority 

NI-463-09-9 which is currently being updated. Some records considered as permanent 

will be maintained in accordance with NARA requirements. 

Limited Animal Welfare Act electronic records are maintained permanently on a 

separate secured server for trend analysis and maintained by NARA.

BRS Records are proposed to be retained for 30 years.

3.2 Has the retention period been approved by the component records 

officer and the National Archives and Records Administration 

(NARA)? 

Dog permitting disposition authority in being updated and pending approval.

BRS records retention schedule is pending approval.

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

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

The system must maintain a disposition authority and without approval to destroy 

records the data will be maintained longer than needed. This has negative impacts on 

the privacy risk of the data. Once the NARA disposition is approved the system 

owner will ensure records are destroyed according to the authority.

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? 

At this time APHIS eFile does not share information internally.
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4.2 How is the information transmitted or disclosed? 

N/A

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. 

N/A

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? 

Information is shared to agencies such as Department of Homeland Security (DHS)

Custom and Border Protection (CBP) agents who work to support the APHIS mission 

at various ports of entry.

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. 

The information shared outside the USDA is compatible with its original collection as 

it is used directly to monitor and enforce the regulations governing the issuance of 

permits. The outside agencies that use the information assist the USDA in protecting 

and enforcing their policies at the various ports of entry across the United States and 

its territories. This sharing is covered by an appropriate routine use in APHIS-10

APHIS Comprehensive Electronic Permitting System (ePermits) SORN and live dog 

permitting is covered under pending APHIS 8 SORN that has been updated and 

pending approval.
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5.3 How is the information shared outside the Department and what 

security measures safeguard its transmission? 

The information is shared through controlled user access as defined by system 

requirements. The user’s role, is limited to the information needed to perform their 

duties.

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

privacy risks identified and describe how they were mitigated. 

The information shared is protected through various levels of security and policy. The 

system itself is protected by role-based access layers and positive identification 

techniques to ensure that only people authorized to view and act upon information 

about others can do so. By policy, individuals are only able to access the information 

they need to perform their duties and should not share the information with anyone 

unless specifically authorized. No reports are shared externally. In addition, limited 

information is sent to CBP through secure file transfer based on role-based 

permissions.

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 Was notice provided to the individual prior to collection of 

information? 

Yes, prior to logging into APHIS eFile and providing information the user is required 

to acknowledge a privacy and security notice. This page also provides additional links 

that provide the user further information on their rights.

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

information? 

No, applicants must provide the information in order to obtain a permit.

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

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

The individual does not have the ability to consent (or opt out) of particular uses of the 

information collected in the system.
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6.4 Privacy Impact Analysis: Describe how notice is provided to 

individuals, and how the risks associated with individuals being 

unaware of the collection are mitigated. 

Individuals are provided sufficient notice as to their rights and are required to 

positively acknowledge receipt of this notice prior to using the APHIS eFile system. 

Users are not permitted to submit an application without first acknowledging they 

understand the information is being collected and used for the purposes of reviewing 

and issuing regulatory decisions regarding permit issuance. A privacy statement will 

appear at the bottom of the system home page. The public is also made aware through 

the publication of the SORN(s).

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 that allow individuals to gain access to their information is documented 

in the System of Records Notice located at the following link: 

https://www.ocio.usda.gov/policy-directives-records-forms/recordsmanagement/system-records

7.2 What are the procedures for correcting inaccurate or erroneous 

information? 

Customers may access information by submitting a Freedom of Information Act 

(FOIA) request to: APHIS FOIA Office, 4700 River Road, Unit 50, Riverdale, MD 

20737 or email the FOIA Officer at FOIA.Officer@aphis.usda.gov.

The USDA Privacy Policy can be located at the following URL: 

https://www.usda.gov/privacy-policy. Information about FOIA/Privacy Act requests 

can be found at: 

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

7.3 How are individuals notified of the procedures for correcting their 

information? 

They are notified via the system of records notice.
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7.4 If no formal redress is provided, what alternatives are available to the 

individual? 

N/A

7.5 Privacy Impact Analysis: Please discuss the privacy risks associated 

with the redress available to individuals and how those risks are 

mitigated. 

No privacy risks are associated with the redress available. The redress procedures 

were developed based on the requirements of the Privacy Act.

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?

APHIS implements a Rules of Behavior (ROB) for which all users must consent prior 

to being granted systems credentials for access. The system inherits the USDA 

implementation of User Security Awareness training which is provided annually by the 

Department. In addition, APHIS provides personally identifiable Information Lite 

training via AgLearn.

Safeguards:

All APHIS eFile users are required to complete USDA's registration process called 

eAuthentication, a system that enables individuals to obtain user-identification 

accounts that allow password protected access to certain USDA web-based 

applications and services through the Internet. The web-based service identifies and 

validates USDA customers before they can access APHIS eFile. Role-based security 

and access rights are implemented to protect the security of the information. 

Additionally, the APHIS eFile security plan includes management, operational, and 

technical controls to prevent misuse of data by system users.

8.2 Will Department contractors have access to the system? 

Only specifically authorized Department contractors have access to the system. Those 

individuals must first obtain relevant security clearances along with specific 

authorization to access information at various levels.
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8.3 Describe what privacy training is provided to users either generally 

or specifically relevant to the program or system? 

The MRP Privacy Program requires all APHIS users to take the USDA Protection of

PII training on an annual basis. Names are submitted to the MRP Privacy Compliance 

Officer and the training is added to their AgLearn account.

8.4 Has Certification & Accreditation been completed for the system or 

systems supporting the program? 

Yes.

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 the application system. 

Both MRP and DSC perform active monitoring and oversight of account management 

best practices using account management policy and active reporting.

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? 

This information is protected through various levels of security and policy. The 

system itself is protected by role-based access layers and positive identification 

techniques to ensure that only people authorized to view and act upon information 

about others can do so. In addition, the system is designed to track all changes made 

against the lifetime of a record (version history). Data is retained a minimum of 5 

years, but not to exceed 30 years. Length of retention is governed by the type of 

record.

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? 

APHIS eFile is a web based information system on a cloud base system
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9.2 Does the project employ technology which may raise privacy 

concerns? If so please discuss their implementation. 

The system resides on the Salesforce cloud platform. The information is being 

managed by a contractor and storage and protections are not in the control of the 

agency. However, the platform is FedRAMP approved.

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

10.3 What personally identifiable information (PII) will become available 

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

Not Applicable

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

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

websites and/or applications purged periodically? 

Not Applicable

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

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

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

10.10 Does the system use web measurement and customization technology?

Not Applicable

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

opt-out of of all uses of web measurement and customization 

technology?

Not Applicable

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
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Approval Signature 

________________________________ 

John Golden

System Owner – APHIS eFile

Animal and Plant Health Inspection Service

United States Department of Agriculture

________________________________ 

MRP CISO/MRP ISSPM

Animal and Plant Health Inspection Service

United States Department of Agriculture

________________________________ 

Tonya Woods

APHIS Privacy Act Officer 

Animal and Plant Health Inspection Service 

United States Department of Agriculture