Version: 2.1

Date: January 2020

Prepared for: USDA OCIO – Policy and 

Directives – Privacy Office

Technology, Planning, Architecture, & E-Government

Privacy Impact Assessment 
Privacy Impact Assessment 

USDA APHIS VS SCS

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Privacy Impact Assessment for the

Surveillance Collaboration Services (SCS)

January 2020

Contact Point 

Orlando Baca

USDA APHIS Veterinary Services

Reviewing Official 

Tonya Woods

Director, Freedom of Information and Privacy Act Staff

United States Department of Agriculture

(301) 851-4076 
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Abstract 

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

Inspection Service (APHIS), Veterinary Services (VS), Surveillance Collaboration 

Services (SCS) components: SCS CoreOne Web, SCS CoreOne Mobile, SCS Mobile 

Information Management (MIM), Animal Health Services (AHS) and SCS Mobile Forms.

• VS SCS is a collection of multiple commercial off the shelf (COTS) platforms and USDA 

developed services. VS SCS allows for the collection and reporting of animal health and 

surveillance information. It provides an electronic means of data input, data transmission, 

data storage, and data reporting. This enables USDA APHIS to take a comprehensive and 

integrated approach to collecting and managing animal health data for disease 

management and surveillance programs.

• This PIA was conducted as part of the annual assessment documents update. 

Overview 

VS SCS is a collection of multiple COTS platforms and USDA developed services focused on

animal health and surveillance. VS SCS enables VS to perform comprehensive surveillance of 

animal health for numerous species and diseases to facilitate the detection, management, 

prevention, investigation, control and eradication of animal diseases. 

VS SCS maintains test and/or vaccination data and other program information such as disease or 

certification status for flocks/herds subject to or involved with APHIS VS animal disease/pest 

surveillance and or control programs such as: Viral Hemorrhagic Septicemia, Johne’s disease, 

Brucellosis, Tuberculosis, Chronic Wasting Disease, Pseudorabies, and Avian Influenza. Included 

in this functional data is privacy related data such as USDA and State employee name, address, 

and phone information for employees directly involved in the above-mentioned program 

activities. VS SCS supports the VS mission to protect and improve the health, quality, and 

marketability of our nation's animals by providing a nationwide repository of animal health and 

productivity information. 

VS SCS also maintains name, address, and phone information for individuals identified as 

contacts for premises (locations) and owners of animals or animal related operations involved 

with the various programs. Because of the variable nature of the premises, including sole 

proprietorships, and the undocumented relationship of the contact to the premises, many of the 

contacts are simply private citizens. 

VS SCS is funded by Congress through appropriated funds for the Animal Health Technical 

Services budget line item. The system received a renewal of its Authority to Operate (ATO) in 

September 2020. SCS has a security categorization of “Moderate”.

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? 

Information/Record Type Component Data (Examples)

Premises Physical location of a business or animal 

herd/flock 

Premises Supplemental Detail Commercial operation records to provide 

additional details about the business, such as 

type of operation, type of livestock, and 

whether or not they are approved to receive 

international livestock. 

Health management Operation management and practices related to 

animal health care

Events Events are activities such as tissue collections, 

vaccinations, inspections, or inventories. 

Surveillance Test submission information and test results for 

diseases such as Johne’s disease, Brucellosis, 

Tuberculosis, Chronic Wasting Disease, 

Pseudorabies, Swine Influenza Virus, Scrapie 

or Avian Influenza. 

Animal Animal species, breed, sex, age, classification, 

and any associated individual or group 

identifiers.

Other Specific ad-hoc data, miscellaneous 

identification numbers such as: the regulatory 

official ID and/or the Veterinary Accreditation 

number of the animal health official. It also 

includes information about the medicine or 

vaccine name, the manufacturer, and medicine 

license code. 

Status Temporary conditions or groups that a herd 

may be part of or subject to, such as 

quarantined, infected, certified free, or 

scheduled for future testing. 

Aggregated Instance of surveillance and program data that 

allows state-wide aggregation of data by 

species, disease, premises type, herd status 

and/or location (state, county, zip code). 
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Concerning the privacy related information there are two types collected in VS SCS:

• Employee information – VS SCS maintains name, address, phone and personal 

identification number (professional license number, Veterinary Accreditation 

number, regulatory official ID) information for USDA and State animal health 

employees directly involved in disease program activities. 

• Other information – VS SCS maintains name, address, and phone information for 

individuals identified as contacts for premises (locations) and owners of animals or 

animal related operations involved with the various animal disease/pest surveillance 

and or control programs that could be identified in agency assigned miscellaneous 

numbers (case numbers, flock IDs, permits, etc.) and personal identification number 

(professional license number, Veterinary Accreditation number) information for 

private veterinarians. Because of the varying nature of the premises, including sole 

proprietorships, and the undocumented relationship of the contact to the premises, 

many of the contacts are simply private citizens entitled to protection under the 

Privacy Act. 

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

There are three sources of information for VS SCS: Federal, State/Tribal/Local 

Government and third-party. Information in this system comes primarily from the users 

and individuals and/or businesses in the general public involved in or supporting the 

production, management or holding of livestock. In addition, the USDA Food Safety 

Inspection Service (FSIS), Farm Services Agency (FSA), and APHIS (Veterinary Services 

and Wildlife Services), will provide data to the system. The USDA National Agriculture 

Statistics Service (NASS) currently provide animal and farm population Census data 

aggregated at the county level for spatial display. 

The individual State Veterinarian Offices, as well as multiple state and university animal 

diagnostics and genotyping testing laboratories will provide data for use in the USDA 

APHIS VS SCS system. 

Third party sources of information may include the American Veterinary Medical 

Association (AVMA), National Turkey Federation (NTF), and private genotype testing 

laboratories, private individuals and companies who are the subject of the programs for 

whom we keep data and third-party data suppliers.

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

maintained? 

The purpose of the Surveillance Collaboration Services system is to allow animal health 

officials to effectively manage animal disease, pest and surveillance programs including 

providing:

a) rapid detection and effective response to animal disease and animal pest events in the 

United States thereby reducing the spread of infections to new flocks/herds;
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b) epidemiological analysis, including animal tracing, diagnostic testing, surveillance 

activities, and other factors of epidemiologic importance for evaluating disease risk;

c) notification of owners or buyers of potentially exposed or infected livestock and State 

and Federal regulatory officials, including notification through a public web site when 

records are inadequate to trace such animals to a specific owner or premises;

d) documentation of U.S. animal health program expenditures, statistical data and 

accomplishments that support national animal disease control programs and 

international trade agreements;

e) documentation of compliance with and provisions for a public listing of participants in 

voluntary certification or quality assurance programs; and

f) provide a public listing of approved or qualifying facilities such as approved livestock 

markets.

Summarized animal disease information is reported to the (OIE) Office International des 

Epizooties (World Organization for Animal Health). Some animal disease information is 

shared with world trading partners provided for risk analysis to demonstrate that US 

agricultural animal products are safe for export to other countries. Most risk analysis 

information is aggregated information and does not describe detailed record information. 

Some animal disease information is shared with state and federal wildlife agencies, as 

animal diseases frequently cross over between domesticated animals and wildlife. 

Similarly, some animal disease information is shared with state and federal public health 

agencies, as animal diseases can cross over between domesticated animals and humans. 

All information for a State, by definition, is shared with state animal health officials and 

state animal health databases for that State. State employees who are authenticated users 

have access to all the data collected about animals in their state. Federal users have access 

to data to meet the mission of Veterinary Services. State partners use the information to 

manage animal diseases in their state.

1.4 How is the information collected? 

The information collected from states, users, individuals and/or businesses in the general 

public is collected on OMB approved- forms or directly as referenced in Information 

Collections numbers 0579-0047, 0579-0146, 0579-0212, 0579-0007 and 0579-0101. As 

these packages come up for renewal appropriate screen shots will be included. In some 

cases, the information is entered directly into the USDA APHIS VS SCS CoreOne Web 

application by animal lab employees who are entering results from their internal lab 

documents or a state or federal employee entering information provided over the phone, in 

an email, or letter by a producer typically in order to fulfill a request for a flock ID or ear 

tags. State or federal employees and private practitioners can also enter field data directly 

into the SCS AHS component. Members of the public do not access the SCS CoreOne 

Web or SCS MIM systems to enter data themselves. For the SCS Mobile Forms 
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application, the information is entered directly into the application by state or federal 

employees. Members of the public do not access the SCS Mobile Forms system to enter 

data themselves. Data input is by authenticated state and federal employees.

1.5 How will the information be checked for accuracy? 

Data collected from customers is verified for accuracy, relevance, timeliness and 

completeness by USDA and state employees. These employees are responsible for the 

review and accuracy of the data. Verification of data records occurs on an as-needed basis. 

Also, there are limited systematic data entry constraints to ensure entry completeness. 

Data collected from USDA sources is verified for accuracy, relevance, timeliness and 

completeness by USDA and state employees. These employees are responsible for the 

review and accuracy of the data. Verification of data records occurs on an as-needed basis. 

Also, there are limited systematic data entry constraints to ensure entry completeness. 

Data collected from non-USDA sources will be verified for accuracy, relevance, 

timeliness and completeness by USDA Veterinary Services employees, state employees 

and or other federal employees. These employees are responsible for the review and 

accuracy of the data. Data verification occurs on an as-needed basis. Also, there are 

limited systematic data entry constraints to ensure entry completeness.

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

defined the collection of information? 

• The Animal Damage Control Act of 1931, 7 U.S.C. 8351 et seq. of the Animal Health 

Protection Act;

• The Animal Health Protection Act, 7 U. S. C. 8301-8317;

• The Farm Security and Rural Investment Act of 2002, 7 U.S.C. 7901 et seq.;

• Public Health Security and Bioterrorism Preparedness and Response Act of 2002, 116 

Stat 674-678;

• The Homeland Security Presidential Directives 7 and 9; and

• Farm Bills - an omnibus, multiyear law that governs an array of agricultural and 

food programs. 

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

collected, discuss the privacy risks identified and how they were

mitigated. 

Unauthorized disclosure of employee and other personal data, as identified in Section 1.1 

above, was the primary privacy risk identified in the PTA. USDA APHIS, including the 

VS Executive Team, District and Commodity Directors, Assistant District Directors, 

Centers for Epidemiology and Animal Health (CEAH), Center for Informatics (CFI) and 

State Veterinarians are all responsible for protecting the privacy rights of the employees 
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and other persons identified in the SCS as required by applicable State and Federal laws. 

Specific mitigation activities are:

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

individual’s supervisor, or APHIS representative in the case of external users, must 

identify (authorize) what functional roles that individual needs in the VS SCS

platforms / services. 

• Access to VS SCS platforms / services is controlled by the USDA eAuthentication 

system. 

• The application limits access to relevant information and prevents access to 

unauthorized information. 

• All users receive formal system training and are required to sign Rules of Behavior on 

an annual basis as part of the USDA mandatory information system security 

awareness training.

• At the login screen of the application the warning banner must be acknowledged 

before users are allowed access. 

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 data is used for routine animal health surveillance, management of domestic animal 

disease and pest control programs, and to monitor for and respond to the introduction of 

foreign animal diseases. 

State Veterinarians and State/Tribal Animal Health officials, as co-owners of the data, 

have the discretion to share information stored in the VS SCS relevant to premises or 

persons within their state in accordance with state laws and regulations via public web 

sites and/or may store such information in animal health and surveillance management 

databases developed by State IT developers, contractors or other third party software 

vendors in a manner that provides secure data access. 

Certain disease information reported by State/Tribal/Local and/or Federal employees is 

recorded in VS SCS. These reports are then summarized by APHIS in reports to the (OIE) 

Office International des Epizooties (World Organization for Animal Health). No 

‘customer’, ‘employee’ or ‘other’ classifications of private information is published or 

distributed to OIE. 

The Surveillance Design and Analysis (SDA) and the Commodity Health Centers have 

agency responsibility for reporting surveillance and program management activities on a 
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nationwide basis. The SDA and the Commodity Health Centers will have direct access to 

VS SCS and provide and publish summarized data to the public and our trading partners.

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

may be produced? 

VS SCS platforms / services use multiple tools to analyze data such as IBM® Enterprise 

Cognos®, Excel spreadsheets, SAS® (a statistical application), Tableau®, Palantir® Data 

Integration Services (DIS). Data is used to produce summary reports for stakeholders, and 

detailed internal reports, which may contain name, address, and phone information for 

persons identified in VS SCS.

2.3 If the system uses commercial or publicly available data please 

explain why and how it is used. 

VS SCS uses Google Mapping data and USDA National Agriculture Statistics Service 

(NASS) animal and farm population Census data aggregated at the county level for spatial 

display. This data allows APHIS to see how much surveillance has been completed by 

Veterinary Services versus how many animals are reported to live in a particular county.

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 employees and other persons will be protected by USDA APHIS VS 

management within the limits of the Privacy Act of 1974. VS SCS has security controls to 

address access/security of information. 

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

individual’s supervisor must identify (authorize) what functional roles that individual 

needs in VS SCS. 

• All requests for access to the system are verified by user identification and 

authentication. Users must have a government issued login and password that is controlled 

and managed either at the Veterinary Services, National, District or local offices or in the 

case of local State databases the State Veterinarian’s office. 

• VS SCS limits access to relevant information and prevents access to unauthorized 

information through role-based access. 

• Detailed reports with personally identifiable information will be marked with an 

appropriate sensitivity classification. 

• All users receive security basics training and are required to sign rules of behavior before 

being given access to the system. Additionally, all users receive security basics refresher 

training and sign rules of behavior on an annual basis.

• At the application login screen the warning banner must be acknowledged before users are 

allowed to log into the application.
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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? 

Paper and electronic records will be retained in accordance with an established records 

retention schedule. Some records considered as permanent will be maintained in 

accordance with NARA requirements. 

3.2 Has the retention period been approved by the component records 

officer and the National Archives and Records Administration 

(NARA)? 

USDA APHIS Records Officer submitted records schedule request to NARA in 2018. 

APHIS is awaiting NARA 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. 

Unauthorized disclosure of employee and other personal data, as identified in Section 1.1 

above, is the primary privacy risk, as identified by the PTA. The benefit of having that 

data available for premises backtracking and other trending information during an 

emergency overrides any risk due to data retention timescale. To date, all records have 

been retained as VS awaits NARA disposition and retention scheduling. To mitigate this 

risk, authorization access is strictly monitored. Personally Identifiable Information (PII) is 

limited to names, addresses, email and phone numbers of submitters. VS SCS maintains 

information in a secure manner and disposes of information per APHIS Directive 3440.2.

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? 

All data is available (for the areas/states for which they have responsibility) to USDA 

APHIS, including District and Commodity Directors, Assistant District Directors, district 

and national staff, Centers for Epidemiology and Animal Health (CEAH), Center for 
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Informatics (CFI), and APHIS Wildlife Services for program implementation, oversight, 

and reporting. 

Detailed data is shared with internal VS IT systems (Emergency Management and 

Response Services 2.0, MRP AWS GSS Animal Disease and Traceability Information 

System AHER component via VS Data Integration Services, and VSISM Alteryx and 

Tableau components), for integration, reporting and analysis.

National Import Export Services (NIES) gets summary data to assist in trade negotiations.

4.2 How is the information transmitted or disclosed? 

The APHIS and state users have access to VS SCS through the APHIS Enterprise 

Infrastructure (AEI) and MRP Azure Cloud GSS and can extract detailed or summary 

reports that are pertinent to their organizations. ETL processes are used to transmit data 

from SCS to other VS IT systems, such as ADTIS AHER. The VS Rhapsody messaging 

system is used to move MIM and VSLS data into SCS CoreOne.

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. 

Unauthorized disclosure of employee and other personal information, as identified in 

Section 1.1 above, is the primary privacy risk to information shared internally to APHIS. 

These risks are mitigated through VS SCS, AEI, and MRP Azure Cloud GSS’ security 

controls as delineated in the current VS SCS System Security Plan. Further, the animal 

health professionals who have access to the data are trained in the proper use and 

dissemination of this data. All access must be approved, before it is granted. VS, where 

feasible and within the technical limitations, ensures activities within the SCS are audited, 

PII is used only for authorized purposes and in a manner that is compatible with Privacy 

Act, and PII use is minimized to the extent necessary to meet the mission needs of the VS 

surveillance program.

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? 

• To State/Tribal animal health officials and their contractors and other cooperators 

authorized access by State/Tribal animal health officials, data from their State/Tribe as 

co-owners of the data to: (a) Collaborate with USDA in conducting, managing, and 

evaluating animal health, disease, or pest surveillance or control programs, and 

monitoring for animal health, diseases or pests; (b) aid in containing and responding to 
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a foreign or domestic animal disease or pest outbreak, bioterrorism, or other animal 

health emergency; (c) disseminate information and solicit feedback on emergency 

preparedness and response guidelines and the system itself for the purpose of 

educating and involving these officials in program development, program 

requirements, and standards of conduct; and (d) States/Tribes may share information 

on premises, persons, or animals within their State or Tribe in accordance with State 

or Tribal laws and regulations via public websites or other means; 

• To Federal, State/Tribal, or local wildlife agencies to collaborate with USDA in 

conducting, managing, or evaluating animal health, disease or pest surveillance or 

control programs, and monitoring for animal health issues, diseases, or pests affecting 

both wildlife and domestic animals or respond to emergencies impacting wildlife and 

domestic animals. Such parties will be bound by the nondisclosure provisions of the 

Privacy Act; 

• To Federal, State/Tribal, or local government agencies involved with public health 

such as the Departments of Health and Human Services and Homeland Security 

(DHS) for the purposes of collaborating with USDA to conduct, manage, or evaluate 

zoonotic disease or pest awareness, surveillance, response or reporting activities, or to 

respond to emergencies impacting humans and domestic animals; 

• To DHS’ Customs and Border Protection for inspection of compliance with permit 

conditions; 

• To cooperating laboratories, Federal, State, and local government officials, employees, 

or contractors, and other parties engaged to assist in administering animal health 

programs to assist the agency in carrying out the program. Such contractors and other 

parties will be bound by the nondisclosure provisions of the Privacy Act;

• To the World Organization for Animal Health (Office International des Epizooties 

(OIE)) for reporting summarized animal diseases information and to document 

country or regional disease status. No customer, employee, or other classification of 

private information is published or distributed to the OIE; 

• To USDA contractors or cooperators with signed agreements collaborating with 

USDA in conducting, managing, or evaluating animal health, disease or pest 

surveillance or control programs, and monitoring for animal health issues, diseases, or 

pests or to aid in containing and responding to a foreign or domestic animal disease 

outbreak, zoonotic disease outbreak, bioterrorism, radiological event, or other animal 

health emergency; 

• To the public through USDA websites: (a) Lists of participants in voluntary animal 

disease certification or quality assurance programs; (b) lists of individuals or entities 

not in compliance with animal disease regulations to reduce the potential risk of 

animal disease spread; and (c) list the herds of origin of exposed or potentially 

exposed animals when needed to notify individuals who may have acquired exposed 

or potentially exposed animals when other means of contact are unavailable.

• To the public and trading partners for their information and dissemination as needed 

and to document country or regional disease status. These summarized reports do not 

contain any customer, employee or other classifications of private data; 

• To appropriate law enforcement agencies, entities, and persons, whether Federal, 

foreign, State, Tribal, local, or other public authority responsible for enforcing, 

investigating, or prosecuting an alleged violation or a violation of law or charged with 
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enforcing, implementing, or complying with a statute, rule, regulation, or order issued 

pursuant thereto, when a record in this system on its face, or in conjunction with other 

records, indicates a violation or potential violation of law, whether civil, criminal, or 

regulatory in nature, and whether arising by general statute or particular program 

statute, or by regulation, rule, or court order issued pursuant thereto, if the information 

disclosed is relevant to any enforcement, regulatory, investigative, or prosecutive 

responsibility of the receiving entity;

• To the Department of Justice when: (a) USDA, or any component thereof; or (b) any 

employee of USDA in his or her official capacity where the Department of Justice has 

agreed to represent the employee; or (d) the United States Government, is a party to 

litigation or has an interest in such litigation, and by careful review, USDA determines 

that the records are both relevant and necessary to the litigation and the use of such 

records by the Department of Justice is therefore deemed by USDA to be for a 

purpose for which USDA collected the records;

• To a court or adjudicative body in a proceeding when: (a) USDA or any component 

thereof; or (b) any employee of USDA in his or her official capacity; or (c) any 

employee of USDA in his or her individual capacity where USDA has agreed to 

represent the employee; or (d) the United States Government, is a party to litigation or 

has an interest in such litigation, and by careful review, USDA determines that the 

records are both relevant and necessary to the litigation and the use of such records is 

therefore deemed by USDA to be for a purpose that is compatible with the purpose for 

which USDA collected the records; 

• To appropriate agencies, entities, and persons when: (a) USDA suspects or has 

confirmed that the security or confidentiality of information in the system of records 

has been compromised; (b) USDA has determined that as a result of the suspected or 

confirmed breach there is a risk of harm to individuals, USDA (including its 

information systems, programs, and operations), the Federal Government, or national 

security; and (c) the disclosure made to such agencies, entities, and persons is 

reasonably necessary to assist in connection with USDA’s efforts to respond to the 

suspected or confirmed compromise and prevent, minimize, or remedy such harm;

• To another Federal agency or Federal entity, when information from this system of 

records is reasonably necessary to assist the recipient agency or entity in (a) 

responding to a suspected or confirmed breach or (b) preventing, minimizing, or 

remedying the risk of harm to individuals, the agency (including its information 

systems, programs, and operations), the Federal Government, or national security;

• To a Congressional office in response to an inquiry made at the written request of the

individual to whom the record pertains;

• To USDA contractors and other parties engaged to assist in administering the 

program, analyze data, information management systems, Freedom of Information Act 

requests, and audits. Such contractors and other parties will be bound by the 

nondisclosure provisions of the Privacy Act; 

• To USDA contractors, partner agency employees or contractors, or private industry 

employed to identify patterns, trends, or anomalies indicative of fraud, waste, or 

abuse; and
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• To the National Archives and Records Administration (NARA) or to other Federal 

government agencies pursuant to records management activities being conducted 

under the authority of 44 U.S.C. 2904 and 2906.

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.

Yes. Where the USDA controls the personally identifiable information in the SCS; use of 

that information will be governed by an appropriate routine use in Animal Health, 

Disease, and Pest Surveillance and Management System, USDA/APHIS-15. APHIS VS 

works with State authorities on data protection through the use of Non-Disclosure 

Agreements (NDAs), Interconnection Security Agreements (ISAs), Memorandum of 

Understandings (MOUs) and other agreements.

5.3 How is the information shared outside the Department and what 

security measures safeguard its transmission? 

State Animal Health users have access within VS SCS to all data for the state in which 

they reside. This is compatible with the original collection and the published SORN. 

For any information sent in an external report, the privacy information is redacted. When 

the external recipient is under contract with USDA Non-Disclosure Agreements are used 

to prevent unauthorized information transfer. When the external recipient is a university or 

research partner, the information is transmitted via a secured web service component.

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

privacy risks identified and describe how they were mitigated. 

Unauthorized disclosure of employee and other personal information, as identified in 

Section 1.1 above, is the primary privacy risk to information shared externally to the 

USDA. This risk has been mitigated for USDA initiated sharing through technical and 

procedural information security controls levied on external holders and through the use of 

NDAs, ISAs, MOUs and other agreements. The data access of state users is restricted to 

users within their state. Data is shared only for the authorized purposes identified in the 

Privacy Act. VS technical staff receives training on the handling and management of 

personally identifiable information. All proposed new instances of sharing PII with 

external parties, must be reviewed/approved by VS Executive Leadership, the VS 

Authorizing Official and APHIS Information Security Branch.

Section 6.0 Notice 
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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? 

Information is collected on approved OMB-approved forms. This PIA is published on the 

USDA website that is accessible by the public.

A System of Record Notice (APHIS -15) was published in the Federal Register on 

November 28, 2011. An update to this SOR is currently ongoing Departmental review. 

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

information? 

Individuals must provide certain information in order to receive animal health services 

from the APHIS. There is no law requiring individuals to provide information, unless they 

are requesting a service or product from APHIS. Further, individuals involved in animal 

disease investigations are required to provide information as governed by specific animal 

health laws and regulations of the state in which they reside.

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

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

No. The data are treated uniformly for all submitters. Once the information is submitted it 

is subject to all routine uses.

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. 

The System of Record Notice is the official notice. No information is collected without an 

individual’s awareness. At the time of data collection, an individual is entering data into a 

paper form or the individual is speaking with a Federal or State employee who is directly 

entering the information into a form. Information pertains to health status and location of 

an individual’s animals.

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? 
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Individuals seeking notification of and access to any record contained in this system of 

records, or seeking to contest its content, may submit a request in writing to the APHIS 

Privacy Act Officer, 4700 River Road Unit 50, Riverdale, MD 20737 or by email: 

APHISPrivacy@usda.gov. If an individual believes more than one USDA component 

maintains Privacy Act records concerning him or her, the individual may submit the 

request to the Chief Privacy Act Officer, Department of Agriculture, 1400 Independence 

Avenue, SW, Washington, DC 20250.

7.2 What are the procedures for correcting inaccurate or erroneous 

information? 

Members of the public are advised to submit requests to correct inaccurate or erroneous to 

the APHIS Privacy Office, as indicated above.

7.3 How are individuals notified of the procedures for correcting their 

information? 

Individuals are notified of procedures by the animal health officials at the point of data 

collection.

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

individual? 

Individuals seeking to contest or amend information maintained in the system should 

direct their requests to the address indicated in Section 7.1 above. Some information may 

be exempt from the amendment provisions, as described in the section entitled 

“Exemptions promulgated for the system.” An individual who is the subject of a record in 

this system may seek amendment of those records that are not exempt. A determination

whether a record may be amended will be made at the time a request is received.

7.5 Privacy Impact Analysis: Please discuss the privacy risks associated 

with the redress available to individuals and how those risks are 

mitigated. 

The primary risk associated with the redress process is that the request for redress might 

be delayed. If the written request is delivered to the address as stated in Section 7.4, and 

then requested by the APHIS Privacy Office, VS is mandated to comply with Privacy 

requirements. VS makes every attempt to act on requests by conducting rapid reviews of 

the request and coordinating a response with the Privacy Office to ensure that requested 

timeframes are met.

Section 8.0 Technical Access and Security 

The following questions are intended to describe technical safeguards and security measures. 
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8.1 What procedures are in place to determine which users may access 

the system and are they documented? 

Access to VS SCS is based on the need to conduct business with USDA and is approved 

by an authorized APHIS VS official. Criteria, procedures, and controls are documented. 

Access must be requested in writing and approved by the supervisor or APHIS authorizing 

official. 

Once access is authorized, users of VS SCS information are further controlled through 

electronic role-based access. The system is integrated with USDA eAuthentication 

application and requires level 2 authenticated access. Users must have a government 

issued login and password that is controlled and managed either at the Veterinary Services 

district or local VS offices or in the case of local State databases the State Veterinarian’s 

office. Password controls, procedures, responsibilities and policies follow USDA 

departmental standards.

8.2 Will Department contractors have access to the system? 

VS IT contractors are provided access only as needed to perform the requirements of a 

given contract. Contractors are involved in the design and development of VS SCS. 

Privacy clauses are included in the associated contracts. Contractors provide 3rd tier 

production support for the application. Contractors are required to pass the USDA 

Information Security Awareness training and sign a Rules of Behavior agreement.

8.3 Describe what privacy training is provided to users either generally 

or specifically relevant to the program or system? 

All APHIS employees provided access to VS SCS 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. VS system owners and 

technical staff are required to complete PII training each year.

8.4 Has Certification & Accreditation been completed for the system or 

systems supporting the program? 

VS SCS renewed its Authority to Operate (ATO) on September 30, 2020 by completing 

an Assessment and Authorization. The ATO for this system will be renewed on or before 

September 30, 2023.

8.5 What auditing measures and technical safeguards are in place to 

prevent misuse of data? 

Formal auditing measures for VS SCS will include security assessments performed by 

USDA APHIS at least annually and independent security assessments performed in 

support of Certification and Accreditation efforts. The independent assessments will be 

performed per the timeframe of VS SCS Re-certification. 
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As to technical safeguards:

• The VS SCS is continuously monitored in several different ways. MRP Azure Cloud 

systems are scanned every thirty days to identify possible threats. The vulnerabilities 

identified are required to be remediated by the responsible parties. 

• Security related incidents are reported to the ISSM and the OCIO Application Security 

Operations Division (ASOD) and requires an investigation. MRP Information 

Technology and USDA ASOD work together to respond and handle all incidents. 

• Operational technical safeguards to prevent data misuse begin with access control. 

Access to VS SCS information is protected by role-based access which is managed by 

the network firewall, eAuthentication, and VS SCS. Users must have a government 

issued login and password that is controlled and managed by MRP Information 

Technology. Password controls, procedures, responsibilities and policies follow 

USDA departmental standards. At most sites, responsibility and scope of data access 

is defined by users’ job descriptions. Policy dictates that a user may not ‘selfnominate’ themselves for access. Requests for access must come from their supervisor 

or other authorized animal health official. 

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? 

Unauthorized disclosure of employee and other personnel information, as identified in 

Section 1.1 above, is the primary privacy risk to information shared both internally and 

externally to the USDA. This risk is mitigated through technical and procedural 

information security controls levied on internal and external holders of VS SCS data. VS 

SCS, MRP Azure Cloud GSS and DISC GSS technical security controls are delineated in 

the current USDA APHIS VS SCS System Security Plan.

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 VS SCS is a major application (MA) that collects, manages, and evaluates animal 

health data for disease management and surveillance programs.

9.2 Does the project employ technology which may raise privacy 

concerns? If so please discuss their implementation. 
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VS SCS 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. VS SCS 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. VS SCS 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. VS SCS 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. VS SCS 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? 

Not applicable. VS SCS 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?
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Not applicable. VS SCS 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. VS SCS 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. VS SCS does not use third party websites or applications.

10.10 Does the system use web measurement and customization technology?

Not applicable. VS SCS does not use third party websites or applications.

If so, is the system and procedures reviewed annually to demonstrate compliance to 

OMB M-10-23?

Not applicable. VS SCS does not use third party websites or applications.

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?

No, 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. 

This application does not employ technology which may raise privacy concerns.
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Responsible Officials

Orlando Baca

System Owner

United States Department of Agriculture

Approval Signature 

________________________________ 

Orlando Baca

System Owner 

Animal and Plant Health Inspection Service 

United States Department of Agriculture

________________________________ 

Preston Griffin

Information System Security Program Manager 

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