United States Department of Agriculture

National Agricultural Statistics Service

NASS Survey Processing System

Privacy Impact Assessment

(PIA)

FINAL

version 2.0 

July 26, 2007 

Prepared by:

DSD Laboratories 

500 Interstate Park Drive, Suite 534 

Montgomery, Alabama 36109

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National Agricultural Statistics Service NASS Survey Processing System 

July 26, 2007 Privacy Impact Assessment

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REVISION AND HISTORY PAGE

Document Description Section/Para. # Page Revision Date Initials Version # of Change # 

1.0 06/25/2007 Initial Draft Document WCG 

2.0 07/26/2007 Revised table entries RAC 

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TABLE OF CONTENTS

Paragraph Page

REVISION EVISION ANDHISTORYPAGE .........................................................................................................................II

1 INTRODUCTION NTRODUCTION..............................................................................................................................................4

1.1 LAWS AND REGULATIONS ...........................................................................................................................4

1.2 SYSTEM DESCRIPTION.................................................................................................................................4

1.3 CONTACT INFORMATION .............................................................................................................................5

2 USDAPRIVACYIMPACTASSESSMENT SSESSMENT QUESTIONNAIRE UESTIONNAIRE ................................................................7

2.1 DATA IN THE SYSTEM..................................................................................................................................7

2.2 DATA ACCESS .............................................................................................................................................8

2.3 DATA ATTRIBUTES......................................................................................................................................8

2.4 MAINTENANCE OF ADMINISTRATIVE CONTROLS ........................................................................................9

3 SUMMARY......................................................................................................................................................11

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1 INTRODUCTION

The Privacy Impact Assessment (PIA) is a process used to evaluate the impact that the NASS Survey 

Processing System has on individuals. The PIA process is designed to guide NASS Survey Processing 

System developers and operators in assessing privacy concerns and safeguards in computer application 

systems. The PIA should be initiated in the early stages of the development of a system and completed as 

part of the required System Life Cycle (SLC) and security reviews. Privacy is one component of system 

confidentiality and must be considered when requirements are being analyzed and decisions are being 

made about data usage and system design. A PIA describes the system and its data, any specific privacy 

concerns, and safeguards established to meet privacy needs. The USDA Privacy Coordinator must be 

involved in the PIA process. 

1.1 Laws and Regulations 

• Privacy act of 1974, as Amended (5 USC 552a); 

• Computer Security Act of 1987, Public Law 100-235, ss 3 (1) and (2), codified at 15 

U.S.C. 272, 278 g-4 and 278 h; 

• Freedom of Information Act, as Amended (5 USC 552); 

• The E-Government Act of 2002, U.S.C. 3531 et seq. 

1.2 System Description 

The NASS Survey Processing System is responsible for processing survey information to provide 

timely, accurate, and useful statistics in service to U.S. Agriculture. Market Sensitive Surveys 

include but are not limited to those which cover commodities that are traded on the Futures 

exchanges and production is concentrated in a small number of states. Knowledge of sensitive 

data would allow a person to anticipate the NASS Agricultural Statistics Board reports pertaining 

to the designated commodities. 

Function: 

Agricultural statistical survey processing and reporting.

Market Sensitive Commodities (Corn, Soybeans, Cotton, Wheat, Rice, Oats, Sugar Crops, Cattle 

and Hogs) are analyzed and summarized using NASS systems and all are summarized using 

NASS’s Survey Processing System (SPS) on the Mainframe environment located at the National 

Information Technology Center (NITC) in Kansas City. 

Platform: 

Data is stored on a NITC provided mainframe, which is an IBM 2064 linked to the NASS LAN. 

Data is analyzed and summarized using NASS’s Survey Processing System (SPS) on the 

Mainframe at NITC in Kansas City. 

The mainframe system where the NASS Survey Processing System operates is logically protected 

by NITC perimeter firewalls. The firewall is used to place extra protection around a server, 

which is used to house data from the Internal Revenue Service that helps measure coverage. A 

CISCO VPN concentrator has been installed and there are test users, but this has not made this a 

production system for all remote users. NASS uses RSA tokens for users accessing the network 

remotely using their Internet Service Provider. Policies and procedures for password control, 

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rules of behavior, data segmentation and security classification have been developed for the 

system. 

Software: 

The software used for the bulk of the processing is SAS (base/AF). NITC provides an IDS 

system for continual scanning of the system for intrusions and unauthorized usage. 

The underlying IBM Mainframe operating systems is MVS-OS. The operating system of the 

NITC network support environment consists of CISCO IOS and IPSO Checkpoint is installed. 

Systems/Applications supported: 

Data is stored on a NITC provided IBM 2064 mainframe. The software used for the bulk of the 

processing is SAS (base/AF). 

User organizations: 

The reports of agricultural statistics and forecasts have a wide user base and statistical reports of 

many types must be issued in a time critical fashion. There are approximately 150 internal users 

of the systems nationwide. 

1.3 Contact Information 

(1) Who is the person completing this document? (Name, title, organization, and contact 

information). 

Name: Renato Chan 

Title: Information System Security Program Manager (ISSPM) 

Organization: NASS 

Address: 1400 Independence Ave., S.W. 

City: Washington, DC 20250 

Phone: 202-720-4068 

Email: renato_chan@nass.usda.gov 

(2) Who is the system owner? (Name, organization and contact information)

Name: Brian Lounsbury 

Title: Chief, Census and Survey Systems Branch 

Address: 1400 Independence Ave. S.W., Washington, DC 20250 

Phone: 202-720-7906 

Email: brian_lounsbury@nass.usda.gov 

(3) Who is the system manager for this system or application? (Name, organization and 

contact information)? 

Name: Debbie Williams 

Title: Head, Survey Processing Systems Section 

Address: 1400 Independence Ave. S.W., Washington, DC 20250 

Phone: 202-690-1401 

Email: deborah_williams@nass.usda.gov 

(4) Who is the IT Security Manager for this system and the contact information? 

Name: Renato Chan 

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Title: ISSPM 

Address: 1400 Independence Ave., S.W., Washington, DC 20250 

Phone: 202-720-4068 

Email: renato_chan@nass.usda.gov 

 (5) Who is the Department/Agency Privacy Act Officer/Coordinator who reviewed this 

document? (Name, organization and contact information) 

Name: Forest Chapman 

Title: Privacy Officer 

Address: 1400 Independence Ave., S.W., Washington, DC 20250 

Phone: 202-720-5221 

Email: forest_chapman@nass.usda.gov

(6) Who is the Reviewing Official (DAA)? 

Name: Jack Nealon 

Title: Director, Information Technology Division 

Address: Rm. 584, 1400 Independence Ave., S.W., Washington, DC 20250 

Phone: 202-720-2984 

Email: jack_nealon@nass.usda.gov 

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2 USDA PRIVACY IMPACTASSESSMENT QUESTIONNAIRE

2.1 Data in the System 

1. Generally describe the information to be used 

in the system in each of the following 

categories: Customer, Employee, and Other. 

The NASS Survey Processing System processes 

data that is collected from farmers and agribusinesses under a strict pledge of confidentiality. 

All information collected and processed by this 

system, including personally identifiable 

information, is protected by US Code: Title 7, 2276 

– Confidentiality of Information. 

2a. What are the sources of the information in the 

system? 

The population of farmers and agri-businesses. 

2b. What USDA files and databases are used? 

What is the source agency? 

The NASS Survey Processing System uses 

secure SAS data sets, proprietary data files from our 

CATI system Blaisé, and FoxPro files to store and 

process the data. 

2c. What Federal Agencies are providing data for 

use in the system? 

FSA. 

2d. What State and Local Agencies are providing 

data for use in the system? 

None. 

2e. From what other third party sources will data 

be collected? 

InfoUSA, Universities (extension), commodity 

organizations, trade magazines. 

2f. What information will be collected from the 

customer/employee? 

The data collected are updates to existing personally 

identifiable information, such as name and address 

information, and data about their farms and agribusinesses, such as acres, economic data, and 

livestock numbers. 

3a. How will data collected from sources other 

than the USDA records and the customer be 

verified for accuracy? 

Criteria questionnaire to the individual under 

review asking them to fill in the specifics for them. 

Name information is not verified by inference from 

a source. Instead that is used to start a questionnaire 

as identified above. 

3b. How will data be checked for completeness? The NASS Survey Processing System will be 

used to perform these checks 

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2.2 Data Access 

1. Who will have access to the data in the system 

(Users, Managers, System Administrators, 

Developers, Other)? 

Data access is limited to only NASS employees 

who have a need to review the data for analytical 

purposes, and those system developers that support 

the system. Each employee must sign a pledge of 

confidentiality that carries severe legal penalties for 

violating the pledge. 

2. How is access to the data by a user determined? 

Are criteria, procedures, controls, and 

responsibilities regarding access documented? 

Access is determined by the above signed pledge of 

confidentiality and the subject area being analyzed, 

such as crops, livestock, and economic areas of 

interest. Access is documented by our Technical 

Services Branch. Computer security staff shares 

access rights with business managers to ensure 

“need-to-know” access only. 

3. Will users have access to all data on the system 

or will the user’s access be restricted? Explain. 

Users will have access to only those data needed to 

carry out their assignments. There are appropriate 

managerial controls for this purpose. 

4. What controls are in place to prevent the 

misuse (e.g. browsing, unauthorized use) of 

data by those having access? 

All NASS employees must sign a pledge of 

confidentiality that carries severe legal penalties for 

violating the pledge. Also the system has design 

features that allow only employees working on the 

particular subject area to gain access. 

5a. Do other systems share data or have access to 

data in this system? If yes, explain. 

No. 

5b. Who will be responsible for protecting the 

privacy rights of the customers and employees 

affected by the interface. 

N/A. 

6a. Will other agencies share data or have access to 

data in this system (International, Federal, 

State, Local, and Other)? 

No. 

6b. How will the data be used by the agency? It will only be used for statistical purposes. 

6c. Who is responsible for assuring proper use of 

the data? 

The NASS Deputy Administrator for Products and 

Programs. 

2.3 Data Attributes 

1. Is the use of the data both relevant and 

necessary to the purpose for which the system 

is being designed? 

Yes. 

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2a. Will the system derive new data or create 

previously unavailable data about an individual 

through aggregation from the information 

collected? 

No. 

2b. Will the new data be placed in the individual’s 

record (customer or employee)? 

N/A. 

2c. Can the system make determinations about 

customers or employees that would not be 

possible without the new data? 

No. 

2d. How will the new data be verified for relevance 

and accuracy? 

N/A. 

3a. If data is being consolidated, what controls are 

in place to protect the data from unauthorized 

access or use? 

The same controls that are in place for the raw data 

collected from farmers and agri-businesses. In this 

case consolidation refers to the normal process of 

aggregation of statistical data and not personally 

identifiable information. 

3b. If processes are being consolidated, are the 

proper controls remaining in place to protect 

the data and prevent unauthorized access? 

Explain. 

N/A. 

4a. How will the data be retrieved? Can it be 

retrieved by personal identifier? If yes, 

explain. 

Yes. The information is processed, prior to 

statistical aggregation, at the personal identifier 

level. In the case of the NASS Survey Processing 

System, a unique ID is assigned to each respondent, 

and that ID is used to retrieve and analyze the data. 

4b. What are the potential effects on the due 

process rights of customers and employees of: 

Our data providers have full protection and due 

process rights under US Code: Title 7, 2276 – 

Confidentiality of Information. None of the items 

listed here can be used to violate these rights to due 

process. 

• consolidation and linkage of files and 

systems; 

• derivation of data 

• accelerated information processing and 

decision making; 

• use of new technologies. 

4c. How are the effects to be mitigated? See above. 

2.4 Maintenance of Administrative Controls 

1a. Explain how the system and its use will ensure 

equitable treatment of customers and 

employees. 

The privacy and confidentiality of all data providers 

are covered equally by US Code: Title 7, 2276. 

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2a. If the system is operated in more than one site, 

how will consistent use of the system and data 

be maintained in all sites? 

This system operates in both a centralized 

mainframe environment and a distributed LAN 

environment. The NASS Survey Processing System 

is administered and controlled from our HQ site. 

Data processed in our Field Offices must meet the 

same rigor applied to our centralized mainframe 

environment. An extensive set of policy 

memoranda, instructions, and technical review 

teams that make regular site visits maintain the 

necessary consistency needed for statistical analysis 

and aggregation. 

2b. Explain any possibility of disparate treatment 

of individuals or groups. 

This possibility does not exist because of the 

statistical use of the data. 

2c. What are the retention periods of data in this 

system? 

Data is retained as long as the information is needed 

for survey data editing, analysis, estimation, and 

sampling. Data are retained for ten to fifteen years 

in electronic form. 

2d. What are the procedures for eliminating the 

data at the end of the retention period? Where 

are the procedures documented? 

Data are expunged from electronic systems, and 

paper questionnaires are either sent to the National 

Archives or shredded. The documentation for these 

procedures is stored in our policy and procedures 

manuals and instructions. They can be found in our 

HQ library and in our Field Offices. 

2e. While the data is retained in the system, what 

are the requirements for determining if the data 

is still sufficiently accurate, relevant, timely, 

and complete to ensure fairness in making 

determinations? 

Data are used only for statistical purposes and are 

deemed accurate, relevant, timely, and complete for 

such purposes as are necessary for the publication 

of statistical reports. 

3a. Is the system using technologies in ways that 

the USDA has not previously employed (e.g. 

Caller-ID)? 

No. 

3b. How does the use of this technology affect 

customer/employee privacy? 

N/A. 

4a. Will this system provide the capability to 

identify, locate, and monitor 

No 

individuals? If 

yes, explain. 

4b. Will this system provide the capability to 

identify, locate, and monitor 

No. 

groups of people? 

If yes, explain. 

4c. What controls will be used to prevent 

unauthorized monitoring? 

All NASS employees must sign a pledge of 

confidentiality that carries severe legal penalties for 

violating the pledge. Also the system has design 

features that allow only employees working on the 

particular subject area to gain access. 

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5a. Under which Systems of Record notice (SOR) 

does the system operate? Provide number and 

name. 

Only a few items on the survey questionnaires 

qualify under the Privacy Act of 1974 as systems of 

records. This system operates under USDA/NASS1 Agricultural Survey Records. 

5b. If the system is being modified, will the SOR 

require amendment or revision? Explain. 

If the scope of the personal data maintained is 

modified, the System of Record will be modified, 

accordingly. 

3 SUMMARY

This assessment describes the privacy concerns of the NASS Survey Processing System and its data. As 

privacy is one the components of system confidentiality this PIA must be considered anytime 

requirements are being analyzed and decisions are being made about data usage, security and system 

design. 

 

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