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NIOSH Radiation Dose Reconstruction Program








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            Cybersecurity Modernization Initiative
                We are taking steps to continue to modernize and secure our data, applications, and systems. We completed the first phase and restored many of the functions put on pause in May 2021. Now that the first phase is complete, work will resume at a slower pace but will speed up as new systems and applications are brought online. For more information and updates, please visit our Cybersecurity Modernization Initiative web page.
								

				Handling Sensitive Data						Print
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			Controlled Unclassified InformationClassified InformationDOE Review for Classified and Controlled Unclassified InformationNIOSH's Department of Energy Classification Review of DocumentsNIOSH's Data Access and Interview ProceduresPrivacy Act and PIIPolicy Documents
		
The Department of Health and Human Services (HHS) manages all data collected by NIOSH employees and contractors under the EEOICPA or the Act. This includes data obtained from the Department of Energy (DOE) and its contractors. Some of this data may be sensitive in nature.
NIOSH is committed to protecting the personal information of our claimants and others involved in the program, as well as data important to our country’s safety.
NIOSH employees and contractors follow data storage and handling plans, procedures, policies, and regulations to safeguard these types of information:
Controlled unclassified information—any unclassified information that, if improperly disclosed, modified, or deleted, could adversely affect the national interest, the conduct of federal initiatives, or the privacy of individuals
Classified information—that available only to authorized people, for reasons of national security
Personally Identifiable Information (PII)—information that can be used to distinguish or trace an individual’s identity (such as a, name, Social Security number, or date of birth)Controlled Unclassified Information
Controlled unclassified information has relative sensitivity and requires protection because of statutory or regulatory restrictions.
Examples of Controlled Unclassified Information:
**Unclassified Controlled Nuclear Information (UCNI):** certain unclassified but sensitive government information concerning nuclear material, weapons, and weapons components. The dissemination of such information is controlled under Section 148 of the Atomic Energy Act of 1954 and it must be protected from release to the general public.
**Official Use Only (OUO):** unclassified information that is confidential (that is, cannot be discarded in the open trash, made available to the general public, or posted on an uncontrolled website). It can, however, be shared with individuals on a need-to-know basis. The public release of this information has the potential to damage governmental, commercial, or private interests by making it available to persons other than those who need it to perform their jobs or other contractual obligations. This information must be protected from public release and must fall under at least one of the Freedom of Information Act (FOIA) exemptions.
**Export Controlled Information (ECI):** information that is not necessarily classified but does require a technology export license or authorization. DOE requires an ECI review before public release of information.Controlled unclassified information requires a degree of protection because inadvertent or deliberate misuse, alteration, disclosure, or destruction could adversely affect national security or other governmental interests (such as program-critical information or controlled scientific and technical information, which might include computer programs used to process such information).
The NIOSH policy document OCAS-PLCY-0001: Handling Controlled Unclassified Information [74 KB (17 pages)] details the handling of controlled unclassified information.
The policy covers these topics:
access (such as authorized individuals, eligibility)
use (such as authority to use the information per the Act)
protection requirements (such as encryption, passwords)
reproduction (such as printing, copying)
transmission (such as by mail, email, phone, hand)
storage (such as locked buildings, rooms, file cabinets, desks, bookcases)
destruction (document disposal such as shredding)Classified Information
Classified information is available only to authorized NIOSH employees and contractors. NIOSH uses unclassified information as much as possible to evaluate exposure potential or to develop models for dose reconstructions.
However, classified information is used when necessary and appropriate such as:
when information is missing and there are no other unclassified sources for it
when information from unclassified sources is incomplete, unsubstantiated, implausible, or inadequate; lacks data integrity; or is plainly erroneousThe NIOSH policy document DCAS-IG-005: Use of Classified Information [184 KB (10 pages)] details the criteria for the use of classified information.
The policy covers topics such as:
when classified information is necessary and appropriate
data capture guidelines for both classified and unclassified information
hierarchy of data sources used in dose reconstruction
Advisory Board’s handling of classified information
handling classified information in the Special Exposure Cohort (SEC) petition processDepartment of Energy Review for Classified and Controlled Unclassified Information
NIOSH requests information from DOE to complete dose reconstructions. DOE understands that NIOSH employees and contractors need to have access to classified and controlled unclassified information, but ensures that the requests are necessary and appropriate. DOE also ensures that classified and controlled unclassified information critical to our national security is kept safe.
DOE developed a plan for such purposes, detailed in the U.S. Department of Energy Office of Health, Safety and Security – Security Plan for the Energy Employees Occupational Illness Compensation Program.
This plan serves to:
identify the security roles and responsibilities of DOE, DOL (Department of Labor), and NIOSH employees and their contractors;
describe the security procedures to be followed by all parties; and
establish processes for resolving security issues as they arise.The DOE/HSS Security Plan balances the need for protecting classified and controlled unclassified information with the need to fairly settle compensation cases. DOE declassifies, decontrols, redacts, and reviews documents as necessary per this security plan and the document-handling procedures described below.
NIOSH’s Department of Energy Classification Review of Documents
The NIOSH Department of Energy Classification Review of Documents [38 KB (6 pages)] outlines the steps required to coordinate the review of documents by a DOE classification office.
The procedure applies to all documents associated with covered DOE and atomic weapons employer (AWE) work sites under the Act, such as the following:
Technical Basis Documents
Site Profiles
SEC Evaluation Reports
Meeting minutes
Personal interviewsNIOSH’s Data Access and Interview Procedures
The NIOSH/OCAS-PR-010: Data Access and Interview Procedures [301 KB (14 pages)] outlines the steps required to coordinate and submit data requests to DOE and to conduct interviews. Interviews of current and former workers are sometimes necessary to understand work practices and radiation monitoring. The document also outlines steps to ensure the protection of sensitive information during reviews.
Privacy Act and Personally Identifiable Information (PII)
The Privacy Act of 1974 protects records that contain personal identifiable information (PII). NIOSH protects all PII per Office of Management and Budget (OMB) guidelines, regulations, and policies.
PII can be used to distinguish or trace an individual’s identity and includes the following:
Name
Social Security number
Date and place of birth
Mother’s maiden name
Biometric recordsThe Privacy Act serves to:
prohibit disclosure of PII records without the written consent of the individual (unless one of the 12 disclosure exceptions apply)
govern the Federal government’s
collection,
usage,
dissemination, and
storage of PII information.
focus on protecting the rights of individuals, such as the right to:
access their records,
request amendment of incorrect records, and
find out how their information is being used.
bind only Federal agencies (that is, it covers only records in the possession and control of Federal agencies).More information on the Privacy Act and its administration at NIOSH can be found on the HHS FOI/Privacy Acts Division Website.
Protection of Information during Transmission
The following requirements apply to data transmitted between agencies:
Data stored on removable media (CD, DVD, USB Flash Drives, etc.) must be protected with use of certified encryption products.
Passwords must meet the current password requirements.
Removable media must be sent by express overnight service with required signature and tracking.
Data files containing PII that are being sent by e-mail must be encrypted with certified encryption products.
Passwords used to encrypt data files must be sent separately from the encrypted data files (in a separate e-mail, telephone call, or letter).
Websites established for submission of information that includes PII must use certified encryption methods.
Remote access to systems and databases that contain PII must require two-factor authentication for logon access control.In addition to other reporting requirements, the loss or suspected loss of PII must be reported immediately upon discovery.
More information on protecting PII can be found in the following Memorandum of Understanding documents concerning DOE and DOL.
Memorandum of Understanding between the U.S. Department of Health and Human Services and the U.S. Department of Energy [2 MB (13 pages)]
Memorandum of Understanding between the U.S. Department of Health and Human Services and the U.S. Department of Labor [1.2 MB (9 pages)]
Policy DocumentsAtomic Energy Act of 1954 (Section 148)
DOE/HSS Security Plan for EEOICPA
Department of Health and Human Services FOI/Privacy Acts Division
Memorandum of Understanding between the U.S. Department of Health and Human Services and the U.S. Department of Energy [2 MB (13 pages)]
Memorandum of Understanding between the U.S. Department of Health and Human Services and the U.S. Department of Labor [1.2 MB (9 pages)]
NIOSH/OCAS-PR-010: Data Access and Interview Procedures [301 KB (14 pages)]
NIOSH/OCAS-PR-011: Department of Energy Classification Review of Documents [38 KB (6 pages)]
NIOSH/OCAS-PLCY-0001: Handling Controlled Unclassified Information [74 KB (17 pages)]
NIOSH/DCAS-IG-005: Use of Classified Information [184 KB (10 pages)]
Privacy Act of 1974
							
					
							Last Reviewed:  June 30, 2022						Source: 	National Institute for Occupational Safety and Health
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        Syndicate homeRadiation Dose ReconstructionAbout DCASThe Act/EEOICPADose Reconstruction (DR)plus iconDataplus iconSourcesFormats & TypesSensitive DataWork History                            Phone CallData Search and Capture EffortsMethodsProductionTechnical Documents Used in Dose ReconstructionsProgram Evaluation Reports and PlansQuality Assurance and Quality ControlSupport ContractorSoftware (IMBA)RECA ClaimsProbability of Causationplus iconCalculating PCNews & UpdatesNIOSH-IREP SoftwareSpecial Exposure Cohortplus iconSubmit a PetitionCheck Petition Statusplus iconSEC Status TableGet HelpResidual ContaminationAdvisory Boardplus iconPublic MeetingsSubcommittee and Work GroupsSEC Petition RecommendationsTechnical Support for the Review of NIOSH Dose Reconstruction ProgramReports from the Advisory Board's Technical Support ContractorTechnical Review Summaries from the Technical Support ContractorProceduresCorrespondenceWork Site InformationPublications & ProductsProgram ReviewsReports to CongressPolicies, Procedures, and GuidelinesNIOSH Public DocketRelated Program LinksContact UsHELPplus iconHelp A – ZAccessibilityAcronymsFrequently Asked Questions (FAQs)plus iconThe ActCase ConcernsClaimant CorrespondenceConflict or BiasDose ReconstructionFreedom of Information Act (FOIA)National Defense Authorization ActNIOSH-IREPProbability of CausationResidual Contamination ReportResponsibilities under Subtitle B of EEOICPA (The Act)Special Exposure CohortTechnical DocumentsWork History Phone CallGlossary Follow NIOSH Facebook
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