PRIVACY IMPACT ASSESSMENT (PIA)

PRESCRIBING AUTHORITY: DoD Instruction 5400.16, "DoD Privacy Impact Assessment (PIA) Guidance". Complete this form for Department of Defense
(DoD) information systems or electronic collections of information (referred to as an “electronic collection" for the purpose of this form) that collect, maintain, use,
and/or disseminate personally identifiable information (Pil) about members of the public, Federal employees, contractors, or foreign nationals employed at U.S.
military facilities internationally. In the case where no Pil is collected, the PIA will serve as a conclusive determination that privacy requirements do not apply to
system.

1, DOD INFORMATION SYSTEM/ELECTRONIC COLLECTION NAME:
(U) Intelligence Community Badge System (ICBS)

2. DOD COMPONENT NAME: 3,PIA APPROVAL DATE:
jational Geospatial-Intelligence Agency ' 11/18/19

Industrial and Physical Security (SISI)

CTION 1: Pil DESCRIPTION SUMMARY (FOR PUBLIC RELEASE)
a. The Pll is: (Check one. Note: foreign nationals are included in general public.)

(C1 From members of the general public [From Federal employees and/or Federal contractors

IES From both members of the general public and Federal employees and/or o

Federal contractors Not Collected (if checked proceed to Section 4)

b. The Pll is in a: (Check one)

Oo New DoD Information System New Electronic Collection

{CJ Existing DoD Information System [X] _ Existing Electronic Collection

[1 Significantly Modified DoD Information System

c. Describe the purpose of this DoD information system or electronic collection and describe the types of personal information about individuals
collected in the system.

(U) The ICBS provides seamless entry control point access at participating Intelligence Community (IC) facilities. Individual IC agencies

maintain complete control of badge operations within their respective agency. IC personnel badge data can be shared through ICBS over a

secure network allowing access to enter participating agencies at entry control points using existing badge and personal identification number

(PIN). ICBS collects and stores personally identifiable information (PII) such as name, social security number, PIN, organization, and other

uniquely identifying data elements to validate access.

d. Why is the Pll collected and/or what is the intended use of the Pll? (e.g., verification, identification, authentication, data matching, mission-related use,
administrative use)

(U) The ICBS interface specifications are documented in the ICBS Specification published by NGA, which defines the format for all ICBS

records. This record format includes numerous mandatory fields including First Name, Last Name, SSN, Badge ID (LCN), PIN, Badge

Creation Date, Badge Expiration Date, Owning Agency, etc. SSN is one of the key mandatory fields for participation in the ICBS, as it is

the primary field used for identification and validation of individuals entering IC facilities.

@. Do individuals have the opportunity to object to the collection of their PII? O Yes [R] No
(1) If "Yes," describe the method by which individuals can object to the collection of Pll.

(2) If "No," state the reason why individuals cannot object to the collection of Pll.

(U) NGA operations require all individuals to be issued an IC badge or Common Access Card (CAC) as part of their employment. Non
consent would result in denial of access to the IC facilities and information systems.

f. Do individuals have the opportunity to consent to the specific uses of their Pil? [] Yes [X] No
(1) If"Yes," describe the method by which individuals can give or withhold their consent.

(2) If "No," state the reason why individuals cannot give or withhold their consent.

(U) Any individual tssued a IC badge or Common Access Card (CAC) is advised of their Privacy Act Statement (PAS) and their rights and
responsibilities prior to issuing badges for facility access.

g. When an individual is asked to provide Pll, a Privacy Act Statement (PAS) and/or a Privacy Advisory must be provided. (Check as appropriate and
provide the actual wording.)

Privacy Act Statement (Privacy Advisory [X] Not Applicable

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h. With whom will the Pil be shared through data exchange, both within your DoD Component and outside your Component? (Check all that apply)

National Geospatial-Intelligence Agency, Industrial and
Physical Security (SISI)

Shared across the Department of Defense/Intelligence
Community Agencies to include National Security Agency
(NSA); Defense Intelligence Agency (DIA); National
Reconnaissance Office (NRO); Office of Naval Intelligence
[k] Other DoD Components Specify. |(ONI); Marine Corps Intelligence Activity (MCIA); U.S.
Army Intelligence and Security Command (INSCOM);
Headquarters U.S. Department of the Air Force (HQ
USAF); U.S. Naval Security Group Command (NSG); and
U.S. Coast Guard (USCG).

All non- Department of Defense (DoD) components
designated as Intelligence Community (IC) Agencies to
include Central Intelligence Agency (CIA); Department of
Energy (DoE); Department of State (DOS/INR); Department

Within the DoD Component Specify.

Other Federal Agenci Specify. A
& eral Agencies pecily. of Homeland Security (DHS); Department of Treasury;
Drug Enforcement Administration (DEA); Federal Bureau
of Investigation (FBI); and Office of the Director of
National Intelligence (DNI).
[21 State and Local Agencies Specify. |
Contractor (Name of contractor and describe the language in
oO the contract that safeguards Pll. Include whether FAR privacy Specity.
clauses, i.¢., 52.224-1, Privacy Act Notification, 52.224-2, pecily.

Privacy Act, and FAR 39.105 are included in the contract.)

1 other (e.g., commercial providers, colleges). Specify. |

i. Source of the PIl collected is: (Check all that apply and list all information systems if applicable)
Individuals [1 Databases

[X] Existing DoD Information Systems [1 Commercial Systems

(1 Other Federal information Systems

National Security Agency (NSA) - the Executive Agent for all Intelligence Community (IC) partners that participate in using the ICBS and
SMS systems.

j. How will the information be collected? (Check all that apply and list all Official Form Numbers if applicable)

OO Email [L1_ Official Form (Enter Form Number(s) in the box below)
1 Face-to-Face Contact Paper

OO Fax [1 Telephone Interview

[&] Information Sharing - System to System 1 Website/e-Form

Other (If Other, enter the information in the box below)

DoD Form 2875 - paper forms for establishing user computer accounts and access controls and permissions on IC systems that are stored by
the NGA Security Office (SIS).

k. Does this DoD Information system or electronic collection require a Privacy Act System of Records Notice (SORN)?

A Privacy Act SORN is required if the information system or electronic collection contains information about U.S. citizens or lawful permanent U.S. residents that]
is retrieved by name or other unique identifier. PIA and Privacy Act SORN information must be consistent.

fx] Yes [No

If "Yes," enter SORN System Identifier ~[NGA003 - Agency Enterprise Workforce

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SORN Identifier, not the Federal Register (FR) Citation. Consult the DoD Component Privacy Office for additional information or http://dpcld.defense.gov/
Privacy/SORNs/
or

Ifa SORN has not yet been published in the Federal Register, enter date of submission for approval to Defense Privacy, Civil Liberties, and Transparency
Division (DPCLTD). Consult the DoD Component Privacy Office for this date

If "No," explain why the SORN is not required in accordance with DoD Regulation §400.11-R: Department of Defense Privacy Program.

|. What is the National Archives and Records Administration (NARA) approved, pending or general records schedule (GRS) disposition authority for
the system or for the records maintained in the system?

(1) NARA Job Number or General Records Schedule Authority. [GRS 3.2-031, 3.2-041, 5.

(2) Ifpending, provide the date the SF-115 was submitiedtoNARA. [sd

(3) Retention Instructions.

GRS 3.2-031 - Destroy 6 eats after password is altered or user account is terminated, but longer retention is authorized if required for

business use. GRS3.2-04T - Destroy when second subsequent backup is verified as successful or when no longer needed for system

restoration, whichever is later, GRS 5.1-020 - Destroy immediately after copying to a record-keeping system Or otherwise preserving, but

longer retention is authori
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records. For PII not collected or mai d in a system of records, the collection or maintenance of the Pll must be necessary to discharge the
requirements of a statue or Executive Order.

(1) If this system has a Privacy Act SORN, the authorities in this PIA and the existing Privacy Act SORN should be similar.
(2) Ifa SORN does not apply, cite the authority for this DoD information system or electronic collection to collect, use, maintain and/or disseminate Pll.
(If multiple authorities are cited, provide all that apply).

(@) Cite the specific provisions of the statute and/or EO that authorizes the operation of the system and the collection of Pll.

(b) If direct statutory authority or an Executive Order does not exist, indirect statutory authority may be cited if the authority requires the
operation or administration of a program, the execution of which will require the collection and maintenance of a system of records.

(©) If direct or indirect authority does not exist, DoD Components can use their general statutory grants of authority (‘internal housekeeping’) as
the primary authority. The requirement, directive, or instruction implementing the statute within the DoD Component must be identified.

* Title 50 United States Code $402a,

+ Executive Order 9397, 10450 & 12968,

+ Federal Register 5 CFR part 732, part 736,

+ Federal Register 32 CFR part 147

+ Title 5 United States Code 301, & Title 5 United States Code 7532

+ Dept of Defense Directive 5105.60, & Dept of Defense Directive 5200.2-R

n. Does this DoD information system or electronic collection have an active and approved Office of Management and Budget (OMB) Control
Number?

Contact the Component Information Management Control Officer or DoD Clearance Officer for this information. This number indicates OMB approval to
collect data from 10 or more members of the public in a 12-month period regardless of form or format.

OO Yes [Ki No [-] Pending

(1) If "Yes," list all applicable OMB Control Numbers, collection titles, and expiration dates.

(2) If "No," explain why OMB approval is not required in accordance with DoD Manual 8910.01, Volume 2," DoD Information Collections Manual:
Procedures for DoD Public Information Collections.”

(3) If "Pending," provide the date for the 60 and/or 30 day notice and the Federal Register citation.

Per Dept of Defense Manual 8910.01" DOD Information Collection Manual: Procedures for DoD Public Information Collections.” -Vol 2,
Enclosure 3, Section 8.a (4), which is the conduct of Intelligence Activities as described in Executive Order 12333 does not require an OMB
control number.

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