Risk Management Agency
USDA
Privacy Impact Assessment
For
RMA UNIX and Business Applications
April 2007
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Name of Project:
Program Office:
Project’s Unique ID:
A. CONTACT INFORMATION:
1. Who is the person completing this document?
Eric Baer, RMA ISSPM
6501 Beacon Dr, MS 0835
Kansas City, MO 64133
(816) 823-1950
eric.baer@rma.usda.gov
2. Who is the system owner?
Vondie W. O’Conner Jr., RMA CIO
6501 Beacon Dr, MS 0800
Kansas City, MO 64133
(816) 823-4459
Vondie@rma.usda.gov
2. Who is the system manager for this system or application?
Denise Hoffmann, Director Program Analysis and Accounting Division
6501 Beacon Dr
Kansas City, MO 64133
(816) 926-3406
denise.hoffmann@rma.usda.gov
4. Who is the IT Security Manager who reviewed this document?
See #1
5. Did the Chief FOI/PA review this document?
Terrie Ray, FIOA
1400 Independence Ave. SW MS 0801
Washington D.C., 20250
(202) 690-5701
terrie.ray@rma.usda.gov
6. Did the Agency’s Senior Office for Privacy review this document? (Name, office,
and contact information).
7. Who is the Reviewing Official?
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See #2
B. SYSTEM APPLICATION/GENERAL INFORMATION:
1. Does this system contain any information about individuals?
(a) Is this information identifiable to the individual?
Yes
(b) Is the information about individual members of the public?
Yes
(c) Is the information about employees?
No
2. What is the purpose of the system/application?
This group of applications processes the reinsurance activities of the Federal Crop
Insurance Corporation. It contains functions that validate the data received from the
Approved Insurance Providers, compare the requests for valid entries, and processes
requests for payment.
3. What legal authority authorizes the purchase or development of this
system/application?
This system is authorized under the Federal Crop Insurance Act.
C. DATA in the SYSTEM:
1. Generally describe the type of information to be used in the system and what
categories of individuals are covered in the system?
The type of information used is that concerning participants in the Crop Insurance
Program, their coverage and loss. Also included is insurance agent and adjustor
information, financial information from the Approved Insurance Providers (AIP), and
other insurance related data.
2. What are the sources of the information in the system?
(a) Is the source of the information from the individual or is it taken from
another source? If not directly from the individual, then what other
source?
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The data is taken directly from the source by the AIP and provided to
RMA. RMA does not directly take the data. The data is collected on official FCIC
forms.
(b) What Federal agencies are providing data for use in the system?
RMA only.
(c) What State and local agencies are providing data for use in the system?
(d) From what other third party sources will data be collected?
Data regarding agents, adjustors, and the AIP financial data is collected
from the AIP.
(e) What information will be collected from the employee and the public?
Typically, the information collected from the public includes name, farm
program information (e.g., crops, acreage, etc.), and SSN.
3. Accuracy, Timeliness, and Reliability
(a) How will data collected from sources other than USDA records be verified
for accuracy?
There is a validation process that runs when data is input (Data
Acceptance System) that validates all information prior to the used by RMA.
(b) How will data be checked for completeness?
The same Data Acceptance System will reject any incomplete information.
It is a financial incentive for the AIP to ensure that data transferred to RMA is
accurate and complete.
(c) Is the data current? What steps or procedures are taken to ensure the data is
current and not out-of-date? Name the document (e.g., data models).
(d) Are the data elements described in detail and documented?
Yes, required data elements are documented in Appendix 3 of the
Standard Reinsurance Agreement.
D. ATTRIBUTES OF THE DATA:
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1. Is the use of the data both relevant and necessary to the purpose for which the
system is being designed?
Yes. The SSN is required for interaction with Treasury and is specified in
the Standard Reinsurance Agreement and the Federal Crop Insurance Act.
2. Will the system derive new data or create previously unavailable data about an
individual through aggregation from the information collected, and how will
this be maintained and filed?
No.
3. Will the new data be placed in the individual’s record?
N/A
4. Can the system make determinations about employees/public that would not be
possible without the new data?
No. Although the data received is partially transmitted to the Strategic
Data Analysis Data Warehouse for data mining to detect fraud, waste, or abuse, that
activity is covered under another PIA.
5. How will the new data be verified for relevance and accuracy?
N/A
6. If the data is being consolidated, what controls are in place to protect the data
from unauthorized access or use?
The resultant databases are protected by the use of Access Control Lists
derived from the operating system.
7. If processes are being consolidated, are the proper controls remaining in place to
protect the data and prevent unauthorized access? Explain.
The processes being consolidated all derive or directly use controls that
are inherent to the operating system.
8. How will the data be retrieved?
Data is retrieved using custom Web or client based reports, depending on the
group requesting the reports.
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9. What kinds of reports can be produced on individuals? What will be the use of
these reports? Who will have access to them?
Reports can be generated that are for ineligible producers or fro those that
owe a debt to the Federal Government.
10. What opportunities do individuals have to decline to provide information (i.e.,
where providing information is voluntary) or to consent to particular uses of
the information (other than required or authorized uses and how individuals
can grant consent.)
An opportunity to decline to give that information is provided on the
Privacy Act statement on the Crop Insurance Application.
E. MAINTENANCE AND ADMINISTRATIVE CONTROLS:
1. If the system is operated in more than one site, how will consistent use of the
system and data be maintained in all sites?
The system is operated in one site, with the alternate site being restored
with data from the primary site. The data at the alternate site is currently a week old.
2. What are the retention periods of data in this system?
Data is maintained indefinitely for statistical purposes.
3. What are the procedures for disposition of the data at the end of the retention
period? How long will the reports produced be kept? Where are the procedures
documented?
N/A
4. Is the system using technologies in ways that the USDA has not previously
employed (e.g., monitoring software, Smart Cards, Caller-ID)?
No
5. How does the use of this technology affect public/employee privacy?
6. Will this system provide the capability to identify, locate, and monitor
individuals? If yes, explain.
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Yes. This system will track participation in the Federal Crop Insurance
Program. Most data is aggregated for statistical purposes and is not individually
identifiable however.
7. What kinds of information are collected as a function of the monitoring of
individuals?
8. What controls will be used to prevent unauthorized monitoring?
Access control lists are used to prevent internal abuse or misuse. There is
a comprehensive security program that prevents unauthorized external access. This
includes access control lists, properly maintained systems, and firewalls.
9. Under which Privacy Act systems of records notice does the system operate?
Provide number and name.
FCIC-1:
FCIC-3:
FCIC-5:
FCIC-6:
FCIC-7:
FCIC-8:
FCIC-9:
FCIC-10:
FCIC-11:
Accounts Receivable
Crop Insurance Actuarial Listing
Rejected Applications
Insurance Contract Analysis
Insurance Contract Files
List of Ineligible Producers
Agent
Policyholder
Loss Adjuster
10. If the system is being modified, will the Privacy Act system of records notice
require amendment or revision? Explain.
They system of records notices are being modified to include the use of
the CIMS project.
F. ACCESS TO DATA:
1. Who will have access to the data in the system?
Access to the system is granted to contractors (in the role of developers),
and Federal Employees that have a specific need to access this specific data in the
course of their duties. AIPs have access to data that they submitted.
2. How is access to the data by a user determined?
Access is granted by access control lists that are arranged by job function. The
supervisor and database/system administrator must approve access.
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3. Will users have access to all data on the system or will the user’s access be
restricted? Explain.
Access is restricted by job function. It is only granted on a least privileged basis.
4. What controls are in place to prevent the misuse (e.g., unauthorized browsing) of
data by those having access?
Users are expected to follow RMA and USDA security and privacy policy.
Access is restricted by access control lists and by a layered security approach on the
external interfaces of the network (e.g firewalls). An additional firewall separates the
General Support System (And hence the applications) from the office automation
(Windows General Support System) portion of the network.
5. Are contractors involved with the design and development of the system and will
they be involved with the maintenance of the system?
Yes. Privacy and non-disclosure language is inserted into the contract.
Additionally, they are also expected to abide by RMA and USDA policy regarding
security and privacy.
6. Do other systems share data or have access to the data in the system? If yes,
explain.
Other then the Data Mining, which is a subset of this information, the data is not
shared.
7. Who will be responsible for protecting the privacy rights of the public and
employees affected by the interface?
The privacy rights are protected by the Office of the Chief Information Officer in
RMA, which includes the Information Security Branch.
8. Will other agencies share data or have access to the data in this system (Federal,
State, Local, Other)?
The data mining initiative is part of RMA. Some data is shared with the
Department of the Treasury.
9. How will the data be used by the other agency?
The Treasury data is used to ensure payments to the AIP are processed.
Additionally, the Debt Management Application will intercept monies due a producer
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(e.g., tax refund) to pay indebtedness to the Federal Government. This data is provided
to Treasury.
10.
Who is responsible for assuring proper use of the data?
The receiving agency.
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APPENDIX A
DECLARATION OF PRIVACY PRINCIPLES
The privacy principles set forth in this declaration are based on the ethical and legal obligations
of the United States Department of Agriculture to the public and are the responsibility of all
USDA employees to recognize and treat their office as a public trust.
The obligation to protect client and partner privacy and to safeguard the information clients and
partners entrust to us is a fundamental part of the USDA’s mission to administer the law fairly
and efficiently. Clients and partners have the right to expect that the information they provide
will be safeguarded and used only in accordance with law. In recognition of these obligations,
policies and procedures must clearly state who should have access to what information and for
what purposes. In addition, appropriate limitations must be placed on the collection, use and
dissemination of clients and partners’ personal and financial information and sufficient
technological and administrative measures must be implemented to ensure the security of USDA
data systems, processes and facilities.
All USDA employees are required to exhibit individual performance that reflects a commitment
to dealing with every client and partner fairly and honestly and to respect the clients and
partners’ right to feel secure that their personal information is protected. To promote and
maintain clients and partners’ confidence in the privacy, confidentiality and security protections
provided by the USDA, the USDA will be guided by the following Privacy Principles:
Principle 1:
Protecting citizen, client and partner privacy and safeguarding confidential
citizen, client and partner information is a public trust.
Principle 2:
No information will be collected or used with respect to citizens, clients and
partners that is not necessary and relevant for legally mandated or authorized
purposes.
Principle 3:
Information will be collected, to the greatest extent practicable, directly from the
citizen, client or partner to whom it relates.
Principle 4:
Information about citizens, clients and partners collected from third parties will
be verified to the greatest extent practicable with the citizens, clients and partners
themselves before action is taken against them.
Principle 5:
Personally identifiable citizen, client or partner information will be used only for
the purpose for which it was collected, unless other uses are specifically
authorized or mandated by law.
Principle 6:
Personally identifiable citizen, client or partner information will be disposed of at
the end of the retention period required by law or regulation.
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Principle 7:
Citizen, client or partner information will be kept confidential and will not be
discussed with, nor disclosed to, any person within or outside the USDA other
than as authorized by law and in the performance of official duties.
Principle 8:
Browsing, or any unauthorized access of citizen, client or partner information by
any USDA employee, constitutes a serious breach of the confidentiality of that
information and will not be tolerated.
Principle 9:
Requirements governing the accuracy, reliability, completeness, and timeliness of
citizen, client or partner information will be such as to ensure fair treatment of all
clients and partners.
Principle 10: The privacy rights of citizens, clients and partners will be respected at all times
and every citizen, client and partner will be treated honestly, fairly, and
respectfully.
The Declaration does not, in itself, create any legal rights for clients and partners, but it is
intended to express the full and sincere commitment of the USDA and its employees to the laws
which protect client and partner privacy rights and which provide redress for violations of those
rights.
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APPENDIX B
POLICY STATEMENT ON CITIZEN, CLIENT AND PARTNER PRIVACY RIGHTS
The USDA is fully committed to protecting the privacy rights of all citizens, clients and partners.
Many of these rights are stated in law. However, the USDA recognizes that compliance with
legal requirements alone is not enough. The USDA also recognizes its social responsibility
which is implicit in the ethical relationship between the USDA and the citizen, client or partner.
The components of this ethical relationship are honesty, integrity, fairness, and respect.
Among the most basic of a citizens, clients, or partners’ privacy rights is an expectation that the
USDA will keep personal and financial information confidential. Citizens, clients and partners
also have the right to expect that the USDA will collect, maintain, use, and disseminate
personally identifiable information and data only as authorized by law and as necessary to carry
out agency responsibilities.
The USDA will safeguard the integrity and availability of citizens, clients and partners’ personal
and financial data and maintain fair information and record keeping practices to ensure equitable
treatment of all citizens, clients and partners. USDA employees will perform their duties in a
manner that will recognize and enhance individuals’ rights of privacy and will ensure that their
activities are consistent with law, regulations, and good administrative practice. In our record
keeping practices, the USDA will respect the individual’s exercise of his/her First Amendment
rights in accordance with law.
As an advocate for privacy rights, the USDA takes very seriously its social responsibility to
citizens, clients and partners to limit and control information usage as well as to protect public
and official access. In light of this responsibility, the USDA is equally concerned with the
ethical treatment of citizens, clients and partners as well as their legal and administrative rights.
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