USDA
Privacy Impact Assessment
(PIA)
Price Support Systems
(PSS)
Electronic Loan Deficiency Payments
Revision: 1.03
Farm Service Agency
Date: July 23, 2009
Page ii
Date: July 23, 2009
Document Information
Owner Details
Name
Fred Gustafson
Contact Number
(816) 926-2137
Fred.Gustafson@kcc.usda.qov
E-mail Address
Document Revision and History
Revision
Date
Author
Commen~
Draft .0 l
07/21/09
T. Ostrander
1.01
07/22/09
T. Ostrander
1.02
7/23/09
Dave Goodman
Update by application point of contact
1.03
7~3~9
D.Brizendine
Document review
Page iii
Changed 24, 25, 26, 26.1
Date: July 31, 2009
Table of Contents
1
PURPOSE OF DOCUMENT ................................................................................................1
2
SYSTEM INFORMATION ...................................................................................................2
3 DATA INFORMATION ........................................................................................................4
3.1
Data Collection ....................................................................................................................4
3.2
Data Use ...............................................................................................................................5
6
3.3 Data Retention .....................................................................................................................
3.4
Data Sharing ........................................................................................................................
7
3.5 Data Access ..........................................................................................................................7
3.6
Customer Protection ...........................................................................................................
8
4
1
SYSTEM OF RECORD .........................................................................................................
5
TECHNOLOGY .....................................................................................................................1
6
COMPLETION INSTRUCTIONS .......................................................................................2
Page iv
Date: July 31,2009
1 Purpose of Document
USDA DM 3515-002 states: "Agencies are responsible for initiating the PIA in the early stages
of the development of a system and to ensure that the PIA is completed as part of the required
System Life Cycle (SLC) revie~vs. Systems include data from applications housed on
mainframes, personal computers, and applications developed for the Web and agency databases.
Privacy must be considered when requirements are being analyzed and decisions are being made
about data usage and system design. This applies to all of the development methodologies and
system life cycles used in USDA.
Both the system owners and system developers must work together to complete the PIA. System
owners must address what data are used, how the data are used, and who will use the data.
System owners also need to address the privacy implications that result from the use of new
technologies (e.g., caller identification). The system developers must address ~vhether the
implementation of the owner’s requirements presents any threats to privacy."
Re Privacy Impact Assessment (PIA) document contains information on how the Electronic
Loan Deficiency Payments affects the privacy of its users and the information stored within. This
assessment is in accordance with NIST SP 800-37 Guide for the Security Certification and
Accreditation of Federal Information Systems.
Page !
Date: July 23, 2009
2 System Information
System Information
Agency:
Farm Service Agency
System Nan~e:
Electronic Loan Deficiency Payments
System Type:
[] Major Application
[] General Support System
[] Non-major Application
System Categorization
(per FIPS 199):
[] High
[] Moderate
[] Low
To establish eligibility the applicant/producer is required to visit their local
FSA Service Center (SC) where program eligibility data is determined and
recorded. The Internet-based eLDP application process can subsequently
be accessed by the producer using an electronic Authentication (eAuth)
assigned identification and password, or entered by a SC employee on
behalf of the producer. The eLDP request is submitted for processing and
once the payment request is certified, funds are automatically routed by
electronic funds transfer to the producer’s direct deposit account. This
typically occurs within 48 hours. Listings of processed transactions are
viewable online by SC and Kansas City Finance Office (KCFO)
accounting personnel. Notification to producers is forwarded immediately
via email to confirm the receipt of an eLDP application.
Description of System:
This application allows FSA to provide agricultural producers with more
convenient, efficient, and flexible services while reducing the amount of
prompt payment interest paid by the Commodity Credit Corporation (CCC)
to producers in the process.
Who owns this system?
(Nanae, agency, contact
information)
Fred Gustafson
(816) 926-2137
Fred.Gustafson(~,kcc.usda.~ov
Who is the security
contact for this system?
(Name, agency, contact
information)
Brian Davies
Information System Security Program Manager (ISSPM)
U.S. Department of Agriculture
Farm Service Agency
1400 Independence Avenue SW
Washington, D.C. 20250
(202) 720-2419
brian.davies,~,wdc.usda.~ov
Page 2
Date: July 31, 2009
Who completed this
document? (Name,
agency, contact
information)
Page 3
David Goodman
(816) 926-2136
David.Goodman(~kcc usda.~ov
Date: July 31, 2009
3 Data Information
3.1 Data Collection
Soo
Response
Question
Electronic Loan Deficiency Payments
(eLDP)-Web:
Social Security/Tax ID Number, name,
address, entity type.
Cotton receipt data, acreage/production
data, AGI/Permitted Entity and
Eligibility data.
1
Generally describe the data to be used in the
system.
2
Does the system collect Social Security
Numbers (SSNs) or Taxpayer Identification
Numbers (TINs)?
[] Yes
[] No - If NO, go to question 3.
2.1
State the law or regulation that requires the
collection of this information.
FSA Accounting systems require SSN in order
to issue payments.
3
ls the use of the data both relevant and
necessary to the purpose for which the system
is being designed? In other words, the data is
absolutely needed and has significant and
demonstrable bearing on the system’s purpose
as required by statute or by Executive order of
he President.
[] Yes
4
Sources of the data in the system.
SCIMS (name & address), COPS (cotton
receipt data), Compliance (acreage data), AGI
& Eligibility web services.
4.1
7qhat data is being collected from the
customer?
Acreage/Production information
Eligibility information
Producer information
Customer profile - including Social
Security/Tax 1D Number, name, address.
4.2
What USDA agencies are providing data for
use in the system?
SCIMS (name & address), COPS (cotton
receipt data), Compliance (acreage data), AGI
& Eligibility web services, all originating
from FSA.
4.3
What state and local agencies are providing
data for use in the system?
From what other third party sources is data
being collected?
n/a
4.4
Page 4
[] No
laJa
Date: July 31, 2009
5
Response
Question
No.
Will data be collected from sources outside [] Yes
your agency? For example, customers, USDA[] No - If NO, go to question
sources (i.e., NFC, RD, etc.) or Non-USDA
sources.
5.1
How will the data collected from customers beReasonability checks through eligibility and
verified for accuracy, relevance, timeliness, profile processes (i.e. certification).
and completeness?
5.2
How will the data collected from USDA
sources be verified for accuracy, relevance,
timeliness, and completeness?
5.3
How will the data collected from non-USDA Reasonability checks through eligibility and
sources be verified for accuracy, relevance, profile processes (i.e. certification).
:imeliness, and completeness?
Profile and application disbursement
certification,
3.2 Data Use
Question
[
Response
6
The
Individuals must be informed in writing of the FSA Cooperative Marketing Association
principal purpose of the infomaation being System (CMA) is a National Computer
collected from them. What is the principal System that is designed, maintained and
operated to allow marketing cooperatives the
purpose of the data being collected?
ability to provide Cooperative Marketing
Associations (CMAs) and Loan Servicing
Agents (LSAs) timely and accurate eligibility,
farm record and payment limitation .data i~
order to determine producer eligibility for
obtaining marketing assistance loans, loans
and loan deficiency payments (LDP) through
CMA’s, LSAs and DMAs.
7
Will the data be used for any other purpose?
7.1
What are the other purposes?
8
[] Yes
Is the use of the data both relevant and
necessary to the purpose for which the system [] No
is being designed? In other words, the data is
absolutely needed and has significant and
demonstrable bearing on the system’s purpose
as required by statute or by Executive order of
the President
Page 5
[] Yes
[] No - If NO, go to question 8.
Date: July 31,2009
Response
No.
Question
[] Yes
9 Will the system derive new data or create
previously unavailable data about an individnal No - lfNO, go to question 10.
[]
through aggregation from the information
collected (i.e., aggregating farm loans by zip
codes in which only one farm exists.)?
9.1
Will the new data be placed in the individual’s] Yes
[
record (customer or employee)?
[] No
9.2
Can the system make determinations about
customers or emp!oyees that would not be
possible without the new data?
9.3
S
How will the new data be verified for relevance ystem and manual validations.
and accuracy?
[] Yes
[] No
Individuals must be informed in writing of the o report/track payments by entity/producer.
T
routine uses of the information being collected
from them. What are the intended routine uses
of the data being collected?
11 Will the data be used for any other uses (routine [] Yes
or otherwise)?
[] No - lfNO, go to question 12.
10
11.1 What are the other uses?
12 Automation of systems can lead to the
[] Yes
consolidation of data - bringing data from
[] No- lfNO, go to question 13.
multiple sources into one central
location!system - and consolidation of
adminlstfafive controis~ When adthinistrative
controls are consolidated, they should be
evaluated so that all necessary privacy controls
remain in place to the degree necessary to
continue to control access to and use of the
data. Is data being consolidated?
12.l What controls are in place to protect the data
and prevent unauthorized access?
13
Are processes being consolidated?
Profile and application disbursement
certification.
[] Yes
[] No - If NO, go to question 14.
13.1 What controls are in place to protect the data eAuthentication and role-based authorization.
and prevent unauthorized access?
3.3 Data Retention
Noel
Question
Is the data periodically purged from the
system?
Page 6
t
ResPonse
[] Yes
[] No - If NO, go to question 15.
Date: July 31, 2009
Question
No. i
14.1 How long is the data retained whether it is on
~aper, electronic, in the system or in a backup? Indefinitely.
Response
What are the procedures for purging the data at Data is retained indefinitely; however data can
be archived on removable media.
the end of the retention period?
RFA documents.
14.3 Where are these procedures documented?
14.2
15
While the data is retained in the system, what As per FSA Policy and Procedures.
are the requirements for determining if the data
is still sufficiently accurate, relevant, timely,
and complete to ensure fairness in making
determinations?
16
Is the data retained in the system the minimum Yes
[]
necessary for the proper performance of a
[] No
documented agency function?
3.4 Data Sharing
17
17.1
Will other agencies share data or have access to Yes
[]
data in this system (i.e., international, federal,[] No - If NO, go to question 18.
state, local, other, etc.)?
How will the data be used by the other agency?
17.2
Who is responsible for assuring the other
agency properly uses the data?
18
Is the data transmitted to another agency or an [] Yes
independent site?
[] No - If NO, go to question 19.
18.1
Is there appropriate agreement in place to
document the interconnection and ensure the
PII and/or Privacy Act data is appropriately
~rotected?
19
ls the system operated in more than one site? [] Yes
[] No - If NO, go to question 20.
19.1
How will consistent use of the system and data
be maintained in all sites?
3.5 Data Access
No~ [
20
Page 7
Question
Response
Who will have access to the data in the system UsersfManagers access data through a web(i.e., users, managers, system administrators, based interface.
developers, etc.)?
Date: July 31, 2009
NO.
Response
Question
eAuthentication (Usemame/Password) &
EAS authorization process maintained by
Security staff:
21
How will user access to the data be
determined?
21.1
[] Yes
Are criteria, procedures, controls, and
responsibilities regarding user access
[] No
documented?
How will user access to the data be restricted? Producer can only obtain information on
his/her application. State, County, and
National employees have role-based access.
22
22.1
23
[] Yes
Are procedures in place to detect or deter
browsing or unauthorized user access?
[] No
Does the system employ security controls to [] Yes
make information unusable to unauthorized [] No
individuals (i.e., encryption, strong
mthentication procedures, etc.)?
3.6 Customer Protection
No. ]
Question
I
Response
Who will be responsible for protecting the USDAPrivacyOffice
privacy rights of the customers and employees
affected by the interface (i.e., office, person,
departmental position, etc.)?
ttow c-aa customers and employees-contact the:By Contacting John Under~o0di2yivacy~,.- "
O
office or person responsible for protecting their fficer, atjohn.underwood(~kcc.usda.gov&
816.926.6992
privacy rights?
[] Yes - If YES, go to question 27.
26 A "breach" refers to a situation where data
and!or information assets are unduly exposed. Common FSA incident reporting process.
Is a breach notification policy in place for this[] No
system?
24
26.!
If NO, please enter the Plan of Action and
vlilestones (POA&M) number with the
~stimated completion date.
27
[] Yes
Consider the following:
[] No - If NO, go to question 28.
Consolidation and linkage of files and
systems
Appeal process (manual not system driven)
Derivation of data
Accelerated information processing and
decision making
Use of new technologies
Is there a potential to deprive a customer of due
process rights (fundamental rules of fairness)?
Page 8
Date: July 31, 2009
NO, ’
Question
27.1
Explain how this will be mitigated?
28
How will the system and its use ensure
equitable treatment of customers?
Response
All users use the same system... System
cannot be circumvented unless through
manual intervention.
[
29 Is there any possibility of treating customers or ] Yes
employees differently based upon their
[] No - If NO, go to question 30
ndividual or group characteristics?
None, all users use the same system.
29.1 Explain
Page 9
Date: July 31, 2009
4 System of Record
No.
Question
Response
30 Can the data be retrieved by a personal
[] Yes
identifier? In other words, does the system [] No - lfNO, go to question 31
actually retrieve data by the name of an
individual or by some other unique number,
symbol, or identifying attribute of the
individual?
30.1 How will the data be retrieved? In other words, SSN or SCIMS unique I.D.
what is the identifying attribute (i.e., employee
number, social security number, etc.)?
30.2 Under which Systems of Record (SOR) notice USDA/PSA-2 - Farm Records File
does the system operate? Provide number,
Automated)
name and publication date. (SORs can be
viewed at www.access.GPO.gov.)
30.3 If the system is being modified, will the SOR [] Yes
require amendment or revision?
[] No
Page I
Date: July 23, 2009
5 Technology
No.
Question
Response
31
Is the system using technologies in ways not [] Yes
previously employed by the agency (e.g.,
[] No - If NO, the questiormaire is complete.
Caller-ID)?
31.1
How does the use of this technology affect
customer privacy?
Page 1
Date: July 23, 2009
6 Completion Instructions
Upon completion of this Privacy Impact Assessment for this system, the answer to OMB A-11,
Planning, Budgeting, Acquisition and Management of Capital Assets, Part 7, Section E, Question
8c is:
1. Yes.
PLEASE SUBMIT A COPY TO THE OFFICE OF THE ASSOCIATE CHIEF INFORMATION
OFFICE FOR CYBER SECURITY.
Page 2
Date: July 31, 2009
