ML24260A145
| ML24260A145 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/2024 |
| From: | Office of the Chief Human Capital Officer, NRC/OCIO, Oasis Systems |
| To: | |
| Bobryakova N | |
| References | |
| Download: ML24260A145 (20) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment Workforce Transformation and Tracking System (WTTS)
Office of the Chief Human Capital Officer (OCHCO) /
Office of the Chief Information Officer (OCIO)
Version 1.0 07/17/2024 Template Version 2.2 (05/2024)
Workforce Transformation and Tracking System (WTTS)
Version 1.0 Privacy Impact Assessment 07/17/2024 Document Revision History Date Version PIA Name/Description Author 7/17/2024 1.0 Workforce Transformation and Tracking System (WTTS) - Initial Release OCHCO / OCIO Oasis Systems, LLC 06/25/2024 DRAFT Workforce Transformation and Tracking System (WTTS) - Draft Release OCHCO / OCIO Oasis Systems, LLC
Workforce Transformation and Tracking System (WTTS)
Version 1.0 Privacy Impact Assessment 07/17/2024 Table of Contents 1
Description 1
2 Authorities and Other Requirements 3
3 Characterization of the Information 4
4 Data Security 6
5 Privacy Act Determination 8
6 Records and Information Management-Retention and Disposal 9
7 Paperwork Reduction Act 12 8
Privacy Act Determination 13 9
OMB Clearance Determination 14 10 Records Retention and Disposal Schedule Determination 15 11 Review and Concurrence 16
Workforce Transformation and Tracking System (WTTS)
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The agency is subject to the requirements of the E-Government Act and is committed to identifying and addressing privacy risks whenever it develops or makes changes to its information systems. The questions below help determine any privacy risks related to the E-Government Act or later guidance by the Office of Management and Budget (OMB) and the National Institute of Standards and Technology (NIST).
Name/System/Subsystem/Service Name: Workforce Transformation and Tracking System (WTTS).
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): WTTS is hosted and operated by the U.S. Department of the Interior (DOI) Interior Business Center (IBC).
Date Submitted for review/approval: September 13, 2024.
1 Description 1.1 Provide the description of the system/subsystem, technology (i.e., Microsoft Products), program, or other data collections (hereinafter referred to as project).
Explain the reason the project is being created.
The Workforce Transformation and Tracking System (WTTS) is a federal shared service provided to federal agencies by the Department of the Interior (DOI) Interior Business Center (IBC).
The U.S. Nuclear Regulatory Commission (NRC) personnel specialists use WTTS to initiate, authorize, and track recruitment, hiring, and onboarding activities. WTTS allows the NRC Office of the Chief Human Capital Officer (OCHCO) to create and track vacancies and assign, monitor, and approve forms filled out by new hires. WTTS enables real-time data exchange via encrypted web connections with other NRC authorized applications such as FPPS, NRCareers (Monster Hiring Management Enterprise), and the Electronic Official Personnel Folder (eOPF).
Please mark appropriate response below if your project/system will involve the following:
PowerApps Server/Database Design Dashboard Public Website SharePoint Internal Website Cloud Service Provider Other Web-based system hosted and operated by DOI/IBC
Workforce Transformation and Tracking System (WTTS)
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1.2 Does this privacy impact assessment (PIA) support a proposed new project, proposed modification to an existing project, or other situation? Select options that best apply in table below.
Mark appropriate response.
Status Options
New system/project
Modification to an existing system/project.
If modifying or making other updates to an existing system/project, provide the ADAMS ML of the existing PIA and describe the modification.
Annual Review If making minor edits to an existing system/project, briefly describe the changes below.
This PIA was separated from Federal Personnel Payroll System (FPPS), Workforce Transformation and Tracking System (WTTS), Entrance on Duty System (EODS) Privacy Impact Assessment(ML23339A180) to have an individual PIA for WTTS.
Other (explain) 1.3 Points of
Contact:
Project Manager System Owner/Data Owner/
Steward ISSM Business Project Manager Technical Project Manager Executive Sponsor Name John Shea Eric Dilworth Natalya Bobryakova Brendan Cain John Shea Eric Dilworth Office
/Division
/Branch Office of the Chief Human Capital Officer (OCHCO) /
Human Capital Analysis Branch (HCAB)
Office of the Chief Human Capital Officer (OCHCO)
Office of the Chief Information Officer (OCIO)
/ Cyber and Infrastructure Security Division (CISD) /
Information Assurance and Oversight Branch (IAOB) /
Information Assurance Team (IAT)
Office of the Chief Human Capital Officer (OCHCO) /
Human Capital Analysis Branch (HCAB)
Office of the Chief Human Capital Officer (OCHCO) /
Human Capital Analysis Branch (HCAB)
Office of the Chief Human Capital Officer (OCHCO)
Telephone 301-415-0246 240-381-9983 301-287-0671 301-287-0545 301-415-0246 240-381-9983
Workforce Transformation and Tracking System (WTTS)
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2 Authorities and Other Requirements 2.1 What specific legal authorities and/or agreements permit the collection of information for the project?
Provide all statutory and regulatory authorities for operating the project, including the authority to collect the information; NRC internal policy is not a legal authority. Please mark appropriate response in table below.
Mark with an X on all that apply.
Authority Citation/Reference
Statute
Executive Order Pub. L. 104-193, Personal Responsibility and Work Opportunity Reconciliation Act of 1996; 5 United States Code (U.S.C.) 6334; 31 U.S.C. 716, 1104, 1105,1108, 3325, 3511, 3512. 3701, 3711, 3713, 3718; Executive Order 9397; and 42 U.S.C.
2000e-16.
Federal Regulation
Memorandum of Understanding/Agreement
Other (summarize and provide a copy of relevant portion) 2.2 Explain how the information will be used under the authority listed above (i.e., enroll employees in a subsidies program to provide subsidy payment).
WTTS supports the federal hiring process and reduces the duplication of information that is collected during the hiring process. Information about new hires or selectees is gathered once and is disseminated to other authorized systems that use the data.
If the project collects Social Security numbers, state why this is necessary and how it will be used.
N/A.
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3 Characterization of the Information In the table below, mark the categories of individuals for whom information is collected.
Category of individual
Federal employees
Contractors
Members of the Public (any individual other than a federal employee, consultant, or contractor)
Licensees
Other In the table below, is a list of the most common types of PII collected. Mark all PII that is collected and stored by the project/system. If there is additional PII not defined in the table below, a comprehensive listing of PII is provided for further reference in ADAMS at the following link: PII Reference Table 2023.
Categories of Information
Name
Resume or curriculum vitae
Date of Birth
Driver's License Number
Country of Birth
License Plate Number
Citizenship
Passport number
Nationality
Relatives Information
Race
Taxpayer Identification Number
Home Address
Credit/Debit Card Number
Social Security number (Truncated or Partial)
Medical/health information
Gender
Alien Registration Number
Ethnicity
Professional/personal references
Spouse Information
Criminal History
Personal e-mail address
Biometric identifiers (facial images, fingerprints, iris scans)
Personal Bank Account Number
Emergency contact e.g., a third party to contact in case of an emergency
Personal Mobile Number/Home Number
Accommodation/disabilities information
Marital Status
Children Information
Mother's Maiden Name
Other: WTTS/EODS stores new hire employment forms including personnel, benefits, and payroll forms, direct deposit bank information, benefits elections, beneficiary forms, federal income tax withholding information, and federal/military service records.
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3.1 Describe how the data is collected for the project. (i.e., NRC Form, survey, questionnaire, existing NRC files/ databases, response to a background check).
HR Specialists enter information directly into WTTS. Additionally, select information is populated from NRCareers through secure encrypted web interconnections operated by DOI/IBC.
3.2 If using a form (paper or web) to collect the information, provide the form number, title and/or a link to the form.
Federal employees provide the information on forms required during the application and onboarding process. The federal employment forms to collect the information from an individual to be considered for federal employment include.
OF-306, Declaration for Federal Employment I-9, Employment Eligibility Verification Fair Credit Reporting Release 3.3 Who provides the information? Is it provided directly from the individual or a third party.
The information is self-reported by the subject individual.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
The NRC OCHCO and payroll staff perform various functions to check data for accuracy and completeness. In some cases, the information provided by individuals is not verified, and the individual providing the information is responsible for the accuracy of the information.
Employees review their Earnings and Leave Statement in Employee Express, and they are responsible for verifying the accuracy and correctness of data (pay, deductions, leave, and home address) and reporting any errors to OCHCO staff in a timely manner. Annual audits of data and records are also performed.
3.5 Will PII data be used in a test environment? If so, explain the rationale for this and how the PII information is protected.
N/A.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous privacy information?
Employees have different methods to correct data, including updated HR forms or the use of Employee Express to initiate personnel and payroll actions.
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4 Data Security 4.1 Describe who has access to the data in the project (i.e., internal NRC, system administrators, external agencies, contractors, public).
The authorized staff from all NRC offices and Regions have access to the systems.
4.2 If the project/system shares information with any other NRC systems, identify the system, what information is being shared and the method of sharing.
WTTS enables real-time data exchange via encrypted web connections with other NRC authorized applications such as FPPS, NRCareers (Monster Hiring Management Enterprise),
and the Electronic Official Personnel Folder (eOPF).
4.3 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.
If so, identify what agreements are in place with the external non-NRC partner or system in the table below.
Agreement Type
Contract
License
Memorandum of Understanding Provide ADAMS ML number for MOU: Interconnection Security Agreement (ISA) and Memorandum of Understanding (MOU) Between the Nuclear Regulatory Commission (NRC) and Department of the Interior (DOI) for FPPS and HRMS, ML21265A519
Other
None 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.
The same credentials are used to access WTTS, which also utilizes user roles to enforce different levels of permissions.
4.5 Explain how the data is transmitted and how confidentiality is protected (i.e.,
encrypting the communication or by encrypting the information before it is transmitted).
WTTS information is transmitted using secure, encrypted web connections.
4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).
WTTS is operated by DOI/IBC at their data center in Denver. It is housed in the same facility as FPPS. For WTTS, NRC users connect via the DOI managed router at NRC Headquarters in Rockville, MD.
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4.7 Explain if the project can be accessed or operated at more than one location.
N/A.
4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?
DOI/IBC is responsible for all design, development, and maintenance of the systems. DOI/IBCs contractors supporting the systems and performing system maintenance and other related activities have access to the systems. They do not possess an NRC badge.
4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
Technical safeguards in place include separation of duties, unique IDs and passwords, and annual audits of the system.
Access is limited based on job functions and/or assigned roles and enforced by the Resource Access Control Facility Time Sharing Option for FPPS and by ColdFusion for WTTS. An audit record of all user activity is created.
4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,
trace/track/observe) individuals.
N/A.
4.11 Define which FISMA boundary this project is part of.
NRCs WTTS is a subsystem of Third-Party System (TPS).
4.12 Is there an Authority to Operate (ATO) associated with this project/system?
Authorization Status
Unknown
No If no, please note that the authorization status must be reported to the Chief Information Security Officer (CISO) and Computer Security Organization (CSOs)
Point of Contact (POC) via e-mail quarterly to ensure the authorization remains on track.
In Progress provide the estimated date to receive an ATO.
Estimated date:
Yes NRCs Authority to Operate (ATO) for Third Party System (TPS) and WTTS was granted as an ongoing authorization on March 21, 2018 (ML18299A325).
Indicate the data impact levels (Low, Moderate, High, Undefined) approved by the Chief Information Security Officer (CISO)
Confidentiality-Moderate Integrity-Moderate Availability-Moderate
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4.13 Provide the NRC system Enterprise Architecture (EA)/Inventory number. If unknown, contact EA Service Desk to get the EA/Inventory number.
WTTS is a subsystem of TPS. The EA number for TPS is 20180002.
5 Privacy Act Determination 5.1 Is the data collected retrieved by a personal identifier?
Mark the appropriate response.
Response
Yes, the PII is retrieved by a personal identifier (i.e., individuals name, address, SSN, or other unique number, etc.)
List the identifiers that will be used to retrieve the information on the individual.
A set of standard reports satisfy most inquiries. Additional reports are created as needed. Information can be retrieved on WTTS reports by: WTTS record ID, report type, WTTS status, selectee last name, organization code, entrance on duty date, position title, series, supervisor/hiring official ID, employee type (permanent/non-permanent), vacancy announcement number, record modified date, or fiscal year.
No, the PII is not retrieved by a personal identifier.
If no, explain how the data is retrieved from the project.
5.2 For all collections where the information is retrieved by a personal identifier, the Privacy Act requires that the agency publish a System of Record Notice (SORN) in the Federal Register. As per the Privacy Act of 1974, "the term 'system of records' means a group of any records under the control of any agency from which information is retrieved by the name of the individual or by some other personal identifier assigned to the individual.
Mark the appropriate response in the table below.
Response
Yes, this system is covered by an existing SORN. (See existing SORNs:
https://www.nrc.gov/reading-rm/foia/privacy-systems.html )
Provide the SORN name, number, (List all SORNs that apply):
NRC 21 - Payroll Accounting Records (84 FR 71552)
NRC 11 - Reasonable Accommodations Records (84 FR 71545)
OPM/Govt General Personnel Records OPM/Govt Recruiting, Examining and Placement Records
SORN is in progress
SORN needs to be created
Unaware of an existing SORN
No, this system is not a system of records and a SORN is not applicable.
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5.3 When an individual is asked to provide personal data (i.e., form, webpage, survey), is a Privacy Act Statement (PAS) provided?
A Privacy Act Statement is a disclosure statement required to appear on documents used by agencies when an individual is asked to provide personal data. It is required for any forms, surveys, or other documents, including electronic forms, used to solicit personal information from individuals that will be maintained in a system of records.
Mark the appropriate response.
Options
Privacy Act Statement
Not Applicable
Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?
The individuals have the option of not providing information on forms required during the application and onboarding process. However, employees are required by law to provide certain types of information, such as name and SSN as a part of the employment process and to allow personnel, payroll and time and attendance processing. Declining to provide the information that is required from an individual to be considered for federal employment may affect the employment eligibility and selection of the individual.
6 Records and Information Management-Retention and Disposal The National Archives and Records Administration (NARA), in collaboration with federal agencies, approves whether records are Temporary (eligible at some point for destruction/deletion because they no longer have business value) or Permanent (eligible at some point to be transferred to the National Archives because of historical or evidential significance). Records/data and information with historical value, identified as having a permanent disposition, are transferred to the National Archives of the United States at the end of their retention period. All other records identified as having a temporary disposition are destroyed at the end of their retention period in accordance with the NARA Records Schedule or the General Records Schedule.
These determinations are made through records retention schedules and NARA statutes (44 United States Code (U.S.C.), 36 Code of Federation Regulations (CFR)). Under 36 CFR, agencies are required to establish procedures for addressing Records and Information Management (RIM) requirements. This includes strategies for establishing and managing recordkeeping requirements and disposition instructions before approving new electronic information systems or enhancements to existing systems.
The following questions are intended to determine whether the records/data and information in the system have approved records retention schedules and disposition instructions, whether the
Workforce Transformation and Tracking System (WTTS)
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If the project/system:
Does not have an approved records retention schedule and/or Does not have an automated RIM functionality, Involves a cloud solution, And/or if there are additional questions regarding Records and Information Management
- Retention and Disposal, please contact the NRC Records staff at ITIMPolicy.Resource@nrc.gov for further guidance.
If the project/system has a record retention schedule or an automated RIM functionality, please complete the questions below.
6.1 Does this project map to an applicable retention schedule in NRCs Comprehensive Records Disposition Schedule (NUREG-0910), or NARAs General Records Schedules?
NUREG-0910, NRC Comprehensive Records Disposition Schedule
NARAs General Records Schedules
Unscheduled 6.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.
System Name (include sub-systems, platforms, or other locations where the same data resides)
Workforce Transformation and Tracking System (WTTS)
Records Retention Schedule Number(s)
Approved Disposition Instructions N/A (See table below on page 14)
Is there a current automated functionality or a manual process to support RIM requirements?
This includes the ability to apply records retention and disposition policies in the system(s) to support records accessibility, reliability, integrity, and disposition.
N/A Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
Workforce Transformation and Tracking System (WTTS)
Version 1.0 Privacy Impact Assessment 07/17/2024 PIA Template (05-2024)-ML050460335 11 Disposition of Permanent Records Will the records be exported to an approved format and transferred to the National Archives based on approved retention and disposition instructions?
If so, what formats will be used?
NRC Transfer Guidance (Information and Records Management Guideline - IRMG)
N/A GRS 2.1 item 050 - Job Vacancy Case Files.
Records of one-time competitive and Senior Executive Service announcements/ selections.
Temporary. Destroy 2 years after selection certificate is closed or final settlement of any associated litigation; whichever is later.
GRS 2.1 item 051 - Job Vacancy Case Files.
Records of standing register competitive files for multiple positions filled over a period of time.
Temporary. Destroy 2 years after termination of register.
GRS 2.1 item 060 - Job Application Packages Temporary. Destroy 1 year after date of submission.
GRS 2.1 Item 010 - Classification Standards Temporary. Destroy 2 years after selection certificate is closed or final settlement of any associated litigation whichever is later.
GRS 2.2 item 050 - Notification of personnel actions Temporary. Destroy when business use ceases.
(Exclusion: Standard Form (SF) SF-50s filed in the OPF. Items 040 and 041 of GRS 2.2 cover these records).
GRS 2.5 item 050 - Phased retirement administrative records Temporary. Destroy when 3 years old or 3 years after revision or replacement, as appropriate, but longer retention is authorized if required for business use.
GRS 2.3 item 020 - Reasonable or religious accommodation case files.
Temporary. Destroy 3 years after employee separation from the agency or all appeals are concluded, whichever is later, but longer retention is authorized if required for business use.
GRS 2.1 item 050 Records of delegation of authority for examination and certification.
Temporary. Destroy 3 years after agreement terminates but longer retention is authorized if required for business use.
Workforce Transformation and Tracking System (WTTS)
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GRS 2.1 item 051 -- Job Vacancy Case Files.
Records of one-time competitive and SES announcements/elections.
Temporary. Destroy 2 years after termination of register.
OPM Form 4896 is obsolete and the entire work process no longer exists.
GRS 2.2 item 072 - Employee performance file system records. Records of senior executive service employees.
Temporary. Destroy no sooner than 5 years after date of appraisal, but longer retention is authorized if required for business use.
7 Paperwork Reduction Act The Paperwork Reduction Act (PRA) of 1995 requires that agencies obtain an Office of Management and Budget (OMB) approval in the form of a "control number"before promulgating a paper form, website, surveys, questionnaires, or electronic submission from 10 or more members of the public. If the data collection is from federal employees regarding work-related duties, then a PRA clearance is not necessary.
7.1 Will the project be collecting any information from 10 or more persons who are not Federal employees?
Yes, the information is collected from job applicants who may be not Federal employees.
7.2 Is there any collection of information addressed to all or a substantial majority of an industry (i.e., Fuel Fabrication Facilities or Fuel Cycle Facilities)?
No.
7.3 Is the collection of information required by a rule of general applicability?
No.
Note: For information collection (OMB clearances) questions: contact the NRCs Clearance Officer. Additional guidance can be found on the NRCs internal Information Collections Web page at: https://intranet.nrc.gov/ocio/33456.
Workforce Transformation and Tracking System (WTTS)
Version 1.0 Privacy Impact Assessment 07/17/2024 PIA Template (05-2024)-ML050460335 13 8 Privacy Act Determination Project/System Name: Workforce Transformation and Tracking System (WTTS)
Submitting Office: Office of the Chief Human Capital Officer (OCHCO) /
Office of the Chief Information Officer (OCIO)
Privacy Officer Review Review Results Action Items
This project/system does not contain PII.
No further action is necessary for Privacy.
This project/system does contain PII; the Privacy Act does NOT apply, since information is NOT retrieved by a personal identifier.
Must be protected with restricted access to those with a valid need-to-know.
This project/system does contain PII; the Privacy Act does apply.
SORN is required-Information is retrieved by a personal identifier.
Comments:
Covered by NRC 21 - Payroll Accounting Records (84 FR 71552), NRC 11 - Reasonable Accommodations Records (84 FR 71545), OPM/Govt General Personnel Records, OPM/Govt Recruiting, Examining and Placement Records Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 11/14/24
Workforce Transformation and Tracking System (WTTS)
Version 1.0 Privacy Impact Assessment 07/17/2024 PIA Template (05-2024)-ML050460335 14 9 OMB Clearance Determination NRC Clearance Officer Review Review Results
No OMB clearance is needed.
OMB clearance is needed.
Currently has OMB Clearance. Clearance No.
3150-0260, 3206-0182, 1615-0047 for the forms listed in 3.2 and NRCareers.
Comments:
If WTTS collects information directly from individuals, it needs a clearance. If the system is populated using only previously collected information, it does not need a clearance.
Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 11/14/24
Workforce Transformation and Tracking System (WTTS)
Version 1.0 Privacy Impact Assessment 07/17/2024 PIA Template (03-2024)-ML050460335 15 10 Records Retention and Disposal Schedule Determination Records Information Management Review Review Results
No record schedule required.
Additional information is needed to complete assessment.
Needs to be scheduled.
Existing records retention and disposition schedule covers the system - no modifications needed.
Comments:
Reviewers Name Title Sr. Program Analyst, Electronic Records Manager Signed by Dove, Marna on 11/13/24
Workforce Transformation and Tracking System (WTTS)
Version 1.0 Privacy Impact Assessment 07/17/2024 PIA Template (03-2024)-ML050460335 16 11 Review and Concurrence Review Results
This project/system does not collect, maintain, or disseminate information in identifiable form.
This project/system does collect, maintain, or disseminate information in identifiable form.
I concur with the Privacy Act, Information Collections, and Records Management reviews.
Director Chief Information Security Officer Cyber Information Security Division Office of the Chief Information Officer Signed by Nalabandian, Garo on 11/14/24
Workforce Transformation and Tracking System (WTTS)
Version 1.0 Privacy Impact Assessment 07/17/2024 PIA Template (03-2024)-ML050460335 17 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Workforce Transformation and Tracking System (WTTS)
Date CISD received PIA for review:
September 13, 2024 Date CISD completed PIA review:
November 5, 2024 Action Items/Concerns:
Recommend review of the MOU/ISA at next opportune time to determine DOI plans to transition of ColdFusion for WTTS access.