Privacy Impact Assessment Questionnaire
Technical Information Management System (TIMS) – FY2011
Overview
- The system name and the name of the DOL component(s) which own(s) the system.
The Technical Information Management System (TIMS) is a document imaging and management support system for the Occupational Safety and Health Administration (OSHA) Directorate of Technical Support and Emergency Management (DTSEM).
- The purpose/function of the program, system, or technology and how it relates to the component’s and DOL mission
TIMS is a document imaging and management support system used by OSHA to manage and organize referenced and imaged documents and to preserve workplace evaluation records taken in areas of the country that are recovering from natural disasters. These functions are performed by the Occupational Safety and Health Response Annex (OSHRA) minor application, which is the only component of TIMS that collects and stores personally identifiable information (PII).
All of the following answers address the OSHRA minor-application only.
- A general description of the information in the system.
OSHRA records contain worker safety and industrial hygiene information collected during clean-up and recovery work following natural disasters. OSHA inspects the work areas affected by the disasters and records various information, such as location, name of contractors, and any potentially dangerous conditions. If sampling for toxic substances is conducted, the names, addresses, and phone numbers of individuals is recorded in order to contact them later and alert them to any potentially dangerous exposures.
- A description of a typical transaction conducted on the system.
Inspection records are created on site either on paper or through the use of tablet computers. If tablet computers are used, the information can be uploaded via the Internet and entered into the database.
- Any information sharing conducted by the program or system.
None.
- A general description of the modules and subsystems, where relevant, and their functions.
No subsystems are supported by TIMS.
- Where appropriate, a citation to the legal authority to operate the program or system.
OSHA is mandated by the Occupational Safety and Health Act to “assure safe and healthful working conditions for working men and women.” The OSHRA application was devised in order to help extend this aim to the unpredictable and treacherous environment that can exist after a major calamity.
- A description of why the PIA is being conducted.
The OSHRA application of the TIMS contains the names and contact information of workers who are working in a dangerous environment during clean-up operations following a natural disasters. This information is requested of the workers in order to notify them of whether they have been exposed to toxic or injurious substances.
Characterization of the Information
The following questions are intended to define the scope of the information requested and/or collected as well as reasons for its collection as part of the program, system, or technology being developed.
Specify whether the system collects personally identifiable information (PII) on DOL employees, other federal employees, contractors, members of the public (U.S. citizens), foreign citizens, or minor children.
The system collects names and contact information on working men and women. This group may include foreign citizens.
- What are the sources of the PII in the information system?
Worker safety and industrial hygiene information is collected during recovery work or clean up operations in an area that has been designated as a Disaster. The PII is collected from individuals only on a voluntary basis.
- What is the PII being collected, used, disseminated, or maintained?
Personal names and contact information such as addresses and telephone numbers voluntarily supplied by involved parties. This information is currently maintained in the TIMS database.
- How is the PII collected?
The information is collected directly from the individual at the evaluation site.
- How will the information be checked for accuracy?
It is the responsibility of the intervention team that completes the industrial hygiene evaluation to ensure that a worker’s name and contact information are entered correctly and verified.
- What specific legal authorities, arrangements, and/or agreements defined the collection of information?
- Privacy Impact Analysis
During cleanup operations the names and contact information may be collected and stored on the system in order to notify individuals of the results of toxicity sampling completed in their immediate work area. The individuals provide this information on a voluntary basis.
The PII is used by the either the OSHA Area Office or an Emergency Annex Office to contact the individual and provide them with personal exposure information.
Despite the relatively low sensitivity of this PII, the system owners understand the need to ensure that this information is protected from unauthorized access and that the system’s security controls are adequate to accomplish this. The system has been labeled “Moderate” because of the PII it contains and has an Authority to Operate (ATO) based on that classification. All of the security controls imposed by the network are an important part of this defense, including boundary defenses, Active Directory controlled settings, and protection from malicious software.
Uses of the PII
The following questions are intended to clearly delineate the use of information and the accuracy of the data being used.
- Describe all the uses of the PII
Names and contact information are used to contact individuals and provide them with the results of sampling for toxic substances conducted in their immediate work area (breathing zone).
- What types of tools are used to analyze data and what type of data may be produced?
None. Collected contact information is used solely to provide information to the tested individual.
- Will the system derive new data, or create previously unavailable data, about an individual through aggregation of the collected information?
No.
- If the system uses commercial or publicly available data, please explain why and how it is used.
N/A.
- Privacy Impact Analysis
Name and contact information are used either to contact or to confirm the identity of an individual who contacts the Agency in order to provide that individual with the results of personal sampling for toxic exposure. The contact information is only shared with Agency personnel who are directly involved with providing the exposure information to the worker. The PII is used for no other purposes.
Retention
The following questions are intended to outline how long information will be retained after the initial collection.
- How long is information retained in the system?
25 years.
- Has the retention schedule been approved by the DOL agency records officer and the National Archives and Records Administration (NARA)?
Yes.
- How is it determined that PII is no longer required?
The PII that is collected is limited to name and contact information and is given freely by the individual.
- What efforts are being made to eliminate or reduce PII that is collected, stored or maintained by the system if it is no longer required?
PII collected is very minimal and is not comprised of sensitive PII. Because there may always be a need to contact the individual (to recommend medical follow-up, for example) the Agency feels it is important to keep names of exposed individuals for a reasonable period of time.
- Privacy Impact Analysis
It is expected that the OSHRA records, including name and contact information for sampled workers will be held for a period of 25 years.
Internal Sharing and Disclosure
The following questions are intended to define the scope of sharing within the Department of Labor.
- With which internal organization(s) is the PII shared, what information is shared, and for what purpose?
PII is not expected to be shared with any other internal DOL organization.
- How is the PII transmitted or disclosed?
N/A.
- Privacy Impact Analysis
There are no plans to share OSHRA PII with any internal DOL organization.
External Sharing and Disclosure
The following questions are intended to define the content, scope, and authority for information sharing external to DOL which includes federal, state and local government, and the private sector.
- With which external organization(s) is the PII shared, what information is shared, and for what purpose?
None.
- Is the sharing of PII outside the Department compatible with the original collection? If so, is it covered by an appropriate routine use in a SORN? If so, please describe. If not, please describe under what legal mechanism the program or system is allowed to share the PII outside of DOL.
N/A.
- How is the information shared outside the Department and what security measures safeguard its transmission?
N/A.
- Privacy Impact Analysis
The agency does not plan to share collected PII with any organizations outside of the Agency.
Notice
The following questions are directed at notice to the individual of the scope of PII collected, the right to consent to uses of said information, and the right to decline to provide information.
- Was notice provided to the individual prior to collection of PII?
Name and contact information are obtained directly from the individual, and the purpose for collection, to notify the individual of their possible exposure to toxic substances, is explained at the time the industrial hygiene sampling is conducted
- Do individuals have the opportunity and/or right to decline to provide information?
Yes. Names and contact information are given voluntarily if the individual wants to be notified of industrial sampling results concerning their possible exposure to toxic substances.
- Do individuals have the right to consent to particular uses of the information? If so, how does the individual exercise the right?
No other use of the information is envisioned.
- Privacy Impact Analysis
Individuals are made aware of the use of PII at the time they provide this information to the field evaluation team. Providing this information is voluntary and this point must be explained to the worker. If provided, name and contact information are used for no other purpose than to notify the individual of the results of industrial hygiene sampling conducted in their immediate work area.
Access, Redress, and Correction
The following questions are directed at an individual’s ability to ensure the accuracy of the information collected about them.
- What are the procedures that allow individuals to gain access to their information?
Individuals can contact the OSHA Technical Data Center at the following address if they wish to review their contact information:
US Department of Labor - OSHA
Technical Data Center
Room N-2625
200 Constitution Avenue, N.W.
Washington, DC 20210
(202)693-2350
e-mail: TechnicalDataCenter@dol.gov
- What are the procedures for correcting inaccurate or erroneous information?
Individuals who feel that their contact information has been recorded inaccurately can contact the OSHA Technical Data Center at the address given above for procedures to correct the information.
- How are individuals notified of the procedures for correcting their information?
Individuals may contact the Technical Data Center at the above address.
- If no formal redress is provided, what alternatives are available to the individual?
Individuals may contact the Technical Data Center at the above address.
- Privacy Impact Analysis
Name and contact information are collected by the agency in order to notify the individual; correctly recording this information benefits both parties. It is important to the Agency that this information is correct. Although there is no formal redress procedure, individuals can contact Technical Data Center staff in order to review their contact information and, if necessary, request corrections.
Technical Access and Security
The following questions are intended to describe technical safeguards and security measures.
- What procedures are in place to determine which users may access the system and are they documented?
OSHRA information is stored on TIMS, which has received a Department of Labor Authority to Operate at a security level appropriate for the sensitivity of the PII stored on the system. Access is limited to only those OSHA staff who have a need to work with the information. Outside access is further protected by network firewalls and security protection. PII is encrypted when it is passed over the network. All users of the internal network must abide by the rules of the network and must electronically sign Rules of Behavior and complete annual training courses on privacy and information security policies and best practices.
- Will Department contractors have access to the system?
Yes. Contactors are involved with the maintenance of the system.
- Describe what privacy training is provided to users, either generally or specifically relevant to the program or system?
All OSHA employees are given general training on the importance of protecting PII. DTSEM staff working on the OSHRA project receive specific instruction on the need to record the information accurately, ensure that it is used for only the intended purpose, and to restrict access to the information to only the appropriate OSHA staff.
- What auditing measures and technical safeguards are in place to prevent misuse of data?
Access to the supporting network and to the database management system is controlled through logon procedures which meet Department of Labor requirements for password complexity. Access logons and attempted logons are audited. All user interfaces provided are restricted to read-only access. The system is further protected by the access controls and technical safeguards of the network.
- Privacy Impact Analysis
To prevent unauthorized disclosure of PII it is important to maintain an appropriate level of security. The OSHRA module resides on TIMS which has an Authority to Operate from the Department of Labor and a security level deemed appropriate to protect PII of this nature. In addition, the tablets used in the collection of this information are password protected and all the information on them encrypted in case the machine is lost or stolen. All transfers of the information over the Internet or the internal network are protected against disclosure through encryption. The system is further protected from outside intrusion by the access controls, firewalls and other security measures of the Agency network.
Technology
The following questions are directed at critically analyzing the selection process for any technologies utilized by the system, including system hardware, RFID, biometrics, and other technology.
- What stage of development is the system in, and what project development life cycle was used?
The information is currently stored on the TIMS which is operational and has an ATO from the Department of Labor. The OSHRA module is largely complete with some ongoing development and maintenance work.
- Does the project employ technology which may raise privacy concerns? If so please discuss their implementation?
No.
Determination
As a result of performing the PIA, what choices has the agency made regarding the information technology system and collection of information?
OSHA has completed the PIA for Technical Information Management System (TIMS) which is currently in operation. OSHA has determined that the safeguards and controls for this moderate system adequately protect the information.
OSHA has determined that it is collecting the minimum necessary information for the proper performance of a documented agency function.
