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USDA Privacy Impact Assessment for,Farm Basiness Plan Web Equity Manager FBP WEM. Document Information,Owner Details,Name Nancy New USDA FSA DAFLP PDEED. Contact Number 202 720 7719,E mail Address nancy new wdc usda ov. Document Revision and History,Revision Date Author Comments. 1 01 July 6 2009 Scott Tanos Initial version, 1 02 July 8 2009 Scott Tanos Populated sections 3 4 and 5 from.
previous PIA, 1 03 July 22 2009 D Brizendine ISO Updated System Owner Information. 1 04 July 24 2009 Terry Mills Completed questions in Sections 3 1. thru 3 6 and Section 4 SOR information,1 05 July 28 2009 D Brizendine Document review. 1 06 8 3 09 D Brizendine Updated response for 30 2 document. review template updates, i 1 07 8 5 09 S Tanos Updated response for 30 2 and 30 3 per. Shelly Nuessle,Page iii Date August 5 2009,USDA Privacy Impact Assessment for. Farm Business Plan Web Equity Manager FBP WEM,Table of Contents.
1 PURPOSE OF DOCUMENT 1,2 SYSTEM INFORMATION 2,3 DATA INFORMATION 3. 3 1 Data Collection 3,3 2 Data Use 5,3 3 Data Retention 6. 3 4 Data Sharing 7,3 5 Data Access 8,3 6 Customer Protection 8. 4 SYSTEM OF RECORD 10,5 TECHNOLOGY 11,6 COMPLETION INSTRUCTIONS 12. Page iv Date August 5 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 reviews 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 vork 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. The Privacy Impact Assessment PIA document contains information on how the Farm. Business Plan Web Equity Manager 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. Farm Business Plan Web Equity Manager FBP WEM,2 System Information. System Information,Agency Farm Service Agency,System Name Farm Business Plan Web Equity Manager. System Type Major Application,General Support System. Non major Application,System Categorization High,per FIPS 199 Moderate.
Description of System The Farm Business Plan Web Equity Manager FBP WEM system. provides financial data collateral info livestock equipment real estate. balance sheet and classification of the borrower for determination of. eligibility It empowers SCO staffto better assess each producer s. financial situation and their goals for the future The resulting formal. business plan outlining the details of the producer is required to begin. their loan eligibility decisions and processing The FBP WEM continues. the mission of its predecessor system called Farm Home Plan FHP and. provides new capabilities for improved management and customer. Who o vns this system Nancy New,Name agency contact USDA FSA DAFLP PDEED. information 202 720 7719,nancv new wdc usda gov,Who is the security Brian Davies. contact for this system Information System Security Program Manager ISSPM. Name agency contact U S Department of Agriculture,information. Farm Service Agency,1400 Independence Avenue SW,Washington D C 20250. 202 720 2419,Brian Davies wdc usda gov,Page 2 Date August 5 2009.
USDA Privacy Impact Assessment for,Farm Business Plan Web Equity Manager FBP WEM. System Information,Who completed this Terry Mills,document Name Farm Credit Application Office FCAO. agency contact,816 926 2147,information,Tercv Mills kcc usda gov. 3 Data Information,3 1 Data Collection,No I Question ReSponse. t Generally describe the data to be used in the Customer Name Social Security Number. system Fin n ial Info rm ation loan information Farm. roduction information Liabilities assets,owned tax id.
employees name,2 Does the system collect Social Security Yes. Numbers SSNs or Tmxpayer Identification No If NO go to question 3. Numbers TINs, 2 1 State the law or regulation that requires the 7 U S C 135b 450j 450k 405t 1281 1393. collection of this information 1421 1449 146 1469 1471 1471i 1781. 1787 15 U S C 714 714p 16 U S C 590a,590q 1301 1311 1501 1510 1606 2101. 2111 2201 2205 3501 3801 3847 4601,5822 26 U S C 6109 40 U S C App 1 2. 203 43 U S C 1592 and 48 U S C 1469,Page 3 Date August 5 2009.
USDA Privacy Impact Assessment for,Farm Business Plan Web Equity Manager FBP WEM. Question Response,3 Is the use of the data both relevant and Yes. 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.
4 Sources of the data in the system Agencies FSA NRCS IRS Geological. Survey NASS and Commerce RD,Application Data Customer Tax records credit. reports SCIMS creditors banks GLS,customer case file IRS RMA DPH Database. yield records crop insurance company records,USDA statistics Public records MAC FBP. GLS MRT PLAS ADPS, 4 1 What data is being collected from the Financial information for determining credit. customer worthiness including Income Expenses,Assets Liabilities Farm Production Personal.
Information DOB Spouse Address Co, 4 2 What USDA agencies are providing data for Farm Service Agency SC1MS. use in the system, 3 What tate and lOcal agencies are providing i County offides Tax records Courthous. data for use in the system Records UCC filings Deed Recorder. 4 4 From what other third party sources is data Other lenders credit reporting agencies private. being collected appraisers Crop insurance companies multi. list data Farm Credit System sales data Ag,Lenders business owners. 5 Will data be collected from sources outside Yes, your agency For example customers USDA No If NO go to question 6. sources i e NFC RD etc or Non USDA, 5 1 How will the data collected from customers beData is verified manually Use 3 FLP verify.
verified for accuracy relevance timeliness employment lenders tax records IRS. and completeness FBP depends on the accuracy of the. information given from the sources summary,data is calculated employees manually check. for completeness,Page 4 Date August 5 2009,USDA Privacy Impact Assessment for. Farm Business Plan Web Equity Manager FBP WEM,Question Response. 5 2 How will the data collected from USDA Data is verified manually Use 3 FLP verify. sources be verified for accuracy relevance employment lenders tax records IRS. timeliness and completeness FBP depends on the accuracy of the. information given from the sources summary,data is calculated employees manually check. for completeness, 5 3 How will the data collected from non USDA Data is verified manually Use 3 FLP verify.
sources be verified for accuracy relevance employment lenders tax records IRS. timeliness and completeness FBP depends on the accuracy of the. information given from the sources summary,data is calculated employees manually check. for completeness,3 2 Data Use,No Response, 6 Individuals must be informed in writing of theCredit Worthiness for FLP loan assistance. principal purpose of the information being,collected from them What is the principal. purpose of the data being collected,7 Will the data be used for any other purpose Yes. No If NO go to qaestion 8,7 1 What are the other purposes.
8 s the use of the data both relevant and Yes,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,9 Will the system derive new data or create Yes. previously unavailable data about an individual No If NO 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,Page 5 Date August 5 2009. USDA Privacy Impact Assessment For,Farm Business Plan Web Equity Manager FBP WEM. Question Response,9 2 Can the system make determinations about Yes. customers or employees that would not be No,possible without the new data.
9 3 Spot check audits manual verification,How will the new data be verified for relevance. and accuracy Certification testing of the application. functions that derive data such as Borrower,Classification. 10 Individuals must be informed in writing of theDetermining credit worthiness for FLP loan. routine uses of the infomaation being collectedassistance. 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 If NO go to question 12,11 1 What are the other uses. 12 Automation of systems can lead to the Yes, consolidation of data bringing data from No If NO go to question 13.
multiple sources into one central,locatiordsystem and consolidation of. administrative controls When administrative,controls are consolidated they should be. evaluated so that all necessary privacy controls,remain n place to the degree necessary to. continue to control access to and use of the,tata Is data being consolidated. 2 1 What controls are in place to protect the data DBMO ITS ISO security standards. and prevent unauthorized access eAuthentication SSL protocols firewalls user. login aud passwords,13 Are processes being consolidated Yes.
No If NO go to question 14, 13 1 What controls are in place to protect the data DBMO 1TS ISO security standards. and prevent unauthorized access eAuthentication SSL protocols firewalls user. login and passwords alls,3 3 Data Retention,No Question Response. 14 Is the data periodically porged from the Yes,system No If NO go to question 15. Page 6 Date August 5 2009,USDA Privacy Impact Assessment for. Farm Business Plan Web Equity Manager FBP WEM,No Question Response.
14 1 How long is the data retained whether it is on Data is stored indefinitely Some exists until. paper electronic in the system or in a backup the user is deleted from the database 5 Years. on average for some systems FSA 25 AS, 14 2 What are the procedures for purging the data atFollow procedures in FSA 25 AS Handbook. the end of the retention period, 14 3 Where are these procedures documented Follow procedures in FSA 25 AS Handbook. 15 While the data is retained in the system what Data is locked down Data in evaluated by user. are the requirements for determining if the datadetermination Reports can be run as a check. 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,No Question Response, 17 Wilt other agencies share data or have access to Yes. data in this system i e international federal No If NO gotoq estion 8. state local other etc, 17 1 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 ls the data transmitted to another agency or an Yes. independent site No If NO go to question 19,Is there appropriate agreement in place to Yes. document the intercormection aud ensure the,PI1 and or Privacy Act data is appropriately.
19 Is 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 dataUser training and ITS support. be maintained in all sites,Page 7 Date August 5 2009. USDA Privacy Impact Assessment for,Farm Business Plan Web Equity Manager FBP WEM. 3 5 Data Access,Question Response, 20 Who will have access to the data in the systemNational State FLP staff System. i e users managers system administrators Administrators Testing and Certification. developers etc Application Developer, 21 How will user access to the data be Approval from ISO based on FSA 13A.
determined requests and approval from CIO for,transferring of data to independent agencies. such as the application developer,21 1 Are criteria procedures controls and Yes. responsibilities regarding nser access No,tocumented. 22 How will user access to the data be restricted Based authentication and role assigned to the. 22 1 Are procedures in place to detect or deter Yes. browsing or unauthorized user access No, 23 Does the system employ security controls to Yes. make information unusable to unauthorized No,individuals i e encryption strong.
authentication procedures etc,3 6 Customer P tection. 24 Who will be responsible for protecting the USDA Privacy Office. privacy rights of the customers and employees,affected by the interface i e office person. departmental position etc, 25 How can customers and employees contact the By contacting John Underwood Privacy. office or person responsible for protecting theirOfficer at john underwood kcc usda gov. privacy rights 8 t 6 926 6992, 26 A breach refers to a situation where data Yes If YES go to question 27. and or information assets are unduly exposed Common FSA incident reporting process. ls a breach notification policy in place for this No. 26 1 If NO please enter the Plan of Action and,Milestones POA M number with the.
estimated completion date,Page 8 Date August 5 2009. USDA Privacy Impact Assessment for,Farm Business Plan Web Equity Manager FBP WEM. NOo Question Response,27 Consider the following Yes. Consolidation and linkage of files and No lfNO go to question 28. Derivation of data,Accelerated information processing and. decision making,Use of new technologies,ls there a potential to deprive a customer of due.
process rights fundamental rules of fairness,27 1 Explain how this will be mitigated. 28 How will the system and its use ensure FSA guidelines for fair and equitable treatment. equitable treatment of customers already exist Privacy and Ethics training as. mandated by FSA Automated consideration,or uniform calculations of all available. 29 Is there any possibility of treating customers or Yes. employees differently based upon their No If NO go to question 30. individual or group characteristics,29 1 Explain,Page 9 Date August 5 2009. 4 System of Record,No Question,30 Can the data be retrieved by a personal Yes. identifier In other words does the system No If NO 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 reMeved In other words SCIMS core customer identifier. what is the identifying attribute i e employee,number social security number etc. 30 2 Under which Systems of Record SOR notice USDA FSA 2 USDA FSA 14. does the system operate Provide number,name and publication date SORs can be. viewed at www access GPO gov, 30 3 lfthe system is being modified will the SOR Yes. require amendment or revision No,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 questionnaire is complete. 31 1 How does the use of this technology affect,customer privacy. USDA Privacy Impact Assessment for,Farm Business Plan Web Equity Manager FBP WEM. 6 Completion Instructions, Upon completion of this Privacy Impact Assessment for this system the ans ver to OMB A 11. Planning Budgeting Acquisition and Management of Capital Assets Part 7 Section E Question. PLEASE SUBMIT A COPY TO THE OFFICE OF THE ASSOCIATE CHIEF INFORMATION. OFFICE FOR CYBER SECURITY,Page 12 Date August 5 2009.

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