SOCIAL SECURITY ADMINISTRATION

PRIVACY IMPACT ASSESSMENT

 

 ·        Name of project.

       Race Ethnicity Collection System

·        Unique project identifier.

       TBD

·        Privacy Impact Assessment Contact.

Director
      Division of Enumeration and Death Alerts
      Office of Earnings, Enumeration, and Administrative Systems
      Social Security Administration
       6401 Security Boulevard

Baltimore , MD 21235

·        Describe the information to be collected, why the information is being collected, the intended use of the information, and with whom the information will be shared.

Race Ethnicity Collection System (RECS)

RECS is an electronic application that captures race and ethnicity (RE) information collected during contacts with successfully enumerated applicants for Social Security number (SSN) cards when such persons voluntarily provide RE data.  We seek RE information on those applicants for SSN cards who do not apply through the enumeration-at-birth (EAB) or enumeration-at-entry (EAE) processes.  We collect   RE information solely because of our need for such data for program evaluation, research, and statistical reporting purposes.  We do not use RE data to make decisions about a person’s application for benefits or any other programmatic determination.  

Prior to 1987, we collected RE data from persons on a voluntary basis when they applied for either original or replacement SSN cards.  Since 1987, however, we have issued most original SSN cards through EAB, which is administered by the states.  As the states do not collect RE information, we do not maintain RE information for EAB applicants.  Since 2002, the Department of Homeland Security (DHS) has taken applications for SSN cards from aliens entering the United States through the EAE program.  DHS does not provide us with RE information on EAE applicants. 


Collection of Information

Historically we covered the RE data that we collect in an existing Privacy Act system of records, the Master Files of SSN Number Holders and SSN Applications.  The RE data we cover by that system of records is limited to these categories:  Asian, Asian-American or Pacific Islander; Hispanic; Black (Not Hispanic); North American Indian or Alaskan Native; and White (Not Hispanic).  Under the historical standards, persons who provide us race information can designate only one of these categories, and they do not have the option of designating both their race and ethnicity. 

In October 1997, the Office of Management and Budget (OMB) announced revised government-wide standards for Federal agencies collecting RE data (62 F.R. 58782, Oct. 30, 1997, “Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity”).  Implementing the revised standards, we no longer collect RE information using our limited categories.  Pursuant to the OMB mandated standards, we will use the following categories to collect RE information:  Race:  Alaska Native, American Indian, Asian, Black/African American, Native Hawaiian, Other Pacific Islander, and White; Ethnicity:  Hispanic/Latino.  Under the OMB standards, persons may voluntarily designate one or more categories under “Race” and designate “yes” or “no” under the “Ethnicity” category.  We will collect RE information that conforms to the OMB standards for the continuing purposes of program evaluation, research, and statistical reporting.  Once we fully transition our systems to collect RE information using the new OMB standards, we will maintain RE data only in RECS.  We will retain our historical RE data using the Master Files of SSN Number Holders and SSN Applications. 

We will disclose the information in the RECS only as necessary to our authorized employees or contractors who require the information in performing their official duties, as it relates to the collection of this data, for program evaluation, research, and statistical reporting purposes.  We will also disclose this information to the person to which the information pertains as permitted by the Privacy Act, or as otherwise permitted by Federal law.  We will disclose all published research and statistical data in a form whereby the information cannot be associated with a specific person.  RECS will not be accessible to members of the public.  

·        Describe the administrative and technological controls that are in place or that are planned to secure the information being collected.

We have performed a security risk analysis on the RECS.  This process includes an evaluation of security and audit controls proven to be effective in protecting the information collected, stored, processed, and transmitted by our information systems.  These include technical, management, and operational controls that permit access to our information only to persons with an official “need to know.”  Audit mechanisms are in place to record sensitive transactions as an additional measure to protect information from unauthorized disclosure or modification. 

We secure the electronic information in the RECS by requiring the use of access codes to enter the computer system that will house the data.  This process requires employees and contractors authorized to access the RECS to use a unique Personal Identification Number.  We permit only our authorized employees and contractors who require the information to perform their official duties to access the RECS.  We limit users’ access to only the information they need to perform their job functions.  We annually provide appropriate security awareness and training to all our employees and contractors that include reminders about the need to protect personally identifiable information and the criminal penalties that apply to unauthorized access to, or disclosure of, personally identifiable information.  See 5 U.S.C. § 552a(i)(1).  Furthermore, employees and contractors with access to databases maintaining personally identifiable information must annually sign a sanction document, acknowledging their accountability for inappropriately accessing or disclosing such information.

·        Describe the impact on individuals’ privacy rights.

Are individuals afforded an opportunity to decline to provide information? 

We collect information only when we have specific legal authority to do so in order to administer our responsibilities under the Social Security Act.  When we collect information from persons, we advise them of our legal authority for requesting the information, the purposes for which we will use and disclose the information, and the consequences of their not providing any or all of the requested information.  The persons can then make informed decisions as to whether or not they should provide the information.

Providing RE data is voluntary.  Persons who choose not to provide such information will not be impacted.  In no way will such a choice affect their or their dependents’ eligibility to insurance coverage, monthly benefits, or any other business matter that they may have before us in the future.  If persons do not want to provide their RE information, they can state their refusal at the time they request an SSN card. 

Are individuals afforded an opportunity to consent to only particular uses of the information?

When we collect information from persons, we advise them of the purposes for which we will use the information.  We further advise them that we will disclose this information without their prior written consent only when we have specific legal authority to do so (e.g., the Privacy Act). 

We collect identity information at the time a person files for a SSN card.  The RE information that we collect will be used only for program evaluation, research, and statistical reporting purposes.  If persons choose to provide their RE information, we will give them assurances that it will not be used to make a determination about any business matter they have with us.  Within the agency, we will give information in the RECS only to authorized employees and contractors who have a need for the information to perform their official duties.  We will only disclose information contained in the RECS outside the agency in a form that does not contain the identity of specific persons, or as otherwise permitted under the Privacy Act or other Federal laws.  We will disclose all published research and statistical data in a form whereby the information cannot be associated with a specific person.  Therefore, persons are not offered an opportunity to determine how and with whom their RE information will be shared. 

·        Does the collection of this information require a new system of records under the Privacy Act (5 U.S.C. § 552a) or an alteration to an existing system of records?

Yes.  Since we will collect, maintain, and retrieve personally identifiable information (i.e., SSNs) of persons who voluntarily provide their RE data when they request an original or replacement SSN card from us, the RECS information collection is a system of records (SOR) as defined by the Privacy Act.  The SOR we established is entitled Race and Ethnicity Collection System, 60-0104.    

PIA CONDUCTED BY PRIVACY OFFICER, SSA:

_/s/ Dawn S. Wiggins_______________                                    11/03/09____            SIGNATURE                                                             DATE

PIA REVIEWED BY SENIOR AGENCY PRIVACY OFFICIAL, SSA:

/s/ David F. Black_________________                                   11/18/09____            SIGNATURE                                                             DATE


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