Preliminary Privacy Impact Assessment

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TITLE: PAS/LOCCS Maintenance Program Accounting System (PAS) Line of Credit Control System (LOCCS)

UPI # 025-00-01-01-01-1010-00-402-126

PCAS # 202540

Is this a new or substantially revised electronic information system? If revised, describe revisions.

No, this is a steady-state maintenance project. Any revisions are minor in scope.

If any question does not apply, state not applicable (N/A) for each question and explain why.

I. Describe the information to be collected (e.g., nature and source). Be sure to include any information in an identifiable form, e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc).

This system is a budgetary control and accounting system used to control and report on the Department's financial activities. Information stored includes the following:

User Ids and User Names
Social Security Numbers
Tax Identification Numbers
Names of grant/subsidy/contract recipients and addresses
Payment history information for recipients
Bank names and bank accounts of recipients and employees

Information is collected to control obligations and payment and to ensure that the correct recipient is paid.

III. How will the information be used (e.g., to verify existing data)?

Information is used to identify the correct recipients due payments and to direct payments to the correct bank accounts.

IV. Will you share the information with others (e.g., another agency for a programmatic purpose)? If yes, list the entities.

Information is shared when deemed appropriate, e.g., GAO for audit purposes or the Office of the Inspector General for audit of controls.

V. Describe what opportunities individuals have been given to decline to provide information or to consent to particular use of the information (e.g., whether individual may withhold permission for a particular use).

Representatives/agents of State Government recipients, have declined to provide social security numbers as proof of their identity and as a control measure to approve access to HUD funds.

VI. How will the information be secured (e.g., administrative and technological controls)?

User Security physical information is safeguarded in a secured room within the HUD building.

VII. How will the data be retrieved (e.g., will it be retrieved by a personal identifier such as name, social security number, address, telephone number or some other identifier that is unique to an individual)?

Data can be retrieved using names, social security numbers, address, telephone numbers, user Ids, bank accounts, tax identification numbers, etc.