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Privacy Impact Assessment for the Libby Asbestos Exposure Assessment Records

On this page:

I. Data in the System

  1. Generally describe what data/information will be collected in the system.

    Results of health screening efforts of residents in and around Libby, Montana.

  2. What are the sources and types of the information in the system?

    The database includes environmental, biological and demographic information collected by both EPA and the Agency for Toxic Substances and Disease Registry (ATSDR).

  3. How will the data be used by the Agency?

    To assess pathways and outcomes from exposure to amphibole asbestos.

  4. Why is the information being collected? (Purpose)

    To support EPA's CERCLA process at the Libby Asbestos site thus enabling EPA to provide long-term protection of public health and welfare.

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II. Access to the Data

  1. Who will have access to the data/information in the system (internal and external parties)? If contractors, are the Federal Acquisition Regulations (FAR) clauses included in the contract (24.104 Contract clauses; 52.224-1 Privacy Act Notification; and 52.224-2 Privacy Act)?

    EPA staff, and where appropriate 1) law enforcement personnel, 2) Department of Justice, 3) contractors, grantees and others who have a need to access the information in performance of their duties for EPA, and 4) others in connection with litigation or settlement discussions.

  2. What controls are in place to prevent the misuse of data by those having authorized access?

    Data to used only under direct oversight by system manager or EPA staff responsible for project.

  3. Do other systems share data or have access to data/information in this system? If yes, explain who will be responsible for protecting the privacy rights of the individuals affected by the interface? (i.e., System Administrators, System Developers, System Managers)


  4. Will other agencies, state or local governments share data/information or have access to data in this system? (Includes any entity external to EPA.)

    Only individuals listed in no. 1 and ATSDR (original data collection agency).

  5. Do individuals have the opportunity to decline to provide information or to consent to particular uses of the information? If yes, how is notice given to the individual? (Privacy policies must clearly explain where the collection or sharing of certain information may be optional and provide users a mechanism to assert any preference to withhold information or prohibit secondary use.)

    A majority of participants (97%) signed consent forms for EPA to obtain their personal files associated with the project; direct and indirect personal identifiers were purged for any individuals not signing consent forms.

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III. Attributes of the Data

  1. Explain how the use of the data is both relevant and necessary to the purpose for which the system is being designed.

    The data allow analysis of pathways and outcome of exposure to amphibole asbestos at the Libby Asbestos superfund site.

  2. If data are being consolidated, what controls are in place to protect the data from unauthorized access or use? Explain.

    Data are not being consolidated.

  3. If processes are being consolidated, are the proper controls remaining in place to protect the data and prevent unauthorized access? Explain.

    Processes are not being consolidated.

  4. How will data be retrieved? Can it be retrieved by personal identifier? If yes, explain. (A personal identifier is a name, Social Security Number, or other identifying symbol assigned to an individual, i.e. any identifier unique to an individual.)

    Personal identifiers including Social Security Numbers have been deleted from the data base.

  5. Is the Web privacy policy machine readable? Where is the policy stated? (Machine readable technology enables visitors to easily identify privacy policies and make an informed choice about whether to conduct business with that site.)

    The data base is not available on the web.

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IV. Maintenance of Administrative Controls

  1. Has a record control schedule been issued for the records in the system? If so, provide the schedule number. What are the retention periods for records in this system? What are the procedures for eliminating the records at the end of the retention period? (You may check with the record liaison officer (RLO) for your AA-ship, Tammy Boulware (Headquarters Records Officer) or Judy Hutt, Agency Privacy Act Officer, to determine if there is a retention schedule for the subject records.)

    The records will be maintained during the pendency of EPA's investigation and cleanup of the Libby Asbestos site and for a period in compliance with EPA's records retention requirements.

  2. While the data are retained in the system, what are the requirements for determining if the data are still sufficiently accurate, relevant, timely, and complete to ensure fairness in making determinations?

    The data were transferred at one time (as a complete data base) after consideration of accuracy and relevance.

  3. Will this system provide the capability to identify, locate, and monitor individuals? If yes, explain.

    Personal identifiers (including Social Security numbers) have been deleted from the system, and EPA agreed (in the original transfer agreement) that no effort would be made to re-identify individual participants.

  4. Does the system use any persistent tracking technologies?


  5. Under which System of Records (SOR) notice does the system operate? Provide the name of the system and its SOR number if applicable. For reference, please view this list of Agency SORs. (A SOR is any collection of records under the control of the Agency in which the data is retrieved by a personal identifier. The Privacy Act Officer will determine if a SOR is necessary for your system.)


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