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National Government Services Virtual Data Center

Date signed: 10/31/2023

PIA QuestionsPIA Answers
OPDIV:CMS
PIA Unique Identifier:P-7687799-003719
Name:National Government Services Virtual Data Center
The subject of this PIA is which of the following?General Support System
Identify the Enterprise Performance Lifecycle Phase of the system.Operate
Is this a FISMA-Reportable system?Yes
Does the system include a Website or online application available to and for the use of the general public?No
Identify the operator:Contractor
Is this a new or existing system?Existing
Does the system have Security Authorization (SA)?Yes
Date of Security Authorization4/22/2025
Indicate the following reason(s) for updating this PIA. Choose from the following options.PIA Validation (PIA Refresh/Annual Review)
Describe in further detail any changes to the system that have occurred since the last PIA.There have been no changes.  NGS VDC SSO David Eberling reviewed on 01/21/2025
Describe the purpose of the systemThe National Government Services (NGS) Virtual Data Center (VDC) General Support System (GSS) provides infrastructure hosting services for several CMS Major Applications (MA) that provide communication and other services for CMS. The NGS VDC is comprised of network devices, computer operating systems and computer backup systems.
Describe the type of information the system will collect, maintain (store), or share. (Subsequent questions will identify if this information is PII and ask about the specific data elements)

The NGS VDC collects and maintains the system support user credentials, which are the name, user ID and password. The system support staff are CMS employees and direct contractors.

The NGS VDC does not directly collect, maintain, or share any other information but provides the infrastructure hosting environment for several CMS MAs.

Provide an overview of the system and describe the information it will collect, maintain (store), or share, either permanently or temporarily.

The NGS VDC is an information technology infrastructure system that supports several CMS MAs. The system is comprised of operating systems, network devices (routers, servers, firewalls, and intrusion detection/prevention systems) and computer systems backup.

The MAs are communication platforms and websites that CMS uses to communicate or provide services externally or internally. These MAs collect, maintain, and share a broad scope of information, which may include PII. As such, each of these MAs is responsible for maintaining the security of the information within their boundaries. Each CMS MA maintains their own PIA to address the security and privacy controls in place to protect the information. 

The following CMS MAs are supported by the NGS VDC: Next Generation Desktop (NGD), Training, Quality and Content (TQC) System; , Centers for Medicare and Medicaid Innovation- Innovation Payment Contractor (CMMI-IPC), Common Electronic Data Interchange (CEDI) (MA), and Supplemental Medical Review Contractor (SMRC) (MA) 

The NGS VDC system support staff, who are CMS employees and direct contractors, must log into the system with user credentials to operate system. The user credentials consist of name, user ID and password. The credentials are stored for as long as necessary for the individual to access the system. If/when user credentials are no longer required, then the user credentials are deleted. 

Does the system collect, maintain, use or share PII?Yes
Indicate the type of PII that the system will collect or maintain.
  • Name
  • Other - User IDs and passwords
Indicate the categories of individuals about whom PII is collected, maintained or shared.Employees
How many individuals' PII in the system?100-499
For what primary purpose is the PII used?The primary purpose of PII, user credentials, is for system access.
Describe the secondary uses for which the PII will be used (e.g. testing, training or research)None
Describe the function of the SSN.Not applicable
Cite the legal authority to use the SSN.Not applicable
Identify legal authorities​ governing information use and disclosure specific to the system and program.5 U.S.C 301, Departmental Regulations
Are records on the system retrieved by one or more PII data elements?No
Identify the sources of PII in the system: Directly from an individual about whom the information pertains
  • In-person
  • Online
Identify the sources of PII in the system: Government Sources
  • Within the OPDIV
Identify the sources of PII in the system: Non-Government Sources 
Identify the OMB information collection approval number and expiration dateNot applicable
Is the PII shared with other organizations?No
Describe the process in place to notify individuals that their personal information will be collected. If no prior notice is given, explain the reason.As part of the CMS employment onboarding process or for access to CMS systems, individuals are notified that their personal information is being collected. As such, there is not a mechanism in the NGS VDC system itself to directly notify system users. 
Is the submission of the PII by individuals voluntary or mandatory?Voluntary
Describe the method for individuals to opt-out of the collection or use of their PII. If there is no option to object to the information collection, provide a reason.To access the NGS VDC information technology system, an authorized user must provide their PII, user credentials. Therefore, there is not a method for an individual to opt-out.
Describe the process to notify and obtain consent from the individuals whose PII is in the system when major changes occur to the system (e.g., disclosure and/or data uses have changes since the notice at the time of original collection). Alternatively, describe why they cannot be notified or have their consent obtained.If a major system change were implemented in the NGS VDC that affected the disclosure or use of the user credentials, PII, the system users would be notified by email or other CMS or NGS communication channels.
Describe the process in place to resolve an individual's concerns when they believe their PII has been inappropriately obtained, used, or disclosed, or that the PII is inaccurate. If no process exists, explain why not.

If a user believes their PII has been inappropriately obtained, used, or disclosed, the user must contact the NGS Service Desk who will assign an incident ticket to the NGS Computer Security Incident Response Team, who will investigate and determine any additional steps.

The individual may also contact the CMS IT Service Desk by email or telephone. Details of the incident are logged and investigated to determine if further action is required to resolve the concern. 

Describe the process in place for periodic reviews of PII contained in the system to ensure the data's integrity, availability, accuracy and relevancy. If no processes are in place, explain why not.

The NGS VDC maintains the data integrity and availability of PII by employing security technologies such as firewalls, and encryption of workstations and communication protocols; and maintaining, monitoring, and reviewing system access logs. 

The system users maintain data accuracy and relevancy by correcting/updating their own PII data and administrators perform account review procedures. User account data is not validated but is monitored for activity and audited for usage. Accounts can be disabled for non-activity and accounts that have not been used at least once every 366 days are deleted.

Identify who will have access to the PII in the system and the reason why they require access.
  • Administrators: Administrators have access to PII as part of the system logs that monitor the access of the NGS VDC.
  • Contractors: Direct contractors, in their role as an IT system administrator, would have access to PII to perform those job functions.
  • Other: To access the NGS VDC information technology system, an authorized user must provide their PII, user credentials. Therefore, there is not a method for an individual to opt-out.
Describe the procedures in place to determine which system users (administrators, developers, contractors, etc.) may access PII.The NGS VDC uses role-based access permissions to determine which system users have access to PII.
Describe the methods in place to allow those with access to PII to only access the minimum amount of information necessary to perform their job.The methods in place to allow only minimum access to PII are approval and monitoring of system access requests and role-based access permissions and role access based on least privilege. These methods restrict users to only the resources needed to perform their job functions.
Identify training and awareness provided to personnel (system owners, managers, operators, contractors and/or program managers) using the system to make them aware of their responsibilities for protecting the information being collected and maintained.CMS employees and direct contractors are required to take annual training regarding the security and privacy requirements for protecting PII, which includes the CMS Annual Security and Privacy Awareness Training through the Computer-based Training (CBT) system and the NGS internal annual training.
Describe training system users receive (above and beyond general security and privacy awareness training)In addition to annual security and privacy awareness training, role-based training is provided to individuals with significant security responsibilities.
Do contracts include Federal Acquisition Regulation and other appropriate clauses ensuring adherence to privacy provisions and practices?Yes
Describe the process and guidelines in place with regard to the retention and destruction of PII. Cite specific records retention schedules.The NGS VDC follows the CMS guidelines for record retention by following the National Archive and Records Administration (NARA) Transmittal publications. The NARA General Records Schedule (GRS) 3.1 states that technology records will be destroyed after a maximum of five years. The NARA GRS 3.2 states that system access records will be destroyed after a maximum of six years. 
Describe, briefly but with specificity, how the PII will be secured in the system using administrative, technical, and physical controls.

The administrative controls in place to secure the PII include role-based access and permissions, periodic review of users and deletion of non-active accounts. 

The technical controls in place are firewalls that prevent unauthorized access, encrypted access at log on, security scans, penetration testing, and intrusion detection and prevention systems (IDS/IPS). 

The physical controls in place are as follows: the use of security cards and pass codes, video monitoring, security guards and a separately located backup system.

Privacy Impact Assessment (PIA) published by CMS as an Operating Division of the U.S. Department of Health and Human Services