Management Notification Regarding Access to Social Security Numbers in the NSF Report Database

Published by the National Science Foundation, Office of Inspector General on 2020-09-16.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                     National Science Foundation • Office of Inspector General
                           2415 Eisenhower Avenue, Alexandria, VA 22314


DATE:                 September 16, 2020

TO:                   Wonzie L. Gardner
                      Office Head and Chief Human Capital Officer
                      Office of Information and Resource Management

                      Daniel A. Hofherr
                      Division Director
                      Division of Information Systems

FROM:                 Mark Bell
                      Assistant Inspector General
                      Office of Audits

SUBJECT:              OIG Project No. 20-6-003, Management Notification Regarding Access to
                      Social Security Numbers in the NSF Report Database

In February 2020, we initiated an audit of the National Science Foundation’s Graduate Research
Fellowship Program (GRFP), OIG Project No. 20-P-1-004. The objective of this audit is to
determine whether NSF properly distributes, monitors, and accounts for GRFP funding. We are
issuing this memorandum to alert you to a matter regarding access to social security numbers
(SSNs). We found some NSF staff and contractors without a current or continuing business need
could view SSNs in the Report Database.

This memorandum contains three recommendations aimed at strengthening controls over access
to sensitive information, including SSNs. We have included NSF’s response to the draft
memorandum in its entirety as an attachment. NSF concurred with all our recommendations. In
accordance with Office of Management and Budget Circular A-50, Audit Followup, please
provide a written corrective action plan to address the recommendations. In addressing the
recommendations, this corrective action plan should detail specific actions and associated
milestone dates. Please provide the action plan within 60 calendar days.


NSF has several transaction databases that may be populated with information or modified
throughout the proposal life cycle by NSF staff, panelists, reviewers, and the research
community. These databases are copied regularly into the read-only Report Database, which
contains personally identifiable information and is used for a variety of functions, such as
querying award and financial data. NSF’s Division of Information Systems (DIS) provides
individuals different levels of access to information, including SSNs, depending on their business
needs. During our ongoing GRFP audit, we found that our data analyst could view SSN fields in
the Report Database. 1 Accordingly, we reviewed NSF’s internal controls to determine whether
NSF staff and contractors who did not have a business need could view SSNs in the Report
Database. 2

NSF Needs Better Controls over Access to SSNs

Office of Management and Budget Circular A-130, Managing Information as a Strategic
Resource, requires agencies to develop and implement agency-wide information security and
privacy programs to “…[p]rotect information and information systems from unauthorized
access….” According to DIS, 115 NSF staff and contractors had SSN access in the Report
Database at the time of our review. 3 After we initiated our review, DIS began determining how
many of these individuals needed continued access. We interviewed 11 people with access to
SSNs to learn whether they were aware they had this level of access, why they needed to view
this information, and how they obtained access. Of the 11 staff and contractors we interviewed, 5
said they were unaware of their access to SSNs in the Report Database, and 8 said they did not
need access to this information to accomplish their duties. Some staff did not know who
provided them access to this information.

NSF’s IT Security Handbook establishes controls for handling sensitive information, including
SSNs. However, the Handbook does not specify controls for how staff or contractors receive
access to SSNs in NSF databases, whether they must justify a business need for access, or
whether their supervisors must review or approve these requests. Additionally, NSF’s IT Security
Handbook did not detail whether or how DIS recertifies if users require use of sensitive
information, including SSNs, after access is provided. DIS said it is currently verifying who still
requires access to SSNs in the Report Database.

We also found that several individuals DIS included on the list of users with SSN access were no
longer working at NSF. DIS stated it blocks former users who are no longer affiliated with NSF
from accessing NSF systems. We did not test this assertion as part of this review. However, the
assertion is currently being tested as part of the audit of NSF’s compliance with the Federal
Information Security Management Act for FY 2020.


We recommend the Division Director, Division of Information Systems, Office of Information
and Resource Management:

    1. Strengthen controls to ensure staff and contractors have a business need to view sensitive
       information, including SSNs, before providing this level of access in the Report

    2. Verify whether individuals with current SSN access in the Report Database have a

  As this level of access was unexpected, we reported this observation to DIS.
  We did not evaluate whether NSF meets applicable requirements for the collection and use of SSNs.
  DIS showed us how it identified these individuals; we did not independently verify this information because we
concluded it was sufficient for our limited review.

         business need for this level of access.

      3. Take steps to regularly remove or recertify access to sensitive information, including
         SSNs, in the Report Database to ensure only individuals with continuing business need
         may view this sensitive information.

We appreciate the courtesies and assistance NSF staff provided during the review. Should you
have questions, please contact Elizabeth Kearns, Director of Audit Execution, at 703.292.7100 or

          Christina Sarris              Allison Lerner             Vashti Young
          Nancy Kaplan                  Lisa Vonder Haar           Ashley Lippolis Aviles
          Mary Lou Tillotson            Dan Buchtel                Laura Rainey
          John McCarthy                 Elizabeth Kearns           Melissa Prunchak


Attachment: Agency Response

                         N ational Sci en ce F oundation
                         Chief Information Security Officer

         Date:    September 14, 2020

         To:      Ms. Allison C. Lerner
                  Inspector General

         From:    Daniel Hofherr
                  Chief Information Security Officer, National Science Foundation
                   DANIEL A HOFHERR                g;,~•;~;;9;;::;i:,~;'~~:""'
         Subject: Response to OIG August 2020 Memo "OIG Project No. 20-P-1-004, Management
                  Notification Regarding Access to Social Security Numbers in the NSF Report Database"

         NSF appreciates the opportunity to review the subject memorandum related to access to Social
         Security Numbers in the NSF report database. The memorandum contains three
         recommendations on strengthening NSF's management of access to Social Security
         Numbers. NSF concurs with the recommendations and has taken prompt action to ensure that
         only staff and contractors who have a business need are able to view sensitive information,
         including Social Security Numbers, in the report database. We reviewed each individual with
         Social Security Number access and either validated continued business need or deleted access
         where no longer needed. We are strengthening our process by documenting procedures to
         regularly remove or recertify access for those with a continuing business need to view sensitive
         information. We are documenting the completed actions and planned improvements and will
         provide our corrective action plan to the OIG .

         We recognize the importance of protecting sensitive information. NSF is committed to
         safeguarding the personal information of the employees, and other individuals who conduct
         business with the Foundation from inappropriate access, use, or disclosure. We will
         incorporate information gained from this review as part of our continuous improvements.

         If you need more information, you may contact me at (703) 292-4241 or dhofherr@nsf.gov.

                                 2415 E isenhower Avenue          I Alexandria, VA 22314