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Third Party Websites and Applications Privacy Impact Assessment - Instagram Social

Date:
11/08/2016

OPDIV:
CMS

TPWA Unique Identifier (UID):

Tool(s) covered by this TPWA:
Instagram Social

Is this a new TPWA?
Yes.

  • If an existing TPWA, please provide the reason for revision:
    Not applicable (N/A).

Will the use of a third-party Website or application create a new or modify an existing HHS/OPDIV System of Records Notice (SORN) under the Privacy Act?
No.

  • If yes, indicate the SORN number (or identify plans to put one in place.):
    N/A because CMS is not collecting or storing any personally identifiable information (PII).

Will the use of a third-party Website or application create an information collection subject to OMB clearance under the Paperwork Reduction Act (PRA)?
No.

  • If yes, indicate the OMB approval number and approval number expiration date (or describe the plans to obtain OMB clearance.)
    OMB Approval Number:
    N/A.
    Expiration Date:
    N/A.

Does the third-party Website or application contain Federal Records?
No.

Describe the specific purpose for the OPDIV use of the third-party Website or application
Instagram Social is a free social networking site that allows registered users to create profiles, upload photos and videos, send messages, and keep in touch with the people in their social network. Instagram Social account holders provide a username, password, and email address when they register for an account. Users may also link their Facebook account to their Instagram Social account. CMS maintains a presence on Instagram Social in the form of a HealthCare.gov branded page. Occasionally CMS will leverage the innate social sharing capacity of this platform by asking fans of our branded page to share our content with their friends on the platform; for the purpose of disseminating a particular message as it relates to an initiative or information related to HealthCare.gov.

Instagram Social allows CMS to communicate directly with users to provide broad educational opportunities and provide limited opportunities to address consumer questions and concerns, by maintaining an Instagram Social account. In addition, CMS will disseminate information related to CMS programs and provide resources to consumers who may not be regular visitors to the CMS or HHS websites.
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Have the third-party privacy policies been reviewed to evaluate any risks and to determine whether the Website or application is appropriate for OPDIV use?
Yes, and the review has determined that Instagram Social is appropriate for OPDIV use, taking into account the risks posed by the following: limited availability of HealthCare.gov privacy notice; Instagram Social account information leading to identification of HealthCare.gov visitors; and CMS’s potential to access PII from Instagram Social users.

Describe alternative means by which the public can obtain comparable information or services if they choose not to use the third-party Website or application:
If consumers do not want to interact with Instagram Social, consumers can learn about CMS campaigns through other advertising channels such as TV, radio, CMS websites, and in-person assisters and events.

Does the third-party Website or application have appropriate branding to distinguish the OPDIV activities from those of nongovernmental actors?
Yes.

How does the public navigate to the third party Website or application from the OPDIV?
By clicking on the external hyperlink on HealthCare.gov.

  • Please describe how the public navigates to the third party Website or application:
    Directly to Instagram.com (the website or mobile app), via a connect icon on the HealthCare.gov site, using a web search or via a web-based URL to content hosted on Instagram.com.

    If the public navigates to the third-party Website or application via an external hyperlink, is there an alert to notify the public that they are being directed to a nongovernmental Website? 
    Yes.

Has the OPDIV Privacy Policy been updated to describe the use of a third-party Website or application?
Yes.

Is an OPDIV Privacy Notice posted on the third-party Website or application?
Yes.

  • Confirm that the Privacy Notice contains all of the following elements: (i) An explanation that the Website or application is not government-owned or government-operated; (ii) An indication of whether and how the OPDIV will maintain, use, or share PII that becomes available; (iii) An explanation that by using the third-party Website or application to communicate with the OPDIV, individuals may be providing nongovernmental third-parties with access to PII; (iv) A link to the official OPDIV Website; and (v) A link to the OPDIV Privacy Policy:
    Yes.

    Is the OPDIV's Privacy Notice prominently displayed at all locations on the third-party Website or application where the public might make PII available?
    Yes, because of Instagram Social’s biography character limitation, a link to the HealthCare.gov Privacy Notice is included in the Biography.

Is PII collected by the OPDIV from the third-party Website or application?
No.

Will the third-party Website or application make PII available to the OPDIV?
Yes, when users comment on an Instagram Social post, their username is visible.

Describe the PII that will be collected by the OPDIV from the third-party Website or application and/or the PII which the public could make available to the OPDIV through the use of the third-party Website or application and the intended or expected use of the
PII:
CMS does not receive any PII through its use of Instagram Social. Individual users who register with Instagram Social are required to provide a first name, last name, valid email address, and password to create a personal Instagram Social profile. HealthCare.gov does not routinely solicit, collect, or maintain any personally identifiable information from individuals who visit, like, comment, or otherwise engage with the HealthCare.gov Instagram Social page. The HealthCare.gov Instagram Social page Administrator may however, read, review, or rely upon information that individuals make available on the HealthCare.gov Instagram Social page in the form of comments for the purposes of responding to a user's question.

HealthCare.gov Instagram Social Page Administrators may delete any comments on the Instagram page that contains unnecessary amounts of PII.

Describe the type of PII from the third-party Website or application that will be shared, with whom the PII will be shared, and the purpose of the information sharing:
Instagram Social does not share any PII with CMS.

  • If PII is shared, how are the risks of sharing PII mitigated?
    N/A.

Will the PII from the third-party Website or application be maintained by the OPDIV?
No.

  • If PII will be maintained, indicate how long the PII will be maintained:
    N/A.

Describe how PII that is used or maintained will be secured:
CMS does not store or maintain any PII received through its Instagram Social account. Instagram Social does not share any PII with CMS.

What other privacy risks exist and how will they be mitigated?
CMS will conduct periodic reviews of Instagram Social’s privacy policy to ensure its policies continue to align with agency objectives and privacy policies and do not present unreasonable or unmitigated risks to user’s privacy interests.

Limited Availability of HealthCare.gov Privacy Notice

Potential Risk:
Due to limitations on Instagram Social, the HealthCare.gov Privacy Notice is not posted in all locations on the HealthCare.gov Instagram Social page.

Mitigation:
A link to the HealthCare.gov Privacy Notice is located on the HealthCare.gov branded page. The HealthCare.gov Privacy Notice is also available to users in other places, including on HealthCare.gov where users can access the privacy policy directly.

Instagram Social Account Information Leading To Identification of HealthCare.gov Visitors

Potential Risk:

Instagram Social’s access to both personally identifiable and non-personally identifiable data about registered Instagram Social users presents the risk that HealthCare.gov visitors who are also registered Instagram Social users could be identified, and the data about these users could be misused by Instagram Social. In addition, users who link their Facebook and Instagram Social accounts may make available additional PII to Instagram.

Mitigation:
CMS does not receive any personally identifiable information from Instagram Social.

Instagram Social provides information on the types of information collected about users in its privacy policy, as well as choices with respect to such information collection and/or how it is used. 

CMS’s Potential to Access PII from Instagram Social Users

Potential Risk:
Instagram Social users who interact directly with the HealthCare.gov branded page on Instagram Social could leave PII in their comments on the page. CMS would have access to this PII.

Mitigation:
CMS does not collect any PII that users leave on Instagram Social. Individual users who register with Instagram Social are required to provide a first name, last name and valid email address and password.  Once registered, users may comment on HealthCare.gov Instagram Social posts. HealthCare.gov does not routinely solicit, collect, or maintain any personally identifiable information from individuals who visit, like, comment, or otherwise engage with the HealthCare.gov Instagram Social page. The HealthCare.gov Instagram Social page Administrator may however, read, review, or rely upon information that individuals make available on the HealthCare.gov Instagram Social page in the form of comments for the purposes of responding to a user's question. Any public comments that users leave on Instagram Social that are re-used for additional outreach activities will be de-identified so as to exclude any PII (e.g., Name, email, etc). CMS also reserves the right to remove comments on their Instagram Social branded page.

Content created by Centers for Medicare and Medicaid Services (CMS)
Content last reviewed on November 29, 2016