Privacy Impact Assessment

Privacy Impact Assessment
for the
Chemical Security Assessment Tool (CSAT)

March 27, 2007
Contact Point
Matthew Bettridge
DHS/PREP/IP
(703) 235-5495
Reviewing Official
Hugo Teufel III
Chief Privacy Officer
Department of Homeland Security
(571) 227-3813

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 2

Abstract
The Department of Homeland Security / Preparedness Directorate / Infrastructure Protection
Division (DHS/PREP/IP) will deploy and maintain the Chemical Security Assessment Tool (CSAT).
The CSAT is designed to be a web-based self-assessment tool for use by chemical facilities. The
CSAT will collect and maintain information for a Point of Contact (POC) for each participating
facility. This PIA covers the new CSAT system.

Introduction
Section 550 of Public Law 109-295 provided the Department of Homeland Security (DHS)
the responsibility and authority to regulate high risk chemical facilities. Further, it requires the
Secretary of the Department of Homeland Security (the Secretary) to identify high risk facilities and
provide for the protection of the information regarding and provided by those facilities. Currently,
the federal government does not possess the asset specific risk data to regulate high risk chemical
facilities. CSAT has been identified by DHS/PREP/IP as the Information Technology (IT) system to
obtain and quantify this key risk data from facilities covered under the Statute. It is the intent of the
Secretary to begin the assessment of the chemical sector upon the issuance of the interim final
regulations. Interim final regulations are required to be issued 6 months from the date of
enactment, or April 4, 2007. In conjunction with the release of the interim final regulation that
will be published in the Federal Register, Infrastructure Protection will inform the public and
private sector of its goals and purpose via public announcements, participation in trade shows, and
other means of public relations.
To complete their duties under Section 550, Infrastructure Protection compiled a list of
chemical companies that could potentially be considered to have high risk chemical facilities.
Companies may receive a letter informing them of their potential risk under the new Section 550
of Public Law 109-295. The letter will include a notification code, to be used in the registration
process. If a company independently determines that it needs to complete the assessment for a high
risk chemical facility, but has not received a mailing with a notification code, the company may
presumptively register its facility by accessing the CSAT website 1 .
Two parts of the CSAT may be used to collect Personally Identifiable Information (PII). The
first part is the User Registration and the second part is the Top Screen, a self-assessment tool. In
order to gain access to the Top Screen, the User Registration must be completed and approved by
Infrastructure Protection. An internal CSAT database then maintains the User Registration
information and is accessible only through onsite, DHS, authorized personnel.
The User Registration part of CSAT collects information on three different individuals
given their relationship with CSAT. The three individuals are the Submitter, the Preparer, and the
Authorizing Person. The Submitter is an individual that is certified by the company or corporation
to formally submit the regulatory data to DHS. The Submitter must be a United States (U.S.)
Citizen, an officer of the company (or equivalent), and domiciled in the United States. The
Preparer must also be a U.S. Citizen and is the individual authorized to enter data into the CSAT
1

http://www.dhs.gov/chemicalsecurity

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 3

Top Screen (on-line screening tool); however, the Preparer is not authorized to formally submit
the data on the company’s behalf. The Preparer should be a person familiar with the facility in
question. The Authorizing Person is the official company representative that identifies and verifies
the individuals who will maintain the CSAT user roles, the Submitter and the Preparer, on behalf of
the company. A facility may choose to designate a single person to be both the Submitter and
Preparer. Many chemical companies are multinational corporations. Knowingly providing
incomplete or false information is a punishable offense, and therefore the program has required
that the Submitters and Preparers be US Citizens and be subject to US law.
The Submitter must complete the User Registration form found on the CSAT website.
When the Submitter submits the form online, a Portable Document Format (PDF) file is
automatically generated. The PDF must then be printed in hard copy and signed by the Submitter
and Authorizing Person. Then, the printed and signed User Registration form must either be faxed
or mailed to the CSAT program for confirmation. Upon receipt, CSAT will scan the form and verify
that it has been signed. Once CSAT scans and confirms the form, unique usernames and temporary
passwords are generated and assigned: one to the Submitter and one to the Preparer. The Preparer
will then access the Top Screen portion of the CSAT website and provide information on the
specifics of the chemical company, including but not limited to types of chemicals stored and
produced, location of company, and safety measures. The Submitter then logs into the Top Screen
and submits the completed form. Based on the information submitted, a chemical risk level is
determined using a tier designation system. CSAT generates a letter with the final tier designation
(risk level) and mails it to the Submitter. 2

Section 1.0 Information Collected and Maintained
1.1

What information is to be collected?

The CSAT collects Personally Identifiable Information (PII) on the three following individuals: the
Submitter, the Preparer, and the Authorizing Person.
Information collected by the CSAT to issue access for the Submitter includes:
-Name (First, Middle Initial, Last)
-Business Mailing Address
-Business Phone Number (including extension if required)
-Business Email address
-Acknowledgement of US Citizenship (only US Citizens may participate)
-Whether or not the Submitter is an Officer of the Corporation
-Confirmation Submitter is domiciled in US,
2

A final tier designation is determined. If the company believes the tier determination is incorrect they can petition
CSAT for a change.

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 4

Information collected by the CSAT to issue access for the Preparer includes:
-Name (First, Middle Initial, Last)
-Business Mailing Address
-Business Phone Number (including extension if required)
-Business Email address
-Acknowledgement of US Citizenship (only US Citizens may participate)
Information collected by the CSAT for the Authorizing Person includes:
-Name (First, Middle Initial, Last)
-Job Title
-Business Phone Number (including extension if required)
The CSAT program creates unique usernames and assigns temporary passwords for CSAT users,
such as the Submitter and Preparer, when their accounts are created.

1.2

From whom is information collected?

Information will be collected from individuals who are labeled the Submitter; the Preparer; and the
Authorizing Individual. The Submitter is the person who approves the information to be submitted
to CSAT. The Preparer provides information on the running of the chemical facility. Facilities may
include but are not limited to chemical manufacturing plants, petroleum refineries, liquid natural
gas terminals and short storage facilities. The official company representative, known as the
Authorizing Individual, verifies that the Submitter and Preparer are authorized to represent their
company.

1.3

Why is the information being collected?

Contact information is collected to allow for communications between CSAT and the participant.
Acknowledgement of U.S. Citizenship will also be required and collected. Many chemical
companies are multinational corporations. In the event that a company knowingly provides
incomplete or false information, the Submitters and Preparers will be US Citizens and subject to US
law.

1.4

How is the information collected?

The information will be collected only through a web-based registration. Users will be asked to
complete the registration, print and sign the form, and mail or fax the form to DHS.
The data collected by the CSAT registration form will be saved electronically by the CSAT webserver and matched against the hard copy once received.

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 5

1.5

What specific legal authorities/arrangements/agreements
define the collection of information?

The Chemical Security Assessment Tool (CSAT) is the system responsible for executing the risk data
collection and risk-level determinations under Section 550 of the DHS 2007 Appropriations Statute.
Section 550 grants DHS the responsibility and authority to regulate high risk chemical facilities.
Interim final regulations are required to be issued 6 months from the date of enactment, or April 4,
2007. It is the intent of the Secretary of Homeland Security to begin the assessment of the
chemical sector upon the issuance of the interim final regulations.

1.6

Privacy Impact Analysis: Given the amount and type of
data being collected, discuss what privacy risks were
identified and how they were mitigated.

The system was designed to use as little personally identifiable information as possible and still be
able to contact those individuals responsible for regulating both the submitted Acknowledgement
of U.S. Citizenship will also be required and collected. Many chemical companies are multinational
corporations. Knowingly providing incomplete or false information is a punishable offense, and
therefore the program has required that the Submitters and Preparers be US Citizens and be subject
to US law. Submissions to the CSAT will be protected as allowed by the Section 550 through the
enactment of interim final regulations. DHS may classify data on an as-needed basis.

Section 2.0 Uses of the System and the Information
2.1

Describe all the uses of information.

The PII collected may be used as reference in case further communication is required between
CSAT and the chemical facility.
CSAT collects acknowledgement of U.S. citizenship as mentioned in the Advanced Notice of
Proposed Rules Making (ANPRM) issued by DHS in December. It was determined that the
individual(s) fulfilling the role(s) of the Submitter and/or of the Preparer must be a U.S. citizens.
Many chemical companies are multinational corporations. Knowingly providing incomplete or
false information is a punishable offense, and therefore the program has required that the
Submitters and Preparers be US Citizens and be subject to US law.

2.2
No.

Does the system analyze data to assist users in identifying
previously unknown areas of note, concern, or pattern?

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 6

2.3

How will the information collected from individuals or
derived from the system be checked for accuracy?

Submitter information will not be verified prior to access being granted. The process to issue
access will ensure that users solicited by CSAT will have a higher degree of confidence than the
users who submit information of their own volition. Specifically, a letter will be mailed to a very
broad base of known chemical facilities notifying them that they may be regulated under Section
550. The letter will contain a randomly generated notification code. During the user registration
process the facility will be asked to enter the notification code if they have been provided one.
Those entities that are not provided a notification code may also be issued access but may be more
rigorously scrutinized, prior to the issuance of access.

2.4

Privacy Impact Analysis: Given the amount and type of
information collected, describe any types of controls that
may be in place to ensure that information is used in
accordance with the above described uses.

CSAT collects a minimum amount of personally identifiable information to reduce the risk that the
information may be used improperly. Information in this system is safeguarded in accordance with
applicable rules and policies, including any applicable Infrastructure Protection and DHS automated
systems security and access policies. Strict controls have been imposed to minimize the risks of
compromising the information that is being stored. Access to the computer system containing the
records in this system is limited to those individuals specifically authorized and granted access by
DHS regulations, who hold appropriate access credentials, and who have a need to know the
information in the performance of their official duties. The system also maintains a real-time
auditing function of individuals who access the system. Classified information is appropriately
stored in a secured facility, in secured databases and containers, and in accordance with other
applicable requirements, including those pertaining to classified information. Access is limited to
properly authorized personnel only. Acknowledgement of U.S. Citizenship will also be required
and collected so in the event that a company knowingly provides incomplete or false information,
the Submitters and Preparers will be US Citizens and subject to US law.

Section 3.0 Retention
3.1

What is the retention period for the data in the system?

Preparedness has proposed a ten year retention schedule for these records.
Until the records in the system have a NARA-approved disposition schedule, the records must be
considered permanent and nothing may be deleted.

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 7

3.2

Has the retention schedule been approved by the National
Archives and Records Administration (NARA)?

An approval request is in process. The Office of Infrastructure Protection/Preparedness is currently
working with the DHS Senior Records Officer to develop a disposition schedule which will be sent
to NARA for approval.

3.3

Privacy Impact Analysis: Given the purpose of retaining
the information, explain why the information is needed for
the indicated period.

The proposed records retention schedule is based on the fact that regulatory requirements and
company representatives may change over time. The on-going process of DHS regulating
(applicable) chemical facilities requires that regular communication be maintained between CSAT
and those chemical facilities. Because of the continual regulation over time, extensive records
maintenance is critical to the program in order to ensure proper compliance, litigation, and redress
as necessary. Retention and destruction policies have been determined in strict accordance with the
appropriate guidelines. This ensures that Preparedness retains data no longer than necessary,
thereby minimizing any risks associated with the retention of personally identifiable information.

Section 4.0 Internal Sharing and Disclosure
4.1

With which internal organizations is the information
shared?

The system will be utilized solely by the Infrastructure Protection division of the Preparedness
Directorate of the Department of Homeland Security.
PREP/IP chemical facility regulators and analysts will be the internal entities utilizing the CSAT
system.
PREP may share information with the DHS Office of General Counsel (OGC) on an as needed basis
for such necessary reasons as litigation.

4.2

For each organization, what information is shared and for
what purpose?

If an objection or appeal to the CSAT tier determination occurs, OGC will be privy to the
information for litigation and legal purposes.

4.3

How is the information transmitted or disclosed?

Information is shared as printouts and written reports that have first been cleansed to provide only
the information that is necessary for the purposes of the report. Information shared will not

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 8

include personally identifiable data unless there is a specific requirement to do so, such as
litigation. There is currently no expectation that information will be shared for a purpose other
than litigation.

4.4

Privacy Impact Analysis: Given the internal sharing,
discuss what privacy risks were identified and how they
were mitigated.

Internal sharing of personally identifiable information would only occur in certain instances when
the information is required for litigation and other legal purposes. The privacy risks involved with
this sharing are mitigated by the controls in place as a function of legal jurisprudence and laws
governing information used in legal actions.

Section 5.0 External Sharing and Disclosure
5.1

With which external organizations is the information
shared?

The CSAT will share Submitter’s and Preparer’s personally identifiable information with the
organization submitting the form in order to confirm these individuals are the appropriate people
to represent the company.

5.2

What information is shared and for what purpose?

The CSAT will share Submitter’s and Preparer’s personally identifiable information with the
organization submitting the form in order to confirm these individuals are the appropriate people
to represent the company.

5.3

How is the information transmitted or disclosed?

CSAT will transmit very limited personally identifiable information to the originating facility via
email (i.e. usernames and passwords) and letters (e.g. tier determinations sensitive
communications between DHS and the covered facility).

5.4

Is a Memorandum of Understanding (MOU), contract, or
any agreement in place with any external organizations
with whom information is shared, and does the agreement
reflect the scope of the information currently shared?

User agreements are signed by all individuals that request and receive access to CSAT. The user
agreements will reflect the scope of the information shared

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 9

5.5

How is the shared information secured by the recipient?

Users agreements will require that PII be secured in accordance with DHS requirements. In the
event MOU, contracts, or any other agreement is made it will require that PII be secured in
accordance with DHS requirements.

5.6

What type of training is required for users from agencies
outside DHS prior to receiving access to the information?

There is currently no CSAT specific training related to the protection of PII. All information
collected through CSAT will have the SBU protections pursuant to Section 550 of P.L 109-295.
Specific training is being developed and will be required prior to access being provided.

5.7

Privacy Impact Analysis: Given the external sharing, what
privacy risks were identified and describe how they were
mitigated.

At this point in time there is no intention or arrangement for any regular or routine external
sharing of information.

Section 6.0 Notice
6.1

Was notice provided to the individual prior to collection of
information? If yes, please provide a copy of the notice as
an appendix. (A notice may include a posted privacy
policy, a Privacy Act notice on forms, or a system of
records notice published in the Federal Register Notice.) If
notice was not provided, why not?

Notice is provided in the Systems of Records Notice (71 FR 78446) published in the Federal
Register on December 29, 2006. The language is in accordance with the Chemical Facility AntiTerrorism Standards Proposed Rule, regarding how to obtain a user name and password. A Privacy
Act notice will be provided on the webpage.

6.2

Do individuals have an opportunity and/or right to decline
to provide information?

To receive access to CSAT, individuals must provide the personal information required to grant
access.

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 10

6.3

Do individuals have the right to consent to particular uses
of the information, and if so, how does the individual
exercise the right?

The individual does have the right to consent to using their information for contact purposes.
Consent of the individual is implicit. The use of an individual’s information is for contact purposes
only. Personal information will not be used in any other way.

6.4

Privacy Impact Analysis: Given the notice provided to
individuals above, describe what privacy risks were
identified and how you mitigated them.

Due to the limited information required of any Point of Contact (POC), PREP/IP determined that
the privacy risk for any individual is minimal with regard to the collection of personally
identifiable information for the CSAT.
Collecting information necessary for communication between PREP/IP and a facility submitter or
other facility POCs is the primary objective. Notice of an individual’s right to privacy, including
but not limited to a posted copy of the Privacy Act of 1974, will be provided to all Submitters and
Preparers of information. Contact information collected from the CSAT participants will be
maintained in a secure database and will not be disseminated.
All submissions to the CSAT will be considered “chemical-terrorism vulnerability information
(CVI)”, a category of sensitive but unclassified information (SBU), for security purposes by DHS
classifications standards; this is a necessary step even when operating on a government portal. The
application and its components must adhere to DHS and Preparedness security standards as well as
Federal Regulations regarding the types of data collected and stored in CSAT.

Section 7.0 Individual Access, Redress and Correction
The following questions are directed at an individual’s ability to ensure the accuracy of the
information collected about them.

7.1

What are the procedures which allow individuals to gain
access to their own information?

Any individual may submit a request in writing through the Freedom of Information Act (FOIA) in
order gain access to the information collected and maintained on oneself. The procedures for
submitting FOIA requests are available in 6 C.F.R. Part 5. A request may also be sent directly to
CSAT.

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 11

7.2

What are the procedures for correcting erroneous
information?

A copy of the submissions to CSAT may be saved as an electronic file on the submitting computer.
If the submitter or facility requests a copy of their submission, it will be sent to them in hard copy.
Further, in the event that a facility’s information is found to be incorrect, the facility will be
required to resubmit the correct information.

7.3

How are individuals notified of the procedures for
correcting their information?

The information entered into CSAT by the company will be displayed on the confirmation screen
prior company’s submission with instructions on how to correct erroneous information.

7.4

If no redress is provided, are alternatives available?

Redress is provided for by a facility completing the top screen or submitting a new user access
request.

7.5

Privacy Impact Analysis: Given the access and other
procedural rights provided for in the Privacy Act of 1974,
explain the procedural rights that are provided and, if
access, correction and redress rights are not provided
please explain why not.

The procedural rights of the individual are rudimentary and include the ability to request a copy of
the data maintained through FOIA. Correcting any erroneous information may be done so simply
by submitting information to CSAT pertaining to the appropriate facility which will consequently
be updated.

Section 8.0 Technical Access and Security
8.1

Which user group(s) will have access to the system?

The following user communities within IP will have routine and regular end user privileges to
CSAT:
- Chemical Security Office (or title to be determined), with Access to Privacy Information
- Homeland Infrastructure Threat and Risk Analysis Center (HITRAC), with Potential Access to
Privacy Information

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 12

8.2

Will contractors to DHS have access to the system?

Argonne and Oak Ridge National Laboratories are contracted to assist with system production and
maintenance, and as such will have access to the system. There is currently an MOU in place with
the Department of Energy, for the utilization of both Argonne and Oak Ridge National Labs for the
development and maintenance of this system.

8.3

Does the system use “roles” to assign privileges to users
of the system?

Yes, the system is role-based and users will only have access to data determined by their roles. The
role(s) given to a user dictates what he/she can see and do within the system.

8.4

What procedures are in place to determine which users
may access the system and are they documented?

An individual review and approval process for each user will occur and be documented. Access
roles for any non-chemical sector entities or those users who will not maintain a user role as a
Submitter or Preparer will be strictly reviewed and considered on a case by case basis.

8.5

How are the actual assignments of roles and rules verified
according to established security and auditing
procedures?

Submitters and Preparers will not have access to the CSAT database. All other roles will follow an
established procedure that will be documented and audited.

8.6

What auditing measures and technical safeguards are in
place to prevent misuse of data?

The CSAT system was developed using DHS 4300 policy and guidelines to ensure a high level of
data protection. The system will audit all users and audit logs will be analyzed to determine if any
misuse or incident is occurring. All users will authenticate using standards set forth by DHS 4300
policy. The CSAT database will be accessible only to those with access to the SIPRNET (SECRET
LAN). All users accessing these databases will be cleared to the highest level of classified data stored
on the system. These networks have implemented security precautions inherent to the level of
classified data and will following hardening procedures set forth in the DHS 4300B. All users are
required to sign non-disclosure agreements prior to access to the system.

8.7

Describe what privacy training is provided to users either
generally or specifically relevant to the functionality of the
program or system?

There is no privacy related training provided for users in regard to this system. General privacy and
security training is, however, part of mandatory training for all DHS employees and contractors.

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 13

8.8

Is the data secured in accordance with FISMA
requirements? If yes, when was Certification &
Accreditation last completed?

The system will be certified and accredited at the SBU and Secret levels prior to implementation
and per NIST 800-53 specifications and DHS guidance and regulations. Prior to implementing the
system, the IP security office will conduct independent testing of the CSAT system and will
complete a Security Assessment Report identifying security control weaknesses. The developer,
after consulting with the DHS Program Manager, will verify an Independent Verification &
Validation and usability review process and identify an organization to carry that process out.

8.9

Privacy Impact Analysis: Given access and security
controls, what privacy risks were identified and describe
how they were mitigated.

The CSAT system includes components with different user and data sets. The system design
includes access to collected data and system performance data as well. The complete system
includes collected infrastructure data and is a high sensitivity system. The limited public access
parts of the system would be used to accept submissions of data and maintain in-progress partial
submissions (but not to store completed submissions). The IT security requirements will be
outlined in detail in the System Security Plan and in accordance with DHS Policy 4300A and DISA
specifications. The system will be FIPS 199 and FIPS 200 compliant.

Section 9.0 Technology
9.1

Was the system built from the ground up or purchased and
installed?

CSAT is a custom system that leverages available Commercial off the Shelf and Government off the
Shelf software wherever possible to reduce costs without negatively impacting the performance and
functionality of the system.

9.2

Describe how data integrity, privacy, and security were
analyzed as part of the decisions made for your system.

The CSAT system was designed around the principles of compartmentalization and redundant
layers of security to mitigate the risks inherent in any automated system. In particular, access
authorization was partitioned to protect all data in the system including privacy data. The CSAT
system implements independent directory services using different technologies to reduce the
impact of single failures on the confidentiality of private data.
CSAT must support a large number of participants from multiple organizations, many of which
have not undergone an extended and rigorous background check. CSAT users authenticate to
Oracle Internet Directory (OID), which accounts can access only the CSAT application, helping to
reduce threats to the operating system

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 14

CSAT accounts are further limited to working only on CSAT self assessments for their organization.
The administration and analysis accounts that have rights to view and modify the OID accounts
authenticate to a separate system that uses Active Directory as an authentication service.
Traffic to the system is protected by layered security as follows:
•

A firewall that protects the systems from attempts to access ports other than those that have
been designated for the application's use.

•

A hardware security device that isolates the encryption of the data stream from the
applications and from the firewall. The use of a dedicated external device further protects
the application from attempts to compromise it through hacker techniques like "hidden"
field injections.

•

A dedicated Intrusion Detection System/Intrusion Prevention System (IDS/IPS) which
monitors the decrypted traffic flowing between the hardware encryption devices and the
application. By using a dedicated Secure Sockets Layer/Transport Layer Security (SSL/TLS)
appliance and not running an https web server, we eliminate the issue of the traffic going
through the IDS/IPS being encrypted and therefore not capable of supporting a security
scan.

•

Applications reside on hardened servers that have dedicated external log servers to support
additional assurance that only proper access is being made to the systems.

9.3

What design choices were made to enhance privacy?

Beyond the physical security restrictions and the network security restrictions, the CSAT system has
multiple security mechanisms that have been implemented to provide additional security features.
Utilization of login restrictions, session tracking and monitoring, data labeling/tagging of classified
information, role based access controls, and advanced auditing ensure proper security of the
application. The system hardware and software in place meet all requirements for system and data
protection.

Conclusion
The Department of Homeland Security/Preparedness Directorate/Infrastructure Protection Division
will deploy and maintain the Chemical Security Assessment Tool (CSAT). The CSAT is designed to be a
web-based self-assessment tool for use by chemical facilities to quantify asset specific risk data variables.
The system’s objective is to obtain and quantify the key risk data from facilities covered under Section 550
to inform the assessment of high risk chemical sites as required under Section 550. Data collected by the
system is primarily based on the aspects of facilities, only Points of Contact (POCs) for facilities will
provide personal information in order to maintain contact data for communication purposes with the
CSAT. Beyond the physical security restrictions and the network security restrictions, the CSAT system has
multiple security mechanisms that have been implemented to provide additional security features. It has
been determined that because of the system architecture, security features, and the primary nature of data
collection and analysis, there is a nominal level of impact to the privacy of the American public.

Privacy Impact Assessment
Preparedness, Chemical Security Assessment Tool
Page 15

Responsible Officials
Sandy Ford Page
Privacy Officer, Preparedness
Department of Homeland Security

Matt Bettridge
Project Manager

Approval Signature Page

________________________________
Hugo Teufel III
Chief Privacy Officer
Department of Homeland Security