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pdfThe Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 1 of 9
PRIVACY THRESHOLD ANALYSIS (PTA)
This form is used to determine whether
a Privacy Impact Assessment is required.
Please use the attached form to determine whether a Privacy Impact Assessment (PIA) is required under
the E‐Government Act of 2002 and the Homeland Security Act of 2002.
Please complete this form and send it to your component Privacy Office. If you do not have a component
Privacy Office, please send the PTA to the DHS Privacy Office:
Rebecca J. Richards
Director of Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 703‐235‐0780
[email protected]
Upon receipt, the DHS Privacy Office will review this form. If a PIA is required, the DHS Privacy Office
will send you a copy of the Official Privacy Impact Assessment Guide and accompanying Template to
complete and return.
A copy of the Guide and Template is available on the DHS Privacy Office website, www.dhs.gov/privacy,
on DHSOnline and directly from the DHS Privacy Office via email: [email protected], phone: 703‐235‐0780.
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 2 of 9
PRIVACY THRESHOLD ANALYSIS (PTA)
Please complete this form and send it to the DHS Privacy Office.
Upon receipt, the DHS Privacy Office will review this form
and may request additional information.
SUMMARY INFORMATION
DATE submitted for review: June 23, 2009
NAME of Project: Customs Trade Partnership Against Terrorism (C‐TPAT)
Name of Component: Customs and Border Protection
Name of Project Manager: Lamont Newton
Email for Project Manager: [email protected]
Phone number for Project Manager: 703‐553‐1785
TYPE of Project:
Information Technology and/or System ∗
A Notice of Proposed Rule Making or a Final Rule.
Other:
∗
The E‐Government Act of 2002 defines these terms by reference to the definition sections of Titles 40 and
44 of the United States Code. The following is a summary of those definitions:
•“Information Technology” means any equipment or interconnected system or subsystem of
equipment, used in the automatic acquisition, storage, manipulation, management, movement,
control, display, switching, interchange, transmission, or reception of data or information. See 40
U.S.C. § 11101(6).
•“Information System” means a discrete set of information resources organized for the collection,
processing, maintenance, use, sharing, dissemination, or disposition of information. See: 44. U.S.C. §
3502(8).
Note, for purposes of this form, there is no distinction made between national security systems or
technologies/systems managed by contractors. All technologies/systems should be initially reviewed
for potential privacy impact.
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 3 of 9
SPECIFIC QUESTIONS
1.
Describe the project and its purpose:
The objective of Customs Trade Partnership Against Terrorism C‐TPAT is to further the
efforts of CBP to secure entry of goods into the United States from terrorist infiltration and
the introduction of other illegal activities. One of the best means to prevent further terrorist
attacks is to use border authorities to make it more difficult for terrorist and terror weapons
to enter the U.S. and to better secure the international supply chain by preventing terrorist
access to transportation modalities, thereby eliminating the potential for trafficking of
implements of terror within the global supply chain. The C‐TPAT system is a critical
component of reaching that goal, because it provides a mechanism to meet the C‐TPAT
mandate: to inform and engage its members in a way that will continue to foster and improve
global supply‐chain security. This goal directly supports the Department of Homeland
Security (DHS) efforts to secure supply channels by enlisting Trade Partners in security
efforts.
C‐TPAT recognizes that CBP can provide the highest level of cargo security only through
close cooperation with the ultimate owners of the international supply chain such as
importers, carriers, consolidators, licensed customs brokers, and manufacturers. C‐TPAT
offers trade‐related businesses an opportunity to play an active role in the war against
terrorism. By participating in this first worldwide supply chain security initiative, companies
will ensure a more secure and expeditious supply chain for their employees, suppliers and
customers.
To
participate,
businesses
must
apply
online
at
https://ctpat.cbp.dhs.gov/CompanyProfile.aspx , through a CBP host site.
The PIA was submitted to the CBP Privacy Office in May 2008 and is currently awaiting
review and approval.
2.
Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: March 1, 2006
Date last updated: May 1, 2009
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 4 of 9
3.
Could the project relate in any way to an individual?1
No. Please skip ahead to the next question.
Yes. Please provide a general description, below.
Initially, business‐identifying information is collected by C‐TPAT through the online
application form. Business‐identifying information may include identification numbers such
as U.S. Social Security Numbers for sole proprietors, Internal Revenue Service Business
Identification Numbers, Customs assigned identification numbers such as Manufacturer
Identification numbers and Broker/Filer codes, etc.
Pre‐set fields of business‐identifying information within the online application include:
Business Entity Type
Tax Identification Number (TIN)
Legal Company Name
Company “Doing Business As”
Company Telephone
Company Fax
Physical Address
Mailing Address
Owner Type: (Select) Corporation\ Partnership\ Sole Proprietor
Years In Business
Number of Employees
Company Contacts
First Name
Last Name
Title
Email Address
Telephone
1
Projects can relate to individuals in a number of ways. For example, a project may include a camera for
the purpose of watching a physical location. Individuals may walk past the camera and images of those
individuals may be recorded. Projects could also relate to individuals in more subtle ways. For example, a
project that is focused on detecting radioactivity levels may be sensitive enough to detect whether an
individual received chemotherapy.
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 5 of 9
Contact Type
4.
Do you collect, process, or retain information on: (Please check all that apply)
DHS Employees
Contractors working on behalf of DHS
The Public
The System does not contain any such information.
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 6 of 9
5.
Do you use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs)
No.
Yes. Why does the program collect SSNs? Provide the function of the SSN and the
legal authority to do so:
6.
What information about individuals could be collected, generated or retained?
Tax Identification Number (TIN)
Legal Company Name
Company “Doing Business As”
Company Telephone
Company Fax
Physical Address
Mailing Address
Company Contacts
First Name
Last Name
Title
Email Address
Telephone
7.
If this project is a technology/system, does it relate solely to infrastructure? [For example, is
the system a Local Area Network (LAN) or Wide Area Network (WAN)]?
No. Please continue to the next question.
Yes. Is there a log kept of communication traffic?
No. Please continue to the next question.
Yes. What type of data is recorded in the log? (Please choose all that apply.)
Header
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 7 of 9
Payload Please describe the data that is logged.
8.
Can the system be accessed remotely?
No.
Yes. When remote access is allowed, is the access accomplished by a virtual private network
(VPN)?
No. C‐TPAT is an outward facing system that is only accessible via the internet for
both internal and external users. The connection (session) is encrypted via HTTPS over
TLS and the certificates are generated from DHS.
Yes.
9.
Is Personally Identifiable Information2 physically transported outside of the LAN? (This can
include mobile devices, flash drives, laptops, etc.)
No.
Yes. Trade Partners are only able to access their own information, therefore any removal of
such PII informtiaon is limited to what pertains to them.
10.
Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems3?
No
Yes. Please list:
11.
Are there regular (ie. periodic, recurring, etc.) data extractions from the system?
No.
2
Personally Identifiable Information is information that can identify a person. This includes; name, address, phone
number, social security number, as well as health information or a physical description.
3
PII may be shared, received, or connected to other DHS systems directly, automatically, or by manual processes.
Often, these systems are listed as “interconnected systems” in TAFISMA.
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 8 of 9
Yes. Are these extractions included as part of the Certification and Accreditation4?
Yes.
No.
12.
Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown.
No.
Yes. Please indicate the determinations for each of the following:
Confidentiality:
Integrity:
Availability:
4
Low
Moderate
High
Undefined
Low
Moderate
High
Undefined
Low
Moderate
High
Undefined
This could include the Standard Operation Procedures (SOP) or a Memorandum of Understanding (MOU)
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, [email protected]
www.dhs.gov/privacy
Privacy Threshold Analysis
Version date: June 10th, 2009
Page 9 of 9
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)
DATE reviewed by the DHS Privacy Office: October 22, 2009
NAME of the DHS Privacy Office Reviewer: Rebecca J. Richards
DESIGNATION
This is NOT a Privacy Sensitive System – the system contains no Personally Identifiable
Information.
This IS a Privacy Sensitive System
Category of System
IT System
National Security System
Legacy System
HR System
Rule
Other:
Determination
PTA sufficient at this time
Privacy compliance documentation determination in progress
PIA is not required at this time
A PIA is required
System covered by existing PIA:
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN:
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS
File Type | application/pdf |
File Title | DHS PRIVACY OFFICE |
Author | pia |
File Modified | 2009-10-22 |
File Created | 2009-10-22 |