Privacy Threshold Analysis (PTA)

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 1 of 8
PRIVACY THRESHOLD ANALYSIS (PTA)

CONTACT LISTS
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 8
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: May 8, 2010
NAME of Project: Integrated Aids to Navigation Information System (I-ATONIS)
Name of Component: US Coast Guard
Name of Project Manager: LTJG Christina Neiss
Email for Project Manager:
Phone number for Project Manger: (202) 372-1572
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 8
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
There are five components of I-ATONIS used to collect personal information: Private
Aid to Navigation Owner Contact Information, Wreck Owner Contact Information,
Oil Rig Owner Contact Information, Private Property Owner Contact Information,
and U.S. Coast Guard Auxiliary Member Contact Information
Collecting the applicant’s contact information is important because it allows the
Coast Guard to contact the owner should there be a discrepancy or mishap with the
aid to navigation. A discrepant aid is one that is not functioning in the manner it was
permitted. Types of discrepancies include the light being extinguished, a buoy
sinking, or an aid out of position. Certain discrepancies create hazards to navigation
and must be immediately corrected or repaired. The contact information is available
to Coast Guard aids to navigation personnel and contact is only initiated if the
private aid becomes discrepant or in need of repair.
If a Coast Guard unit discovers a discrepant private aid to navigation, the unit will
report the discrepancy to the District office and the District office will contact the
private aid’s owner to effect repairs. Additionally, the Coast Guard solicits the
assistance of the Coast Guard Auxiliary to monitor and inspect certain aids to
navigation. When a Coast Guard Auxiliary member discovers a discrepant aid to
navigation, they complete and submit ANSC 7054 (Aids to Navigation Report).
Auxiliary members submit their contact information which includes their First/Last
Name, Telephone Number, Region Name, District, Division, and Flotilla Number.
When a District office receives an ANSC 7054, the District office will contact the
private aid’s owner to effect repairs.
I-ATONIS stores information which allows the Coast Guard to contact owners of
wrecks, oil rigs, private aids to navigation, private property owners on which an aid
to navigation is located, and operators of oil rigs. If the owner designates another
individual as the point of contact for the Coast Guard with respect to the wreck, oil
rig, private aid, or leased property, the point of contact information is retained as
well.
I-ATONIS has program user access controls in place governing who may view or
access the contact information. The information is only stored for the purpose of
contacting individual points of contact. Only I-ATONIS authorized users may view
the contact information collected.
To ensure accuracy of the information collected about them, applicants are provided
copies of the approved or disapproved private aid to navigation application. The
applicant can revise the original application by submitting a revised application and
indicting the application is a "Change" to the original.

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 8
I-ATONIS is a password-protected database application available to authorized users
within the aids to navigation community. Data analysis is not performed on the
personal information maintained in I-ATONIS.
2.

Status of Project:
This is a new development effort.
This an existing project.
Date first developed:
Date last updated:

3.

Is the information collected directly from the individuals seeking information from the
Department or working collaboratively with the Department on various projects?
Yes.
No. Please describe the information source and collection method.

4.

Does the individual have the option to decline submitting the information collected?
Yes.
No.

5.

Is the information collected limited to non-sensitive personally identifiable information? An
example of sensitive personally identifiable information is the social security number or date of
birth.
Yes.
No.

6.

What information about individuals could be collected, generated or retained?
An applicant submits either CG Form 2554 (Private Aids to Navigation Application)
or CG Form 4143 (Application for Class 1 Private Aids to Navigation on Artificial
Islands and Fixed Structures) to the Coast Guard district office where the private aid
is to be established. The application is reviewed and approved by the district's aids
to navigation staff. The information is entered into I-ATONIS by an authorized staff

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 8
user and contains the description and position of the aid to navigation in addition to
the applicant’s first/last name, title, organization name, address, telephone number,
fax number, email address.
A Coast Guard Auxiliary member may submit an ANSC 7054 (Aids to Navigation
Report) notifying the district office of the discovery of a discrepant aid to navigation.
The Auxiliary member’s contact information is entered into I-ATONIS by an
authorized staff user and includes the member’s First/Last Name, Telephone
Number, Region Name, District, Division, and Flotilla Number.
7.

Is the contact information only being used for the purpose for which it originally was
collected, i.e., to contact individuals?
Yes.
No.

8.

With whom could the information be shared?
Information is available only to those with access to the I-ATONIS system. Contact
information is available to Coast Guard aids to navigation personnel at the district office
that approved the private aid or where the private property, wreck, or oil rig is located,
the local Coast Guard unit in the area where the private aid, property, wreck, or oil rig is
located, as well as the Coast Guard Headquarters’ Aids to Navigation Program
Manager’s office (CG-5531). Contact information is only accessed if the owner of the
private aid, property, wreck, or oil rig must be notified in the course of Coast Guard aids
to navigation related matters.

9.

Are program or project user access controls in place governing who may view or access the
contact information?
Yes.
No.

10.

Has an Authority to Operate from the Chief Information Security Officer been granted to the
program or project that the document or database which stores the contact information?
No.
Yes. Please indicate the determinations for each of the following:
Confidentiality:

Low

Moderate

High

Undefined

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 8
Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

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 8
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: July 12, 2011
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: DHS/ALL/PIA-006 DHS General
Contact Lists
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/ALL-002 DHS Mailing and
Other Lists System
A new SORN is required.

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 8
DHS PRIVACY OFFICE COMMENTS