1625-0093 Privacy Threshold Analysis (PTA)

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD ANALYSIS (PTA)
This form serves as the official determination by the DHS Privacy Office to
identify the privacy compliance requirements for all Departmental uses of
personally identifiable information (PII).
A Privacy Threshold Analysis (PTA) serves as the document used to identify
information technology (IT) systems, information collections/forms, technologies,
rulemakings, programs, information sharing arrangements, or pilot projects that involve
PII and other activities that otherwise impact the privacy of individuals as determined by
the Chief Privacy Officer, pursuant to Section 222 of the Homeland Security Act, and to
assess whether there is a need for additional Privacy Compliance Documentation. A PTA
includes a general description of the IT system, information collection, form, technology,
rulemaking, program, pilot project, information sharing arrangement, or other Department
activity and describes what PII is collected (and from whom) and how that information is
used and managed.
Please complete the attached Privacy Threshold Analysis and submit it to your
component Privacy Office. After review by your component Privacy Officer the PTA is sent
to the Department’s Senior Director for Privacy Compliance for action. If you do not have a
component Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
[email protected]
Upon receipt from your component Privacy Office, the DHS Privacy Office will review this
form and assess whether any privacy compliance documentation is required. If compliance
documentation is required – such as Privacy Impact Assessment (PIA), System of Records
Notice (SORN), Privacy Act Statement, or Computer Matching Agreement (CMA) – the DHS
Privacy Office or component Privacy Office will send you a copy of the relevant compliance
template to complete and return.

Privacy Threshold Analysis – IC/Form

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:

N/A

Form Title:

N/A

Component:

U.S. Coast Guard (USCG) Office:

CG-REG

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Facilities Transferring Oil or Hazardous Materials in Bulk -- Letter of
Collection Title:
Intent and Operations Manual
1625-0093
January 31, 2017
OMB Control
OMB Expiration
Number:
Date:
Extension
N/A
Collection status:
Date of last PTA (if
applicable):

Name:
Office:
Phone:

Name:
Office:
Phone:

PROJECT OR PROGRAM MANAGER
Mr. David Du Pont
CG-REG
Reg Dev Mgr
Title:
202-372-1497
[email protected]
Email:
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Mr. Anthony Smith
CG-612
PRA Coordinator
Title:
202-475-3532
[email protected]
Email:

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

SPECIFIC IC/Forms PTA QUESTIONS
1. Purpose of the Information Collection or Form
The purpose of the information collection is to aid the Coast Guard in determining if a facility
is operating in accordance with the regulations. A Letter of Intent (LOI) is a notice to the CG
Captain of the Port (COTP) that an operator intends to operate a facility that will transfer bulk
oil or hazardous materials to or from vessels. An Operations Manual (OM) is also required for
this type of facility. The OM establishes procedures to follow when conducting transfers and
in the event of a spill.
There is no form associated with this collection. The records contain basic business contact
information which may include the name and address of the facility owner/operator, if
owned/operated by an individual.
The authority for this collection is 33 U.S.C. 1321.

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII1)?
b. From which type(s) of
individuals does this form
collect information?
(Check all that apply.)

c. Who will complete and
submit this form? (Check
all that apply.)

Yes
☐ No
Members of the public
U.S. citizens or lawful permanent
residents
Non-U.S. Persons.
☐ DHS Employees
☐ DHS Contractors
☐ Other federal employees or contractors.
The record subject of the form (e.g., the
individual applicant).
☐ Legal Representative (preparer, attorney, etc.).
Business entity.

1

Personally identifiable information means any information that permits the identity of an individual to be directly or indirectly inferred, including
any other information which is linked or linkable to that individual regardless of whether the individual is a U.S. citizen, lawful permanent resident,
visitor to the U.S., or employee or contractor to the Department.
Privacy Threshold Analysis – IC/Form

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

If a business entity, is the only
information collected business contact
information?
Yes
☐ No
☐ Law enforcement.
☐ DHS employee or contractor.
☐ Other individual/entity/organization that is
NOT the record subject. Please describe.
There is no form associated with this collection.
d. How do individuals
complete the form? Check
all that apply.

Paper.
Electronic. (ex: fillable PDF)
☐ Online web form. (available and submitted via
the internet)
Provide link:

e. What information will DHS collect on the form?
The records contain basic business contact information which may include the name and address
of the facility owner/operator, if owned/operated by an individual.
f. Does this form collect Social Security number (SSN) or other element that is standalone Sensitive Personally Identifiable Information (SPII)? No.
☐ Social Security number
☐ Alien Number (A-Number)
☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Social Media Handle/ID
☐ Known Traveler Number
☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
N/A

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

h. How will this information be used? What is the purpose of the collection? Describe
why this collection of SPII is the minimum amount of information necessary to
accomplish the purpose of the program.
N/A
i. Are individuals
☐ Yes. Please describe how notice is provided.
provided notice at the
Click here to enter text.
time of collection by
No.
DHS (Does the records
subject have notice of
the collection or is
form filled out by third
party)?

3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. Please describe.
the original,
Click here to enter text.
completed IC/forms?
☐ Electronic. Please describe the IT system that will
store the data from the form.
Click here to enter text.
Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
The records that the Coast Guard receives are
maintained in Marine Information for Safety and Law
Enforcement (MISLE) database.
b. If electronic, how
does DHS input the
responses into the IT
system?

Manually (data elements manually entered).
Please describe.
A scanned record is uploaded to the facility-specific
file in MISLE.
☐ Automatically. Please describe.
Click here to enter text.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?

☐ By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
Click here to enter text.
By a non-personal identifier. Please describe.
A search can be done using facility-specific
information.
A record is retained for the life of the facility; NARA
retention schedule number N1-026-05-015.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
As records are maintained in the MISLE database,
e. How do you ensure
disposal/deletion is in accordance with the business rules
that records are
for the database.
disposed of or deleted
in accordance with
the retention
schedule?
f. Is any of this information shared outside of the original program/office?
No. Information on this form is not shared outside of the collecting office.
☐ Yes, information is shared with other DHS components or offices. Please describe.
Click here to enter text.
☐ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.

2

Generally, a unique identifier is considered any type of “personally identifiable information,” meaning any information that permits the identity
of an individual to be directly or indirectly inferred, including any other information which is linked or linkable to that individual regardless of
whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to the Department.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office
Reviewer:

Robert Herrick

Date submitted to component
Privacy Office:
Date submitted to DHS Privacy
Office:
Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component
Privacy Act Statements.)

October 11, 2017
October 18, 2017
☐ Yes. Please include it with this PTA
submission.
No. Please describe why not.
There is no form associated with this
collection.

Component Privacy Office Recommendation:
The purpose of the Facilities Transferring Oil or Hazardous Materials in Bulk -- Letter of Intent
and Operations Manual information collection is to aid the Coast Guard in determining if a
facility is operating in accordance with the regulations. A Letter of Intent (LOI) is a notice to the
CG Captain of the Port (COTP) that an operator intends to operate a facility that will transfer
bulk oil or hazardous materials to or from vessels. An Operations Manual (OM) is also required
for this type of facility. The OM establishes procedures to follow when conducting transfers and
in the event of a spill.
The records contain basic business contact information which may include the name and address
of the facility owner/operator, if owned/operated by an individual.
This collection is covered by DHS/USCG/PIA-008 Marine Information for Safety and Law
Enforcement (MISLE) and DHS/USCG-013 Marine Information for Safety and Law
Enforcement (MISLE).

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PRIVACY THRESHOLD ADJUDICATION
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Riley Dean

PCTS Workflow Number:
Date approved by DHS Privacy
Office:
PTA Expiration Date

1152087
October 19, 2017
October 19, 2020
DESIGNATION

Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

Determination:

☐ PTA sufficient at this time.
☐ Privacy compliance documentation determination in
progress.
☐ New information sharing arrangement is required.
☐ DHS Policy for Computer-Readable Extracts Containing SPII
applies.
☐ Privacy Act Statement required.
X Privacy Impact Assessment (PIA) required.
☐ System of Records Notice (SORN) required.
☐ Specialized training required.
☐ Other. Click here to enter text.

DHS IC/Forms Review: Choose an item.
Click here to enter a date.
Date IC/Form
Approved by PRIV:
Click here to enter text.
IC/Form PCTS
Number:
No.
Privacy Act
There are no forms associated with this collection.
Statement:
PTA:
Choose an item.
Click here to enter text.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

PIA:

System covered by existing PIA
If covered by existing PIA, please list: DHS/USCG/PIA-008 Marine
Information for Safety and Law Enforcement (MISLE)
If a PIA update is required, please list: Click here to enter text.
SORN:
Choose an item.
If covered by existing SORN, please list: Click here to enter text.
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
USCG is submitting this PTA to discuss the Facilities Transferring Oil or Hazardous
Materials in Bulk - Letter of Intent and Operations Manual information collection, which is
associated with OMB Control Number 1625-0093. This collection provides information to
aid USCG in determining if a facility is operating in accordance with the regulations. A
Letter of Intent (LOI) is a notice to the CG Captain of the Port (COTP) that an operator
intends to operate a facility that will transfer bulk oil or hazardous materials to or from
vessels. An Operations Manual (OM) is also required for this type of facility. The OM
establishes procedures to follow when conducting transfers and in the event of a spill.
There is no form associated with this collection; however, the PII collected includes basic
business contact information such as the name and address of the vessel owner/operator.
The records that USCG receives are maintained in Marine Information for Safety and Law
Enforcement (MISLE) database and are not shared outside of the office.
The DHS Privacy Office agrees that this information collection is privacy-sensitive.
PIA coverage is provided by DHS/USCG/PIA-008 MISLE, which outlines the risks of
capturing information required to support the Coast Guard’s marine safety, security,
environmental protection and law enforcement programs. SORN coverage is not
technically required as the information is retrieved by search using facility-specific
information. However, DHS/USCG-013 MISLE does provide notice of this type of
information collection.

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