1625-new Cgrc-1132 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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Version number: 04-2016

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:
Form Title:
Component:

(CGRC-1132)
United States Coast Guard “Chat Now” Questionnaire.
DHS
Office: Coast
Coast Guard Recruiting
Guard
Command

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
GOCOASTGUARD.COM CHAT NOW FORM
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:
Office:
Phone:

1625-TBD
Initiated

OMB Expiration
Date:
Date of last PTA (if
applicable):

TBD
N/A

PROJECT OR PROGRAM MANAGER
Mauro Cooper
Coast Guard Recruiting
Title:
Chief, Marketing Division
Command
202-795-6823
Email:
[email protected]

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Anthony Smith
CG-611
Office:
Information Collection
Manager
(202) 475-3532
E-mail:
[email protected]

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

SPECIFIC IC/Forms PTA QUESTIONS
1. Purpose of the Information Collection or Form
This information is collected to identify prospective members, assess eligibility, and
qualify candidates for service in the United States Coast Guard, and to manage, support,
and enhance the Coast Guard’s enlisted and commissioned officer recruiting mission.
The “Chat Now” form is an online submission tool that allows for prospective applicants
to chat via instant message in real time with a recruiter. These questions allow for the
recruiter to have basic information about the applicant, answer questions, make an initial
eligibility determination, and to contact the person in the future if they are interested in an
eligible for service.
14 USC 468 authorizes the United States Coast Guard to recruit personnel for military
service. The information requested on the gocoastguard.com web site is collected in
accordance with Section 503 of Title 10, United States Code, and may only be used to
identify and process individuals interested in applying for enlistment or commission in
the United States Coast Guard or Coast Guard Reserve. Other legal authorities include
10 USC 504, 1475-1480; 14 USC 211, 350, 632; and HSPD-12. MOUs between Military
Entrance Processing Command (MEPCOM) and USCG define the PII requirements for
processing USCG applicants.
Records are maintained at USCG Headquarters in Washington, DC and recruiting
offices.
2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII 1)?

b. From which type(s) of
individuals does this form
collect information?
(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

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

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

☐ Other federal employees or contractors.

☐ The record subject of the form (e.g., the
individual applicant).
☐ Legal Representative (preparer, attorney, etc.).
☐ Business entity.
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.

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: http://www.gocoastguard.com/chatnow
e. What information will DHS collect on the form?
Name (first, middle, last,), e-mail, phone number, zip code, date of birth, gender,
education level, citizenship, ethnicity, race and felony conviction or pending legal
action.
f. Does this form collect Social Security number (SSN) or other element that is standalone Sensitive Personally Identifiable Information (SPII)? No.
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number
☐ Visa Number
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other

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

financial account number
☐ Other. Please list:

☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
Legal authorities include: 10 USC 504, 1475-1480; 14 USC 211, 350, 632; and Homeland
Security Presidential Directive (HSPD) 12.
h. How will this information be used? What is the purpose of the collection?
Data is used to make recruiting contacts with potential candidates and to answer questions
regarding the Coast Guard, ranging from applicants seeking to join to members of the public
seeking to learn about the Coast Guard.

Primary purpose is to provide a potential applicant with answers about joining the Coast Guard
and an initial assessment about eligibility.
i. Are individuals
☐ Yes. Please describe how notice is provided.
provided notice at the
Collection notice / Privacy Act statement is prominently placed
on collection form / website. User must acknowledge they
time of collection by
understand CG privacy policy before they can answer any
DHS (Does the records
questions.
subject have notice of
☐ No.
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.

Privacy Threshold Analysis – IC/Form

USCG Direct Access
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
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

b. If electronic, how
does DHS input the
responses into the IT
system?

☐ Manually (data elements manually entered). Please
describe.

c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?
d. What is the records
retention
schedule(s)? Include
the records schedule
number.

☐ By a unique identifier. 2 Individual’s name and address.
If information is retrieved by personal identifier,
please submit a Privacy Act Statement with this PTA.

Web entries automatically transferred into Direct Access.
CGRC personnel can manually edit to correct errors.

☐ Automatically. Web entries automatically transferred
into Direct Access

By a non-personal identifier. Please describe.

NARA records retention schedule pending:

Electronic data for all applicants is retained through the
end of the second fiscal year after the year of collection.

Data is archived off-line for an additional two years.
Information on selected applicants (who are accessed) is
forwarded for inclusion in the Official Military Personnel
File (OMPF).
Direct Access data base managers are responsible for
records disposition IAW established business rules.

e. How do you ensure
that records are
disposed of or deleted
in accordance with
the retention
schedule?
f. Is any of this information shared outside of the original program/office?
☐ Yes, information is shared with other DHS components or offices. Please describe.
Information is shared with other DHS components or offices, including: Internal to USCG at
accession points for the purposes of completing hire transactions and initiating personnel data
records; Internal to USCG with selection board members for determination of which

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.

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

applicants are most suitable for selection as commissioned officers. USCG personnel at
accession and initial training points also receive reports via encrypted email attachments, and
as hard copy, hand carried reports and forms.

☐ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
Data is shared with DOD (MEPCOM, Defense Manpower Data Center (DMDC)), and third
party contractor performing marketing support.

☐ No. Information on this form is not shared outside of the collecting office.

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

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

Kenlinishia Tyler
March 3, 2017

March 24, 2017

X☐ Yes. Please include it with this PTA
submission.
☐ No. Please describe why not.
Click here to enter text.

Component Privacy Office Recommendation:
The USCG Chat Now Questionnaire collects name (first, middle, last,), e-mail, phone number,
zip code, date of birth, gender, education level, citizenship, race and felony conviction or
pending legal action for prospective applicants interested in joining the USCG.
DHS/USCG/PIA-024 (Direct Access) and DHS/USCG-014 (Military Pay and Personnel System)
provides coverage for this collection.

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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:

Click here to enter text.

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

Click here to enter text.
Click here to enter a date.
Click here to enter a date.

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.
☒ 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:
Privacy Act
Choose an item.
Statement:
Click here to enter text.
PTA:
No system PTA required.
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

Click here to enter text.
PIA:
System covered by existing PIA
If covered by existing PIA, please list:
DHS/USCG/PIA-024 – Direct Access
If a PIA update is required, please list: Click here to enter text.
SORN:
System covered by existing SORN
If covered by existing SORN, please list:
DHS/USCG-014 - Military Pay and Personnel October 28, 2011 76 FR
66933
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.
The DHS Privacy Office finds that the United States Coast Guard “Chat Now” Questionnaire
is a privacy sensitive collection, requiring both PIA and SORN coverage. The questionnaire
collects a variety of name (first, middle, last,), e-mail, phone number, zip code, date of
birth, gender, education level, citizenship, race, and felony conviction or pending legal
action. These information is collected in order to allow a recruiter to have basic information
about the applicant, answer questions, make an initial eligibility determination, and to contact
the person in the future if they are interested in an eligible for service.
The DHS Privacy Office finds that PIA coverage is provided by DHS/USCG/PIA-024 – Direct
Access, which assesses the privacy risks associated with the Coast Guard’s use of PII in its
Direct Access system to conduct human resources and payroll functions. SORN coverage is
provided DHS/USCG-014 - Military Pay and Personnel System of Records Notice, which
outlines the Coast Guard’s collection and maintenance of records in order to administer the
USCG active duty, reserve, and retired active duty and retired reserve military pay and personnel
system.

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