1625-0015 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

Version number: 04-2016
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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:

Office of Bridge
Programs (CG-BRG)

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Bridge Permit Application Guide
OMB Control
1625-0015
OMB Expiration
February 28, 2019
Number:
Date:
Collection status:
Extension
Date of last PTA (if
N/A
applicable):

Name:
Office:
Phone:

Name:
Office:
Phone:

PROJECT OR PROGRAM MANAGER
Allen Garneau
CG-BRG-2
Title:
Project Manager
202-372-1519
Email:
[email protected]
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Anthony Smith
CG-612
Title:
PRA Coordinator
202-475-3532
Email:
[email protected]
SPECIFIC IC/Forms PTA QUESTIONS

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

1. Purpose of the Information Collection or Form
33 U.S.C. 401, 491, and 525 authorize the Coast Guard to approve the location and plans of
bridges and causeways across navigable waters of the U.S. and impose any necessary
conditions relating to the construction, maintenance, and operation of these bridges in the
interest of public navigation. A bridge permit is the written approval of the location and plans
of the bridge or causeway to be constructed or modified across a navigable waterway. Any
individual, partnership, corporation, or local, state, or federal legislative body, agency, or
authority planning to construct or modify a bridge or causeway across a navigable waterway
of the U.S. must apply for a Coast Guard bridge permit.
In accordance with 33 CFR 115.50, the applicant must apply for a bridge permit via letter for
construction of or modification to bridges crossing navigable waters. 33 CFR 115.50 sets forth
the procedures by which the application is processed by the Coast Guard.

The information needed for the change to the rule can only be obtained from the bridge
owners.

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.)

X Yes
No
X Members of the public
X U.S. citizens or lawful permanent
residents
☐Non-U.S. Persons.
☐DHS Employees
☐DHS Contractors
☐Other federal employees or 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.)

X 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.
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: N/A
There is no form associated with this collection.
e. What information will DHS collect on the form?
There is no form associated with this collection. The record, a Coast Guard Bridge Permit
letter contains the following PII:
Applicant Name
Applicant Address (normally business)
Applicant Phone Number
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? No.
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
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

☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ 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
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
X 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?
X☐Electronic. Please describe the IT system that will
store the data from the form.
The records are entered onto the CG server.
☐Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
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

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

X☐Manually (data elements manually entered).
Please describe.
Electronic records are entered onto a digital folder
via the CG server.
☐Automatically. Please describe.

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.
X☐By a non-personal identifier. Please describe.
Permit case numbers are assigned to each record and
are used for retrieving information.

The application records are permanent files. (NC1-26-82d. What is the records
11, items 51 and 310a).
retention
schedule(s)? Include
the records schedule
number.
The application records are not disposed or deleted, as they
e. How do you ensure
are Permanent files.
that records are
disposed of or deleted Records are transferred to Federal Records Center 1 year
after completion and transferred to NARA 10 years after
in accordance with
completion of project.
the retention
schedule?
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☐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.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
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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.
X 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.

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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:

Kenlinishia Tyler

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:

August 7, 2018

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.)

November 15, 2018
☐Yes. Please include it with this PTA
submission.
X No. Please describe why not.
There is no form associated with this
collection.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
The Bridge Permit Application Guide is a privacy sensitive collection that collects name, business address
and business phone number of the entity (i.e. individual, partnership, corporation, or local, state, or

federal legislative body, agency, or planning authority) that applies for a USCG bridge permit to
construct or modify a bridge or causeway across a navigable waterway of the U.S.
DHS/USCG/PIA-008, Marine Information for Safety and Law Enforcement provides coverage for this
activity.

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

Click here to enter text.
November 16, 2018
November 16, 2021

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

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.

Date IC/Form Approved Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
e(3) statement not required.
Statement:
Click here to enter text.
PTA:
Choose an item.
Click here to enter text.
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:
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

Please describe rationale for privacy compliance determination above.
USCG is submitting this PTA to discuss the Bridge Permit Application Guide, which is
associated with OMB Control Number 1625-0015. USCG is authorized to approve the
location and plans of bridges and causeways across navigable waters of the U.S. and
impose any necessary conditions relating to the construction, maintenance, and
operation of these bridges in the interest of public navigation. A bridge permit is the
written approval of the location and plans of the bridge or causeway to be
constructed or modified across a navigable waterway. Any individual, partnership,
corporation, or local, state, or federal legislative body, agency, or authority planning
to construct or modify a bridge or causeway across a navigable waterway of the U.S.
must apply for this permit from the USCG.
In order to do this, USCG uses basic contact information from those applying for a
permit.
The DHS Privacy Office finds that this form is privacy-sensitive, requiring PIA
coverage.
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 not retrieved by a unique identifier.
However, DHS/USCG-013 MISLE does provide notice of this type of information
collection. Additionally, a Privacy Act Statement is not required.

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