1625-0122 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:

CG-REG

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Cargo Securing Manuals
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:
Office:
Phone:

1625-0122
Extension

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

June 30, 2019
N/A

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

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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 Coast Guard requires cargo securing manuals (CSMs) on vessels of 500 gross tons or
more traveling on international voyages and carrying cargo that is other than solid or
liquid bulk cargo
The purpose of the information collection is provide to the Coast Guard information to:
1) authorize a recognized classification society to approve a CSM on its behalf; and 2)
process applications for a new, or revisions to an existing, CSMs.
There is no form associated with this collection.
A recognized classification society submission (i.e., record) contain basic business contact
information, which may include the name, phone number and email of the submitter. A
CSM is not submitted to the Coast Guard, rather it is reviewed by recognized classification
society and then maintained onboard the vessel.
The authority for this collection is 46 U.S.C. 2103 and 3306.

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.)

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.

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.
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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.)

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:

e. What information will DHS collect on the form?
The record contain basic business contact information, which may include the name, phone
number and email of the submitter.
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
☐ Driver’s License Number
financial account number
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

☐ Other. Please list:

☐ 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
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.
A CG employee manually enters certain
information into the Marine Information for
Safety and Law Enforcement (MISLE) database.
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
N/A.
b. If electronic, how
does DHS input the
responses into the IT
system?

Manually (data elements manually entered).
A CG employee manually enters certain
information into the MISLE database.
☐Automatically. Please describe.
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

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.
Name can be retrieved. There is no form
associated with this collection.
By a non-personal identifier. Please describe.
A search can be done using classification societyspecific information.
A record is retained for the life of the classification
society; NARA retention schedule number N1-026-05015.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
As records are maintained in the MISLE database,
that records are
disposal/deletion is in accordance with the business
disposed of or deleted
rules for the database.
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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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 REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office
Reviewer:

A.L. Craig

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.)

April 24, 2019
May 7, 2019
☐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:
The Coast Guard requires cargo securing manuals (CSMs) on vessels of 500 gross tons or
more traveling on international voyages and carrying cargo that is other than solid or
liquid bulk cargo
The purpose of the information collection is provide to the Coast Guard information to:
1) authorize a recognized classification society to approve a CSM on its behalf; and 2)
process applications for a new, or revisions to an existing, CSMs.
There is no form associated with this collection.
A recognized classification society submission (i.e., record) contain basic business contact
information, which may include the name, phone number and email of the submitter. A
CSM is not submitted to the Coast Guard, rather it is reviewed by recognized classification
society and then maintained onboard the vessel.
This Coast Guard activity is covered by the DHS/USCG Marine Information for Safety and Law
Enforcement (MISLE) PIA and SORN (i.e., DHS/USCG PIA-008 and DHS/USCG-013).
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

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

Joseph McCaskill

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

1180585
May 8, 2019
May 8, 2022
Riley Dean
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
Privacy Act Statement not Required
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Statement:
PTA:

Click here to enter text.
System PTA Required
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:
System covered by existing SORN
If covered by existing SORN, please list: DHS/USCG-013 - Marine
Information for Safety and Law Enforcement (MISLE), June 25, 2009 74
FR 30305
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 Privacy is submitting this renewal PTA for USCG requiring cargo securing manuals
(CSMs) on vessels of 500 gross tons or more traveling on international voyages and
carrying cargo that is other than solid or liquid bulk cargo. The purpose of the information
collection is provide to the Coast Guard information to: 1) authorize a recognized
classification society to approve a CSM on its behalf; and 2) process applications for a new,
or revisions to an existing, CSMs. There is no form associated with this collection. A
recognized classification society submission (i.e., record) contain basic business contact
information, which may include the name, phone number and email of the submitter. A
CSM is not submitted to the Coast Guard, rather it is reviewed by recognized classification
society and then maintained onboard the vessel.
DHS Privacy Office (PRIV) agrees with USCG Privacy this is privacy sensitive. While there is
no form associated with this PTA, the collection of basic business contact information,
which may include the name, phone number and email of the submitter, is covered by
DHS/USCG/PIA-008 MISLE. The retrieval of information by name and classification
society-specific information is covered by DHS/USCG-013. This PTA is valid until May 8,
2022.

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