1625-0078 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:
Form Title:
Component:

N/A
N/A

U.S. Coast Guard (USCG)

Office:

CG-REG

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Credentialing and Manning Requirements for Officers of Towing
Vessels
OMB Control
1625-0078
OMB Expiration
July 31, 2017
Number:
Date:
Collection status:
Extension
Date of last PTA (if
N/A
applicable):
Name:
Office:
Phone:

Name:
Office:
Phone:

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 purpose of the information collection is to ensure that a mariner’s training information is
available to assist the Coast Guard in determining the mariner’s overall qualifications to hold
certain credentials. A mariner submits his/her training information at the time that they apply
for a merchant mariner credential. While the materials may be submitted in paper format or
electronically, the Coast Guard prints all e-files and creates a paper file for evaluation at the
National Maritime Center.
The Coast Guard requires that certain mariners maintain documentation of ongoing
participation in training and drills if they are seeking an endorsement as master or mate of
towing vessels or for renewal of the credential. Recording this information is necessary so
those mariners are able to demonstrate proficiency in: vessel management, seamanship,
navigation, watchkeeping, radar operation, fire prevention/fighting, emergency procedures,
lifesaving training, and environmental regulations. This information helps ensure that a
mariner's training information is available to assist in determining an individual’s overall
qualification to hold a Coast Guard issued merchant mariner’s towing vessel endorsement.
There is no form associated with this collection. The information contains the mariner’s name
and reference number, along with the designated examiner’s name and identification number.
The authority for this collection is 46 U.S. Code 2013 and chapter 71 and 75.

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

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.)

d. How do individuals
complete the form? Check
all that apply.

☐ 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.
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.
☐ 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? None, there is no form associated
with this collection.
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
provided notice at the
time of collection by
DHS (Does the records
subject have notice of
the collection or is
form filled out by third
party)?

☐ Yes. Please describe how notice is provided.
Click here to enter text.
No.

3. How will DHS store the IC/form responses?
a. How will DHS store
Paper. Please describe.
the original,
Training information is maintained as part of a
completed IC/forms?
mariner’s application.
☐ 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).
b. If electronic, how
does DHS input the
responses into the IT
system?

Privacy Threshold Analysis – IC/Form

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

X No information is retrieved.
A record is retained for 1-year after the final action on
the mariner’s application. After that time, the records
are sent to the Federal Records Center.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
See above.
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?
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:
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.)

Robert Herrick

March 28, 2017
April 7, 2017

☐ Yes. Please include it with this PTA
submission.
No. Please describe why not.
There are no forms associated with this
collection.

Component Privacy Office Recommendation:
Credentialing and Manning Requirements for Officers of Towing Vessels (1625-0078) is not
a privacy sensitive 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:

Michael Capparra

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

1141518
4/25/17
4/25/20

DESIGNATION
Privacy Sensitive IC or
Form:
Determination:

Yes If “no” PTA adjudication is complete.

☐ 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.
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-015 Merchant Mariner Licensing and
Documentation System
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-030 - Merchant Seamen's Records June 25, 2009 74 FR
30308
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 Credentialing and Manning Requirements for Officers
of Towing Vessels (CG 1625-0078) is a privacy-sensitive information collection,
requiring both PIA and SORN coverage. The Coast Guard collects a mariner’s name,
unique identifying number, documentation of training, and the name and ID number
of the designated examiner associated with the training. PRIV understands that
information is retrieved from the collection using a unique identification number
assigned by the Coast Guard, and is used to determine whether a merchant mariner is
proficient in the skills (vessel management, seamanship, navigation, watchkeeping,
radar operation, fire prevention/fighting, emergency procedures, lifesaving training,
and environmental regulations, necessary to attain an endorsement as master or mate
of a towing vessel.
PRIV finds that PIA coverage is provided by DHS/USCG/PIA-015 Merchant Mariner
Licensing and Documentation System, which assesses the privacy implications of the
Coast Guard’s use of PII in (1) managing the issuance of credentials to Merchant
Mariners and processing merchant mariner applications; (2) producing merchant
mariner credentials; (3) tracking merchant mariner credentials issued by the Coast
Guard; (4) tracking the status of merchant mariners with respect to service, training,
credentials, and qualifications, related to the operation of commercial vessels; (5)
qualifying merchant mariners for benefits and services administered by other
agencies; and (6) performing merchant mariner call-ups related to national security.
PRIV finds that SORN coverage is provided under DHS/USCG-030 - Merchant Seamen's
Records, which outlines the Coast Guard’s collection and maintenance of records in
order to administer the Commercial Vessel Safety Program to determine domestic and
international qualifications for the issuance of licenses, documents, and staff officer
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

certifications. This includes establishing eligibility of a merchant mariner's document,
duplicate documents, or additional endorsements issued by the Coast Guard and
establishing and maintaining continuous records of the persons documentation
transactions.

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