1625-0018 Privacy Impact Assessment (PIA)

privacy-pia-uscg-015-MMLDS-20110301.pdf

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1625-0018 Privacy Impact Assessment (PIA)

OMB: 1625-0018

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Privacy Impact Assessment
for the

Merchant Mariner Licensing and
Documentation System
DHS/USCG/PIA-015
March 1, 2011
Contact Point
Gary Chappell
MMLD Project Officer
U.S. Coast Guard
CG-633
(202) 372-1293
Reviewing Official
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security
(703) 235-0780

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Merchant Mariner Licensing and Documentation System
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Abstract
The United States Coast Guard (USCG) owns and operates the Merchant Mariner Licensing and
Documentation (MMLD) System. The USCG uses MMLD to manage the issuance of credentials to
Merchant Mariners and process merchant mariner applications; to produce merchant mariner credentials;
to track the who of merchant mariner credentials issued by the Coast Guard; to track the status of merchant
mariners with respect to service, training, credentials, and qualifications, related to the operation of
commercial vessels; to qualify merchant mariners for benefits and services administered by other agencies;
and to perform merchant mariner call-ups related to national security. The records include the credential,
background check, and medical status on each U.S. Mariner and World War II Merchant Mariner Veteran.
USCG has conducted this privacy impact assessment (PIA) because MMLD collects and uses personally
identifiable information (PII).

Introduction
The United States Coast Guard (USCG) is responsible for issuing merchant mariner credentials
(MMCs) to merchant mariners in accordance with 46 U.S.C. Part E. Merchant mariners are vessel
employees that operate U.S. registered vessels. Any U.S. citizen may apply for a mariner license and any
legal U.S. resident may apply for a merchant mariner document. Applicants for merchant mariner
credentials are screened by the USCG to ensure they do not present a safety or security risk, they are
medically qualified to serve, and they have the training and experience to serve in the position for which
they are applying.
The purpose of the Merchant Mariner Licensing and Documentation system is to automate the
various credentialing processes, including maintaining records of U.S. merchant mariners. The records
include the credentials for each U.S. mariner and World War II Merchant Mariner Veteran's Status
information (DD214 program).
The mission of the MMLD is to support the Mariner Credentialing Program (MCP) in ensuring that
merchant mariners are qualified in an efficient manner to perform their duties for the purpose of:

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promoting the safety of life and property at sea;
promoting public safety;
protecting the marine environment; and
promoting homeland security

Merchant Mariner Credentials (MMCs) are issued to:

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Deck officers;

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Engineers;

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Pilots;

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Merchant Mariner Licensing and Documentation System
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Radio Officers on merchant vessels;

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Operators of un-inspected towing and passenger vessels;

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Staff Officers, including pursers, medical doctors, and nurses,

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Crew members for qualified ratings, such as able seamen and qualified members of the engine
department; and

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Entry-level ratings, such as ordinary seaman, wiper, and steward.

Applications are received at regional exam centers located across the United States. If a position
requires applicants to pass an exam, the exam would be administered at a regional exam center. Each
mariner application is reviewed in three capacities: medical, security, and professional.
Medical
The medical review ensures that the mariner is fit to perform the duties for which he is applying.
Certain positions require applicants to pass a physical examination and meet certain standards of physical
performance. For example, a deck officer needs visual acuity and color perception sufficient to identify
aids to navigation in order to operate a vessel, so those attributes would be checked during a physical exam.
Applicants may seek a waiver for any medical restrictions on a profession. The medical review is conducted
by a team of doctors and medical personnel employed by the U.S. Coast Guard at the National Maritime
Center (NMC). The only information entered into MMLD by the medical reviewers is the determination
of medical fitness and any medical limitations that will be applied to the credential. Medical information
that is not entered into MMLD is maintained as paper files first at NMC and later at NARA.
Security
Each mariner application is sent to the USCG’s National Maritime Center (NMC) for processing.
Biographic information is collected during the application process, including photographs submitted with
the application and fingerprints collected when the mariner applies for a Transportation Worker
Identification Card (TWIC) and provided to the NMC by the Transportation Security Administration
(TSA). At the National Maritime Center the applicant’s biographic information is used to screen against
terrorist watch lists and other law enforcement databases. TSA sends fingerprints to the Federal Bureau of
Investigation (FBI) for a related law enforcement check in National Crime Information Center (NCIC) and
provides the results to NMC.
NMC does not share the results or analysis of the security screening. This information is
maintained in MMLD. 1 NMC will only share with USCG a determination of “approved” or “denied”.
Professional
The professional review of the application ensures that the applicant has met the required
professional certifications to perform a job. For example, an applicant to be a medical officer aboard a

1

Please see the Merchant Seaman Records System of Records Notice (June 25, 2009,74 FR 30308 at
www.dhs.gov/privacy for additional information)

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vessel must be an accredited doctor and provide documentation proving that fact. Such professional
certifications are validated by personnel at the NMC.
It is important to note that MMLD only collects and stores the medical, security, and professional
evaluation information required to process the specific credential requested. MMLD may not have the
same information on all mariners because each credential has different requirements. MMLD is a
processing system designed to facilitate transfer of applications to the experts (medical, security,
professional) responsible for making final suitability determinations.

Section 1.0 Information Collected and Maintained
The following questions are intended to define the scope of the information requested as well as
the reasons for its collection as part of the system, rule, and/or technology being developed.

1.1 What information is collected, used, disseminated, or
maintained in the system?
The information that is collected, used, disseminated and maintained in MMLD consists of the following:
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Full name (including maiden name, if applicable);
MMLD identification number;
Medical limitations;
Mailing address;
Date and place of birth;
Phone number(s), include home and work;
Email Address;
Next of kin’s Name, mailing address, phone number and email address;
Country of citizenship;
Social Security number;
Physical Characteristics (including color of eyes, hair, weight and height);
Type of credential for which the individual is applying or was issued;
Credential issue and expiration date;
Shipping articles (including Information on ships and documented lengths of sea duty);
Seaman’s sea service records;
Seaman’s biometrics including photographs and fingerprint records;
Safety records (findings and working notes of latest Safety and Suitability evaluations are
maintained in MMLD);
Current state of application, including granted or denied with place and date of issuance;
Information related to narcotics, driving while under the influence, and conviction records; and
Character references, including full names, addresses, and telephone numbers.

1.2

What are the sources of the information in the system?

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Merchant Mariner Licensing and Documentation System
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Information is primarily collected from the mariner applying for the credentials. Additional
information is provided by shipping companies, schools, and physicians. Information is also obtained from
various commercial, federal and state databases to include but not limited to; commercial data providers,
such as Accurint, 2 states’ Department of Motor Vehicles, Marine Information for Safety and Law
Enforcement (MISLE), and NCIC.
Although MMLD obtains information from Accurint it is important to note that the actual results
are not retained in MMLD. Accurint results are used to verify the accuracy of MMLD information. If
Accurint indicates the information is incorrect, further investigation is conducted and the information is
corrected in MMLD, if appropriate.

1.3

Why is the information being collected, used,
disseminated, or maintained?

MMLD is the system of record for administering the Mariner Credentialing Program (MCP) to
certify domestic and international qualifications for the issuance of Merchant Mariner Credentials (MMCs)
to professional U.S. mariners. The information is required to verify that the mariner applicant has the
requisite general knowledge and skill to hold the credential issued and is of sound health as required by 46
U.S.C. § 4701, is a U.S. citizen as required by 46 U.S.C. § 4702 and 46 U.S.C. § 7304, and does not present
a threat to vessel safety or security. Mailing addresses, email addresses, and phone numbers are collected
to contact the mariner concerning licensing issues and for the purpose of call-ups related to national
security. Date of birth and SSN are required to check the National Driver Register (NDR) per 46 U.S.C. §
7302.

1.4

How is the information collected?

Information is collected from the mariner applying for the credential on the application form
number CG-719B (OMB control number 1625-0040), through supporting documents submitted with,
following the evaluation of, the application. Supporting documents may include sea service records, course
completion records, and medical records. In addition to information collected directly from the individual,
the USCG may collect the following:
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Shipping articles and sea service records provided by shipping companies;

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Medical Review Officer (MRO) provide drug test results, and

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Medical records collected from physicians.

Information is obtained directly from the following databases: MISLE, NCIC, and National Driver
Register. MISLE provides information on disciplinary actions. NCIC provides information on any criminal
convictions. The National Driver Register provides information on convictions for driving while impaired
by alcohol or drugs.

2

Accurint is a commercial person locating and research database available to government and commercial
customers.

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Merchant Mariner Licensing and Documentation System
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1.5

How will the information be checked for accuracy?

Information submitted by mariners is verified by examiners during the application process by
comparison with supporting documentation and information from other databases, including Accurint,
MISLE, NCIC, and the National Driver Register. Information may also be compared against past
applications and other data sources.

1.6

What specific legal authorities/arrangements/agreements
define the collection of information?

Pursuant to 46 U.S.C. § 7101, the USCG issues credentials to U.S. mariners. It also requires
verification that the applicant has the requisite general knowledge and skill to hold the credential issued
and is of sound health. Pursuant to 46 U.S.C. § 7102, the USCG limits issuance of credentials to operate
documented vessels to U.S. citizens. Pursuant to 46 U.S.C. § 7302, the USCG issues documents to U.S.
mariners only. It also allows a check of the National Driver Register, testing for the use of dangerous drugs,
and a check of criminal history. Pursuant to 46 U.S.C. § 7304, the USCG requires proof of citizenship
before notation of that fact on merchant mariner documents. Pursuat to 46 U.S.C. § 7319, the USCG
maintains records on each merchant mariner's document issued, including the name and address of the
seaman to whom issued and the next of kin of the seaman. Pursuant to 46 U.S.C. § 7502, the USCG to
maintains computerized records on the issuances, denials, suspensions, and revocations of licenses,
certificates of registry, merchant mariners' documents, and endorsements on those licenses, certificates, and
documents. Public Law 93-579 § 7 and 31 U.S.C. § 7701 requires the USCG to obtain a social security
number when an individual applies for a credential. These record keeping requirements are met by MMLD
system.

1.7

Privacy Impact Analysis: Given the amount and type of
data collected, discuss the privacy risks identified and how
they were mitigated.

Privacy Risks: Privacy risks include collecting more information from mariners than is needed to
process credential applications.
Mitigation: Personnel tasked with processing credential applications are trained to collect and
retain only supporting documents containing information pertinent to the credential. All information not
needed to process the application is returned to the mariner.

Section 2.0 Uses of the System and the Information
The following questions are intended to delineate clearly the use of information and the
accuracy of the data being used.

2.1

Describe all the uses of information.

The information is used to administer the MMLD Program and to certify domestic and international
qualifications for the issuance of credentials to professional U.S. mariners. Information in MMLD tracks

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Merchant Mariner Licensing and Documentation System
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the status of merchant mariner credential applications from submission to credential issuance or denial. It
also tracks credential expiration to verify whether a credential is valid. This information in turn is used to
monitor processes, identify process improvements and make other program management decisions.
Specifically, management uses MMLD data to determine areas for process improvements and to identify
the need for other changes to the credential program in addition to supporting the process for evaluating
applications and issuing credentials. For example, the number of requests from mariners about the status
of the credential applications led management to develop the on-line mariner credential application status
functionality in Homeport. MMLD information is also used to: determine whether a mariner has the
citizenship, service, training, licenses, and qualifications necessary to qualify for a credential; determine
whether a mariner is in sound health; determine whether a mariner presents a threat to vessel safety;
determine if a mariner qualifies for benefits and services administered by other agencies; and to perform
merchant mariner call-ups related to national security.
Information is checked during credential renewal every five years and more frequently if there is a
change in the credential type. TSA conducts regular checks against the Terrorist Screening Database
(TSDB) and other law enforcement databases as part of the issuance of a TWIC, which is required for
issuance of a credential. Other checks are also performed by the Coast Guard such as against the National
Driver Register.

2.2

What types of tools are used to analyze data and what type
of data may be produced?

USCG uses MMLD to create reports and extracts to analyze MMLD data for management decisions
and data quality control. Extracts are provided daily from MMLD to the Coast Guard Business Intelligence
(CGBI) system which uses software for data analysis. Data analysis primarily involves reports of the
number and type of credentials issued.

2.3

If the system uses commercial or publicly available data
please explain why and how it is used.

USCG uses commercial data aggregators, such as Accurint in order to verify the accuracy of
addresses and other information provided on an application. MMLD does not maintain data from
commercial or publicly available data sources. If an analyst identifies inconsistent information between the
commercial data provider and the applicant, NMC will research the discrepancy by contacting the applicant
or someone (employer, spouse) who can verify the accuracy of the information.

2.4

Privacy Impact Analysis: Describe any types of controls
that may be in place to ensure that information is used in
accordance with the above described uses.

Privacy Risks: Accuracy of data contained in Accurint commercial database; possible error
committed during the verification process used to ensure the accuracy of application information.
Mitigation: Data is progressively audited and verified. If application data is inconsistent with
Accurint data, NMC will contact the applicant to resolve the discrepancy.

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Merchant Mariner Licensing and Documentation System
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Section 3.0 Retention
The following questions are intended to outline how long information will be retained after
the initial collection.

3.1

What information is retained?

MMLD retains all information it collects. For a complete list of this information, please see
Section 1.1.

3.2

How long is information retained?

Paper records related to issuance of Merchant Mariner Licenses and Documents are held on site
for one year past the last activity with the file. After that time they are then transferred to the regional
Federal Records Center in Suitland, MD where they are stored for up to 60 years after last discharge or
evidence of death is reviewed, depending on record. See COMDTINST M5212.12A, Section II, Chapter
16, SSIC 16720 and 16721 for details. Electronic records related to issuance of Merchant Mariner Licenses
and Documents will be retained in the system for 60 years pending NARA approval of the SF 115, Request
for Disposition Authority.

3.3

Has the retention schedule been approved by the
component records officer and the National Archives and
Records Administration (NARA)?

Yes. SF 115, Request for Disposition Authority signed by Records Officer and registered by
NARA September 24, 2008. Disposition Pending.

3.4

Privacy Impact Analysis: Please discuss the risks
associated with the length of time data is retained and how
those risks are mitigated.

Privacy Risks: As with the retention of documents for any length of time, there lies the risk of
unauthorized access or loss of documents/information.
Mitigation: By retaining documentation on site for only one year, MMLD minimizes the
possibility of loss or unauthorized access, as much as possible.

Section 4.0 Internal Sharing and Disclosure
The following questions are intended to define the scope of sharing within the Department
of Homeland Security.

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Merchant Mariner Licensing and Documentation System
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4.1

With which internal organizations is the information
shared, what information is shared and for what purpose?

Information may be shared with Immigration and Customs Enforcement (ICE), U.S. Citizenship
and Immigration Services (USCIS), or Customs and Border Patrol (CBP) on request when required for their
agency mission.
Information is shared with USCG personnel responsible for examining applications and issuing
licenses and documents. It may also be shared with USCG personnel responsible for conducting marine
safety investigations.
ICE, USCIS, or CBP may require MMLD data for their respective missions such as: name, address,
date of birth, and Social Security number to identify individual; or information on place of birth or
citizenship. Such information would be required if NMC detects a violation of laws enforced by the agency
during the review of the application or related background checks.

4.2

How is the information transmitted or disclosed?

Information is shared with USCG personnel using the MMLD and MISLE information systems to
registered users of those systems. If requested by ICE, CIS, or CBP, information would be transmitted
either as an encrypted electronic file or hand carried paper document.

4.4

Privacy Impact Analysis: Considering the extent of internal
information sharing, discuss the privacy risks associated
with the sharing and how they were mitigated.

Privacy Risks: Sharing information within DHS could unintentionally result in access by
unauthorized personnel.
Mitigation: Internal Information sharing with other DHS components, although necessary to
perform missions, does pose a risk. The risk is mitigated as best as possible through security procedures.
When sharing information internally, it is done only with authorized components and users.

Section 5.0 External Sharing and Disclosure
The following questions are intended to define the content, scope, and authority for
information sharing external to DHS which includes federal, state and local government, and the
private sector.

5.1

With which external organizations are the information
shared, what information is shared and for what purpose?

Information from the MMLD is shared with the United States Naval Reserve (USNR). Information
shared includes: Credential type;issue and expiration dates;mariner number; and Issue date of Merchant
Mariner Documentation. The particular information shared is only on existing Navy Reserve Officers who
are in the Navy’s Merchant Marine Reserve (MMR) program and have previously agreed to share this

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Merchant Mariner Licensing and Documentation System
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information with the USNR. This information is intended to improve the mission readiness levels and to
reduce the amount of paper reporting required by their Navy officers.
Some MMLD information is shared with the Maritime Administration (MARAD) for use in the
Mariner Outreach System and national security mariner recalls. 3 Information shared includes: Mariner
name, address, phone number, last 4 digits of SSN, date of birth, sea service record information, and
credentials issued. MARAD presently requires the last 4 of the SSN to differentiate between mariners with
the same first and last names. Presently, the MMLD number is not used because it is an internal number to
MMLD that the data recipient (MARAD) is unaware of, and hence could not use.
As part of the mariner security and suitability evaluation some information is shared with the
National Driver Register. Personal information shared with the National Driver Register consists of: Last
Name; First Name; Middle Name; Suffix; SSN; and Date of Birth. These data elements are used to query
the Registry and return data on suspended or revoked state driver’s licenses or convictions of serious traffic
violations such as driving while impaired by alcohol or drugs.

5.2

Is the sharing of personally identifiable information outside
the Department compatible with the original collection? If
so, is it covered by an appropriate routine use in a SORN?
If so, please describe. If not, please describe under what
legal mechanism the program or system is allowed to
share the personally identifiable information outside of
DHS.

The USCG has a Memorandum of Understanding (MOU) with MARAD regarding the sharing of
MMLD data. The agreement identifies the information to be shared, requirements for protecting the
information and restrictions on further transmission of the information. The USCG has a Memorandum of
Agreement (MOA) with the United States Naval Reserve regarding the sharing of MMLD data. The
agreement identifies the information to be shared, requirements for protecting the information, and the
restrictions on further transmission of the information.
Information is shared with the FBI and NCIC pursuant to the Merchant Seamen's Records System
of Records Notice (DHS/USCG-030, June 25, 2009, 74 FR 30308). In addition, the USCG has a
Memorandum of Agreement (MOA) with the FBI and the NCIC regarding the sharing of MMLD data.

5.3

How is the information shared outside the Department and
what security measures safeguard its transmission?

Information for the Naval Reserve is transmitted as an encrypted electronic file via e-mail.
3

One mission of MARAD is to be able to recruit mariners for service on National Defense Reserve Fleet vessels to
support the military in times of national emergency. On method to do this is to contact mariners (recall) for service
on these vessels in times of emergency. The Marine Outreach System is a MARAD web-based application that
allows mariners to update their contact information to facilitate recalls. The system also makes some information
from MMLD available to mariners as a reward for their participation in the system.

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Merchant Mariner Licensing and Documentation System
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Information for MARAD is transmitted as an electronic file either by a secure Internet site in the
Homeport Internet portal for which users must be registered. A National Highway Traffic Safety
Administration secure site is used to submit requests for National Driver Register checks and to retrieve the
results.
Recipients are required to secure sensitive data in accordance with the handling requirements set
by law, regulation and policy. No requirements are established for securing non-sensitive information.

5.4

Privacy Impact Analysis: Given the external sharing, what
privacy risks were identified and describe how they were
mitigated.

Privacy Risks: The primary risks identified with data sharing are as follows: releasing the wrong
sensitive information to a recipient; failing to properly encrypt or secure information during transmission;
and unauthorized release of information by recipient.
Mitigation: These risks were minimized by: only releasing the information required by the
recipient and removing sensitive information when possible; providing training to USCG personnel to
recognize sensitive information and know how to handle it; limiting personnel authorized to share data;
establishing a review process for data that is shared; using secure networks, encryption or secure delivery
methods to protect information during transfer; marking media and documents to identify the type of
information they contain; establishing MOUs/MOAs with recipients that specify their responsibilities
including handling requirements.

Section 6.0 Notice
The following questions are directed at notice to the individual of the scope of information
collected, the right to consent to uses of said information, and the right to decline to provide
information.

6.1

Was notice provided to the individual prior to collection of
information?

Yes. A System of Records Notice was published in the Federal Register (DHS/USCG 030) for
MMLD notifying the public of the information collected in that system. This PIA and the Merchant
Seamen’s Records System of Records Notice (DHS/USCG-030, June 25, 2009, 74 FR 30308) also provide
notice.
Each form and website that collects information from individuals contains a Privacy Act notice
indicating the use of the information and providing the option to not submit that information. An example
of such notice is as follows:
Privacy Act Statement
In accordance with 5 U.S.C. §552a(e)(3), the following information is provided to you when
supplying personal information to the Maritime Administration.

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1. Authority which authorized the solicitation of the information: 46 App. USC 1295b and 1295g.
2. Principal purpose(s) for which information is intended to be used: The information is used to
evaluate each applicant for an appointment to the U.S. Merchant Marine Academy.
3. The routine uses which may be made of the information: As background information on
applicants for the selection process. To contact the applicant, the social security number is a basic identifier.
4. Whether or not disclosure of such information is mandatory or voluntary (required by law or
optional) and the effects on the individual, if any, of not providing all or any part of the requested
information: Disclosure of the information is voluntary, but the applicant will not be considered further if
all information is not provided.

6.2

Do individuals have an opportunity and/or right to decline
to provide information?

Yes. Privacy Act notices are provided and individuals are given the opportunity to decline to
provide personal information. If they do not consent to the intended uses, however failure to provide
personal information may result in the individual not receiving a service.

6.3

Do individuals have the right to consent to particular uses
of the information, and if so, how does the individual
exercise the right?

Consent is granted by signing the form providing the information collected from the individual.
Examples include: Application for a Merchant Mariner Document, License or Certificate of Registry (CG719B), Merchant Mariner Physical Examination Report (CG-719K), DOT/USCG Periodic Drug Testing
Report (CG-719P), Small Vessel Sea Service Form (CG-719S), and Request Pertaining to Military Records
(SF-180).

6.4

Privacy Impact Analysis: Describe how notice is provided
to individuals, and how the risks associated with individuals
being unaware of the collection are mitigated.

Privacy Risks: Individuals may not receive a Privacy Act notice and/or understand their right to
consent.
Mitigation: These risks are mitigated by including a Privacy Act notice in a prominent place on
all forms and web sites to ensure they are available and visible to the individual at the time of collection.
The Privacy Act notice is written so it is easy to understand and includes the right to refuse to provide the
information. Also, Privacy Act Training is provided to USCG personnel annually so they can explain the
consent right. Furthermore, the system of records notice and this PIA provide extensive detail about the
merchant mariner application process, information collected and how it will be used.

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Section 7.0 Individual Access, Redress and Correction
The following questions are directed at an individual’s ability to ensure the accuracy of the
information collected about them.

7.1

What are the procedures which allow individuals to gain
access to their own information?

The individual should submit a written request for the information that includes their name,
mailing address, social security number, and if applicable, their merchant mariner license or document
number, to the System Manager at the following address: Department of Homeland Security, United States
Coast Guard, Commandant (CG-611), 2100 2nd Street, SW, Washington, DC 20593-7101. SSNs are
needed to uniquely identify an individual’s records in MMLD because of the large number of names in the
system (their name may not be associated in the system with their current address and there may be more
than one person with the same name at an address) and for the required Safety and Suitability checks. They
should also include the name and identifying number (documentation number, state registration number,
International Maritime Organization (IMO) number, etc.) of any vessel with which they have been
associated. They or their legal representative must sign the request. These procedures are published in the
MMLD Privacy Act Systems of Record Notice. The Secretary of Homeland Security has exempted this
system from subsections (c)(3), (d), (e)(1), (e)(4)(G), (H), (I), and (f) of the Privacy Act pursuant to 5 U.S.C.
552a(k)(2).
FOIA requests may be sent to Commandant (CG-611), United States Coast Guard, 2100 2nd Street
SW, Washington D.C. 20593-7101, Attn: FOIA.

7.2

What are the procedures for correcting erroneous
information?

The individual should submit a written request that identifies the erroneous information, how they
know the information is erroneous, and (if available) the correct information to the System Manager at the
following address: Department of Homeland Security, United States Coast Guard, Commandant (CG-611),
2100 2nd Street SW, Washington D.C. 20593-7101. They should also include any available documentation
supporting their claim that the information is erroneous.

7.3

How are individuals notified of the procedures for
correcting their information?

Individuals were notified through publication of the Systems of Record Notice in the Federal
Register. They may also be notified by USCG personnel during information collection or on request.

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Merchant Mariner Licensing and Documentation System
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7.4

If no redress is provided, what alternatives are available to
the individual?

Individuals have the right to appeal a decision to not correct information contained in MMLD.
Appeals follow the USCG chain of command. A decision by the Commandant of the USCG will be
considered the final agency action.

7.5

Privacy Impact Analysis: Please discuss the privacy risks
associated with the redress available to individuals and
how those risks are mitigated.

Privacy Risk: Risks associated with this process include: mishandling or improper release of
information by Coast Guard personnel and entering erroneous information into the system.
Mitigation: These risks are mitigated through a combination of training, procedures and policies.
USCG personnel with access to MMLD are verified as requiring access for their job before being assigned
an account. Those personnel are required to receive training on the proper handling of PII and other
sensitive information contained in the system. Logs are maintained to track user access to the system.
SSNs are collected to uniquely identify individuals so that they are only provided their own record.
Procedures require an investigation before any requested changes are made to the system to verify the
authenticity of the information to be entered.

Section 8.0 Technical Access and Security
The following questions are intended to describe technical safeguards and security
measures.

8.1

What procedures are in place to determine which users
may access the system and are they documented?

Authorized and vetted users, managers, systems administrators, and developers all have access.
Users are authorized through the MMLD account creation process. During that process a user requests an
account, their need for access is investigated and verified, then a MMLD account is created and a password
is assigned. Access levels are driven by need to know, eligibility, and suitability.
The MMLD User Guide establishes the policy used by approvers to ensure only those persons who
should have access to the system are approved.

8.2

Will Department contractors have access to the system?

Yes. Contract employees at the National Maritime Center and Regional Examination Centers
require access to MMLD in the course of their duties. Contract employees at the Operations Systems Center
maintain the MMLD system. The Privacy Act, 5 U.S.C 552a (m) (1) states that contractors maintaining a
system of record on behalf of a Government agency shall be considered employees of that agency.

Privacy Impact Assessment
United States Coast Guard
Merchant Mariner Licensing and Documentation System
Page 15

8.3 Describe what privacy training is provided to users either
generally or specifically relevant to the program or system?
All Coast Guard Personnel accessing MMLD are required to have periodic training in the use of
Sensitive But Unclassified (SBU) information in addition to basic system operation instruction. Annual
Privacy Act training is provided to USCG personnel who will access the system.
At a minimum, users from other agencies must be trained on the specified handling requirements
set by law, regulation or policy. Additional requirements may be established by the system or agency
distributing the information.

8.4

Has Certification & Accreditation been completed for the
system or systems supporting the program?

Yes. Final C&A with Authority to Operate was signed on February 20, 2011 and is scheduled to
expire February 19, 2014.

8.5

What auditing measures and technical safeguards are in
place to prevent misuse of data?

Audits are conducted annually to validate access. Users must maintain a current valid USCG email
address. Users who do not access the system for 60 days are automatically deactivated. The system logs
data access for review, audit, and/or disciplinary action.
Requests for access are reviewed and approved or disapproved by USCG personnel that manage
the MMLD system. Requests are submitted electronically and include: user name, email address, assigned
unit. Users are assigned the appropriate role based on their job requirements. All approvals are logged for
audit purposes.

8.6

Privacy Impact Analysis: Given the sensitivity and scope of
the information collected, as well as any information
sharing conducted on the system, what privacy risks were
identified and how do the security controls mitigate them?

Privacy Risks: Privacy risks include potential release of personal information if unauthorized
personnel access information in the MMLD database, potential release of personal information by
authorized MMLD users and potential release of personal information by third parties provided access to
that information
Mitigation: These risks have been mitigated through security procedures and checks. MMLD has
implemented security controls appropriate for a sensitive but unclassified information system in accordance
with FISMA. MMLD is only accessible via the USCG Intranet to prevent access by personnel from outside
the USCG. Requests for data from organizations outside the USCG are highly scrutinized. Any
information transferred to users outsite the USCG is transmitted in encrypted format to prevent accidental
release. Standards for handling data by users outside the USCG are established by Memorandum of

Privacy Impact Assessment
United States Coast Guard
Merchant Mariner Licensing and Documentation System
Page 16

Agreement, including a clause that prohibits transfer to other persons or organizations. Access is restricted
to specific users based on their profile and job requirements so that users only will have access to such
information that they are allowed to access. All access is logged for security purposes.

Section 9.0 Technology
The following questions are directed at critically analyzing the selection process for any
technologies utilized by the system, including system hardware, RFID, biometrics, and other technology.

9.1

Was the system built from the ground up or purchased and
installed?

MMLD was built using a combination of commercial off-the-shelf software and custom designed
software.

9.2

Describe how data integrity, privacy, and security were
analyzed as part of the decisions made for your system.

MMLD Servers are built to DHS and USCG guidelines. A FIPS-199 analysis was completed in
2004 and a full authority to operate was granted in December 2004. This system completed a FIPS-199
analysis to ensure the categorization of the system is accurately and appropriately labeled and secured.
Security and privacy requirements were derived based on the sensitivity category of the system, which is
considered to be HIGH sensitivity. The high baseline requirements reflect that stringent controls are
necessary for protecting the confidentiality, integrity, and availability of the data in this system. The system
is designed to support the high baseline requirements and protects the integrity and privacy of personal
information.

9.3

What design choices were made to enhance privacy?

User accounts, access restrictions, and encryption of data transmissions were built in to ensure data
integrity, privacy, and security.

Privacy Impact Assessment
United States Coast Guard
Merchant Mariner Licensing and Documentation System
Page 17

Conclusion
MMLD account and access security was evaluated in order to ensure controlled and powerful
software functionality, as such; the system has various user access levels to mitigate privacy risks. USCG
Security Officials follow the same policy and guidelines for approving accounts and determining access
groups. The USCG has designed a system that will ensure that only those individuals with an appropriate
need to know have access to the information deemed PII sensitive.

Responsible Officials
Project Manager, Commandant (CG-633)
U. S. Coast Guard
2100 2nd Street SW, STOP 7124
Washington, DC 20593-7124

Approval Signature Page

Original signed copy on file with the DHS Privacy Office
Mary Ellen Callahan
Chief Privacy Officer
Department of Homeland Security


File Typeapplication/pdf
File TitleMerchant Mariner Licensing and Documentation System
AuthorDepartment of Homeland Security Privacy Office
File Modified2016-09-12
File Created2016-05-27

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