PIA DHS Financial Management Systems

Privacy Impact Assessment
for the

DHS Financial Management Systems
DHS/ALL/PIA-053
July 30, 2015
Contact Point
Chip Fulghum
Chief Financial Officer
Department of Homeland Security
202-282-8000
Reviewing Official
Karen L. Neuman
Chief Privacy Officer
Department of Homeland Security
(202) 343-1717

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Abstract
Department of Homeland Security (DHS) Financial Management Systems (FM Systems)
include web-based, workflow management, and financial transaction systems that provide core
financial management functions for the Department and are designated by the Chief Financial
Officer (CFO) as financial management systems. DHS FM Systems are used to create and maintain
records of each allocation, commitment, obligation, travel advance, and accounts receivable issued
by the Department. The systems contain personally identifiable information (PII) about DHS
employees, contractors/vendors, customers, and members of the public that participate in DHS
programs. This privacy impact assessment (PIA) covers multiple financial management systems
with similar practices and functional capabilities. This PIA covers all core CFO-designated
systems listed herein and in the Appendix. DHS will publish a separate PIA for any system that
differs substantially or that raises distinct privacy risks from those covered by this PIA. DHS is
conducting this PIA because DHS FM Systems collect and maintain PII.

Overview
DHS Chief Financial Officer (CFO)-Designated Systems are information technology
systems that require additional management accountability to ensure effective internal control
exists over financial reporting. CFO-Designated Systems can be non-financial, financial-mixed,
or true financial systems; 1 External Information Systems (EIS); or General Support Systems
(GSS). Generally, DHS uses its CFO-designated systems for recording and processing
commitments, obligations, collections, and payments (collectively “financial transactions”), which
are defined as follows:

1

•

Commitments: The reservation of agency funds to ensure the availability of those funds
before the agency awards a contract for goods or services, or for anticipated expenditures
such as payroll and contingent liabilities.

•

Obligations: The designation of agency funds toward a legal liability or definite promise
to pay for goods and services received or ordered. Examples of liabilities are: procured
goods or services under a government contract, monthly payments on a lease, government
purchase card transactions, DHS employee travel or relocations, etc.

•

Collections: Invoices sent to and payments received by the agency, often from customers
(i.e., other federal, state, and local agencies) for goods or services provided by the agency.

A financial system is an information system, comprised of one or more applications, that is used for any of the
following: (i) collecting, processing, maintaining, transmitting, and reporting data about financial events; (ii)
supporting financial planning or budgeting activities; (iii) accumulating and reporting cost information; or (iv)
supporting the preparation of financial statements. A mixed financial system is a system that supports both financial
and non-financial functions of an organization.

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•

Payments: Disbursements of agency funds (including reimbursements) to satisfy an
obligation.

Generally, these financial transactions occur between DHS and its employees (e.g., payroll,
benefits, work-related travel), contractors/vendors that provide goods and services to DHS, or
customers who receive goods and services from DHS. For several Components, financial
transactions may also occur with members of the public who participate in programs in which the
public pays fees or other payments to the agency (e.g., immigration benefit application fees, cash
immigration bonds for the release of detained aliens, trusted traveler programs, or credentials).
These transactions are generally conducted via Treasury’s Pay.gov system. 2
Criteria for CFO-Designated Systems
CFO-Designated Systems perform important functions within the financial reporting
process at a Component or across the Department. However, not all systems in the Department’s
inventory will be CFO-Designated. These systems require additional management accountability
to ensure effective internal control exists over financial reporting, and must meet a set of criteria
to receive the designation.
CFO-Designated Systems are not simply limited to those systems owned by the
Department. The Department depends on cross-Component servicing, federal shared service
providers, and external commercial providers to perform key financial management functions. In
addition, several DHS Components operate as financial management service providers for other
DHS Components.
Additionally, the Department uses external federal agencies and commercial service
providers to perform key processes. Systems at these entities are considered EIS, and may also be
considered CFO-Designated.
CFO-Designated Systems are not limited to applications. The financial transactions and
reports generated or processed by CFO-Designated Systems traverse GSS (i.e., networks).
National Institute of Standards and Technology (NIST) also requires that GSS have controls in
place to protect the transactions from unapproved alteration. DHS 4300A, Attachment R:
Compliance Framework for CFO-Designated Systems 3 includes network security requirements for
protecting data that resides in systems and on the network. These network controls must also be
regularly evaluated for design and effectiveness and are frequently included in the scope of security
control assessments and audits.

2

See Department of Treasury Pay.gov PIA, available at http://www.fms.treas.gov/pia/paygov_pia%20.pdf.
See DHS SENSITIVE SYSTEMS HANDBOOK 4300A, Attachment R (July 24, 2012), available at
https://www.dhs.gov/sites/default/files/publications/4300A-Handbook-Attachment-R-Compliance-Framework-forCFO-Designated-Systems.pdf.
3

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A CFO-Designated System can be a:
1. DHS-owned non-financial, financial mixed, or true financial system 4 that is hosted and
used within the same Component;
2. Intra-Department EIS that is hosted at one Component and used across the Department;
3. EIS that is hosted at another federal agency or commercial service provider and used across
the Department; or
4. GSS (network), supporting applications that sustain key business processes. A GSS
normally includes hardware, software, information, applications, communications, data,
and users. Examples of a GSS at DHS include a local area network (LAN) with financial
applications, a Component or Department-wide backbone, a communications network, or
a Departmental data processing center including its operating system and utilities.5
Uniform criteria are necessary to ensure that CFO-System designations are made consistently. The
most prominent criteria are typically the annual volume of dollars and transactions processed by
the system. However, other qualitative factors should be equally considered, such as key interfaces,
placement of the system within the financial reporting process, and mission criticality of the
system. The following criteria apply to vetting a system and GSS for CFO system designation.
CFO-Designated Systems are classified as such when they meet one or more of the criteria in their
respective category below.
DHS CFO-Designated Systems
DHS CFO has designated six information technology systems as FM Systems for the
Department’s core financial management requirements. They include:

4

•

Federal Financial Management System (FFMS) owned and operated by ICE. Services
ICE, MGMT, USCIS, NPPD, S&T;

•

Financial Accounting and Budgeting System (FABS) owned and operated by FLETC.
Services FLETC, I&A, and OPS;

A financial system is an information system, comprised of one or more applications, that is used for any of the
following: (i) collecting, processing, maintaining, transmitting, and reporting data about financial events; (ii)
supporting financial planning or budgeting activities; (iii) accumulating and reporting cost information; or (iv)
supporting the preparation of financial statements. A mixed financial system is a system that supports both financial
and non-financial functions of an organization.
5
A general rule of thumb is that if systems residing on a GSS are considered CFO-Designated, the GSS will likely
be deemed CFO-Designated as well. However, this is not always the case. Together, the system and GSS provide
protection and security over the financial data. DHS 4300A, Attachment R, details control requirements for CFODesignated systems, and includes specific requirements for specific GSS (network layer) level controls. For
example, the Access Control (AC) and Configuration Management (CM) sections of Attachment R require specific
network and communications security controls from DHS 4300A, Section 5.4.

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•

Core Accounting System (CAS) Suite owned and operated by USCG. Services USCG,
TSA, and DNDO;

•

Travel Manager, Oracle Financials, Compusearch/Purchase Request Information System
(PRISM), and Sunflower (TOPS) – USSS;

•

Systems, Applications, and Products in Data Processing (SAP) – CBP; and

•

Web Integrated Financial Management Information System – FEMA.

DHS FM Systems are a collation of existing independent systems used to create and maintain
records of each allocation commitment, obligation, travel advance, and accounts receivable issued
by the Department. DHS also has smaller financial management systems and applications that are
CFO-designated but not considered “core” financial management systems. These systems are
described in the Appendix to this PIA. DHS will publish a separate PIA for any system that differs
substantially, or that raises distinct privacy risks from those covered by this PIA. If DHS designates
other systems as FM Systems, DHS will update this PIA or Appendix as appropriate.
1. Federal Financial Management System (FFMS) - ICE
U.S. Immigration and Customs Enforcement’s (ICE) Office of the Chief Financial Officer
(OCFO), Office of Financial Management (OFM) is responsible for operating and maintaining
FFMS, which supports and processes financial management activities for ICE and five other DHS
Components, Directorates, or Offices (“Components,” for purposes of this PIA) specifically,
United States Citizenship and Immigration Services (USCIS), Office of Science and Technology
(S&T), the National Protection and Programs Directorate (NPPD), Office of Health Affairs
(OHA), and Office of Management (MGMT) 6. FFMS is a web-based, core financial management
system used to record and process financial transactions for ICE and five other DHS Components.
The system’s primary functions include processing:

6

•

Payroll and payroll-related transactions (e.g., health benefits and retirement) for DHS
employees;

•

Travel reimbursements and other personnel payments (e.g., conference attendance fees,
local travel) for DHS employees and other individuals such as invitational
travelers/speakers;

•

Payments for contractors/vendors providing goods and services (e.g., training and purchase
card services/activities) to DHS;

For the purpose of this discussion regarding financial management systems, references to MGMT include the
Office of the Secretary and Executive Management (OSEM) [i.e., the Offices of Policy, Privacy, Civil Rights and
Civil Liberties, Legislative Affairs, Public Affairs, General Counsel].

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•

Collections of debts owed to DHS, often by customers (i.e., other federal, state, and local
agencies) who receive services from DHS; and

•

Collections of fees or other funds from the public related to the operation of a DHS program
(e.g., immigration benefit application fees, posting of cash immigration bonds), and any
associated reimbursements of such funds.

The system is also used to generate statistical and financial transaction reports required for
reporting to the Department of the Treasury (Treasury) and other federal agencies outside DHS
(e.g., Office of Management and Budget (OMB)) as well as ad hoc reports for internal,
congressional, and senior management purposes.
FFMS is comprised of eight modules briefly described below:

7

•

Cost Management: Used for recording and tracking costs associated with reimbursable
agreements. 7 This module enables a user to track allocation costs (e.g., labor, expenses,
hours).

•

Database Administrator Management: Used to customize menus and profiles (e.g.,
granting screen and report access), and view the audit trail of maintenance data (i.e., the
business rules that govern various procedures in FFMS) recorded in FFMS.

•

Funds Management: Used for entering and processing commitments and obligations and
for managing and controlling funds, availability checks, and allocations.

•

General Ledger Management: Used for maintaining general accounting data and
processing general ledger reports and financial statements that detail current expenditures,
allocations, collections, and payments for reporting to DHS (e.g., CFO Reports) and
Treasury (e.g., Federal Agencies’ Centralized Trial-Balance System [FACTS] I and II
Reports). 8 In addition, it maintains employee personnel and payment remittance
information.

•

Payroll Management: Used for receiving and processing DHS employee payroll
accounting and time and attendance information.

•

Payment Management: Used for maintaining vendor records; processing and transmitting
payment transactions to Treasury; and recording financial transactions to update the
general ledger with the proper accounts payable and related expense amounts.

A reimbursable agreement means any arrangement whereby a federal agency agrees to provide goods or services to
another agency in return for reimbursement of costs incurred.
8
FACTS I is a system that collects agency pre-closing adjusted trial balances, and FACTS II is a computer program
that allows agencies to submit required budgetary information to Treasury. FACTS I and II reflect federal agency
budgetary information required for the Report on Budget Execution and Budgetary Resources, the Year-End Closing
Statement, and the Program and Financing Schedule of the President's Budget.

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•

Receipts Management: Used for maintaining customer records; generating customer
invoices and credit memos (in the event of an overpayment to DHS); processing customer
payments and miscellaneous cash receipts issued to customers for services provided by
DHS. In addition, it records transactions to update the general ledger with proper accounts
receivable, cash receipts, and related revenue amounts.

•

Workflow Management: Used to electronically route financial transaction records to
designated FFMS users for approval.

Each DHS Component that uses FFMS has its own instance of FFMS including separate,
partitioned back-end databases. The structure of FFMS limits the information users can access to
that of their own Component. NPPD has separate instances of FFMS; one for the Office of
Infrastructure Protection and one for the Office of Biometric Identity Management (OBIM). NPPD
users that support the Federal Protective Service (FPS), which was part of ICE until transferred to
NPPD in 2009, also have separate query/read-only accounts to access the ICE instance of FFMS
to access historical financial transaction data for FPS. FPS still uses the ICE instance.
Through reimbursable agreements, ICE provides financial services to the other
Components that use FFMS. Specifically, ICE processes collections and payments for the other
Components and conducts debt collection activities on their behalf. ICE OFM personnel who
perform these functions have separate user accounts by which they access the other Components’
instances of FFMS and record information relevant to the financial services ICE provides. Because
ICE is the system owner of FFMS, limited users within the ICE Office of the Chief Information
Officer (OCIO) can access the other Components’ instances of FFMS to provide IT support
services (e.g., manage user access, system maintenance, troubleshooting).
2. Financial Accounting and Budgeting System (FABS) – FLETC
The FABS application is an all-in-one financial processing system. 9 It functions as the
automated accounting and budgeting system for the Federal Law Enforcement Training Center
(FLETC). FLETC uses FABS to support its financial management and fixed asset management
system requirements. This version of the software requires a separate contract to provide custom
and technical support. This software provides a web based architecture that supports: a web user
interface; an open-standards-based interface for integration with external systems; and serviceoriented capabilities. It also provides reporting capabilities, data management capabilities, and
business rule capabilities.
As an Internal Shared Service Provider (ISSP) for the Department of Homeland Security,
FLETC currently provides financial management services to the Office of Intelligence and
Analysis (I&A) and the Office of Operations Coordination and Planning (OPS). FLETC currently
9

FLETC “Momentum” IT system functions as the single computerized accounting and budgeting system for
FLETC. Momentum resides within the security accreditation boundary of FABS.

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processes approximately 1,000,000 General Ledger (GL) transactions annually. These transactions
consist of the following document types: vendor payments, vendor records, payroll documents,
credit card purchases, travel, cash receipts, and dunning as well as approximately 30,000 reports.
3. Core Accounting System (CAS) Suite – USCG
The United States Coast Guard (USCG) CAS Suite 10 provides integrated accounting,
financial reporting, and asset management services to USCG, the Transportation Security
Administration (TSA), and the Domestic Nuclear Detection Office (DNDO). The CAS Suite
consists of six main subcomponents including: Core Accounting System (CAS), Financial
Procurement Desktop (FPD), Workflow Imaging Network System (WINS), Sunflower, Pay and
Personnel Center (PPC) Checkfree, and the Contract Information Management System (CIMS).
The CAS Suite provides a wide variety of business functions as described below.
Core Accounting System
The CAS Suite has been the primary Financial Management Solution (FMS) for USCG,
TSA, and DNDO. However, the Components now have a need to move this capability to a new
FMS solution provided by a Federal Shared Service Provider (FSSP). To address this common
need, each Component established its own acquisition project under the DHS Financial Systems
Modernization (FSM) Initiative.
•

DNDO - Financial, Acquisition, and Asset Management Solution (FAAMS)

•

TSA - Financial Services Replacement (FSR)

•

USCG - Financial Management Service Improvement Initiative (FMSII)

The goal of the three referenced DHS projects is to transition from the legacy CAS solution to a
common shared FMS solution. DNDO, TSA, and USCG intend to transition to the Oracle Federal
Financials (OFF), hosted by the Department of the Interior-Interior Business Center (DOI-IBC),
which is a FSSP. Under this approach USCG, DNDO and TSA will not own, design, configure,
manage, host, or customize financial management software and associated hardware. Instead,
DOI-IBC will be responsible for providing the required FMS functionality as a service and deliver
Component requirements through configuration of the Commercial-Off-The-Shelf (COTS)
solution to the maximum extent possible, while maintaining alignment with Treasury
Department’s Office of Financial Innovation and Transformation (FIT) modernization evaluation
criteria for financial services.
All key CAS Suite data and functionality referenced in the earlier section of this document
will be delivered through the new DHS FSM service. All applications within the new service will
10

See DHS/USCG/PIA-009 Core Accounting Suite (September 18, 2009), available at
http://www.dhs.gov/xlibrary/assets/privacy/privacy_pia_uscg_cas.pdf for additional information. However, note that
in 2017 CAS Suite will be replaced by the Financial Management Service Improvement Initiative (FMSII). USCG
will retire the CAS PIA and replace it with a new PIA for FMSII prior to deployment.

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be web accessible to the end users via an interface provided by DOI-IBC.
Of the three DHS Components planning to transition into this new service, DNDO will be
the first to transition (FY16), followed by TSA (FY17) and USCG (FY18) respectively. To ensure
successful transitions, multiple tests, involving data transfer (which will include PII data) from
CAS to the new solution, are currently being conducted by the FSSP, with additional tests
scheduled in FY15, FY16 and FY17 respectively. Following USCG’s successful migration over
to the new FSM service, CAS will be dispositioned.
The personally identifiable information (PII) that passes through the Core Accounting
System is required in order to process financial data. The Core Accounting System services a user
base of military personnel, civilian employees, and contractors from USCG, DNDO, and TSA.
The functions of the Core Accounting System include:
•

Processing and payment of obligations to commercial and government vendors and
members;

•

Collection of payments received for services from the general public, contractors, or other
government agencies;

•

The ability to track, report costs, and receipts on projects;

•

Maintenance of a general ledger containing the financial status of each agency serviced in
terms of planned versus actual expenditures, obligations, accruals, and commitments for
industrial projects; and

•

Asset management including the ability to track the original cost, the current value, owner,
and location of all capital assets and inventory.
Finance and Procurement Desktop (FPD)

FPD is the enterprise-wide system used by USCG, TSA, and DNDO to create and manage
simplified procurement documents and to maintain accurate accounting records agency wide.
Some functions of FPD include:
•

Ledger management;

•

Budgeting and funds distribution;

•

Procurement (procurement requests and simplified acquisitions);

•

Receipt of goods/services (accruals);

•

Interoperability with the USCG Core Accounting System;

•

System administration (account management & setup);

•

Reconciliation; and

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•

Reports.

FPD is designed to meet the needs of the user community by providing a simplified view of both
funds spent and funds available, in essence acting as an electronic checkbook for funds
management. Purchase Orders are created in FPD and then transmitted and captured by the Core
Accounting System. After the process is complete, a reconciliation occurs that is similar to how
an electronic checkbook balances its accounts with a statement from a bank. With this
functionality, as well as the application’s ease of use, FPD is similar to leading commercial
checkbook programs. The difference between these products and FPD is that FPD incorporates all
of the federal government accounting and procurement practices to meet the needs of federal
agency end-users.
The FPD portal uses graphical user interface (GUI) screens for the Web. Real-time
integration also exists among FPD, Contract Management Information System, and Core
Accounting System. Integration allows financial events from FPD to be recorded immediately in
the Core Accounting System. FPD’s integration capabilities result from the use of Web-friendly
technologies.
Workflow Information Network System (WINS)
WINS is the USCG imaging and document processing system. Paper documents (purchase
orders, obligations, modifications, receiving reports, invoices, correspondence, etc.) are
electronically loaded or scanned directly into the system upon receipt. For paper documents and
fax images received, relevant data elements are entered into the system and associated with the
document image in WINS. Files received electronically are entered into the system and images are
rendered automatically. All documents entering the system are routed, or “workflowed,” to the
appropriate accounting operations team at the Financial Crimes Enforcement Network (FINCEN)
for processing.
WINS allows electronic images of paper documents to be processed according to
procedures established at FINCEN. Processing procedures allow for data verification,
reconciliation, and prompt payment of invoices. User roles and workflows established within
WINS ensure established business practices are followed while the separation of accounting duties
is maintained. Information flows to several information systems that are dependent on WINS, but
are external to the application. WINS functions include:
•

Producing accurate and timely financial management information and related business
reports;

•

Processing financial transactions effectively;

•

Executing fiduciary and stewardship responsibilities consistent with policy and regulatory
authorities; and

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•

Establishing and maintaining accounting controls over Coast Guard resources.
Contract Management Information System (CIMS)

CIMS is a contracting management system that is used for formal contract creation and
management, including milestone planning, solicitations, award, and closeout. This system is
integrated with FPD to receive commitments and send contract procurement information back to
FPD. The primary users of the system include the contracting officer and contracting specialists.
CIMS functions include:
•

Creation and management of milestones, solicitations, multiple award setup, and formal
contract acquisitions;

•

Integration with FPD to receive commitments and send contracts back to FPD;

•

Combination of Purchase Request Information System (PRISM) and a customized
interface to FPD.
Sunflower Asset Management (SAM) Subsystem

SAM is a property management system providing primary business functions such as
acquisitions, transfers, retirements, modifications, and asset tracking. SAM is integrated with
Oracle Financials Fixed Assets (FA) for capitalized asset transactions.
Although the USCG uses the Oracle Financials FA module to manage assets and perform
property management, Sunflower is hosted by FINCEN for use by TSA. Sunflower is fully
integrated with the Oracle Financials FA module for capitalized asset transactions; however, it is
not considered to be a module of Oracle Financials because it was developed by a third party.
Sunflower does not reside in the same Oracle instance as the Core Accounting System. TSA uses
SAM as the property management system of record. SAM functions include:
•

Property management system, which provides the primary business functions like
Acquisitions, Transfers, Retirements, Modifications and Asset tracking;

•

Integrated with Oracle Financials Fixed Assets for capitalized asset transactions;

•

FPD is integrated with Sunflower by providing the purchase order and/or receipts to create
assets;

•

PPC Checkfree Subsystem; and

•

Supports the reconciliation of military payroll with four reconciliation sets and a single
general ledger.

4. TOPS – U.S. Secret Service (USSS)
TOPS is an Enterprise Financial Management System that consists of the Travel Manager,
Oracle Financials, Compusearch/PRISM, and Sunflower (TOPS) components that support the

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acquisition, accounting, travel, and property management functions of the USSS. These
components comprise a single, comprehensive, integrated financial management system. TOPS is
used by the entire USSS, including field offices.
5. Systems, Applications and Products in Data Processing (SAP) – U.S. Customs and
Border Protection (CBP)
The CBP SAP Program is a major integrated financial information system using a
commercially available software product, SAP, on a dedicated client server platform. CBP
implemented SAP to:
•

Combine many old system functions into one more efficient system;

•

Eliminate old legacy systems with insufficient security controls;

•

Support management goals of the CBP Office of Administration by aligning and improving
two core processes: asset (e.g., budget, logistics, procurement, property, and related policy)
and revenue (e.g., accounting and commercial operations: trade, tariff, and law
enforcement);

•

Provide an integrated solution to allow the agency to process and interpret financial data
more effectively;

•

Develop an agency-wide control and integration system for financial information, which is
essential to strategic decision-making;

•

Incorporate tools included in the public sector, solution management, and travel
management extension sets, to enhance customer service; and

•

Facilitate a shift in the role of finance from a transaction process/recordkeeping function
to a more analytical and decision making function.

SAP is based on client-server architecture and is accessible throughout CBP. SAP uses a relational
database (Oracle) to track information, and allows users to provide finance, procurement, property,
and logistic support for all of CBP. SAP is an Enterprise Resource Planning (ERP) System, which
provides an integrated, enterprise-wide information software solution.
SAP consists of modules. Each module provides a unique functionality for a specific
business process. Since SAP is an integrated system, all modules interact with each other to share
information. Information is only entered once into SAP, and the same information can be accessed
from other modules. CBP implemented the following modules:
•

Accounts Payable (AP): Allows CBP the ability to generate and uniquely identify multiple
types of payments with unique formats.

•

Asset Accounting (AA): Tracks all CBP personal properties including custom-owned real
property assets and capital/leasehold improvements along with depreciation.

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•

Budget Control System (BCS): Provides flexible data entry options (Transaction codes,
screen variants, user defaults, GUI, etc.), Multi-level funds check, and ability to route
messages when budget is exhausted. It has the capability to drill down to the spending
source document.

•

Business Information Warehouse (BW): Allows for one fully integrated reporting system
with real-time query and reporting capabilities.

•

Controlling (CO): Tracks costs by Cost Centers and Internal Orders.

•

Financial Accounting (FI): Acts essentially as the regulatory ‘books of record,’ including
Funds Management, Accounts Payable, Accounts Receivable, General Ledger and closing.

•

General Ledger (GL): Provides all details to support GL balances.

•

Special Purpose Ledger (SPL): Provides the capability of Special Ledger and Split
Processor to capture data for specialized agency reporting.

•

Funds Management (FM): Generates details to support end user budget monitoring and GL
balances.

•

Human Resources (HR): Creates organizational structure and personnel administration for
support of other modules (Note: Does not replace systems used by Human Resources
Management (HRM)).

•

Materials Management (MM): Standardizes all procurement processes.

•

Public Budget Formulation (PBF): Provides a collaborative environment to accommodate
the requirements of the end-to-end public sector budget formulation process.

•

Profitability and Cost Management (PCM): Supports modeling business according to the
activities that it carries out using Activity Based Costing (ABC).

•

Plant Maintenance (PM): Manages and tracks maintenance requirements for CBP real and
personal properties and includes corrective and preventative maintenance.

•

Procurement for Public Sector (PPS): Facilitates the development and execution of the
contracting process.

•

Project Systems (PS): Tracks project costs, activities, tasks, and milestones.

•

Real Estate (RE): Tracks all CBP-occupied and managed facilities.

•

Reimbursable Agreements (RIA): Includes Internal Orders and Sales & Distribution.

•

Standard reporting from all SAP Modules: Allows flexible report creation options.

•

Travel Management (TM): Provides all details to support Travel Management.

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•

Workflow (WF): Routes documents for approval, information, and action.

As an integrated ERP, SAP processes transactions in real time. Data is entered once, which reduces
the scope for error and results in a single source of reliable data. SAP establishes budget and
performance integration as a core capability of the information management system. Electronically
linking automated business processes including requisitioning, receiving, invoicing, payment
processing, and accounting allows CBP to be more efficient because costs can be captured once.
The drill-down capability of SAP is a powerful tool that allows users to see the details of
original documents. For example: from a SAP procurement invoice, users can drill down to the
goods receipt and acceptance, purchase order, and purchase requisition. Once the business process
is complete, links also allow CBP users to go from the purchase requisition to the purchase order,
goods receipt and acceptance, and invoice.
6. Web Integrated Financial Management Information System (Web-IFMIS) – Federal
Emergency Management Agency (FEMA)
FEMA Web-IFMIS is FEMA’s official accounting and financial management system that
tracks all of FEMA’s financial transactions. 11 Web-IFMIS does not collect information directly
from individuals; the information contained in the system is pulled from other systems. WebIFMIS provides FEMA’s financial managers a global view of all FEMA’s financial systems. WebIFMIS uses information provided through these various subsystems in order to make payments to
entitled groups (grantees), FEMA employees for payroll and travel reimbursement, and contractors
and other vendors for payment of services. Web-IFMIS is also used to account for the expenditure
of public funds as mandated under various statutes, Executive Orders, OMB guidance, regulations,
and DHS and FEMA policies. To account for expenditures, Web-IFMIS generates report invoices,
payment receipts, cash receipts, commitments, obligations, receiving reports, expenditures, and
advanced charges.
Web-IFMIS carries out the budgeting, management of vendor accounts, payment approval,
and accounting for FEMA’s finances. The process begins when Congress appropriates and OMB
approves FEMA’s funding. Next, FEMA’s OCFO establishes accounts within Web-IFMIS to
correspond with the funding appropriated by Congress and approved by OMB. FEMA program
offices then request allocation of funds, via Web-IFMIS’s subsystems, as part of FEMA’s annual
and ongoing budgeting, financial, and accounting processes.
FEMA’s OCFO receives funding requests from the various program offices and processes
these requests by first reviewing the request and determining whether funds are available for the
transaction. If funds are available then FEMA commits the funds in Web-IFMIS to prevent those
funds from being used for any other purpose. FEMA’s OCFO also reviews the requests to make
11

For additional FEMA-specific information about Web-IFMIS, please see DHS/FEMA/PIA-020(a) Web Integrated
Financial Management Information System (Web-IFMIS) (August 16, 2013), available at
http://www.dhs.gov/privacy-documents-fema.

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sure that vendor accounts are established for each individual, entitled group, or entity identified on
the requests. FEMA establishes vendor accounts using PII, including name and a unique identifier
(e.g., Social Security number (SSN), employer identification number). Once funding is
appropriated and committed and the proper vendor accounts are established, FEMA is able to
process payments or provide reimbursements to those individuals, entitled groups, or entities
referenced on the initial requests.

Section 1.0 Authorities and Other Requirements
1.1

What specific legal authorities and/or agreements permit and
define the collection of information by the project in question?

Authority for maintenance of DHS FM Systems is provided in 8 U.S.C. §§ 1103 and 1226
as well as 8 Code of Federal Regulation (CFR) Part 103. Authority to collect taxpayer identifying
number from each person doing business with the agency is provided in 31 U.S.C. § 7701(c).

12

•

The Chief Financial Officers Act of 1990 12 – Requires agencies to both establish and assess
internal control related to financial reporting. The Act requires the preparation and audit of
financial statements. In this process, auditors report on internal control and compliance
with laws and regulations related to financial reporting.

•

Federal Financial Management Improvement Act (FFMIA) of 1996 13 – Requires federal
financial management systems to provide accurate, reliable, and timely financial
management information to the government’s managers.

•

Federal Information Security Management Act (FISMA) 14 – Requires agencies to provide
information security controls that are commensurate with the risk and potential harm of not
having those controls in place. The heads of agencies are required to annually report on the
effectiveness of the agencies’ security programs. “Significant deficiencies” found under
FISMA must also be reported as material weaknesses under FFMIA or as a lack of
substantial compliance under FFMIA if related to financial management systems.

•

OMB Circular A-123 Management’s Responsibility for Internal Control 15 – Defines
Management's responsibility for internal control in federal agencies. Circular A-123 and
the statute it implements, the Federal Managers’ Financial Integrity Act of 1982, 16 are at
the center of the existing federal requirements to improve internal control. It further
provides guidance to federal managers on improving the accountability and effectiveness

Pub. L. 101-576.
Pub. L. 104-208.
14
Pub. L. No. 107-296, as amended by Pub. L. No. 108-177.
15
OMB Circular A-123 (December 21, 2004), available at https://www.whitehouse.gov/omb/circulars_a123_rev.
16
31 U.S.C. § 3512.
13

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of federal programs and operations by establishing, assessing, correcting, and reporting on
internal control.

1.2

What Privacy Act System of Records Notice(s) (SORN(s)) apply to
the information?

The information in DHS FM Systems is collected, used, disseminated and maintained in a
manner consistent with the purposes, categories of records, routine uses, and retention periods
described in the following government, department-wide, and specific DHS Component SORNs
published in the Federal Register and available on the DHS Privacy Office website
(www.dhs.gov/privacy):
•

GSA/GOVT-003 Travel Charge Card Program System of Records; 17

•

DHS/ALL-007 Department of Homeland Security Accounts Payable System of Records; 18

•

DHS/ALL-008 Department of Homeland Security Accounts Receivable System of
Records; 19

•

DHS/ALL-010 Department of Homeland Security Asset Management Records; 20

•

DHS/ALL-019 Department of Homeland Security Payroll, Personnel and Time and
Attendance Records; 21 and

•

DHS/ICE-004 Bond Information Management System. 22

In addition, DHS and three of its Components (DNDO, TSA, and USCG), have signed an
interagency agreement with the Department of the Interior-Interior Business Center (IBC) to be
the federal shared service provider for the replacement CAS Suite. DOI is currently scheduled to
update its SORN, to include USCG, DNDO, and TSA data, before the scheduled DNDO transition
date.

1.3

Has a system security plan been completed for the information
system(s) supporting the project?

Yes. Each of the six DHS FM Systems listed above has its own unique system security
plan. Each has been granted an Authority to Operate for three (3) years.

17

GSA/GOVT-003 Travel Charge Card Program System of Records, 69 FR 4517 (January 30, 2004).
DHS/ALL-007 Department of Homeland Security Accounts Payable System of Records, 73 FR 61880 (October
17, 2008).
19
DHS/ALL-008 Department of Homeland Security Accounts Receivable System of Records, 73 FR 61885
(October 17, 2008).
20
DHS/ALL-010 Department of Homeland Security Asset Management Records, 73 FR 63181 (October 23, 2008).
21
DHS/ALL-019 Department of Homeland Security Payroll, Personnel and Time and Attendance Records, 73 FR
63172 (October 23, 2008).
22
DHS/ICE-004 Bond Information Management System, 74 FR 57891 (December 1, 2009).
18

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1.4

Does a records retention schedule approved by the National
Archives and Records Administration (NARA) exist?

Yes. Records retained by DHS FM Systems are covered by the following retention periods:
Financial Transaction Records: DHS retains financial transaction records related to
procuring goods and services, paying bills, collecting debts, and accounting for six years after final
payment or cancellation, unless longer retention is needed for business use, in accordance with
National Archives and Records Administration General Records Schedule 1.1, item 010.
Asset Management Information: Records used to track all DHS-owned or controlled
property that has been issued to current and former DHS employees and contractors. Asset
management records are destroyed in accordance with the following: National Archives Records
Administration General Record Schedule 1.1, item 030, Property, plant and equipment (PP&E)
and other asset accounting (two years after asset is disposed of and/or removed from agency
financial statement); National Archives Records Administration General Record Schedule 1.1,
item 040 Cost Accounting for stores, inventory, and materials (three years); and General Records
Schedule 23, Records Common to Most Offices within Agencies (two years).

1.5

If the information is covered by the Paperwork Reduction Act
(PRA), provide the OMB Control number and the agency number
for the collection. If there are multiple forms, include a list in an
appendix.

Information contained in DHS FM Systems that pertains to DHS employees and
contractors/vendors is not subject to the requirements of the Paperwork Reduction Act (PRA
because the information is not collected directly from the public. DHS FM Systems obtain the
information from various underlying component systems, some of which are covered by the PRA.

Section 2.0 Characterization of the Information
The following questions are intended to define the scope of the information requested and/or collected, as
well as reasons for its collection.

2.1

Identify the information the project collects, uses, disseminates, or
maintains.

DHS FM Systems collect, use, disseminate, and maintain information about DHS
employees, contractors/vendors, customers, and members of the public. Specifically, DHS FM
Systems contains the following categories of information:

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•

Employee personnel information: Limited to DHS employees, and includes name, address,
SSN, occupational data (e.g., job title, duty station), salary, time and attendance data, health
benefit data (e.g., personnel-selected insurance plans and costs), and retirement data.

•

Business-related information: Limited to contractors/vendors and customers, and includes
name of the company/agency, point of contact, telephone number, mailing address, email
address, contract number, vendor number (FFMS-generated), DUNS number, and
Taxpayer Identification Number (TIN), which could be a SSN in the case of sole
proprietors set up as individuals.

•

Financial information: Includes routing transit number, deposit account number, account
type, credit card number, debts (e.g., unpaid bills/invoices, overpayments), and remittance
address.

The following data is also contained in FFMS (ICE):
•

Immigration-related information: Limited to members of the public applying for
immigration benefits, obligors (individuals, entities, or surety companies) posting
immigration bonds, and aliens detained by ICE eligible for bond. Such information
includes Alien Registration Number (A-Number), obligor name and address, obligor
number (FFMS-generated), bond number, total bond and interest amount, bond post date,
and bond breach date and number.

DHS FM Systems also supports external and internal financial-related reporting requirements
(e.g., to Treasury for tax and unpaid debt collection purposes). Both routinely and on an ad hoc
basis, DHS FM Systems are used to generate standard financial reports such as for funding
balances, obligation and commitment balances, vendor payments, and status of a specific financial
transaction.

2.2

What are the sources of the information and how is the information
collected for the project?

The information maintained in DHS FM Systems is primarily received from other systems via
direct, automated system connections. These source systems include:
•

23

Concur Government Edition (CGE): Government-wide travel management system owned
by the General Services Administration (GSA) that is used by federal employees to manage
travel authorizations, vouchers, and expenditures. 23 On a daily basis, DHS FM Systems
receive a batch file from CGE containing new and updated travel records for DHS travelers
(i.e., DHS employees and invitational speakers) in order to obligate funds for temporary

Concur Government Edition (CGE) replaced the former government travel system known as “FedTraveler.” CGE
may also be referred to as Enterprise Travel Systems (ETS2).

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duty and local travel activity as well as pay funds owed to agency employees under
approved travel expense reports.
•

National Finance Center (NFC) Payroll System: Government-wide payroll system owned
by the United States Department of Agriculture (USDA) that is used to set up federal
employee payroll profiles as well as manage payment of salary and benefits. On a biweekly basis, DHS FM Systems receive a batch file from the NFC Payroll System
containing new and updated DHS employee records and time and attendance records.

•

Treasury’s Financial Management Service: A Treasury bureau that operates a suite of
financial systems and services that provide limited financial data to DHS FM Systems.
o Secure Payment System (SPS) – On a daily basis, DHS FM Systems receive a batch
file from SPS containing payment schedule numbers and check numbers for
payments issued on behalf of DHS.
o Intra-Governmental Payment and Collection (IPAC) System – On a daily basis,
DHS FM Systems receive a batch file from IPAC containing payment schedule
numbers, amounts, etc. in order to record payments received from other
government agencies for services provided by DHS that are made payable to DHS.

When contractors/vendors do not exist in DHS FM Systems vendor table, payment technicians
manually search and gather business-related information about contractors/vendors from the
Central Contractor Registration (CCR) database. CCR is a GSA-owned system that tracks data on
all contractors that do business with the Federal Government. All contractors are required to
register with CCR in order to contract with the Federal Government.

2.3

Does the project use information from commercial sources or
publicly available data? If so, explain why and how this
information is used.

Yes. As discussed in Question 2.2, payment technicians manually search the CCR database
to gather contractor/vendor information. The CCR database is available for the public to search;
however, payment technicians have privileged access to CCR in order to gather additional
contractor/vendor information in CCR that is not made available to the public (e.g., DUNS
number, TIN, or information not made public by the vendor). Payment technicians also use CCR
to verify the contractor/vendor is in good standing with the Federal Government. The
contractor/vendor information gathered by the payment technicians is then manually entered into
a DHS FM Systems vendor table, which is a smaller repository of contractors/vendors that provide
services to DHS and Components. This information is used when generating payments for services
rendered and transmitting required information to Treasury for tax purposes (e.g., 1099-INT and
1099-MISC forms).

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2.4

Discuss how accuracy of the data is ensured.

The information maintained in DHS FM Systems is primarily received from other systems
(described in Question 2.2). These source systems generally gather the information directly from
the individual or entity about whom it pertains, and as such is considered to be accurate. In
addition, each DHS FM System employs various internal controls and procedures to ensure the
data accuracy. For instance, the majority of data in DHS FM Systems is received through
automated system connections; this increases data accuracy by minimizing data entry errors.
Before uploading to a DHS FM System, the source data is also automatically evaluated for errors
(e.g., formatting, duplicate records, incorrect financial data/codes), and if errors are found, the
DHS FM System will not accept the record(s) and will generate an error log that must be reviewed
and reconciled by a user in consultation with the source system or provider. Once reconciled, the
record is re-submitted to the DHS FM System as part of the next automated transmission.
Consistent with DHS Management Directive 4300A, DHS FM Systems user roles and
accesses are established following the separation of roles and duties principle, which inherently
creates accuracy checks in the individual DHS FM Systems when processing transactions. Each
DHS FM System employs user roles and access controls that ensure no one user can create and
approve a single financial transaction. Transactions are generated by one user and then reviewed
and approved by another user. With each layer of review and approval, information in each DHS
FM System is checked for accuracy purposes, and errors are returned to the originating user for
correction. Furthermore, when making corrections, users validate the information against the
source data, which increases the data accuracy.

2.5

Privacy Impact Analysis: Related to Characterization of the
information

Privacy Risk: There is a risk of the over-collection of PII.
Mitigation: DHS only collects information in its FM Systems necessary to process
financial transactions and required for reporting to the U.S. Department of the Treasury.
Information maintained in DHS FM Systems is also primarily received via direct system
connections, which limits the information collected to only the information necessary to
appropriately process financial transactions or comply with reporting requirements as required by
law. This risk of over-collection is also not mitigated because of the need to preserve distinct
component financial systems as independent enclaves.

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Section 3.0 Uses of the Information
The following questions require a clear description of the project’s use of information.

3.1

Describe how and why the project uses the information.

DHS FM Systems have similar uses of information. DHS FM Systems use the categories
of information identified in Question 2.1 for the following purposes:
•

Employee Uses: DHS FM Systems use employee personnel information such as name,
SSN, grade, and salary to process employee payroll, health benefits, external training
requests, business travel, and asset management. When received from the NFC, employee
personnel information is used to verify and match employee records.

•

Contractor/Vendor Uses: DHS FM Systems use business-related information such as
company name, address, DUNS number, point of contact, and contract number to generate
commitments and obligations. DHS FM Systems also use this information, including the
TIN, to submit information about the contractor/vendor to the IRS for tax purposes. In
addition, DHS FM Systems use financial information collected from contractors/vendors
such as electronic funds transfer (EFT) numbers and routing numbers to generate payments
for services rendered.

•

Customer Uses: DHS FM Systems use business-related and financial information such as
company name, address, and point of contact to generate obligations and collections (i.e.,
bills/invoices) for debts owed to DHS for services provided to customers.

Specific to FFMS/ICE, certain categories of information identified in Question 2.1 are used for the
following purpose:
•

Public Uses: FFMS uses immigration-related information such as alien name, A-Number,
bond number, and obligor name and address (when applicable) to generate a payment
(including reimbursements). FFMS verifies and matches existing records to information it
receives from the Bond Management Information System regarding cancelled or breached
immigration bonds using immigration-related information (i.e., the bond number). FFMS
also uses financial information about aliens and obligors who have posted immigration
bonds to process payments and reimbursements (as appropriate).
Reporting

Lastly, DHS FM Systems use the information to generate routine and ad hoc reports
described in Question 2.1 above. Such reporting also includes sharing any of the aforementioned
categories of information with external agencies, namely Treasury, for tax-related and debt
collection purposes as required by law.

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For example, information from CBP’s SAP provides reports that are used for analysis and
decision-making. SAP reports significantly reduce the amount of time currently spent on research.
From within SAP, Business Warehouse (BW) systems are used as standard reporting solutions that
integrate widespread financial data across CBP. Business Warehouse systems are designed for
better data visibility across CBP to support accurate and consistent reporting. Report data can be
downloaded into local files in formats such as Excel and users have flexibility in the display
features using various layouts.
Field Offices
DHS FM Systems users may also transmit financial files (invoices) to field offices. The
transactions are recorded in DHS FM Systems. However, most field office system interfaces are
not a real-time direct interface with their corresponding DHS FM Systems. Therefore the field
offices must execute a data transfer to a specified account and location on the DHS FM Systems
to return the processed financial data. DHS financial management personnel then manually rename
the file(s) and move it to another file folder where it is processed via a series of batch jobs that are
each manually initiated within the corresponding DHS FM Systems application. Finally, each DHS
FM System creates a file that is uploaded into the Treasury Information Executive Repository
(TIER) system that is located at DHS Headquarters and managed by DHS.

3.2

Does the project use technology to conduct electronic searches,
queries, or analyses in an electronic database to discover or locate
a predictive pattern or an anomaly? If so, state how DHS plans to
use such results.

No.

3.3

Are there other components with assigned roles and responsibilities
within the system?

Yes. All DHS Components that use DHS FM Systems have access to the discrete
functionality that supports their Component system with assigned user roles and responsibilities
(described below in Question 8.3). DHS FM Systems user roles are similar across all systems;
however, DHS FM Systems follow the DHS policy requirements of “least privilege.”

3.4

Privacy Impact Analysis: Related to the Uses of Information

Privacy Risk: There is a risk that data may become outdated or incorrect without real-time
refresh from all source systems, because of the interconnectedness of DHS FM Systems to multiple
external and internal systems.
Mitigation: This risk is only partially mitigated. Most DHS FM Systems rely on a data
feed from the USDA NFC that is only run once every two weeks. DHS FM Systems vary in their

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refresh or update periods; however, all of them refresh at least as often as the NFC feed from
USDA.
Privacy Risk: There is a risk that DHS FM Systems users export reports to their localized
computer terminals.
Mitigation: This risk is managed by limiting access to DHS FM Systems to only DHS
employees with a financial management business function, and then only to those systems that
support their respective component.
Privacy Risk: There is a risk of unauthorized use of the information maintained in DHS
FM Systems.
Mitigation: To mitigate this risk, all DHS FM Systems employ appropriate role-based
access control so only authorized users have access to their Component’s instance of the system.
The access roles are pre-designated by the individuals’ position, which ensures users are only
granted access to information necessary to perform their official duties. Additionally, all users
receive training regarding the proper use of DHS FM Systems and rules of behavior prior to being
granted access to the system. All DHS FM Systems users complete annual mandatory privacy and
security training, which stresses the importance of appropriate and authorized use of personal data
in government systems.
Privacy Risk: There is a risk involving data quality and minimization arising from DHS
FM Systems user’s practice of manually transmitting financial data to field offices.
Mitigation: This risk is only partially mitigated. Ideally, DHS FM Systems should provide
methods for incorporating financial management data from DHS field offices into the DHS FM
Systems instances as opposed to using Excel or other ad hoc reporting mechanisms. Since the data
does not leave the DHS internal network and is shared via email, the financial management data
submitted to DHS FM Systems from field offices remains secure.

Section 4.0 Notice
The following questions seek information about the project’s notice to the individual about the information
collected, the right to consent to uses of said information, and the right to decline to provide information.

4.1

How does the project provide individuals notice prior to the
collection of information? If notice is not provided, explain why
not.

DHS FM Systems do not generally collect information directly from individuals. Rather,
they serve as aggregate financial management systems for transactions from multiple source
systems—systems that collect directly from individuals. Individuals providing information that is
ultimately transmitted to DHS FM Systems are provided notice at the time of the initial collection
by Privacy Act Statements that inform the individuals of the authority for and purpose of the

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collection, the uses of the information, and whether providing the information is mandatory. Notice
is also provided by this PIA as well as the publication of the SORNs identified in Question 1.2.

4.2

What opportunities are available for individuals to consent to uses,
decline to provide information, or opt out of the project?

Since information in DHS FM Systems is primarily received from other sources,
individuals do not have the option to consent to particular uses of their information once
transmitted to the DHS FM System. Once collected, their information is used for the purposes
described in this PIA and the SORNs identified in Question 1.2.
At the time of collection, however, individuals may decline to provide information, but
failure to provide the information may result in the denial or refusal of a benefit, including the
failed processing of a financial transaction (e.g., payment, reimbursement).

4.3

Privacy Impact Analysis: Related to Notice

Privacy Risk: There is a risk that individuals will not be aware that DHS FM Systems
collects and uses their information.
Mitigation: This PIA provides notice that the DHS FM Systems use data from other DHS
systems. Additional notice is also provided by the publication of the SORNs identified in Question
1.2 as well as by Privacy Act statements at the time of initial collection.

Section 5.0 Data Retention by the project
The following questions are intended to outline how long the project retains the information after the initial
collection.

5.1

Explain how long and for what reason the information is retained.

All information described in Question 2.1 is retained in DHS FM Systems. Under the
existing retention schedule and in accordance with NARA general records schedules, the
information will be maintained for 6 years from the date of the final payment or cancellation and
then deleted from DHS FM Systems. Retention of the information for this amount of time is
necessary in order to apply any additional expenditures, make corrections to payments (i.e., for
overpayments) and account balances, and for reporting and auditing purposes.

5.2

Privacy Impact Analysis: Related to Retention

Privacy Risk: There is a privacy risk that information will be retained on individual DHS
employee computer terminals longer than necessary to accomplish the purpose for which the
information was originally collected, inconsistent with the requisite records retention schedules.
Mitigation: This risk is not mitigated. All DHS FM Systems incorporate functionality to
allow users to export reports and files directly to their local computer terminals. DHS reminds

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DHS FM System users through policy and training that they must follow the applicable retention
schedules for financial information, regardless of where it is stored.

Section 6.0 Information Sharing
The following questions are intended to describe the scope of the project information sharing external to the
Department. External sharing encompasses sharing with other federal, state and local government, and private sector
entities.

6.1 Is information shared outside of DHS as part of the normal agency
operations? If so, identify the organization(s), how the information is
accessed and how it is to be used.
Yes. DHS shares information maintained in its DHS FM Systems outside of DHS with the
below external organizations as explained below. External organizations are responsible for
following their own applicable records retention schedules.
Typical External Sharing Transaction
On a monthly basis, an accountant runs a batch process on a DHS FM Systems Production
Server that creates a file. This file is then uploaded manually to the TIER website. DHS uses data
to prepare monthly and year-end financial statements for the Performance and Accountability
Report (PAR). TIER is a Treasury financial data repository, which collects, processes, and stores
summary financial data that is used to produce Treasury’s consolidated financial statements
required by OMB. The information is provided as an electronic file.
Department of the Treasury
DHS FM Systems share information with the United States Department of the Treasury’s
Financial Management Service to facilitate payment disbursements. Information shared with
Treasury’s Financial Management Service is transmitted electronically via a direct upload to
Treasury’s SPS system. Transmission of data to Treasury via SPS is protected using public key
infrastructure (PKI) encryption. The information includes the payee’s name, address, TIN (when
applicable), and bank account information, and is shared at the time the disbursements are
submitted to Treasury for execution. Treasury uses the information provided to issue federal
payments on behalf of DHS in the form of a paper check or EFT transaction.
As required on an annual basis, ICE shares business-related and financial information
maintained in FFMS with the IRS to report payments issued to vendors/contractors for services
rendered to DHS. Additionally, ICE shares immigration-related information maintained in FFMS
with the IRS when income taxes are withheld from obligor interest payments and to report on
interest payments distributed to obligors (IRS Form 1099). This information includes the obligor’s
name, address, TIN (when applicable), and amounts paid and withheld. This information is shared
with the IRS to support the federal income tax processing and in accordance with the Internal

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Revenue Code and IRS regulations. Information shared with the IRS is sent electronically through
an encrypted transmission to an IRS system, the Filing Information Returns Electronically
(F.I.R.E.) System, which is an IRS system used by financial institutions and other entities including
DHS to file required tax documents to report payments and withholdings.
DHS is also required to share information about to debts with Treasury pursuant to the
Debt Collection Improvement Act of 1996 24. The information shared could relate to all categories
of individuals for whom financial transactions are processed as well as all categories of
information maintained in FFMS. The information shared could or does include name, obligor
name (for immigration bond-related debts), address, TIN (when applicable), SSN (in the case of a
DHS employee), and debt amount (e.g., unpaid amount, overpayment amount). Each DHS FM
System prepares batch data files that are sent electronically to Treasury via an encrypted
transmission to the Treasury Cross-Servicing Program and/or Treasury Offset Program for
appropriate handling/processing including sending out debt collection letters, establishing
repayment agreements, reporting debts to credit bureaus, withholding wages, and other debt
collection activities.
The information that DHS provides to the IRS for interest payments and information
reporting is required under federal income tax laws and regulations. In addition, agencies are
required to share unpaid debt information for collection purposes under several federal laws,
including the Debt Collection Improvement Act of 1996.
Department of Defense
The Coast Guard CAS Suite shares information with the Department of Defense financial
management systems including: Naval and Electronics Supply Support System (NESSS), Defense
Automated Message Exchange System (DAMES), Electronic Transportation Acquisition (ETA),
and the U.S. Air Force Mobility Command.
Department of the Interior
DHS has signed an interagency agreement with the DOI-IBC to be the federal shared
service provider for the replacement CAS Suite for DNDO, TSA, and USCG. The DHS FSM
program team is actively working with DOI-IBC personnel to prepare the FSSP for the migration
of data from the Core Accounting System. Additionally, an Interconnection Security Agreement
has also been signed between DHS and DOI-IBC.
General Services Administration
DHS FM Systems have external connections with various GSA billing and payment
systems to remit payments for telephone, overtime utilities, enhanced custodial services, and
mechanical operations and maintenance services online payments and collections.
24

31 U.S.C. § 3701, and Pub L. 104-134 (Apr. 26,1996).

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External Financial Institutions
DHS FM Systems also share bank account and routing information with external financial
institution “lockboxes” for processing payments and reimbursements. A lockbox is a collection
and processing service provided by a financial agent that accelerates the flow of funds to DHS FM
Systems and processes associated data. This service may include collecting DHS mail from a
specified post office box; opening envelopes, extracting, sorting, and batching the envelope
contents; scanning and capturing required data from payment instruments and remittance
documents; balancing and totaling batches; recording the payments; processing the items; making
the deposit; and transferring the funds. DHS FM Systems receive remittance data either in hard
copy or via electronic format.
Private Collection Agencies (PCA)
DHS may use PCAs to help collect debts owed to the Department. For example, CBP
currently has over three billion dollars outstanding for various reasons, particularly debts owed to
CBP in relation to importing and exporting goods. 25 DHS Components attempt to service the debts
internally prior to referring a debt to a PCA.

6.2

Describe how the external sharing noted in 6.1 is compatible with
the SORN(s) noted in 1.2.

The sharing described above is compatible with the original purpose for which the
information was collected, namely to perform financial management functions in DHS FM
Systems. All external sharing falls within the scope of published routine uses defined in the SORNs
identified in Question 1.2.

6.3

Does the project place limitations on re-dissemination?

There are generally no limitations placed on re-dissemination of this information. Any
further sharing of DHS FM Systems data is permitted as authorized by the recipient agency’s
SORN(s) or information sharing policies.

25

This initiative is driven by intense public interest in the amount of CBP’s growing, uncollected, delinquent debt. A
large majority of the debt (95% or more by dollar value owed) is corporate or commercial debt owed by a business
entity of some sort (e.g., corporation, partnership, LLC), rather than by an individual. CBP provides detailed debtor
information to contracted debt collection services including company name, address, employer identification
number, specific import information related to the debt including amount owed, as well as the names, phone
numbers, and email addresses of individuals employed by or representing the debtor. In rare instances, the debtor
may be an individual (person) using an SSN as his/her importer of record number, home address as business
address, etc.

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6.4

Describe how the project maintains a record of any disclosures
outside of the Department.

DHS uses the payment schedule dates from when batch payment files are transmitted to
Treasury to track disclosures of DHS FM Systems data (including PII) outside of DHS. Upon
successful transmission to Treasury, the same batch data file transmitted to Treasury is also
transmitted to DHS FM Systems in order to record the payments. By recording the payment
schedule date from the batch file, each DHS FM System records the disclosure of the associated
records.

6.5

Privacy Impact Analysis: Related to Information Sharing

Privacy Risk: There is a privacy risk that information from DHS FM Systems may be
improperly disclosed outside of DHS.
Mitigation: These risks are mitigated by the fact that information maintained in DHS FM
Systems is shared in a manner consistent with the routine uses prescribed in the SORNs identified
in Question 1.2 or as required by law.

Section 7.0 Redress
The following questions seek information about processes in place for individuals to seek redress, which may
include access to records about themselves, ensuring the accuracy of the information collected about them, and/or
filing complaints.

7.1

What are the procedures that allow individuals to access their
information?

Individuals may request access to records about them in DHS FM Systems by following
the procedures outlined in the SORNs identified in Question 1.2. All or some of the requested
information may be exempt from access pursuant to the Privacy Act in order to prevent harm to
law enforcement investigations or interest.

7.2

What procedures are in place to allow the subject individual to
correct inaccurate or erroneous information?

If individuals obtain access to the information in DHS FM Systems pursuant to the
procedures outlined in the SORNs identified in Question 1.2, they may seek correction of any
incorrect information in the system by submitting a request to correct the data. The data correction
procedures are also outlined in the SORNs identified in Question 1.2.

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7.3

How does the project notify individuals about the procedures for
correcting their information?

The procedures for submitting a request to correct information are outlined in the SORNs
identified in Question 1.2 and in this PIA in Questions 7.1 and 7.2.

7.4

Privacy Impact Analysis: Related to Redress

Privacy Risk: There is a risk that individuals may not have access to information
maintained about them in DHS FM Systems or be able to correct their information because they
do not know which system maintains information about them.
Mitigation: Individuals can request access to information about them by submitting a
Freedom of Information Act (FOIA) request. They may also request that their information be
corrected once they have reviewed their information and discovered any inaccuracies.
Privacy Risk: There is a risk that because there are so many FM Systems and smaller FM
Systems (see Appendix), an individual may not be able to correct, access, or amend his/her
applicable records in all systems even if he/she files a request via the FOIA process.
Mitigation: DHS believes the PIA will enable individuals to better understand which
systems house their data. As a result, individuals should be able to contact the correct Component
or FOIA office for further assistance. This PIA also serves as a roadmap for FOIA professionals
to locate data pursuant to a request.

Section 8.0 Auditing and Accountability
The following questions are intended to describe technical and policy based safeguards and security
measures.

8.1

How does the project ensure that the information is used in
accordance with stated practices in this PIA?

DHS FM Systems uses database-level auditing to capture information associated with any
viewing, creating, updating, or deleting of records in the dataset and the user that performed the
activity. DHS FM Systems application-specific audit trail provides adequately detailed
information to facilitate reconstruction of events if compromise or malfunction occurs. The audit
trail discloses actions such as unauthorized access, modification, and destruction of data that would
negate its forensic value.
DHS FM Systems information is also safeguarded in accordance with applicable rules and
policies, including all applicable DHS automated systems security and access policies. Strict
controls have been imposed to minimize the risk of compromising the information being stored.
Additionally, information is securely shared via encrypted system connections or encrypted email.

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Additionally, the SSNs maintained in the DHS FM Systems for DHS employees and
contractors/vendors are visible only to those authorized users with a need to know based on their
user access and prescribed official duties (e.g., system administrators).

8.2

Describe what privacy training is provided to users either generally
or specifically relevant to the project.

All DHS personnel and contractors complete annual mandatory privacy and security
training, specifically the Culture of Privacy Awareness and the Information Assurance Awareness
Training.

8.3

What procedures are in place to determine which users may access
the information and how does the project determine who has
access?

Each user account is assigned specific roles with a defined set of privileges to ensure
overall system integrity. The DHS FM Systems system administrators can elect to assign all the
privileges for a given role or can select only certain privileges to assign. Access is limited to DHS
personnel who have a need to access the system based on their roles in support of financial
administration and management operations at DHS. To gain access to a DHS FM System, users
must complete the system-specific user training and submit a request for system access to the
authorized point of contact in their program office. The roles and privileges assigned to a particular
user are predetermined depending on the user’s function. The user roles defined below are similar
across all DHS FM Systems instances, including:
•

Originator – Create and process commitments and obligations in the DHS FM Systems
Desktop Screens.

•

Funding Certifier – Review, edit, and certify commitments and obligations and check
funding availability in the DHS FM Systems Desktop Screens.

•

Approving Official – Review and approve or deny commitments and obligations in the
DHS FM Systems Desktop Screens; cannot edit.

•

Payment Technician – Create and process bills/invoices; create new vendor entries in the
DHS FM Systems vendor table; and create and process reimbursable agreements.

•

Payment Certifier – Review and approve or deny bills/invoices for payment certification.

•

System Administrator – Setup, manage, review, edit, and delete user profiles/accounts in
the Database Administrator Management Screens and other maintenance screens.

•

HelpDesk User (i.e., Database Administrator) – Create user accounts, reset passwords, and
perform system troubleshooting (i.e., technical and maintenance modifications) in the
various DHS FM Systems instances, as necessary.

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8.4

How does the project review and approve information sharing
agreements, MOUs, new uses of the information, new access to the
system by organizations within DHS and outside?

Component financial program managers coordinate with Component Privacy Officers to
review and assess new uses of information consistent with DHS established procedures (i.e., using
Privacy Threshold Analyses). When necessary, Component Privacy Officers will work with
Component financial program managers, counsel, and the DHS Privacy Office to publish
amendments to the SORNs identified in Question 1.2.
Additionally, Component financial program managers, Component Privacy Officers, and
counsel review interconnection service agreement (ISA) for internal and external systems that
interface with DHS FM Systems to ensure adequate protections are in place to safeguard
information transmitted between systems.

Responsible Officials
Chip Fulghum
Chief Financial Officer
Department of Homeland Security

Approval Signature
Original signed copy on file with DHS Privacy Office.
__________________________________________
Karen L. Neuman
Chief Privacy Officer
Department of Homeland Security

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APPENDIX A
In addition to the six Core Financial Management Systems described in the body of this
PIA, the following IT systems are also used by DHS for the collection, use, dissemination, and
maintenance of financial information from DHS employees, contractors, vendors, grantees, and
members of the public.
DHS-wide:
DHS Treasury Information Executive Repository (DHSTIER) (July 23, 2015): The
Department of Homeland Security Treasury Information Executive Repository (DHSTIER)
application collects financial data from the Components for the Office of the Chief Financial
Officer (OCFO). DHSTIER receives monthly uploads of financial accounting and budgetary data
from each Component’s financial system and produces the Department’s monthly, quarterly, and
yearly reports for the Consolidated Financial Statement Audit. DHSTIER generates the Financial
Statements and related Footnotes required for producing the Annual Financial Report (AFR).
DHSTIER is an agency data archive that captures, validates, and maintains this data for reporting
use. Editing functionality of submitted data is not permitted and it is audited annually. Each
Component may only see its own data.
Sunflower Asset Management (SAM) (July 23, 2015): As noted above, SAM is a
property management system providing primary business functions such as acquisitions, transfers,
retirements, modifications, and asset tracking. SAM is integrated with Oracle Financials Fixed
Assets (FA) for capitalized asset transactions.
The USCG CAS Suite relies on its own instance of SAM, but several other DHS
Components use an enterprise-wide instance of SAM, owned and operated by the DHS Chief
Readiness Officer (CRSO) and available to DHS Components. Sunflower is fully integrated with
the Oracle Financials FA module for capitalized asset transactions; however, it is not considered
to be a module of Oracle Financials because it was developed by a third party. SAM functions
include:
•

Property management system, which provides the primary business functions like
Acquisitions, Transfers, Retirements, Modifications, and Asset tracking;

•

Integrated with Oracle Financials Fixed Assets for capitalized asset transactions;

•

FPD is integrated with Sunflower by providing the purchase order and/or receipts to create
assets;

•

PPC Checkfree Subsystem; and

•

Supports the reconciliation of military payroll with four reconciliation sets and a single
general ledger.

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U.S. Customs and Border Protection (CBP)
National Data Center (NDC) Administrative Applications (July 23, 2015): The NDC
Administrative Applications (NDC Admin Apps) are a collection of administrative applications
that operate under the umbrella of the CBP Mainframe architecture in order to perform their
mission-specific functions. They carry out an array of administrative functions related to system
security, as well as providing specific support to personnel processes. The Personnel Action
Request Tracking System (PARTS) Human Resources Management (HRM) personnel system
enables Human Resources (HR) staff and field users to initiate, electronically transmit, track, and
monitor CBP personnel actions to completion.
The NDC Admin Apps collect the following PII about CBP employees: SSN; Name;
Employee’s Birthdate; Employment Status; Military Information; Current Address; Salary
Information; and Bank Account number.
National Finance Center (NFC) System (NFC-LAN) (July 23, 2015): The CBP National
Finance Center (NFC) LAN system is a general support system consisting of desktop computers,
laptop computers, printers, multi-function devices (copy/print/scan/fax), portable media (CDs,
DVDs, flash drives, external hard drives), and peripheral devices (scanners, digital cameras,
webcams, etc.) all connected to the CBP local area networks deployed throughout the NFC
campus. The NFC campus serves over 700 personnel at the Financial Management Services Center
located in Indianapolis, Indiana. The NFC LAN System provides basic platform access to all the
CBP and DHS information systems and major applications, while simultaneously enabling ad-hoc
applications and usage scenarios that support the mission requirements.
CBP employees and contractors use the NFC LAN System to access file storage via
Windows File and Print (WFP System), the email system via Email as a Service (EaaS), and
perform financial resources management via applications such as the Automated Commercial
Environment (ACE), Systems, Applications, and Products in Data Processing (SAP), and the
Automated Commercial System (ACS). These applications are not included in the NFC IT
boundary, and each application is responsible for its own compliance documentation.
The NFC requires employees and contractors to collect, process, transmit, and store
structured and unstructured ad-hoc information such as reports, lists, presentations, and memos
that cannot be categorized or assigned to any other defined program. Every office and every role
of the NFC may be required to execute tasks and functions that require the production and
processing of this type of data. Although PII may be stored on this hardware, such as local hard
drives and portable media, the PII is almost exclusively personal records or case notes, rather than
records in a system of records.
The NFC LAN does not directly collect or store any personally identifiable information.
The system does contain sensitive financial information.

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NDC Financial Applications (NDC Financial Apps) (July 23, 2015): The NDC Financial
Applications are a collection of three (3) administrative CFO‐designated financial applications.
These applications operate under the umbrella of the CBP Mainframe environment in order to
perform their mission‐specific functions. The individual system descriptions are as follows:
1. COSS: The CBP Overtime Scheduling System (COSS) is the official Time and Attendance
system used by CBP for Payroll. This legacy application is a key component required to
effectively manage workforcesʹ schedule and overtime workload. COSS is part of a
collection of administrative applications that execute on the CBP Mainframe architecture
to perform mission functions.
2. TAMS: The Time and Attendance Management System (TAMS) is the timecard system
that was the predecessor to COSS and supports COSS for payroll processing. TAMS is
used to interface with USDA for schedule transmissions. It is no longer used for timecard
entry.
3. Telestaff: Telestaff, formerly known as the Automated Scheduling Tool (AST)
Experiment, is a web-based scheduling tool used to manage the work and overtime
schedules of CBP law enforcement officers in the Office of Field Operations (OFO) in
concert with staffing needs and union bargaining rules. The capability provides built-in
alerts and enhanced transparency to aid in compliance with CBP union bargaining rules, as
well as auditing capabilities to track schedules and overtime.
In total, COSS, TAMS, and Telestaff provide the following functions: a payroll interface, time and
attendance, work tickets, and scheduling capability. COSS currently interfaces with TAMS in
order to transmit the time and attendance data to USDA for payment. SSNs are used as the unique
personal identifier for employees in COSS and TAMS because USDA still requires SSNs to
capture and identify payroll and earnings data for a given employee. The PII received from the
USDA Bi-Weekly download file includes the following employment information about CBP
employees: SSN; first and last name; agency; organization code; duty; city; job series; cost center;
hire date; supervisor code; date of birth; grade; step; and salary. COSS and TAMS also retrieve
information using the following personal identifiers for CBP employees: birthdate; employment
status; full name; military information; current address; salary information; SSN; and hash IDs.
Because Telestaff is used to manage work and overtime schedules, and not for payroll purposes,
it does not collect SSNs.
Federal Emergency Management Agency (FEMA)
Automated Acquisition Management System (AAMS) (July 23, 2015): The Automated
Acquisition Management System (AAMS) is a COTS product used by personnel in FEMA’s
Office of the Chief Procurement Office as the agency’s contract management system.

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AAMS is a web-based application that manages and stores acquisition data and captures
acquisition information including notes, data, attachments, commitment documents, and
milestones. The information is then organized into tabs for storage and reference. AAMS also
formats data and creates acquisitions related documents. AAMS receives commitment documents
from FEMA Program Office users via the Integrated Financial Management Information System
(IFMIS) in the form of purchase requests, which are used to generate award documents that are
then passed back to IFMIS as obligations. These award documents are federal contracts issued
between FEMA and vendors or other agencies in accordance with the Federal Acquisition
Regulation (FAR).
Payment and Reporting System for Grantees (PARS) (July 23, 2015): The Payment and
Reporting System (PARS) is comprised of two PARS application servers and the three PARS web
servers. PARS resides within the IFMIS accreditation boundary as the web-based “front end” to
the IFMIS database. As part of the front end functionality, PARS collects PII and pushes it through
to the Web-IFMIS database where information is maintained. PARS enables grant recipients to
submit requests for grant payments as well as submit financial status reports using an online
representation of OMB Standard Form 425.
Federal Law Enforcement Training Center (FLETC)
Infrastructure and Enterprise Management Tools (IEMT) (July 23, 2015): The
Infrastructure and Enterprise Management Tools System (IEMT) provides infrastructure and
management to Information Technology (IT) network applications and services. This includes the
Administrative, Wireless, Telecommunications, and DMZ networks used by authorized FLETC
personnel, contractors, and partner organizations at the following FLETC facilities: Glynco, GA;
Artesia, NM; Charleston, SC; Cheltenham, MD; Manhattan, KS; and Washington, D.C. The
Administrative LANs at each site are connected via the DHS OneNet WAN to provide customers
with an enterprise platform to receive IT services. The wireless LANs provide customers with IT
capabilities. The Telecommunications LAN provides customers with phone, fax, and voicemail
services. The voice network traverses a private Avaya managed network as well as a logically
separated portion of the FLETC infrastructure to provide IP-based communications. The DMZ
offers capabilities to all FLETC sites to share enterprise management services, training
capabilities, and application services.
The management tools collect logging information for all devices. These logs include
usernames and passwords. Several IEMT subsystems collect the following employee PII during
the normal course of operations:
•

Active Directory collects name, title, address, phone number, Component, email address,
username and password, account profile, permissions, and user groups.

•

The modular messaging system collects phone messages.

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•

The management tools collect logs for all devices. These logs include usernames and
passwords.

•

Exchange collects emails for all account holders.

Immigration and Customs Enforcement (ICE):
Electronic System for Personnel (ESP) (July 23, 2015): ESP is a web-based system
installed on a centralized application web server. ESP automates the processes involved in
managing ICE personnel actions (Using Standard Form SF-52). SF-52s are used to establish and
maintain data pertaining to employment and payroll administrative functions. The system provides
the capability for the ICE Human Capital Office (OHC) to electronically create, edit, submit, copy,
delete, and maintain a history of personnel actions; establish workflow of personnel actions
depending on type and originating office within ICE; create an electronic routing sheet; return
personnel actions to the originator; and make comments concerning personnel actions. ESP also
tracks the status of personnel actions. Personnel action data are supplemented by OHC with
position classification information data. Once the SF-52 is finalized within ICE, the data is
submitted to the USDA NFC for processing to effectuate changes to the personnel and payroll data
for the ICE employee for whom the SF-52 was issued. When finalized, an electronic SF-52 mirrors
the Notice for Personnel Action (SF-50).
FileOnQ (July 23, 2015): FileOnQ provides a database and repository for invoices, bonds,
reimbursable agreements, obligations, field deposits, and related documents. Using FileOnQ, data
can be queried and tracked via invoice number or vendor ID, reports can be generated by support
personnel, and financial actions can be executed by users. FileOnQ obtains information through
three different types of manual uploads:
1. The ICE eBONDS system provides surety bond information. The bond information is
downloaded to a shared drive and then uploaded into FileOnQ via a manually initiated
import utility.
2. Payments and invoices from other federal agencies such as the Treasury are sent to the
Burlington Finance Center via the standard Intra-government Payment and Collection
(IPACS) import utility or electronic transfer. Then, the information is entered into a
spreadsheet by the accounting technician on a daily basis and uploaded into FileOnQ.
3. For invoices and documents sent via email, mail, or FAX, the accounting technician creates
a file in FileOnQ, scans the documents (if not already a PDF file), and uploads the
document into the created file.
Approximately, ninety-five percent (95%) of the data entered into FileOnQ is obtained through
this last method, e.g., cash bonds, invoices, agreements, obligations, field deposits.

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Once the invoice is ready for submission for payment, the invoice number is copied from
FileOnQ and pasted into the ICE Federal Financial Management System (FFMS). The accounting
technician then manually enters the remaining information into FFMS for processing.
FileOnQ collects general contact information such as addresses and telephone numbers
from businesses. Occasionally, personal information is submitted on invoices in lieu of business
information. The system may also contain SSNs when included on submitted invoices. For bonds,
the documents can also include personal addresses and telephone numbers along with alien
numbers.
OFM Online (September 21, 2016): OFM Online is an internal SharePoint site used by
U.S. Immigration and Customs Enforcement (ICE) Office of Financial Management (OFM).
The site provides financial policy and related information to the financial community within ICE
and other DHS components for which ICE provides financial services. Individuals use OFM
Online to research financial policy, process, and procedural information, access links to other
applications and sites, download forms to submit via fax or email, and complete and submit
certain web forms via OFM Online to the ICE Dallas Finance Center.
The following four forms that users submit to the ICE Dallas Finance Center via OFM
Online contain PII, as specified below:
•

Employee Payment Information Form: DHS Point of Contact information (name, email
address, phone number); employee name, TIN/SSN; employee phone number, employee
job title; employee mailing address; bank account number; bank routing number.

•

Vendor Payment Information Form: DHS Point of Contact information (name, email
address, phone number); Dun and Bradstreet Universal Numbering System (DUNS)
number; TIN/SSN; vendor number; bank account number; bank routing number.

•

Extension of Time to Sell/Purchase Real Estate Form: Employee name; duty station
location; mailing address; telephone number; email address.

•

Temporary Quarters Subsistence Expense (TQSE) Actual Expense Worksheet: Employee
name; spouse name; names and ages of dependents.

These forms are only available on the ICE intranet, and can only be completed by ICE employees
and contractors who have access to the site.
Real Property Management System (RPMS) (July 23, 2015): The Real Property
Management System (RPMS) replaced a disorganized set of ad hoc tools used by ICE Office of
Asset Management (OAM) and Office of Co-Location (OCL) to coordinate the acquisition,
management, disposition, and accounting of ICE real property assets. RPMS provides enhanced
project management and tracking tools to the ICE office responsible for managing ICE leased and
owned properties, overseeing active projects including new space requests, construction, build-to-

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suit projects, leases, various infrastructure space actions, and executing ICE repair and alteration
projects.
RPMS collects and maintains limited ICE employee, contractor, and public data for
planning and tracking purposes, such as: name, job title, grade, program office/department,
organization/company, email address, office phone number, employment type, and IRMNet
UserID (if applicable). RPMS generates reports from this data for statistical purposes to support
facilities and asset management functions.
I-901 Fee Collection Services System (June 30, 2017): The web-based I-901 Fee
Collection Services System (I-901 System), as of September 2012, is managed by the U.S.
Immigration and Customs Enforcement (ICE), Student and Exchange Visitor Program (SEVP).
Previously, the U.S. Department of the Treasury, Financial Management Service (FMS) managed
the I-901 System. FMS is still responsible for collecting the fees and for their proper disposition.
The I-901 Fee was established by Congress, which mandated the implementation of a fee to be
paid by prospective nonimmigrant students and exchange visitors and their dependents seeking F,
M or J status (I-901 Fee), to defray the operation and maintenance costs incurred by SEVP. The I901 System is covered by the DHS/ICE-001, Student and Exchange Visitor Information System
(SEVIS) System of Records Notice. 26
The I-901 System serves four purposes: (1) allows applicants to pay the required I-901 Fee;
(2) allows applicants to check the status of a previously submitted I-901 payment; (3) allows
applicants to print proof of payment (I-901 Payment Confirmation) to present at a visa
appointment; and, (4) is a source for detailed information/instructions regarding the I-901 Fee.
The I-901 System is comprised of the following components to support payment of the I901 Fee:
1. A web-based payment system whereby a contracted financial institution hosts an Internetbased electronic version of the I-901 Fee Transmittal Form that allows an individual to file
the Form I-901 and pay the I-901 Fee through a credit card interface to FMS’s Pay.Gov
credit card portal.
2. A lockbox payment mechanism whereby a person can mail a completed Form I-901 and
associated payment to a lock box hosted by the contracted financial institution.
3. A bulk filing capability whereby authorized Exchange Visitor Programs can upload a file
of exchange visitor data and charge the payment via Automated Clearing House (ACH)
debit to a predetermined sponsor bank account.
4. A Western Union payment mechanism whereby a person can remit the I-901 data and
associated payments at a local Western Union office.

26

DHS/ICE 001 Student and Exchange Visitor Information System 75 FR 412 (Jan. 5, 2010).

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The I-901 System involves interactions between DHS ICE SEVP, FMS, and the contracted
financial institution in order to complete I-901 Fee transactions.
In addition to administering the I-901 System, SEVP is also the owner of Student and
Exchange Visitor Information System (SEVIS), an Internet-based system that maintains real-time
information on nonimmigrant students and exchange visitors, their dependents, and schools and
sponsors that host these nonimmigrants. Payments received from F, M and J nonimmigrant
applicants are validated against SEVIS records to ensure that the payment is posted to the
appropriate SEVIS record, and that the applicant is given proper credit for having paid the required
I-901 Fee. Additionally, the validation with SEVIS is used to accurately identify individuals for
visa issuance and entry into the United States. FMS is responsible for the collection of I-901 Fees
and their proper disposition.
The contracted financial institution, an SEVP contractor, serves as an agent for the
government to administer, host, manage, and operate the I-901 Fee site. The contracted financial
institution also provides support services to the I-901 System by processing Form I-901
applications and I-901 Fee payment transactions; supports reporting capabilities, applicant inquiry
and status information, applicant information updates and financial reconciliation.
Transportation Security Administration (TSA)
Electronic Time and Attendance KRONOS (ETA KRONOS) (July 23, 2015): ETA
Kronos is an automated and standardized labor management solution that operates within the TSA
Operating Platform (TOP) environment. The system is deployed at all airports for purposes of
recording employee clock in/out times and transferring that information to appropriate payroll and
human resource systems. Individuals access the system by swiping a TSA issued KRONOS ID
card. The system also requires the user register his or her physical presence by placing a finger on
a scanner tab that converts the individual’s fingerprint to a fingerprint template that is not logged
or stored in the system. The template measures fingerprint minutia/data points and converts the
information using a mathematical representation that provides a one-to-one match to the employee.
The technology prevents the recreation of a full fingerprint from the template.
In order to provide anti-spoofing measures, the system also records several electronic
inputs from the user’s skin to obtain for example: temperature, humidity, impedance, and other
bio-measurements. The technology immediately rejects fake fingers. The Kronos 4500 Touch ID
terminal uses a sub-surface technology that images below the surface layer of the skin.
The system collects the following PII from TSA employees: name, date of birth, fingerprint
template and non-PII anti-spoofing data points, user ID, and location and clock-in/out times for
purposes of recording hours worked. The system contains encrypted SSNs for the purpose of
interoperating with other payroll systems that require this information. The system also contains
non-sensitive PII data such as shift supervisors and general scheduling information.

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U.S. Coast Guard (USCG)
Asset Logistics Management Information System (ALMIS) (July 23, 2015): The Asset
Logistic Management Information System (ALMIS) enables efficient, flexible, and cost-effective
aircraft and surface force operations, logistics, and maintenance support. ALMIS supports data
entry from the start of a mission, recording the mission execution, tracking crew events, asset
aging, asset configuration, asset maintenance requirements, asset part replacements, warehouse
activities, and procurement actions.
ALMIS supports the comprehensive maintenance, operations, and logistical support of
Coast Guard aircraft at 28 Coast Guard air stations, and the Aviation Logistic Center (ALC). In
addition to Coast Guard aviation, ALMIS is currently supporting small boat forces and patrol boat
forces with anticipation of cutter fleet, electronics, and shore assets over the next several years.
ALMIS has over 19,000 registered users that include air crews, surface force crews, maintainers,
contractors, and senior decision makers at Coast Guard Headquarters.
Fleet Logistics System (FLS) (July 23, 2015): The Fleet Logistics System (FLS) is
designed to automate the management of USCG cutter and small boat logistics, which includes
Configuration Management (CM) maintenance actions, procurement and supply activities,
automated Requisition Management (RM), Coast Guard Parts Availability Research Tool (CGPART), and associated financial transactions. CG-PART is a web based inventory locator tool that
allows individuals to search by National Item Identification Number (NIIN), Federal Supply Code
(FSC), Commercial And Government Entity (CAGE) code, part number, or Cognizance Code
(COG). Search results provide the location and quantity of the item. FLS is also integrated with
other enterprise systems, to include the Naval and Electronic Supply Support System (NESSS),
the Naval Engineering Technical Information Management System (NE-TIMS), the FLS Mobile
Asset Manager (MAM) application, and Financial and Procurement Desktop (FPD).
FLS collects name, rank, employee ID, phone numbers, email addresses, and work
addresses from USCG employees and contractors.
Integrated Aids To Navigation Information System (IATONIS) (July 23, 2015):
Integrated Aids to Navigation Information System (IATONIS) is the USCG system used to store
pertinent information relating to short range aids to navigation. There are five components of
IATONIS used to collect personal information: Private Aid to Navigation Owner Contact
Information, Wreck Owner Contact Information, Oil Rig Owner Contact Information, Private
Property Owner Contact Information, and USCG Auxiliary Member Contact Information. This
information allows the Coast Guard to contact owners of wrecks, oil rigs, private aids to
navigation, private property owners on which an aid to navigation is located, and operators of oil
rigs. If the owner designates another individual as the point of contact for the Coast Guard, the
point of contact information is retained as well.

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IATONIS is a privacy sensitive system which collects limited contact information from
members of the public in order to distribute information and perform various other administrative
tasks. Information collected may include name, office address, office email, and office phone for
persons or organizations that can be contacted for information related to private wrecks, oil wells,
private aids, and leased private land.
Joint Uniform Military Pay System (JUMPS) (July 23, 2015): The Joint Uniform
Military Pay System (JUMPS) is a custom designed military payroll system used for computations
of all necessary information used to pay active duty, reservists, and retired military members. This
is an IBM Z/OS Mainframe based system, with encrypted terminal connections for the clients.
JUMPS collects PII from USCG employees and contractors only, including SSN.
Naval and Electronics Supply Support System (NESSS) (July 23, 2015): The Naval and
Electronics Supply Support System (NESSS) automates the maintenance and logistics
management of USCG assets including cutters, small boats, and shore based facilities. NESSS is
described as an Information Resource Management (IRM) system. NESSS is an Oracle-based
database system used primarily by the USCG Yard and the Surface Forces Logistics Center.
NESSS is an integral part of the Vessel Logistics Systems (VLS), which include the Automated
Requisition Management System (ARMS), Coast Guard Parts Availability Research Tool (CGPART), Configuration Management plus (CMplus), and the Fleet Logistics System (FLS). NESSS
incorporates approximately 12 external interfaces with USCG and United States Navy (USN)
systems and over 1,000 application modules. NESSS was originally designed to move a myriad of
legacy applications off aging hardware and has now evolved into a fully integrated system linking
the functions of provisioning and cataloging, unit configuration, supply and inventory control,
procurement, depot-level maintenance and property accountability, and a full financial ledger. The
system is completely matrix driven, allowing maximum user configuration and adaptation. The
system contains the following modules for use by its end users: Supply, Finance, Procurement,
Depot, and Provisioning/Unit Configuration. The various NESSS accounts provide its approved
end users with the capability of inserting, deleting, editing, or viewing any relevant data concerning
USCG Supplies.
NESSS collects the following personal information from USCG employees: names,
business addresses, business phone numbers, business email addresses, and employee pay rates.
Shore Asset Management (SAM) (July 23, 2015): The Shore Asset Management System
(SAM) utilizes a suite of COTS Enterprise Asset Management (EAM) software products
comprised of IBM MAXIMO and TRIRIGA to provide maintenance, project, and inventory
functionality to USCG Civil Engineering (CE), Facilities Engineering (FE), and Real Property
(RP) communities. SAM is available to shore-based USCG units and provides detailed planning
information such as work plans, schedules, costs, labor, materials, equipment, failure analysis, and
related documents by utilizing a work order tracking component. The software allows the
scheduling of work orders based on real-time updates of criticality.

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SAM provides real-time display of work orders and individual assignments using a work
manager dispatch component. This allows supervisors and planners to interactively manage
upcoming work by taking into account factors such as job priority and workforce availability.
SAM tracks equipment, associated costs, histories, and failures of any serialized piece of
equipment as it moves through a facility. A Preventive Maintenance (PM) component generates
work orders individually, in batch, or automatically.
SAM provides core information about USCG shore facility assets. It tracks activities and
assists in management of the CE Program. The information helps the CE Program manage the full
life-cycle of the shore facility assets and adjust to CG mission needs. The following employee data
may be collected
in SAM: name, work address/telephone/email, position
title/department/supervisor, date of birth, hire date, termination date, next/last evaluation dates,
and pay rate.
Windows Integrated Automated Travel System/Travel Preparation and Examination
(WINIATS/T-PAX) (July 23, 2015): The Windows Integrated Automated Travel System/Travel
Preparation and Examination (WINIATS/WEBTPAX) is a USCG-configured COTS application.
The users in the field have the ability to access WEBTPAX via the USCG intranet (via a web
browser) for creating orders and submitting their travel claims for Temporary Duty Travel. Users
must have an Authorizing Official review and approve their claim in WEBTPAX before it can be
released. When the claim is approved, it along with any associated data is moved to WINIATS for
calculation and payment. WINIATS ensures that payment data is correct and determines the
amount the traveler is due to be paid. When this calculation is complete the payment amount is
transmitted to the Finance Center in Chesapeake Virginia for payment to the member via EFT.
The Pay and Personnel Center also receives Temporary Duty travel and Permanent Change of
Station travel claims via hardcopy. These claims are entered into WINIATS for calculation and
payment. The payment is transmitted in the same manner as the claims described above. The
WINIATS/WEBTPAX user base is all active duty, reserve, and civilian employees of the Coast
Guard (approximately 37,000 active duty, 8,000 reserve, and all civilians).
United States Citizenship and Immigration Services (USCIS)
E-Filing (Electronic Filing System) (July 23, 2015): E-Filing is a web-based tool that
supports USCIS mission efficacy and efforts towards greater public transparency by providing a
mechanism for individuals or authorized parties acting on behalf of individuals (referred to herein
collectively as “applicants”) to submit applications and petitions (referred to herein collectively as
“applications”) for certain immigration benefits and services directly to USCIS. E-Filing
eliminates the need for some applications to be submitted to USCIS in hard-copy and then
manually input by USCIS staff into the CLAIMS system. Data submitted to USCIS through eFiling is used to assist USCIS examiners in corroborating information provided by applicants,
thereby ensuring that the process is consistent with all applicable laws and regulations. This data
is used to perform background checks, examinations (review of the information that is being

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provided by applicants), and adjudications (process by which decisions are made to grant or deny
an application).
The e-Filing System collects the following personally identifiable information from
applicants: name, country of citizenship, date of birth, present address, receipt number, SSN, ANumbers, country and place of birth, work authorization information, credit card name and
expiration dates, port of entry, form type for benefit applied for, sex, phone number, family
members, photo, signature, passport information, interview codes, and history codes.