1625-0032 Privacy Threshold Analysis (PTA)

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

PRIVACY THRESHOLD ANALYSIS (PTA)
This form serves as the official determination by the DHS Privacy Office to
identify the privacy compliance requirements for all Departmental uses of
personally identifiable information (PII).
A Privacy Threshold Analysis (PTA) serves as the document used to identify
information technology (IT) systems, information collections/forms, technologies,
rulemakings, programs, information sharing arrangements, or pilot projects that involve
PII and other activities that otherwise impact the privacy of individuals as determined by
the Chief Privacy Officer, pursuant to Section 222 of the Homeland Security Act, and to
assess whether there is a need for additional Privacy Compliance Documentation. A PTA
includes a general description of the IT system, information collection, form, technology,
rulemaking, program, pilot project, information sharing arrangement, or other Department
activity and describes what PII is collected (and from whom) and how that information is
used and managed.
Please complete the attached Privacy Threshold Analysis and submit it to your
component Privacy Office. After review by your component Privacy Officer the PTA is sent
to the Department’s Senior Director for Privacy Compliance for action. If you do not have a
component Privacy Office, please send the PTA to the DHS Privacy Office:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
[email protected]
Upon receipt from your component Privacy Office, the DHS Privacy Office will review this
form and assess whether any privacy compliance documentation is required. If compliance
documentation is required – such as Privacy Impact Assessment (PIA), System of Records
Notice (SORN), Privacy Act Statement, or Computer Matching Agreement (CMA) – the DHS
Privacy Office or component Privacy Office will send you a copy of the relevant compliance
template to complete and return.

Privacy Threshold Analysis – IC/Form

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Version number: 04-2016

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

Privacy Threshold Analysis (PTA)

Specialized Template for
Information Collections (IC) and Forms
The Forms-PTA is a specialized template for Information Collections and Forms. This
specialized PTA must accompany all Information Collections submitted as part of the
Paperwork Reduction Act process (any instrument for collection (form, survey,
questionnaire, etc.) from ten or more members of the public). Components may use this PTA
to assess internal, component-specific forms as well.
Form Number:

CG-950A

Form Title:

Application for Special Permit

Component:

U.S. Coast Guard (USCG)

Office:

CG-REG

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Vessel Inspection Related Forms and Reporting Requirements Under
Title 46 U.S. Code
OMB Control
1625-0032
OMB Expiration
April 30, 2022
Number:
Date:
Collection status:
Extension
Date of last PTA (if
April 5, 2018
applicable):

Name:
Office:
Phone:

Name:
Office:
Phone:

PROJECT OR PROGRAM MANAGER
Mr. David Du Pont
CG-REG
Title:
Reg Dev Mgr
202-372-1497
Email:
[email protected]
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
A.L. Craig
CG-6P
Title:
PRA Coordinator
202-475-3528
Email:
[email protected]

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

SPECIFIC IC/Forms PTA QUESTIONS
1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form.
The U.S. Coast Guard (USCG) is renewing the PTA for form CG-950A, titled “Application
for Special Permit.”
The purpose of the form (CG-950A) is to document an application for permit to carry an
excursion party during a Marine Event of National Significance.
The Coast Guard prescribed excursion and special permit regulations in 46 CFR 2.01-45,
26.03-6 and 26.03-8.
The form is used by the Coast Guard to determine if the excursion or deviation from a
vessel’s current operating profile can be done safely. If the Coast Guard determines that
the excursion can be done safely, the Coast Guard issues a Permit to Carry Excursion
Party.
The form contains vessel specific information and basic business contact information
which may include the name and address of the vessel owner/operator, if
owned/operated by an individual.
b. List the DHS (or Component) authorities to collect, store, and use this
information.
The authority for this collection is 46 U.S. Code 2113, Chapter 33 and 3714.

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII1)?
b. From which type(s) of
individuals does this form

☒ Yes
☐ No
☒ Members of the public

1

Personally identifiable information means any information that permits the identity of an individual to be directly or indirectly inferred, including
any other information which is linked or linkable to that individual regardless of whether the individual is a U.S. citizen, lawful permanent resident,
visitor to the U.S., or employee or contractor to the Department.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

collect information?
(Check all that apply.)

☒ U.S. citizens or lawful permanent
residents
☒ Non-U.S. Persons
☐ DHS Employees/Contractors (list
Components)
☐ Other federal employees or contractors

c. Who will complete and
submit this form? (Check
all that apply.)

☒ The record subject of the form (e.g., the
individual applicant).
☐ Legal Representative (preparer, attorney,
etc.).
☒ Business entity.
If a business entity, is the only
information collected business contact
information?
☒ Yes
☐ No
☐ Law enforcement.
☐ DHS employee/contractor.
☐ Other individual/entity/organization that is
NOT the record subject. Please describe.
Click here to enter text.

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

☒ Paper.
☒ Electronic. (ex: fillable PDF)
☐ Online web form. (available and submitted via
the internet)
Provide link:

e. What information will DHS collect on the form?
The form contains vessel specific information and basic business contact information
which may include the name and address of the vessel owner/operator, if
owned/operated by an individual.
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? No.
Privacy Threshold Analysis – IC/Form

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

☐ Social Security number
☐ Alien Number (A-Number)
☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Social Media Handle/ID
☐ Known Traveler Number
☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
N/A
h. Is SSN necessary to carry out the functions of this form and/or fulfill
requirements of the information collection? Note: even if you are properly
authorized to collect SSNs, you are required to use an alternative identifier. If
there are technological, legal, or regulatory limitations to eliminating the SSN,
privacy-enhancing alternatives should be taken, such as truncating the SSN.
N/A
i. How will this information be used? What is the purpose of the collection?
The purpose of the form (CG-950A) is to document an application for permit to carry an
excursion party during a Marine Event of National Significance.
The form is used by the Coast Guard to determine if the excursion or deviation from a
vessel’s current operating profile can be done safely. If the Coast Guard determines that
the excursion can be done safely, the Coast Guard issues a Permit to Carry Excursion
Party (form CG-949).
j.

Are individuals
provided notice at the
time of collection by
DHS (Does the records
subject have notice of
the collection or is
form filled out by
third party)?

Privacy Threshold Analysis – IC/Form

☐ Yes. Please describe how notice is provided.
☒ No. Information is not retrieved by personal
identifier.

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

3. How will DHS store the IC/form responses?
a. How will DHS store
☐ Paper. Please describe.
the original,
Click here to enter text.
completed IC/forms?
☐ Electronic. Please describe the IT system that will
store the data from the form.
Click here to enter text.
☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Forms that the Coast Guard receives are
maintained in Marine Information for Safety and Law
Enforcement (MISLE) database.
b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
A scanned form is uploaded to the vessel-specific
file in MISLE.
☐ Automatically. Please describe.
Click here to enter text.

c. How would a user
search the
information
submitted on the
forms, i.e., how is the
information
retrieved?

☐ By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
Click here to enter text.
☒ By a non-personal identifier. Please describe.
A search is conducted using vessel-specific
information.
A record is retained for the life of the vessel; NARA
retention schedule number N1-026-05-015.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
2

Generally, a unique identifier is considered any type of “personally identifiable information,” meaning any information that permits the identity
of an individual to be directly or indirectly inferred, including any other information which is linked or linkable to that individual regardless of
whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to the Department.
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

e. How do you ensure
As records are maintained in the MISLE database,
that records are
disposal/deletion is in accordance with the business
disposed of or deleted
rules for the database.
in accordance with
the retention
schedule?
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☐ Yes, information is shared with other DHS components or offices. Please describe.
Click here to enter text.
☐ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
Click here to enter text.
☒ No. Information on this form is not shared outside of the collecting office.

Please include a copy of the referenced form and Privacy Act Statement (if
applicable) with this PTA upon submission.

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Version number: 04-2016

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

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

A.L. Craig

Date submitted to Component Privacy
Office:
Concurrence from other Components
involved (if applicable):
Date submitted to DHS Privacy Office:

September 30, 2021

Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component Privacy
Act Statements.)

N/A
October 7, 2021
☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
Information is not retrieved by a personal
identifier.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
The U.S. Coast Guard (USCG) is renewing the PTA for form CG-950A, titled “Application for
Special Permit.”
The purpose of the form (CG-950A) is to document an application for permit to carry an
excursion party during a Marine Event of National Significance.
The Coast Guard prescribed excursion and special permit regulations are located in 46 CFR
2.01-45, 26.03-6 and 26.03-8.
The form is used by the Coast Guard to determine if the excursion or deviation from a
vessel’s current operating profile can be done safely. If the Coast Guard determines that
the excursion can be done safely, the Coast Guard issues a Permit to Carry Excursion Party
(form CG-949).

Privacy Threshold Analysis – IC/Form

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Version number: 04-2016

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

The form contains vessel specific information and basic business contact information
which may include the name and address of the vessel owner/operator, if owned/operated
by an individual.
46 U.S. Code 2113, Chapter 33 and 3714 are the authorities for this collection. Records are
maintained per NARA retention schedule number: N1-026-05-015. The Form (CG-950A)
USCG receives are scanned/uploaded into the vessel specific file and maintained in Marine
Information for Safety and Law Enforcement (MISLE) database.
The Application for Special Permit (CG-950A) is privacy sensitive with coverage provided
by DHS/USCG/PIA-008 Marine Information for Safety and Law Enforcement (MISLE).

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

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

Kattina Do

DHS Privacy Office Approver (if applicable):
PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

Riley Dean
0020852
October 7, 2021
October 7, 2024

DESIGNATION
Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

Determination:

☐ PTA sufficient at this time.
☐ Privacy compliance documentation determination in
progress.
☐ New information sharing arrangement is required.
☐ DHS Policy for Computer-Readable Extracts Containing SPII
applies.
☐ Privacy Act Statement required.
☒ Privacy Impact Assessment (PIA) required.
☐ System of Records Notice (SORN) required.
☐ Specialized training required.
☒ Other. Privacy Notice

Privacy Act
Statement:
System PTA:
PIA:

SORN:

Choose an item.
Click here to enter text.
Choose an item.
Click here to enter text.
System covered by existing PIA
If covered by existing PIA, please list:
• DHS/USCG/PIA-008 Marine Information for Safety and Law
Enforcement (MISLE)
If a PIA update is required, please list: Click here to enter text.
Choose an item.
If covered by existing SORN, please list: Click here to enter text.

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

If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
USCG is submitting this updated PTA to discuss the Application for Special Permit,
Form CG-950A. The purpose of the form (CG-950A) is to document an application for
permit to carry an excursion party during a Marine Event of National Significance.
The Coast Guard prescribed excursion and special permit regulations in 46 CFR 2.0145, 26.03-6 and 26.03-8. The form is used by the Coast Guard to determine if the
excursion or deviation from a vessel’s current operating profile can be done safely.
If the Coast Guard determines that the excursion can be done safely, the Coast Guard
issues a Permit to Carry Excursion Party.
The form contains vessel specific information and basic business contact
information which may include the name and address of the vessel owner/operator,
if owned/operated by an individual.
The DHS Privacy Office (PRIV) agrees that this project is privacy-sensitive, requiring
PIA coverage because PII is collected from members of the public.
PRIV agrees with USCG Privacy that PIA coverage is provided by DHS/USCG/PIA-008
MISLE, which outlines the risks of capturing information required to support the
Coast Guard’s marine safety, security, environmental protection and law
enforcement programs.
PRIV agrees with USCG Privacy that SORN coverage is not required because
information is not retrieved by a personal identifier. Although, SORN coverage is
required and provided by DHS/USCG-013 Marine Information for Safety and Law
Enforcement (MISLE), which allows for the collection of PII from individuals with
established relationship(s) and/or associations with vessels, marine transportation
facilities, and activities regulated by the USCG.
USCG is required to update the form and use the Privacy Notice attached to this PTA.

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