1625-0028- Privacy Threshold Analysis (PTA)

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

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

Privacy Threshold Analysis – IC/Form

Version number: 04-2016
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis (PTA)

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

N/A

Form Title:

N/A

Component:

U.S. Coast Guard (USCG)

Office:

CG-REG

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Course Approval and Records for Merchant Mariner Training Schools
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:
Office:
Phone:

1625-0028
Extension

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

April 30, 2023
January 17, 2020

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]

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

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 Information Collection Request (ICR) titled,
1625-0028: “Course Approval and Records for Merchant Mariner Training Schools.”
The purpose of the information collection is to determine if merchant mariner training
schools meet minimal statutory requirements. The Coast Guard uses this information to
approve the curriculum, facility and faculty for these schools, and to verify student
course completion.
There is no form associated with this collection. The records contain business contact
information, which may include the name and address of the training school
owner/operator, if owned/operated by an individual. The records also include the
names of course instructors and proctors, and the names of students that complete or
dis-enroll from a course or program.
b. List the DHS (or Component) authorities to collect, store, and use this
information.
The authority for this collection is 46 U.S.C. 2103, 2104 and 7315.

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII1)?

☒ Yes
☐ No

b. From which type(s) of
individuals does this form
collect information?
(Check all that apply.)

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☒ Non-U.S. Persons

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.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

☐ 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 records contain business contact information, which may include the name and
address of the training school owner/operator, if owned/operated by an individual. The
records also include the names of course instructors and proctors, and the names of
students that complete or dis-enroll from a course or program.
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? No.
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
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

☐ Tax Identification Number
☐ Visa Number
☐ Passport Number
☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ 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?
N/A
i. How will this information be used? What is the purpose of the collection?
The purpose of the information collection is to determine if merchant mariner training
schools meet minimal statutory requirements. The Coast Guard uses this information to
approve the curriculum, facility and faculty for these schools, and to verify student
course completion.
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)?

☐ Yes. Please describe how notice is provided.
Click here to enter text.
☒ No. Information is not retrieved by a personal
identifier.

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.

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

A CG course approval specialist enters information
into a limited-access CG file server at the USCG
National Maritime Center (NMC).
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.
b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
A CG course approval specialist enters information
into a limited-access CG file server at the USCG
NMC.
☐ 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 CG course approval specialist would retrieve
information using the training school or course
name.
A record is retained for the life of the training school;
NARA retention schedule number DAA-GRS-20130007-0012 (GRS 4.2, Item 130).

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
that records are
disposed of or deleted
in accordance with

Electronic records are disposed/deleted in
accordance with the Agency business rules and the
retention schedule.

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.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

the retention
schedule?
f. Is any of this information shared outside of the original program/office?
☐ Yes, information is shared with other DHS components or offices. Please describe.
Click here to enter text.
☒ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
To aid mariners, course approval information is available at
https://www.dco.uscg.mil/portals/9/NMC/pdfs/courses/courses.pdf
☐ 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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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:

October 26, 2022

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
January 17, 2023
☐ 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 Information Collection Request (ICR) titled,
1625-0028: “Course Approval and Records for Merchant Mariner Training Schools.”
The purpose of the information collection is to determine if merchant mariner training
schools meet minimal statutory requirements. The Coast Guard uses this information to
approve the curriculum, facility, and faculty for these schools, and to verify student course
completion.
There is no form associated with this collection.
Course Approval and Records for Merchant Mariner Training Schools records contain
business contact information, which may include the name and address of the training
school owner/operator, if owned/operated by an individual. The records also include the
names of course instructors and proctors, and the names of students that complete or disenroll from a course or program.
Privacy Threshold Analysis – IC/Form

Version number: 04-2016
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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Records associated with this collection are maintained in accordance with NARA retention
schedule number DAA-GRS-2013-0007-0012 (GRS 4.2, Item 130) and are in a CG restricted
file server at the USCG National Maritime Center (NMC).
Course Approval and Records for Merchant Mariner Training Schools is privacy sensitivecoverage is proved by DHS/USCG/PIA-015, Merchant Mariner Licensing and
Documentation System (MMLDS).

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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

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

0023745
January 18, 2023
January 18, 2026

DESIGNATION
Privacy Sensitive IC or
Form:

Yes If “no” PTA adjudication is complete.

Determination:

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

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-015 Merchant Mariner Licensing and Documentation
System
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.
If a SORN update is required, 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

DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
USCG is submitting this renewal PTA to discuss the Course Approval and Records for
Merchant Mariner Training Schools. No changes have been made since the last
adjudication on January 17, 2020.
The purpose of the information collection is to determine if merchant mariner
training schools meet minimal statutory requirements. The Coast Guard uses this
information to approve the curriculum, facility and faculty for these schools, and to
verify student course completion.
There is no form associated with this collection. The records contain business
contact information, which may include the name and address of the training school
owner/operator, if owned/operated by an individual. The records also include the
names of course instructors and proctors, and the names of students that complete
or dis-enroll from a course or program.
The DHS Privacy Office (PRIV) agrees that this form 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-015
Merchant Mariner Licensing and Documentation System, which discusses how USCG
uses this system to: (1) manage the issuance of credentials to Merchant Mariners
and process merchant mariner applications; (2) produce merchant mariner
credentials; (3) track merchant mariner credentials issued by the Coast Guard; (4)
track the status of merchant mariners with respect to service, training, credentials,
and qualifications, related to the operation of commercial vessels; (5) qualify
merchant mariners for benefits and services administered by other agencies; and
(6) perform merchant mariner call-ups related to national security. While this PIA
does not explicitly call out the information collected from those at merchant marine
training schools (it focuses more on the actual merchant mariner), the PIA provides
enough notice about the Merchant Marine process in general. USCG should include
information related to this accreditation process next time this PIA is updated.
SORN coverage is also not required because information is not retrieved by personal
identifier.

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