1625-0018 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

Page 1 of 13

Version number: 06-2023

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

Privacy Threshold Analysis (PTA)

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

Component:

CG-706B/C

Official Logbook
U.S. Coast Guard (USCG)

Office:

Flag State Control (CGCVC-4

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Official Logbook
OMB Control
1625-0018
OMB Expiration
January 31, 2024
Number:
Date:
Collection status:
Extension
Date of last PTA (if
August 31, 2018
applicable):
Name:
Office:
Phone:
Name:
Office:
Phone:

PROJECT OR PROGRAM MANAGER
CDR Michael Hjerstedt
CG-CVC-4
Title:
CG-CVC-4 Division Chief
202-372-1215
Email:
[email protected]

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
A.L. Craig
CG-6P1
Title:
PRA Coordinator
202 475-3528
Email:
[email protected]

Privacy Threshold Analysis – IC/Form

Page 2 of 13

Version number: 06-2023

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. Please provide a
general description of the project and its purpose, including how it supports the DHS
mission, in a way a non-technical person could understand (you may use
information from the Supporting Statement).
If this is an updated PTA, please specifically describe what changes or upgrades are
triggering the update to this PTA.
The U.S. Coast Guard (USCG) is renewing the Information Collection Request (ICR) titled,
“1625-0018, Official Logbook.” There have been no significant changes or revisions to
this ICR since the last submission.

The Office of Commercial Vessel Compliance (CG-CVC) is located at Coast Guard (CG)
Headquarters in Washington, D.C. CG-CVC develops & maintains policy and standards,
for the prevention activities of the CG to achieve marine safety, security, and stewardship
mission success. The Office of Commercial Vessel Compliance includes policy experts in
domestic, foreign, and fishing vessels as well as merchant mariner credentialing.

Flag State Control (CG-CVC-4) is a division within CG-CVC and is responsible for
establishing policy, procedures, and guidance, to ensure Recognized Organization (RO)
services complies with International Maritime Organization (IMO) and CG requirements
for U.S. Flag vessels.
The Official Logbook (CG-706B/C) is a legal document required for U.S. vessels on a
voyage from a port in the United States to a foreign port; or vessels of at least 100 gross
tons and on a voyage between a U.S. port on the Atlantic Ocean and a U.S. port on the
Pacific Ocean. The requirement does not apply to a vessel on a voyage from a port in the
U.S. to a port in Canada.

The CG uses CG-706B/C to verify vessel employment and wages for crewmembers and to
certify compliance with laws and regulations concerning vessel operations and safety
procedures (e.g., vessel’s crew list/drills, inspections, watches, maintenance of
watertight integrity of the ship, and operations conducted during the voyage).

Privacy Threshold Analysis – IC/Form

Page 3 of 13

Version number: 06-2023

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

CG-706 B/C includes vessel specific information (i.e., name of vessel, official number,
port of registry, tonnage, nature of voyage, etc.) and the following personally
identifiable information (PII):
Name, Merchant Mariner Credential (MMC) number, and signature of the chief mate (or
any other crewmember that witness logbook entries).
Name and MMC number of crew members.

b. List the DHS (or Component) authorities to collect, store, and use this
information. If this information will be stored and used by a specific DHS
component, list the component-specific authorities.
The authorities for this collection are 46 U.S.C. §§11301, 11302, 11303, and 11304; 46
C.F.R. §§ 42.07-20; 46 C.F.R. subpart 35.07; 46 C.F.R. subpart 78.37; 46 C.F.R. subpart
97.35; 46 C.F.R. §§ 109.431-109.433; 46 C.F.R. §§ 122.280-122.282; 46 C.F.R. §§131.610131.630; 46 C.F.R. § 169.841; 46 C.F.R. §185.280; 46 C.F.R. subpart 196.35-3; and 46
C.F.R. part 199 subpart B § 199.60-199.190.
2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII 1)?

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

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

☒ Yes
☐ No

☒ Members of the public
☒ U.S. citizens or lawful permanent
residents
☐ Non-U.S. Persons
☐ DHS Employees/Contractors (list
Components)
☐ Other federal employees or contractors
☐ The record subject of the form (e.g., the
individual applicant).

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

Page 4 of 13

Version number: 06-2023

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

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

☐ 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.
Pursuant to 46 U.S.C. § 11301, the
master of the vessel shall make the
entries in the official logbook. Pursuant
to 46 U.S.C. § 11302, each entry made in
the official logbook shall be signed by
the master and signed and witnessed by
the chief mate or another mariner
aboard the vessel.
☒ 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? List all individual PII data
elements on the form. If the form will collect information from more than one type of
individual, please break down list of data elements collected by type of individual.
CG-706 B/C includes vessel specific information (i.e., name of vessel, official number,
port of registry, tonnage, nature of voyage, etc.) and the following PII:
Name, Merchant Mariner Credential (MMC) number, and signature of the chief mate (or
any other crewmember that witness logbook entries).
Name and MMC number of crew members.

Privacy Threshold Analysis – IC/Form

Page 5 of 13

Version number: 06-2023

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

f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? Check all that
apply. No
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
☐ Tax Identification Number
☐ Known Traveler Number
☐ Visa Number
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:
g. List the specific authority to collect SSN or these other SPII elements.
N/A
h. How will the SSN and SPII information be used? What is the purpose of the
collection?
N/A
i.

N/A/
j.

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.
Are individuals
provided notice at the
time of collection by
DHS (Does the records
subject have notice of
the collection or is

Privacy Threshold Analysis – IC/Form

☒ Yes. Please describe how notice is provided.
A Privacy Notice will be posted on the CG-Form.
☐ No.

Page 6 of 13

Version number: 06-2023

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

form filled out by
third party)?

3. How will DHS store the IC/form responses?
a. How will DHS store
☒ Paper. Please describe.
the original,
The Official Logbook is to be sent to the U.S. Coast
completed IC/forms?
Guard Sector Officer in Charge Marine Inspection
(OCMI) at the nearest port to the vessel’s place of
discharge. In accordance with our records
retention schedule, the OCMI shall transfer official
logbook records to the nearest Federal Records
Center (FRC) within six months after the last
transaction. Records shall then be transferred to
the National Archives and Records Administration
(NARA) when 30 years old for permanent storage.
☐ Electronic. Please describe the IT system that will
store the data from the form.
☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Click here to enter text.

2

b. If electronic, how
does DHS input the
responses into the IT
system? N/A

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

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

☐ By a unique identifier. 2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
☒ By a non-personal identifier. Please describe.

☐ Automatically. Please describe.
Click here to enter text.

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

Page 7 of 13

Version number: 06-2023

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

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

The information is retrieved by vessel name
and/or the vessel’s official number.
Official Logbook records are Permanent. Transfer
records to a Federal Records Center (FRC) within six
months after the last transaction. Records shall then
be transferred to the National Archives and Records
Administration (NARA) when 30 years old for
permanent storage.
Records Disposition Authority SF-115 NARA job
Number NC1-26-80-4, item 237.
N/A - Records are permanent.

e. How do you ensure
that records are
disposed of or deleted
in accordance with
the retention
schedule?
f. Is any of this information shared outside of the original program/office? 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.

Privacy Threshold Analysis – IC/Form

Page 8 of 13

Version number: 06-2023

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

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

Privacy Threshold Analysis – IC/Form

Page 9 of 13

Version number: 06-2023

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

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

Date submitted to Component Privacy
Office:
Concurrence from other Components
involved (if applicable):
Date submitted to DHS Privacy Office:
Have you approved a Privacy Act
Statement for this form? (Only
applicable if you have received a
waiver from the DHS Chief Privacy
Officer to approve component Privacy
Act Statements.)

A.L. Craig

August 24, 2023
N/A

September 7, 2023

☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
Information is not retrieve by a personal
identifier. However, a Privacy Notice will be
posted on the CG-Form.

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,
“1625-0018, Official Logbook.” There have been no significant changes or revisions to this
ICR since the last submission.

The Office of Commercial Vessel Compliance (CG-CVC) is located at Coast Guard (CG)
Headquarters in Washington, D.C. CG-CVC develops & maintains policy and standards, for
the prevention activities of the CG to achieve marine safety, security, and stewardship
mission success. The Office of Commercial Vessel Compliance includes policy experts in
domestic, foreign, and fishing vessels as well as merchant mariner credentialing.

Flag State Control (CG-CVC-4) is a division within CG-CVC and is responsible for
establishing policy, procedures, and guidance, to ensure Recognized Organization (RO)
services complies with International Maritime Organization (IMO) and CG requirements for
U.S. Flag vessels.

Privacy Threshold Analysis – IC/Form

Page 10 of 13

Version number: 06-2023

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

The Official Logbook (CG-706B/C) is a legal document required for U.S. vessels on a voyage
from a port in the United States to a foreign port; or vessels of at least 100 gross tons and
on a voyage between a U.S. port on the Atlantic Ocean and a U.S. port on the Pacific Ocean.
The requirement does not apply to a vessel on a voyage from a port in the U.S. to a port in
Canada.
The CG uses CG-706B/C to verify vessel employment and wages for crewmembers and to
certify compliance with laws and regulations concerning vessel operations and safety
procedures (e.g., vessel’s crew list/drills, inspections, watches, maintenance of watertight
integrity of the ship, and operations conducted during the voyage).
CG-706 B/C includes vessel specific information (i.e., name of vessel, official number, port
of registry, tonnage, nature of voyage, etc.) and the following PII:
Name, Merchant Mariner Credential (MMC) number, and signature of the chief mate (or
any other crewmember that witnessed logbook entries).
Name and MMC number of crew members.

In accordance with NARA’s record retention schedule: NC1-26-80-4, item 237, Official
Logbook records are permanent and transferred to a Federal Records Center (FRC) within
six months after the last transaction then transferred to NARA when 30 years old for
permanent storage.
The Official Logbook (CG-706B/C) is privacy sensitive – coverage is provided by
DHS/USCG/PIA-015 Merchant Mariner Licensing and Documentation System.

Privacy Threshold Analysis – IC/Form

Page 11 of 13

Version number: 06-2023

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:

Brian Pochatila

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

0015342
September 7, 2023
September 7, 2026
Riley Dean

DESIGNATION

Privacy Sensitive IC or
Form:
Determination:

Privacy Act
Statement:
System PTA:
PIA:

SORN:

Yes If “no” PTA adjudication is complete.
☐ PTA sufficient at this time.
☐ Privacy compliance documentation determination in
progress.
☐ New information sharing arrangement is required.
☐ DHS Policy for Computer-Readable Extracts Containing SPII
applies.
☒ Privacy Act Statement required.
☒ Privacy Impact Assessment (PIA) required.
☐ System of Records Notice (SORN) required.
☐ Specialized training required.
☐ Other. Click here to enter text.

e(3) statement currently accurate.
PN submitted and approved.
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.

Privacy Threshold Analysis – IC/Form

Page 12 of 13

Version number: 06-2023

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 renewing the Information Collection Request (ICR) titled, “1625-0018, Official
Logbook.” There have been no significant changes or revisions to this ICR since the last
submission. The Official Logbook (CG-706B/C) is a legal document required for U.S. vessels
on a voyage from a port in the United States to a foreign port; or vessels of at least 100
gross tons and on a voyage between a U.S. port on the Atlantic Ocean and a U.S. port on the
Pacific Ocean. The requirement does not apply to a vessel on a voyage from a port in the
U.S. to a port in Canada.
The CG uses CG-706B/C to verify vessel employment and wages for crewmembers and to
certify compliance with laws and regulations concerning vessel operations and safety
procedures (e.g., vessel’s crew list/drills, inspections, watches, maintenance of watertight
integrity of the ship, and operations conducted during the voyage).

CG-706 B/C includes vessel specific information (i.e., name of vessel, official number, port
of registry, tonnage, nature of voyage, etc.) and the following PII:
• Name, Merchant Mariner Credential (MMC) number, and signature of the chief mate
(or any other crewmember that witnessed logbook entries).
• Name and MMC number of crew members.
The DHS Privacy concurs that the Official Logbook (CG-706B/C) is privacy sensitive
requiring PIA coverage. PIA coverage is provided by DHS/USCG/PIA-015 Merchant
Mariner Licensing and Documentation System, which manages the issuance of credentials
to Merchant Mariners and process merchant mariner applications; (2) produces merchant
mariner credentials; (3) track merchant mariner credentials issued by the Coast Guard; (4)
tracks the status of merchant mariners with respect to service, training, credentials, and
qualifications, related to the operation of commercial vessels; (5) qualifies merchant
mariners for benefits and services administered by other agencies; and (6) performs
merchant mariner call-ups related to national security.
SORN coverage is not technically required as the information is collected and therefore not
retrieved by a unique identifier. However, DHS/USCG-030 Merchant Seamen’s Records
does provide notice of this type of information collection.
Privacy Threshold Analysis – IC/Form

Page 13 of 13

Version number: 06-2023