Privacy Threshold Analysis

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 1 of 7
PRIVACY THRESHOLD ANALYSIS (PTA)

CONTACT LISTS
This form is used to determine whether
a Privacy Impact Assessment is required.

Please use the attached form to determine whether a Privacy Impact Assessment (PIA) is required under
the E-Government Act of 2002 and the Homeland Security Act of 2002.
Please complete this form and send it to your component Privacy Office. If you do not have a component
Privacy Office, please send the PTA to the DHS Privacy Office:
Rebecca J. Richards
Director of Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 703-235-0780

PIA@dhs.gov

Upon receipt, the DHS Privacy Office will review this form. If a PIA is required, the DHS Privacy Office
will send you a copy of the Official Privacy Impact Assessment Guide and accompanying Template to
complete and return.
A copy of the Guide and Template is available on the DHS Privacy Office website, www.dhs.gov/privacy,
on DHSOnline and directly from the DHS Privacy Office via email: pia@dhs.gov, phone: 703-235-0780.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 2 of 7
PRIVACY THRESHOLD ANALYSIS (PTA)
Please complete this form and send it to the DHS Privacy Office.
Upon receipt, the DHS Privacy Office will review this form
and may request additional information.
SUMMARY INFORMATION
DATE submitted for review: February 24, 2011
NAME of Project: National Recreational Boating Survey
Name of Component: US Coast Guard
Name of Project Manager: Philippe Gwet
Email for Project Manager: Philippe.gwet@uscg.mil
Phone number for Project Manger: 202-372-1102
TYPE of Project:
Information Technology and/or System ∗
A Notice of Proposed Rule Making or a Final Rule.
Other: National survey of recreational boating participants

∗

The E-Government Act of 2002 defines these terms by reference to the definition sections of Titles 40 and
44 of the United States Code. The following is a summary of those definitions:
•“Information Technology” means any equipment or interconnected system or subsystem of
equipment, used in the automatic acquisition, storage, manipulation, management, movement,
control, display, switching, interchange, transmission, or reception of data or information. See 40
U.S.C. § 11101(6).
•“Information System” means a discrete set of information resources organized for the collection,
processing, maintenance, use, sharing, dissemination, or disposition of information. See: 44. U.S.C. §
3502(8).
Note, for purposes of this form, there is no distinction made between national security systems or
technologies/systems managed by contractors. All technologies/systems should be initially reviewed
for potential privacy impact.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 3 of 7
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
The United States Coast Guard’s (USCG) National Recreational Boating Safety
(NRBS) program objective is to ensure the public has a safe, secure, and enjoyable
recreational boating experience by implementing programs that minimize loss of life,
personal injury, and property damage while cooperating with environmental and
national security efforts. The NRBS information collection project enables the USCG
to better identify safety priorities, coordinate and focus research efforts, and
encourage consistency in the information that is collected as well as the applied
analysis methods.

Some survey respondents will return completed questionnaires by mail, while others
will take a telephone interviews, and submit their responses online by completing a
webform. Respondents are typically recreational boating participants, who may or
may not own any boat. The USCG will use that data for various purposes, inlcuding
the cost-benefit analysis of regulatory projects, providing guidance to states in the
development of their safety education programs or safety awareness campaigns.
Summary statistics may also be provided to the USCG boating partners in the
industry and academia.
2.

Status of Project:
This is a new development effort.
This an existing project.
Date first developed:
Date last updated:

3.

Is the information collected directly from the individuals seeking information from the
Department or working collaboratively with the Department on various projects?
Yes.
No. Please describe the information source and collection method.
The information will be collected directly from recreational boating participants, by mail,
by telephone as well as via a web-form

4.

Does the individual have the option to decline submitting the information collected?

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 4 of 7
Yes.
No.
5.

Is the information collected limited to non-sensitive personally identifiable information? An
example of sensitive personally identifiable information is the social security number or date of
birth.
Yes.
No.

6.

What information about individuals could be collected, generated or retained?
The NRBS collects first names, street addresses, phone numbers, and email addresses
in addition to general boating information (e.g. type of boat used, frequency of use,
duration of a boating trip, boating safety courses taken, number of years of
experience operating a boat, usage of safety equipment, type of boating activity
engaged in, etc.). Individuals will report this data themselves either by mail or by
telephone. Occasionally boaters will submit their data online by completing an webform.
The Coast Guard will use the following two methods (Random Digit Dialing (RDD)
& Mailing) for contacting the boaters:
(i) RDD Method
This method is widely used in government-sponsored surveys, and is based on
computer-generated random telephone numbers. These telephone numbers are
made up by generating one digit at a time randomly chosen between 0 and 9. The
number obtained may or may not be a working number. Non-working numbers as
well as numbers associated with non-boating housholds will be eliminated. The
computer will randomly generate a large number of such telephone numbers, and
interviewers will dial them until the quota of responding boaters is reached. The
randomly-generated phone number may happen to be that of boater by pure chance.
(ii) Mailing Method
The Coast Guard will ask the states to contact the recreational boaters on its behalf,
asking them whether they are willing to participate in the National Recreational
Boating Survey. Only those individuals who would agree to participate will receive
the survey questionnaire by mail. The survey questionnaire will then request an
email address from the survey participant in case there is a need to collect further
data from the same boater at a later time.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 5 of 7
7.

Is the contact information only being used for the purpose for which it originally was
collected, i.e., to contact individuals?
Yes.
No.

8.

With whom could the information be shared?
Tthe USCG may share statistical data with its boating partners from industry and
academia. Personal data is not transmitted to any third party.

9.

Are program or project user access controls in place governing who may view or access the
contact information?
Yes.
No.

10.

Has an Authority to Operate from the Chief Information Security Officer been granted to the
program or project that the document or database which stores the contact information?
No.
Yes. Please indicate the determinations for each of the following:
Confidentiality:

Low

Moderate

High

Undefined

Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 6 of 7
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: February 28, 2011
NAME of the DHS Privacy Office Reviewer: Rebecca J. Richards
DESIGNATION
This is NOT a Privacy Sensitive System – the system contains no Personally Identifiable
Information.
This IS a Privacy Sensitive System
Category of System
IT System
National Security System
Legacy System
HR System
Rule
Other: National survey of recreational boating participants
Determination
PTA sufficient at this time
Privacy compliance documentation determination in progress
PIA is not required at this time
A PIA is required
System covered by existing PIA: DHS General Contact Lists
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/ALL-002-Department of
Homeland Security (DHS) Mailing and Other Lists System November 25, 2008, 73 FR
71659
A new SORN is required.

The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
703-235-0780, pia@dhs.gov
www.dhs.gov/privacy

Privacy Threshold Analysis
Version date: June 10th, 2009
Page 7 of 7
DHS PRIVACY OFFICE COMMENTS
The NRBS collects the first names, street addresses, phone numbers & email
addresses of registered/non-registered boat owners and non-owners. This collection
is covered by the DHS Contact List PIA and DHS/ALL-002.