PTA from DHS

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 10, 2010
Page 1 of 6

PRIVACY THRESHOLD ANALYSIS (PTA)
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 from the component Privacy Office, 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 DHSConnect 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 10, 2010
Page 2 of 6

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Date Submitted for Review: September 02, 2010
Name of Project: Intellectual Property Rights e-Recordation application (IPRR)
System Name in TAFISMA: Intellectual Property Rights e-Recordation (IPRR)
Name of Component: Rules and Regulations, Office of International Trade
Name of Project Manager: Glenn Corcoran
Email for Project Manager: GLENN.A.CORCORAN@CBP.DHS.GOV
Phone Number for Project Manager: (571) 468-6131
Type of Project:
Information Technology and/or System. 
A Notice of Proposed Rule Making or a Final Rule.
Form or other Information Collection.
Other:



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 10, 2010
Page 3 of 6
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
Border enforcement of copyright and trademark rights is primarily concentrated on registered
marks that have been recorded with CBP. In order to facilitate CBP’s mission as it relates to
prohibiting the importation of infringing marks, CBP maintains an on-line system for filing
trademark and copyright recordation applications. That system, the Intellectual Property Rights
e-Recordation (IPRR), allows rights owners to electronically record their trademarks and
copyrights with CBP, and facilitates IPR seizures by making IPR recordation information readily
available to CBP personnel, thus providing more timely protection and enforcement of domestic
intellectual property rights.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: February 2005
Date last updated: June 2010
Category for “gray market protection” added.

3.

From whom do you collect, process, or retain information on: (Please check all that apply)
DHS Employees.
Contractors working on behalf of DHS.
The Public.
The System does not contain any such information.

4.

Do you use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs)
No.
Yes. Why does the program collect SSNs? Provide the function of the SSN and the
legal authority to do so:

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 10, 2010
Page 4 of 6
5.

What information about individuals could be collected, generated or retained?
The IPRR system collects and retains contact information, including the name, address, and
phone number of a rights holder and their representative, as well as the name of persons,
foreign and domestic, who are known to have used the mark (licensed or otherwise). The
contact information regarding rights holders and their representatives is maintained in a
publicly searchable section of the system.
The system will also maintain a copy of the financial information submitted pursuant to a
required processing fee (i.e. credit card information) and may contain personally identifiable
information in the form of the mark itself (for example, the trademark may include a picture
of a person).

6.

If this project is a technology/system, does it relate solely to infrastructure? [For example, is
the system a Local Area Network (LAN) or Wide Area Network (WAN)]?
No. Please continue to the next question.
Yes. Is there a log kept of communication traffic?
No. Please continue to the next question.
Yes. What type of data is recorded in the log? (Please choose all that apply.)
Header.
Payload Please describe the data that is logged.
Data is retained in an Oracle database.

7.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems1?
No.
Yes.
Please list:

8.

Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown.

1

PII may be shared, received, or connected to other DHS systems directly, automatically, or by manual processes.
Often, these systems are listed as “interconnected systems” in TAFISMA.

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 10, 2010
Page 5 of 6
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 10, 2010
Page 6 of 6

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
Date reviewed by the DHS Privacy Office: November 9, 2010
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:
Determination
PTA sufficient at this time.
Privacy compliance documentation determination in progress.
PIA is not required at this time.
PIA is required.
System covered by existing PIA:
New PIA is required.
PIA update is required.
SORN not required at this time.
SORN is required.
System covered by existing SORN:
New SORN is required.
DHS PRIVACY OFFICE COMMENTS