1625-0074 Privacy Threshold Analysis (PTA)

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
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
PIA@hq.dhs.gov
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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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
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:
OMB Control
Number:
Collection status:

Direct User Fees for Inspection or Examination of U.S. and Foreign Commercial
Vessels
1625-0074
February 28, 2017
OMB Expiration
Extension

Date:
Date of last PTA (if
applicable):

N/A

PROJECT OR PROGRAM MANAGER
Name:
Office:
Phone:

Mr. David Du Pont
CG-REG
202-372-1497

Title:
Email:

Reg Dev Mgr
David.A.DuPont@uscg.mil

COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Name:
Office:
Phone:

Mr. Anthony Smith
CG-612
202-475-3532

Privacy Threshold Analysis – IC/Form

Title:
Email:

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PRA Coordinator
Anthony.D.Smith@uscg.mil

Version number: 04-2016

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

SPECIFIC IC/Forms PTA QUESTIONS
1. Purpose of the Information Collection or Form
The purpose of the information collection is to aid the Coast Guard in managing the collection of user
fees from U.S. and foreign commercial vessel owners/operators. The Coast Guard uses the information to
associate a user fee payment with a specific commercial vessel.
There is no Coast Guard form associated with this collection. The records contain basic business contact
information which may include the name and address of the vessel owner/operator, if owned/operated by
an individual and an email address. Vessel owner/operator data may include a Tax Identification
Number. Additionally, the vessel identification number is required to ensure that the fee paid is linked to
the proper vessel. The CG does not collect banking/financial information. That information is sent
directly to the U.S. Treasury’s pay.gov website or the financial institution that the Coast Guard identifies
on our Finance Center (FINCEN) website.
The authority for this collection is 46 U.S.C. 2110.

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
collect information?
(Check all that apply.)

Yes
☐No
Members of the public
U.S. citizens or lawful permanent
residents
Non-U.S. Persons.
☐DHS Employees
☐DHS Contractors
☐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.).

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

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

Business entity.
If a business entity, is the only
information collected business contact
information?
Yes
☐No
☐Law enforcement.
☐DHS employee or contractor.
☐Other individual/entity/organization that is
NOT the record subject. Please describe.
There is no form associated with this collection.

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)
Links to Dept. of Treasury www.PAY.gov online forms via
https://www.fincen.uscg.mil/VIF.htm

e. What information will DHS collect on the form?
The records contain basic business contact information which may include the phone number, email
address and name and address of the vessel owner/operator, if owned/operated by an individual. Vessel
owner/operator data may include a Tax Identification Number. Additionally, the vessel identification
number is required to ensure that the fee paid is linked to the proper vessel.

f. Does this form collect Social Security number (SSN) or other element that is standalone Sensitive Personally Identifiable Information (SPII)? Yes.
☐ Social Security number
☐ DHS Electronic Data Interchange
Personal Identifier (EDIPI)
☐ Alien Number (A-Number)
☐ Social Media Handle/ID
Tax Identification Number
☐ Visa Number
☐ Known Traveler Number
☐ Passport Number
☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Bank Account, Credit Card, or other
☐ Driver’s License Number
financial account number
☐ Biometrics
☐ Other. Please list:
Privacy Threshold Analysis – IC/Form

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

g. List the specific authority to collect SSN or these other SPII elements.
Debt Collection Improvement Act of 1996

h. How will this information be used? What is the purpose of the collection? Describe
why this collection of SPII is the minimum amount of information necessary to
accomplish the purpose of the program.
The collection of SPII is essential to ensure that the payee is properly credited with making a user fee
payment.

i. 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.

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.
The inspector’s notes, etc. regarding the inspection that
the Coast Guard receives are maintained in Marine
Information for Safety and Law Enforcement (MISLE)
database. Initially, the payment amount and receipt
number are entered into the Core Accounting Suite (CAS).

☐ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
b. If electronic, how
does DHS input the
responses into the IT
system?

Privacy Threshold Analysis – IC/Form

Manually (data elements manually entered).
Please describe.
The amount and receipt number of vessel-specific user fee
payment is manually entered into a CG IT system—the
CAS. Once entered, the CAS-MISLE database record

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

updates are performed manually via an interface.

☐Automatically. Please describe.
Click here to enter text.
c. How would a user
☐By a unique identifier.2 Please describe. If
search the
information is retrieved by personal identifier, please
information
submit a Privacy Act Statement with this PTA.
submitted on the
Click here to enter text.
forms, i.e., how is the
By a non-personal identifier. Please describe.
information
A search can be done using vessel-specific information.
retrieved?
A record is retained for the life of the vessel; NARA retention
d. What is the records
schedule number N1-026-05-015.
retention
schedule(s)? Include
the records schedule
number.
Disposal/deletion of CAS and MISLE data, are in accordance
e. How do you ensure
with the business rules for each database.
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?
No. Information on this form is not shared outside of the collecting 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.

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

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Version number: 04-2016

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

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, pia@hq.dhs.gov
www.dhs.gov/privacy

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

Robert Herrick

Date submitted to component
Privacy Office:
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.)

October 5, 2018
October 17, 2018

☐Yes. Please include it with this PTA
submission.
No. Please describe why not.
There is no form associated with this collection.

Component Privacy Office Recommendation:
The purpose of the Direct User Fees for Inspection or Examination of U.S. and Foreign Commercial
Vessels information collection is to aid the Coast Guard in managing the collection of user fees from U.S.
and foreign commercial vessel owners/operators. The Coast Guard uses the information to associate a
user fee payment with a specific commercial vessel. The CG does not collect banking/financial
information. That information is sent directly to the U.S. Treasury’s pay.gov website or the financial
institution that the Coast Guard identifies on our Finance Center (FINCEN) website.
The records contain basic business contact information which may include the phone number, email
address and name and address of the vessel owner/operator, if owned/operated by an individual. Vessel
owner/operator data may include a Tax Identification Number. Additionally, the vessel identification
number is required to ensure that the fee paid is linked to the proper vessel.
This collection is covered by DHS/USCG/PIA-009, DHS/USCG/PIA-008 Marine Information for Safety
and Law Enforcement (MISLE) and DHS/USCG-013 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, pia@hq.dhs.gov
www.dhs.gov/privacy

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

Riley Dean

PCTS Workflow Number:

Click here to enter text.

Date approved by DHS Privacy
Office:
PTA Expiration Date

December 7, 2018
December 7, 2021
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.
X Privacy Impact Assessment (PIA) required.
X System of Records Notice (SORN) required.
☐Specialized training required.
☐Other. Click here to enter text.

DHS IC/Forms Review: Choose an item.
Date IC/Form
Approved by PRIV:
IC/Form PCTS
Number:
Privacy Threshold Analysis – IC/Form

Click here to enter a date.
Click here to enter text.

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

Privacy Act
Statement:
PTA:

Choose an item.
Click here to enter text.
Choose an item.
Click here to enter text.
PIA:
System covered by existing PIA
If covered by existing PIA, please list: DHS/USCG/PIA-008 Marine
Information for Safety and Law Enforcement (MISLE)
DHS/USCG/PIA-009 Core Accounting Suite
If a PIA update is required, please list: Click here to enter text.
SORN:
System covered by existing SORN
If covered by existing SORN, please list: DHS/ALL-008 Accounts Receivable
System of Records September 28, 2015, 80 FR 58289
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 submitted this PTA to discuss the Direct User Fees for Inspection or Examination of
U.S. and Foreign Commercial Vessels information collection, which is associated with OMB
Control Number 1625-0074. The purpose of the information collection is to aid USCG in
managing the collection of user fees from U.S. and foreign commercial vessel
owners/operators. The Coast Guard uses the information to associate a user fee payment
with a specific commercial vessel. 46 U.S.C. 2110 requires the collection of user fees for
USCG inspection services. In order to do this, USCG must have certain minimal information
to credit payments to specific vessels. If the required information and payment of fees is
not provided, USCG may not be able to determine which vessel the payment is for, or
resolve problems if discrepancies occur, such as out of balances, overpayments,
underpayments, and payments returned due to insufficiency of funds.
The USCG does not collect banking/financial information. There is no Coast Guard form
associated with this collection. U.S. Treasury forms are used outside of the USCG
information collection to process these user fees. That information is sent directly to
www.PAY.gov or the financial institution that the USCG identifies on our Finance Center
website https://www.fincen.uscg.mil/VIF.htm. The banking information is received by the
US Treasury and the USCG can view limited information like payment amount and
information in comment fields.
What USCG does collect includes information to ensure that the fee paid is linked to the
Privacy Threshold Analysis – IC/Form

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Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, pia@hq.dhs.gov
www.dhs.gov/privacy

proper vessel. For example, records contain basic business contact information which may
include the name and address of the vessel owner/operator, if owned/operated by an
individual and an email address. Vessel owner/operator data may also include a Tax
Identification Number. Records are initially entered into the Core Accounting Suite (CAS);
but again, no financial/banking information is entered into CAS. Generally, the amount and
a receipt number that is provided by U.S. Treasury (which does not relate to any account
numbers) are shared to ensure that USCG can affirm that a vessel paid the required fees.
The inspector’s notes regarding the inspection are maintained in the Marine Information
for Safety and Law Enforcement (MISLE) database.
The DHS Privacy Office finds that this information collection is privacy-sensitive, requiring
PIA and SORN coverage.
PIA coverage is provided by DHS/USCG/PIA-008 Marine Information for Safety and Law
Enforcement (MISLE) and DHS/USCG/PIA-009 Core Accounting Suite. SORN coverage is
provided by DHS/ALL-008 Accounts Receivable System of Records.
Although U.S. Treasury forms are used for the payment function, those forms do include
the USCG logo. Therefore, the DHS Privacy Office advised that USCG should work with U.S.
Treasury to ensure those forms are adequate, including whether a Privacy Act Statement or
Privacy Notice should be added.

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