Statute for SAS

Privacy Threshold Assessment
(PTA)
Federal Aviation Administration (FAA)
Office of Aviation Safety (AVS)
Safety Assurance System (SAS)

CLAIRE W BARRETT

Digitally signed by CLAIRE W BARRETT
DN: c=US, o=U.S. Government, ou=OSTHQ, ou=DOT
Headquarters, cn=CLAIRE W BARRETT
Date: 2018.04.16 13:06:22 -04'00'

4/16/2018

X

Claire W. Barrett

Claire W. Barrett
Departmental Chief Privacy & Information Govern...
Signed by: OSTHQ

DOT Privacy Program

Template
Privacy Threshold Assessment (PTA) Template v2.0

Privacy Threshold Assessment (PTA)
The Privacy Threshold Assessment (PTA) is an analytical tool used to determine the scope of
privacy risk management activities that must be executed to ensure that the Department’s
initiatives do not create undue privacy risks for individuals.
The Privacy Threat Assessment (PTA) is a privacy risk management tool used by the
Department of Transportation (DOT) Chief Privacy Officer (CPO). The PTA determines
whether a Department system1 creates privacy risk for individuals that must be further
analyzed, documented, or mitigated, and determines the need for additional privacy
compliance documentation. Additional documentation can include Privacy Impact
Assessments (PIAs), System of Records notices (SORNs), and Privacy Act Exemption Rules
(Exemption Rules).

The majority of the Department’s privacy risk emanates from its direct collection, use,
storage, and sharing of Personally Identifiable Information (PII),2 and the IT systems used
to support those processes. However, privacy risk can also be created in the Department’s
use of paper records or other technologies. The Department may also create privacy risk
for individuals through its rulemakings and information collection requirements that
require other entities to collect, use, store or share PII, or deploy technologies that create
privacy risk for members of the public.

To ensure that the Department appropriately identifies those activities that may create
privacy risk, a PTA is required for all IT systems, technologies, proposed rulemakings, and
information collections at the Department. Additionally, the PTA is used to alert other
information management stakeholders of potential risks, including information security,
records management and information collection management programs. It is also used by
the Department’s Chief Information Officer (CIO) and Associate CIO for IT Policy and
Governance (Associate CIO) to support efforts to ensure compliance with other information
asset requirements including, but not limited to, the Federal Records Act (FRA), the
Paperwork Reduction Act (PRA), the Federal Information Security Management Act
(FISMA), the Federal Information Technology Acquisition Reform Act (FITARA) and
applicable Office of Management and Budget (OMB) guidance.

Each Component establishes and follows its own processes for developing, reviewing, and
verifying the PTA prior to its submission to the DOT CPO. At a minimum the PTA must be
reviewed by the Component business owner, information system security manager, general
counsel, records officers, and privacy officer. After the Component review is completed, the
Component Privacy Office will forward the PTA to the DOT Privacy Office for final
1

For the purposes of the PTA the term “system” is used throughout document but is not limited to traditional IT
systems. It can and does refer to business activity and processes, IT systems, information collection, a project,
program and/or technology, and proposed rulemaking as appropriate for the context of the assessment.
2
The term “personally identifiable information” refers to information which can be used to distinguish or trace an
individual's identity, such as their name, social security number, biometric records, etc. alone, or when combined
with other personal or identifying information which is linked or linkable to a specific individual, such as date and
place of birth, mother’s maiden name, etc.

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adjudication. Only PTAs watermarked “adjudicated” and electronically signed by the DOT
CPO are considered final. Do NOT send the PTA directly to the DOT PO; PTAs received by
the DOT CPO directly from program/business owners will not be reviewed.

If you have questions or require assistance to complete the PTA please contact your
Component Privacy Officer or the DOT Privacy Office at privacy@dot.gov. Explanatory
guidance for completing the PTA can be found in the PTA Development Guide found on the
DOT Privacy Program website, www.dot.gov/privacy.

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PROGRAM MANAGEMENT
SYSTEM name: Safety Assurance System (SAS)
Cyber Security Assessment and Management (CSAM) ID: 1996
SYSTEM MANAGER CONTACT Information:
Name: John Frye
Email: john.frye@faa.gov
Phone Number: (703) 598-9186
Is this a NEW system?
☐ Yes (Proceed to Section 1)
☒ No
☒ Renewal:
☐ Modification
Is there a PREVIOUSLY ADJUDICATED PTA for this system?
☐ Yes:
Date:
☒ No

1 SUMMARY INFORMATION
1.1

System TYPE
☒ Information Technology and/or Information System
Unique Investment Identifier (UII): 021-189475443
Cyber Security Assessment and Management (CSAM) ID: 1996
☐ Paper Based:
☐ Rulemaking
Rulemaking Identification Number (RIN):
Rulemaking Stage:
☐ Notice of Proposed Rulemaking (NPRM)
☐ Supplemental NPRM (SNPRM):
☐ Final Rule:
Federal Register (FR) Notice:

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☐ Information Collection Request (ICR)3
☐ New Collection

☐ Approved Collection or Collection Renewal
☐ OMB Control Number:
☐ Control Number Expiration Date:

☐ Other:
1.2
System OVERVIEW:
The Federal Aviation Administration (FAA) is developing the initial Privacy Threshold Analysis
(PTA) for the Safety Assurance System (SAS). The SAS replaced the Air Transportation
Oversight Safety System (ATOS).4 It is used by the Office of Aviation Safety (AVS) to support
the System Approach for Safety Oversight (SASO) program office’s safety and risk management
operations. The SAS supports the FAA by monitoring and managing aviation certificate holders
as well as applicants for aviation certificates (CH/As). CH/As include airmen, air carriers,
commuter airlines, repair stations and other relevant business entities, which are considered
members of the public. SAS automates two broad processes for CH/As: Initial Certification and
Continued Operational Safety (COS). SAS is used by all FAA local Flight Standards District
Offices (FSDO)5 and Certificate Management Offices (CMO) responsible for monitoring and
managing CH/As. The SAS is hosted at the FAA Enterprise Data Center at the Mike Monroney
Aeronautical Center at 6500 South Macarthur Boulevard Oklahoma City, Oklahoma 731696901.
SAS Modules and Functions
The SAS software modules provide for initial certification and COS of CH/As through
Configuration, Planning, Resource Management, Data Collection, and Analysis Assessment
Action.
•

•

•

Module 1 – Configuration: This module is the first step in initial certification and
provides information to FAA regarding the identity and particular characteristics of a
certificate applicant. It is accessible by the SAS Internal (https://sas.avs.faa.gov) and
External portals (https://sas.faa.gov) which are each described in detail below. The
initial certification process through the External Portal is also described below.
Module 2 – Planning: This module allows authorized internal FAA users to establish
oversight plans for inspectors in order to perform regulatory compliance on certificate
holders. Chief Inspectors (CI) plan inspections of certificate holders; assign
inspectors to assess CHs; and schedule inspections using the planning module. The
Planning Module is only accessible through the Internal Portal
Module 3 – Resource Management: This module allows CI’s to develop resource
allocation based on established oversight plans. If, for example, an assessment
required resources beyond those available to an FSDO, a CI might assign staff from a

3

See 44 USC 3201-3521; 5 CFR Part 1320
. The ATOS System Disposal Assessment (SDA) was adjudicated by the DOT Chief Privacy Officer on 11/4/16.
5
Flight Standards District Office is a Regional FAA AVS office. There are approximately 82 such regional offices
nationwide. The Flight Standards District Offices particularly concentrates on compliance with the United States
Federal Aviation Regulations.
4

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•

•

neighboring FSDO to assist. This module is only accessible through the Internal
Portal.
Module 4 – Data Collection: This module, which is accessible through the Internal
and External Portals, allows Safety Inspectors to collect regulatory compliance and
safety data on current certificate holders and allows external users and current
certificate holders to collect data on themselves utilizing the Self-Assessment/SelfAudit for 14 Code of Federal Regulations (CFR) Part 145s. The Data Collection Tool
(DCT) is the primary method used for this data collection. A DCT is a survey
consisting of questions designed by the FAA to test a target system for safety and
compliance. DCTs are performed both before and after certification and typically do
not contain Personally Identifiable Information (PII), however some DCTs contain
open text fields that could allow an inspector to inadvertently enter PII. In the
infrequent cases where PII is inadvertently submitted, program staff redact the PII.
The purpose of collecting data is to gather information that Principle Inspectors use to
make informed decisions about the CH/A’s operating systems (1) before approving or
accepting them when required to do so by regulation, and (2) during recurring
Performance Assessments (PAs). Future system enhancements will include all CFR
Parts subject to oversight.
Module 5 – Analysis Assessment Action: This module allows for the analysis and
assessment of design, performance, and level of risk in CH/As. Based on the
information collected through the Data Collection Module and DCTs, FAA staff
determine whether changes to a CH’s configuration (e.g. equipment at a repair
station; number of seats on an airplane) are necessary and/or whether additional
planning, resource management, and data collection is necessary for further
assessment.

External Portal
System Access
The External Portal is a web-based application, https://sas.faa.gov that allows CH/As to:
apply for an initial certificate application; amend an existing certificate; and interact with
their local FSDO.
A typical transaction for the external portal begins when an applicant starts the Initial
Certification process. To do so, the applicant must register for an SAS account on the
external portal website. The applicant requests an SAS account by providing his or her
first name, last name and email address. After submitting this information, a confirmation
screen states that the request for a SAS User ID has been submitted. The registration
information is sent securely to the FAA Point of Contact (POC) at the local FSDO via
hypertext transfer protocol secure (HTTPS). CH/As then receive an automated email with
a link to the webpage where they will choose a submission option (e.g. new certificate
applicant; existing certificate holder) and continue the SAS External Portal registration
process. This link is only valid for 24 hours. The link takes users to a Pre-Application
Information Submission Page.
System Functionality
Once within the External Portal, the CH/A can continue with their certification request.
At the Pre-Application Information Submission page, users manually provide the

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following information: Company Name; FSDO (which is located by using the FAA
FSDO website); First Name, Middle Initial, Last Name; Title; Address, City, State, Zip
Code, Country; Phone Number, and Email Address. On a subsequent screen, users select
a radio button for the CFR regulation applicable to their business activity (14 CFR Part
121, 135, or 145). On this screen, users may also add the following contact information
for the principle base where their operations will be conducted (as opposed to their
company/individual address which was previously provided): Address, City, State, Zip
Code, Country. The next Pre-Application Information screen calls for: the proposed startup date, a self-selected three-letter identifier, and management personnel (First Name,
Middle Initial, Last Name; Title, and Phone Number). The next screen provides radio
buttons for CH/As to select the proposed type of operation (e.g. Part 135 Air Operators,
Air Carrier Certificate, Passengers and Cargo, Cargo Only, Scheduled or Non-Scheduled
Operations, Single-Pilot Operator, Pilot-in-Command Operator). The following screen
requests information regarding the applicable equipment or aircraft (e.g.
make/model/series, seats, payload, and an open-text field for geographic area of intended
operations.6
The subsequent screen allows users to upload the FAA Form 8400-6 Pre-Application
Statement of Intent (PASI)7 form (described below) and any additional forms required for
certification and compliance. A user enters his or her name, title, and date of submission
on this screen as well as additional comments which may be entered in an open text field.
After the Pre-Application Information has been submitted, the users will receive an
automated email confirming receipt of the information.
Finally, the external users sets up his or her user account and receives an SAS User ID.
New external users receive automated emails from the FAA Provisioning Portal
containing: a link to log in to the Provisioning Portal; a User ID; and a temporary log in
password. Users then log in to the Provisioning Portal with a User ID and password;
complete security questions; and, replace the temporary password with a permanent
password. Users then receive an account registration confirmation message. New
External Portal users are added to the FAA EXC Active Directory Domain and
authenticate via User ID and password.
If they have not already done so via the manual upload process, new SAS users then
complete the PASI form electronically through the SAS external portal. PASI forms may
also be found online, printed, and submitted in hard copy to the local FSDO POC. The
local FSDO uses the FAA Form 8400-6 to assess the size and scope of the proposed
operation, and to contact the applicant. The FAA Form 8400-6 collects the following:
name and the mailing address of the company/organization; address of principal base
where operations will be conducted; doing business as (DBA) name; a listing of
management personal (first, middle, last name; title; telephone number; and email
address); any additional information that provides a better understanding of the proposed
operation or business; signature, name and title of the individual providing signature; and

6

The Pre Application Submission Pages contain no PAS. The Program is currently updating the submission pages to
include a PAS.
7
FAA 8400-6, OMB 2120-0593, Expiration 4/30/2018.

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the name of the FDSO employee who received the application. SAS users provide this
information on the site itself as well as a physical form for signature.
After users have been approved for an SAS account they have full user access to the
External Portal. Users then sign in to the External Portal using their SAS ID. They are
then taken to the External Portal homes screen which contains a menu with the following
options: Pre-application Information (discussed above); Certification Request;
Configuration (which contains options for Configuration Data, Operating Profile and
Repair Station Form 8310-3); Schedule of Events; Data Collection Tools; and Document
Management.
•

•

Certification Request
The Certification Request tab allows applicants to review their Applicant Information
and Certification Information which they previously submitted during the preapplication phase. Applicants may also review the status of their application. It
contains the following information: Designator Code8; Applicant Name; SAS ID;
FSDO; FAA Precertification Number9; Proposed Type of Operation; Date of
Proposed Start-up; Certification Status; Last Updated by (SAS System or User); Date
and Time of Last Update; Applicant POC’s Name, Email Address, Phone Number,
Address, City, State, and Country.
Configuration
o Configuration Data
Each certificate has a configuration which describes the proposed operations
and/or specifications of the certificate holder. CH’s can change their
configuration in the SAS external portal and submit the proposed changes to
their FSDO for approval. This process is known as a Change Request.
Configuration includes basic information for the following categories:
 Operations specifications (e.g. number of company’s Boeing 737s,
number of seats on a company’s particular airplane, etc.): documents how
certificate holder operations are conducted. May include items, such as
fleet composition, route structure, and operations specifications
o If applicable, may also include repair station proposed ratings and
capabilities.
 Vitals: information about the company's base of operations and senior
management, its route structure, fleet type, fleet size, domestic versus
international operations, etc.
 Contractors: contact information and background information for service
providers that the company contracts with.
o Operating Profile
The Operating Profile, also known as the Certificate Holder’s Operating
Profile (CHOP), is a tailored list of systems/subsystems, elements, and
questions that are applicable to a certificate holder’s or applicant’s scope of
operation. SAS users create the Operating Profile (OP) in the external portal,
based on the list of the functions that a CH/A performs, as well as applicable

8

The ‘Designator Code’ is the first 4 characters in a user’s operator certificate number issued by the FAA.
The ‘Precertification Number’ is the temporary designation of an applicant who has stated intent to apply for an
FAA certificate.

9

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regulatory requirements, hazards analysis, configuration information, and
performance history. Based on the OP, the FAA can then plan and provide
resource assessments tailored to the CH/A. The OP contains information
about the applicant, such as personnel policies, procedures manuals, quality
control, training and technical data, its record system, housing and facilities,
tools and equipment, and parts and materials. This information is used to help
determine safety risks. The OP also contains the list of assessments the FAA
conducts as a part of the oversight of the CH/A.
o Repair Station Form 8310-3
Repair Station Form 8310-3 is the application for an aviation repair station to
become an authorized Part 145 Repair Station. It allows the FAA to evaluate
the complexity of the proposed operation; establish a certification team based
on the complexity of the certification; and, helps ensure that programs,
systems, and intended methods of compliance are thoroughly reviewed,
evaluated, and tested. The 8310-3 form includes name, title, and authorization
signature, which certifies the individual is authorized by the repair station to
make the application, as well as the FAA Safety Inspector’s name, title and
signature. The owner of the repair station applying for a certificate (or an
individual authorized by the owner) fills out the form using the SAS External
Portal or through a hard copy submission. The FSDO uses the information
provided through Form 8310-3 during the repair station certification process.
o Data Collection Tools (DCTs)
CH/As use the SAS External Portal to perform DCTs by selecting the Data Collection
Tools option in the SAS home screen menu. The DCT screen provides the following
option tabs: Select DCT; Prepare DCT; Enter Common Data Fields; Perform DCT;
Check DCT; and Submit DCT. The Select DCT screen displays all of the DCTs that
are available. The Prepare DCT tab contains information on the DCT a user has
chosen to perform such as relevant regulations, policy and guidance. The Enter
Common Data Fields tab contains fields for: start and end date of the DCT; an open
text field for the location of the nearest airfield; a checkbox indicating “If work is
offsite of the airfield, include one of the following”; radio buttons to select “address”
or “longitude/latitude”. Depending on the radio button selected, a user may enter
information into open text fields to indicate an address (address, city, state, zip code,
country) or longitude and latitude. The Perform DCT tab contains two tabs. The first
tab is a list of questions from the DCT the user has chosen to perform. The second tab
identifies additional information for the particular question to be answered (e.g. radio
buttons to answer specifics about the question; attach supporting documents; an open
text field for additional comments). The second tab will vary depending on the
question and DCT selected. The Check DCT tab is used to ensure that all required
information has been provided by identifying unfinished questions and questions that
require additional information. It displays the number of questions completed and
icons on specific questions indicating that a question has been left blank or requires
additional information. A DCT with missing or incomplete information will not
appear on the final, Submit DCT tab – only a DCT that includes all required
information will appear in the tab. Once all information has been entered, the DCT
may be submitted using the Submit tab.

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o The Schedule of event tab provides a checklist of events; drop down menus
indicating the status of the event; and fields to select proposed, current, accepted
baseline (i.e. accepted date), and completion dates using electronic calendars.
Each event also contains an open text field for user comments.
o The Document Management button allows users to submit supporting
documentation to FAA.10 Document Management contains folders for: Formal
Application, Other Certification, Configuration Changes, and Data Collection.
The Formal Application folder allows CH/As to upload documents for the formal
application. Users cannot submit required documents for review until all required
documents have been uploaded. The Other Certification folder allows users to
upload supporting documents that they believe are applicable to their application
but are not listed in the Formal Application folder. The Configuration and Data
Collection folders are automatically updated when users upload documents in the
SAS External Portal Configuration and Data Collection pages. When uploading
documents, users are provided open text fields to describe the version of the
document being entered as well as additional comments.
Internal Portal
The internal portal is a web-based application that helps aviation Safety Inspectors perform
safety oversight by: providing tools for planning and scheduling, helping to identify hazards
within an environment, and helping to eliminate or control risk. All modules in the internal portal
are used for both initial certification and COS. Safety Inspectors perform Design Assessments11
(DAs) and Performance Assessments (PAs) based on system safety principles and enter all
information collected via the DCT into SAS. The Internal Portal is only accessible on the FAA
internal network to authorized FAA employees and contractors. An FAA AVS Manager must
approve the FAA user’s access to the system. Internal Portal users are authenticated by PIV
identification. Authorized FAA Federal and Contract workforce employees access the SAS
internal portal system at sas.avs.faa.gov.
The internal portal web site contains five interactive panes: a main Home/Links pane; a
Notifications pane; a Messages pane; a Broadcasts pane and an Individual Work Plan (IWP)
plane. The How/Links pane contains web links for the Safety Performance and Analysis System
(SPAS); the Flight Standards Information Management System (FSIMS); WebOPPS; the SAS
Resource Guide; the SAS Assistance Feedback or Enhancement (SAFE); News &
Documentation; Release Notes; Historical Broadcast Messages; How to Use DCTs; and the
Geographic Airport Data Display (GeoADD).
•

Home/Links
In addition to the Useful Links detailed above, the Home/Links pane contains a fly out
window that contains links Inspectors use at each phase of the CH/A process. The menu
has links for: Individual Work Plans; Certification Projects; Configuration (Module 1);

10
The supporting documents should not contain PII information, but there’s always a possibility that an inspector
could inadvertently upload a document that contains PII data. Again, in the infrequent cases where PII is
inadvertently submitted, program staff redact the PII.
11
An assessment is the scheduled and executed work package for assessing a single system, subsystem, or element’s
design or performance with regard to safety. Evaluation allows for compliance with FAA regulations and safety
standards.

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•

•

•
•

Planning (Module 2); Resource Management (Module 3); Data Collection (Module 4);
Reports (detailed in Appendix A); and Create DCTs.
Notifications Pane
The Notifications pane allows applicants and certificate holders to communicate with
Inspectors using text messages. Notifications may include limited PII included at the
sender’s discretion.
Messages Pane
Messages can be used to announce action items or to share supporting certification
documents. Messages include a free-form text field in which additional information could
be entered.
Broadcast Pane
The broadcast pane is used to convey official messages to Internal Portal users.
IWP Pane
The IWP pane links to an inspectors’ IWPs. It provides a drop down menu which allows
users to select an IWP and smaller panes detailing action items, DCTs, configuration
management, and the status of each.

A typical transaction for the Internal Portal begins when a certificate holder submits a change
request of configuration data through the External Portal. The Certification Project Team,
including the Principal Inspector (PI), reviews the submission with the requested changes;
reviews the regulatory requirements, FAA’s policy and guidance for the process; verifies the
questions were answered correctly; and determines if the changes in the process design meet the
requirements for approval and acceptance. This review process allows the certificate holder and
FAA to see how the proposed changes will impact the certificate holder's operating profile and
Comprehensive Assessment Plan (CAP).12 Once a change is approved, the certificate holder's
operating profile and CAP are regenerated to reflect the new information.
SAS Data Exchanges
The SAS exchanges data with the following DOT/FAA internal systems (see Section 2.10 below
for details):
Federal Digital System (FDsys)13,, FAA Directory Services14, FAA.gov, a component of the
FAA Directory Services system (FAA DS)15,SIESS16, Web Operations Safety System
(WebOPSS)17, Comprehensive Airmen Information System (CAIS) - a component of the Civil
Aviation Registry Applications (AVS Registry)18, Aircraft Registration System (ARS) - a
component of the AVS Registry19, Enforcement Information System (EIS)20, Flight Standards

12

The CAP is a quarterly plan developed by inspectors and their managers to plan and schedule oversight activities.
FDsys is a system offered by the U.S. Government Printing Office (GPO). PTA information is not available.
14
The FAA Directory Services PTA is currently under development.
15
The FAA DS PTA update is currently under development.
16
The AIT Networks PTA was adjudicated by the DOT Chief Privacy Officer on 12/29/2015.
17
The WebOPSS PTA update is currently under development.
18
The AVS Registry PTA update is currently under review with the DOT Chief Privacy Officer.
19
See footnote 11.
20
The EIS PTA was adjudicated by the DOT Chief Privacy Officer on 2/6/2017.
13

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Information Management System (FSIMS)21, Safety Performance Analysis System (SPAS)22,
and Enhanced Flight Standards Automation System (eFSAS)23.

2 INFORMATION MANGEMENT
2.1

SUBJECTS of Collection
Identify the subject population(s) for whom the system collects, maintains, or
disseminates PII. (Check all that apply)
☒ Members of the public:

☒ Citizens or Legal Permanent Residents (LPR)
☐ Visitors
☒ Members of the DOT Federal workforce
☒ Members of the DOT Contract workforce

2.2

☐ System Does Not Collect PII. If the system does not collect PII, proceed directly
to question 2.3.

What INFORMATION ABOUT INDIVIDUALS will be collected, used, retained, or
generated?
Members of the Public (airmen, air carriers and commuter airlines, repair stations or
other business entities):
• Name
• Email Address
• Company Name
• Title
• Employee Position
• Address
• Telephone Number
• User ID
• DCT ID
• District Office
• Regional FAA AVS office
• Region
• Signature
• Doing Business As (DBA) Name
• Longitude/Latitude of Nearest Airfield
• FAA Precertification Number
21

The FSIMS PTA was adjudicated by the DOT Chief Privacy Officer on 10/1/2015.
The SPAS PTA update is currently under development.
23
The eFSAS PTA update is currently under review with the DOT Chief Privacy Officer.
22

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•
•
•

•
•
•
•
•

Airman Certificate Number and Type
FAA Tracking Number (FTN)24
Aircraft Registration Data
o Aircraft Registration Number
o Aircraft Make/Model/Serial Number
o Aircraft Manufacturer
o Engine Manufacturer/Model
o Aircraft Owner Name and Address
EIS ID (Enforcement Investigative Report – EIR Number)
Certificate Information (Certificate Number, Certificate Date, Certificate Status,
Certificate Designator Code)
IP Address
Documents Uploaded as Attachments in SAS
Free-Form Text Fields

Members of the DOT Federal and Contract Workforce
• Name
• Telephone Number
• Email Address
• Signature
• Title
• Regional FAA AVS office
• Region
• District Office
• DCT ID
• Free-Form Text Field
2.3

Does the system RELATE to or provide information about individuals?
☒ Yes:
The system collects information pertaining to certificate holders, certificate applicants,
and organizations involved in aviation surveillance activities (described above in the
System Overview). The system also collects information pertaining to FAA employees
tasked with inspection, certification, and/or management of inspection and certification
(also described above in the System Overview). SAS maintains audit logs for its IIS
server which contains no PII and a Database Audit Log which contains the PII saved in
the SAS database (described above).
☐ No

24

The FTN (FAA Tracking Number) is assigned to airmen by the FAA after they complete their registration in
IACRA. IACRA processes applications for airman certification via the web. IACRA interfaces with multiple FAA
national databases to validate data and verify specific fields. IACRA automatically ensures applicants meet
regulatory and policy requirements through business rules and data validation. It implements the use of digital
signatures throughout the certification process. IACRA automatically forwards an Airman Certificate and/or Rating
Application, FAA Form 8710-10, application and test results to the Airman Registry. SAS receives this information
from the Airman Registry.

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If the answer to 2.1 is “System Does Not Collect PII” and the answer to 2.3 is “No”,
you may proceed to question 2.10.
If the system collects PII or relate to individual in any way, proceed to question 2.4.
2.4

Does the system use or collect SOCIAL SECURITY NUMBERS (SSNs)? (This includes
truncated SSNs)
☐ Yes:
Authority:
Purpose:

2.5

☒ No: The system does not use or collect SSNs, including truncated SSNs. Proceed
to 2.6.

Has an SSN REDUCTION plan been established for the system?
☐ Yes:
☐ No:

2.6

Does the system collect PSEUDO-SSNs?
☒ Yes:
• The system collects Airman Certificate Numbers which is some cases, may be the
airman’s SSN. For their convenience, some airmen have kept their Social Security
Number (SSN) as their certificate number. The Civil Aviation Registry
discontinued the practice of using the SSN as a certificate number for original or
new certificates in June of 2002. The Civil Aviation Registry web site provides
instructions for requesting a new certificate that does not include the SSN. The
airman can complete the request online or mail a completed AC Form 8060-67
(10/09), Request for Change of Certificate Number to the Airmen Certification
Branch, AFS-760.
☐ No: The system does not collect pseudo-SSNs, including truncated SSNs.

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2.7

Will information about individuals be retrieved or accessed by a UNIQUE
IDENTIFIER associated with or assigned to an individual?
☒ Yes
Is there an existing Privacy Act System of Records notice (SORN) for the
records retrieved or accessed by a unique identifier?
☒ Yes:
SORN: DOT/FAA 801, Aircraft Registration System, April 11, 2000 65 FR
19518
SORN: DOT/FAA 847, Aviation Records on Individuals, November 9, 2010 75
FR 68849
SORN: DOT/ALL 13, Internet/Intranet Activity and Access Records, May 7, 2002
67 FR 30757
☐ No:
Explanation:
Expected Publication:

2.8

☐ Not Applicable: Proceed to question 2.9

Has a Privacy Act EXEMPTION RULE been published in support of any
Exemptions claimed in the SORN?
☒ Yes
Exemption Rule:
DOT/FAA 847, Aviation Records on Individuals, November 9, 2010 75 FR
68849. Records in this system that relate to administrative actions and legal
enforcement actions are exempted from certain access and disclosure
requirements of the Privacy Act of 1974, pursuant to 5 U.S.C. 552a(k)(2).
☐ No
Explanation:
Expected Publication:

2.9

☐ Not Applicable: SORN does not claim Privacy Act exemptions.

Has a PRIVACY IMPACT ASSESSMENT (PIA) been published for this system?
☐ Yes:
☒ No:

2.10

☐ Not Applicable: The most recently adjudicated PTA indicated no PIA was
required for this system.

Does the system EXCHANGE (receive and/or send) DATA from another INTERNAL
(DOT) or EXTERNAL (non-DOT) system or business activity?
☒ Yes:

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Internal (DOT) Interconnections:
• Federal Digital System (FDsys): FDsys is a system offered by the U.S.
Government Printing Office (GPO) that provides free online access to official
publications from all three branches of the Federal Government. SAS uses FDsys
as the statement of record regarding Title 14 Code of Federal Regulations Parts
121, 135, and 145 covering Air Carrier Certifications, Air Operator Certifications,
and Air Agency Certifications. SAS program staff pull CFR data manually on an
ad-hoc basis in an XML format from the FDsys website. There is no PII obtained
through this exchange and as such there is no applicable SORN. There is no
Memorandum of Understanding (MOU) for this exchange since the information is
publicly available and obtained manually from a public website. FAA Directory
Services – FAA Directory Services is a general services system which provides an
authentication source for FAA users. Non-DOT users accessing the SAS External
Portal are added to the EXC domain (part of FAA Directory Services) and
authenticate via unique user ID and password. Once approved by their local
FSDO Non-DOT users are added to the external FAA EXC Active Directory
Domain and authenticate to the system via unique user ID and password. SORN
coverage is DOT/FAA 847 Aviation Records on Individuals, November 9, 2010
75 FR 68849.
SIESS: SAS has a one-way incoming interconnection with SIESS via Structured
Query Language (SQL) server replication. SIESS maintains information on the
capabilities and sponsors of over 1,000 simulators located in the U.S. and
overseas. SIESS also contains results of the regularly scheduled evaluations of
these simulators by the National Simulator Team. SIESS sends the following data
elements to SAS on a weekly basis: Simulator ID, as well as the type of aircraft
that the training data supports and simulator location. SAS uses SIESS data to
assist in assessing CH’s aircraft. No PII data is processed or exchanged during
this interconnection and therefore no SORN coverage or MOU are required.
WebOPSS: SAS has a one-way interconnection with WebOPSS via SQL server
replication. Data received from WebOPSS enables SAS to produce a certificate
holder operating profile (CHOP) for each CH/A. SORN coverage is DOT/FAA
847 Aviation Records on Individuals, November 9, 2010 75 FR 68849, and
DOT/FAA 801, Aircraft Registration System, April 11, 2000 65 FR 19518. A
MOU for this sharing is required but not been completed. The SO has been
advised of the requirement. A POA&M should be created the missing MOU.
WebOPSS sends the following data elements to SAS:

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

CH/As Operator information (Operation Specifications paragraphs), Areas
of Operation, type of operation (passenger and/or cargo), Airport Data
(Airport ID and Location), Deviations and Exemptions and aircraft
listings, types of aircraft, number of aircraft; date, status, Certificate
Holding District Office, types of aircraft, and number of aircraft.

•

PII data received from WebOPSS includes: Inspector ID, Certificate ID,
Certificate Holder Name, and Aircraft ID.

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•

AR: SAS has a one-way interconnection with AR via SQL server replication on a
real-time basis. The AR system contains information about registered aircraft and
the registered owners of those aircraft. The AR system sends the following data
elements to SAS: Aircraft Registration, Aircraft Make/Model/Serial Number,
Aircraft Manufacturer, Engine Manufacturer/Model, Aircraft Owner Name and
Address.25 SORN coverage is DOT/FAA 801, Aircraft Registration System, April
11, 2000 65 FR 19518. A MOU for this sharing is required but not been
completed. The SO has been advised of the requirement. A POA&M should be
created the missing MOU.

•

EIS: SAS has a one-way incoming interconnection with EIS via SQL remotestored procedure. EIS is the source for Enforcement Investigative Report (EIR)
numbers required by SAS; it is the primary key and the associated number to an
enforcement case, not to an individual. EIS provides the following data elements
to SAS: EIS ID (Enforcement Investigative Report – EIR Number), Designator,
and Status. SAS uses this information to assist in tracking whether CH/As have
any enforcement actions against them.26 SORN coverage is DOT/FAA 847
Aviation Records on Individuals, November 9, 2010 75 FR 68849. A MOU for
this sharing is required but not been completed. The SO has been advised of the
requirement. A POA&M should be created the missing MOU.

•

FAA.gov: SAS has a one-way https interconnection with the FAA.gov web
service. Regulations and Policy website contains advisories and guidance, forms,
FAA regulations, handbooks and manuals, orders and notices, policy and
guidance, reauthorizations and regulatory documents. This is public information
and does not contain any PII data elements and therefore no SORN coverage is
required and no MOU is required. SAS automatically pulls Advisory Circulars
from this site via a public web service.27
FSIMS: SAS has a two-way interconnection with FSIMS to exchange aviation
certification and safety information, specifically regarding FAA Order 8900.1.
The outgoing information from SAS to FSIMS is sent via File Transfer Protocol
(FTP). The incoming information from FSIMS to SAS is database replication of
FAA Order 8900.1 to inform inspection duties. SAS sends DCTs to the FSIMS
Librarian via FTP to manually upload into FSIMS. No PII data is processed or
exchanged during this interconnection and therefore no SORN coverage or MOU
is required.28
SPAS: The SPAS provides users the ability to search for and view information
regarding aviation safety trends. SAS provides inspection data on CHs for SPAS
via a one-way interconnection to SPAS through database replication. SPAS uses

•

•

25

The AR PTA, dated September 2011, does not state that there is an interconnection between AR and the SAS. In
addition, the AR System Characterization Document dated December 2017 does not indicate that there is an
interconnection between AR and the SAS.
26
The EIS PTA, adjudicated February 2017, does not state that there is an interconnection between EIS and the
SAS.
27
The FAA.gov System Characterization Document dated October 2017 does not indicate that there is an
interconnection between FAA.gov and the SAS.
28
The FSIMS PTA, adjudicated October 2015, does not state that there is an interconnection between FSIMS and
the SAS.

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•

SAS inspection data to help assess safety concerns arising from CHs. SAS exports
all SAS database fields populated by SAS users into SPAS. This includes the PII
data elements listed in Section 2.2. The SAS Internal Portal also contains a link to
SPAS. SORN coverage is DOT/FAA 847 Aviation Records on Individuals,
November 9, 2010 75 FR 68849, and DOT/FAA 801, Aircraft Registration
System, April 11, 2000 65 FR 19518. A MOU for this sharing is required but not
been completed. The SO has been advised of the requirement. A POA&M should
be created the missing MOU.
eFSAS: eFSAS provides aviation safety inspection reports and information. SAS
has a two-way interconnection via a remote procedure call with eFSAS, to
exchange configuration information about CHs. CFR Parts 121, 121/135, 135 and
145 configuration data is replicated to SAS. Users can update the CH
configuration information in SAS with changes being sent to eFSAS via a web
service. This includes the PII data elements listed in Section 2.2. eFSAS data is
replicated to SAS in order to ensure that the two databases’ information regarding
CHs is identical.29 SORN coverage is DOT/FAA 847 Aviation Records on
Individuals, November 9, 2010 75 FR 68849, and DOT/FAA 801, Aircraft
Registration System, April 11, 2000 65 FR 19518. A MOU for this sharing is
required but not been completed. The SO has been advised of the requirement. A
POA&M should be created the missing MOU.

☐ No
2.11

Does the system have a National Archives and Records Administration (NARA)approved RECORDS DISPOSITION schedule for system records?
☐ Yes:
Schedule Identifier:
Schedule Summary:
☒ In Progress:
On November 21, 2017 the AVS Records Officer advised that Big Bucket Schedule,
DAA-0237-2016-0012-0017, has been proposed to NARA but has not yet been approved.
☐ No:

29

The eFSAS PTA, dated December 2009, does not state that there is an interconnection between eFSAS and the
SAS. In addition, the eFSAS System Characterization Document dated May 2017 does not indicate that there is an
interconnection between eFSAS and the SAS.

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3 SYSTEM LIFECYCLE
The systems development life cycle (SDLC) is a process for planning, creating,
testing, and deploying an information system. Privacy risk can change depending on
where a system is in its lifecycle.

3.1

Was this system IN PLACE in an ELECTRONIC FORMAT prior to 2002?

3.2

The E-Government Act of 2002 (EGov) establishes criteria for the types of systems
that require additional privacy considerations. It applies to systems established in
2002 or later, or existing systems that were modified after 2002.
☐ Yes: Provide date was the system established as an electronic system.
☒ No: SAS began operation in June 2014.
☐Not Applicable: System is not currently an electronic system. Proceed to Section
4.
Has the system been MODIFIED in any way since 2002?
☒ Yes: The system has been modified since 2002.
☒ Maintenance.
☒ Security.
☐ Changes Creating Privacy Risk:

☒ Other:
• The Standard Reference Table (SRT) was moved from the SAS system boundary
to the AVS SOA-I system boundary in April 2016. The SRT consists of a list of
airports, county codes, and state zip codes; the SRT does not include PII data.
3.3

☐ No: The system has not been modified in any way since 2002.
Is the system a CONTRACTOR-owned or -managed system?
☐ Yes: The system is owned or managed under contract.
Contract Number:
Contractor:

3.4

☒ No: The system is owned and managed by Federal employees.
Has a system Security Risk CATEGORIZATION been completed?

The DOT Privacy Risk Management policy requires that all PII be protected using
controls consistent with Federal Information Processing Standard Publication 199
(FIPS 199) moderate confidentiality standards. The OA Privacy Officer should be
engaged in the risk determination process and take data types into account.
☒ Yes: A risk categorization has been completed.

Based on the risk level definitions and classifications provided above, indicate
the information categorization determinations for each of the following:

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Confidentiality:
Integrity:
Availability:

☐ Low

☒ Moderate

☐ High

☐ Undefined

☒ Low

☐ Moderate

☐ High

☐ Undefined

☐ Low

☒ Moderate

☐ High

☐ Undefined

Based on the risk level definitions and classifications provided above, indicate
the information system categorization determinations for each of the following:
Confidentiality:
Integrity:
Availability:

3.5

☐ Low

☒ Moderate

☐ High

☐ Undefined

☐ Low

☐ Moderate

☒ High

☐ Undefined

☐ Low

☒ Moderate

☐ High

☐ Undefined

☐ No: A risk categorization has not been completed. Provide date of anticipated
completion.
Has the system been issued an AUTHORITY TO OPERATE?
☒ Yes:

Date of Initial Authority to Operate (ATO): 3/24/2017
Anticipated Date of Updated ATO: 3/24/2020
☐ No:
☐ Not Applicable: System is not covered by the Federal Information Security Act
(FISMA).

4 COMPONENT PRIVACY OFFICER ANALYSIS

The Component Privacy Officer (PO) is responsible for ensuring that the PTA is as complete
and accurate as possible before submitting to the DOT Privacy Office for review and
adjudication.
COMPONENT PRIVACY OFFICER CONTACT Information
Name: Barbara Stance

Email: Barbara.stance@faa.gov

Phone Number: 202-267-1403

COMPONENT PRIVACY OFFICER Analysis
Privacy risks exist in the Safety Assurance System (SAS) because the subjects of the PII
collection in the system are Members of the Public and Members for the DOT Federal
and Contract workforce. Such risks are mitigated by the implementation of
administrative, technical and physical security measures which include restrictions on
access to information by authorized individuals, use of userID and passwords and/or PIV,
reviews of security and access logs to determine anomalous activity, and regular reviews
of security procedures and best practices to enhance security. FAA employees and
contractors are additionally required to complete annual privacy and security training.

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A risk exists because the FAA does not currently have an approved ICR that will be
expiring for the current collection of the information. The program office is working with
the PRA office to update and mitigate this risk. A risk also exists because the FAA may
inadvertently receive PII information in supporting documents that was not requested.
This risk is mitigated by program staff who redact the PII if not needed. There is a risk
that the information collected could be used for unauthorized purposes that are
inconsistent with the original purpose of collection. This risk is mitigated because the
FAA is required to protect and use data in accordance with the policies, standards, and
specified regulations. There is risk that the information being shared may not be covered
by a current sharing agreement. This risk is mitigated by FAA working with system
owners to ensure that a MOU or access agreement is executed if required. A risk exists
relative to non-completed and adjudicated privacy plan documents; this risk is being
mitigated by working with the SO’s to complete the required documentation.
The records are covered under: DOT/FAA 801, Aircraft Registration System, April 11,
2000 65 FR 19518 and SORN: DOT/FAA 847, Aviation Records on Individuals,
November 9, 2010 75 FR 68849. Activity and Access records are covered under
DOT/ALL 13, Internet/Intranet Activity and Access Records, May 7, 2002 67 FR 30757.
Records are additionally maintained in accordance with a Big Bucket Schedule, DAA0237-2016-0012-0017, that has been proposed to NARA but has not yet been approved.
COMPONENT PRIVACY OFFICER Analysis

5 COMPONENT REVIEW
Prior to submitting the PTA for adjudication, it is critical that the oversight offices within
the Component have reviewed the PTA for completeness, comprehension and accuracy.
Component Reviewer

Business Owner

General Counsel

Information System
Security Manager (ISSM)
Privacy Officer

Records Officer

Name

Review Date

John Frye

2/6/2018

None

4/6/18

Barbara Stance

3/15/18

Kelly Batherwich

2/6/18

Michael McKinley

None

/Table 1 - Individuals who have reviewed the PTA and attest to its completeness, comprehension and accuracy.

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TO BE COMPLETED BY THE DOT PRIVACY OFFICE
Adjudication Review COMPLETED: April 16, 2018
DOT Privacy Office REVIEWER: Claire W. Barrett
DESIGNATION
This is NOT a Privacy Sensitive System – the system contains no Personally
Identifiable Information.
This IS a Privacy Sensitive System
IT System.
National Security System.
Legacy System.
HR System.
Rule.
Other: Aviation Safety Non-NAS
DETERMINATION
PTA is sufficient at this time.
Privacy compliance documentation determination in progress.
PIA

PIA is not required at this time: Please see adjudication statement.
PIA is required.
System covered by existing PIA: <>
New PIA is required. Leverages new IT to collect information about
individuals
PIA update is required. <>
SORN

SORN not required at this time. System does not collect information in
identifiable form.
SORN is required.
System covered by existing SORN: DOT/FAA 801, Aircraft Registration
System, April 11, 2000 65 FR 19518 and
New SORN is required. <>
SORN update is required. DOT/FAA 847, Aviation Records on Individuals,
November 9, 2010 75 FR 68849 – Exemption information not complete,
Exemption rule not published for

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DOT CHIEF PRIVACY OFFICER COMMENTS
The DOT Privacy Officer (DOT PO) has determined that the Safety Assurance System
(SAS)collects personally identifiable information (PII) on individuals and constitutes a privacy
sensitive system. T
The System was developed after to implementation of the E-Government Act and a Privacy
Impact Assessment (PIA) is required before, “developing or procuring IT systems or projects
that collect, maintain or disseminate information in identifiable form from or about members of
the public.” See “OMB Guidance for Implementing the Privacy Provisions of the E-Government
Act of 2002” (M-03-22) Within 30 days of the PTA adjudication a PIA must be submitted for
approval by the DOT CPO. If a PIA is not received by that date the DOT CPO may recommend
to the Senior Agency Official for Privacy (SAOP) that the system be removed from operational
status until the system has a fully approved privacy plan. The FAA is recommended to establish
a Plan of Actions and Milestones (POA&M) for control AR-2/Privacy Impact and Risk
Assessment.
Information in the system is retrieved by personal identifier and meets the standard for a system
of records as defined by the Privacy Act. The appropriate system of record notices (SORNs) for
records related to the primary purpose of the system are DOT/FAA 801, Aircraft Registration
System, April 11, 2000 65 FR 19518 and DOT/FAA 847, Aviation Records on Individuals,
November 9, 2010 75 FR 68849. Portions of the records by DOT/FAA 847 may be exempt from
portions of the Privacy Act – exemptions for the system have been codified in the DOT
Regulations at 49 CFR Part 10, however the DOT CPO does not have evidence of proper
rulemaking in support of this activity. In addition, the DOT/FAA 847 notice does not accurately
describe the Exemptions claimed for the system. Within 90 days of the PTA adjudication an
updated SORN and Exemption Rule must be submitted for approval by the DOT CPO. If the
SORN and accompanying Exemption Rule are not received by that date the DOT CPO may
recommend to the SAOP that the system be removed from operational status until the system has
a fully approved privacy plan. The SORN and the Exemption Rule should follow the
requirements established in OMB A-108, Federal Agency Responsibilities for Review,
Reporting, and Publication. The FAA is recommended to establish a Plan of Actions and
Milestones (POA&M) for controls TR-1/Privacy Notice and TR-2/System of Records Notices
and Privacy Act Statements
NOTE: The appropriate system of records notice (SORN) for records related to technical access
and administration of the system is DOT/ALL 13 - Internet/Intranet Activity and Access Records
- 67 FR 30757 - May 7, 2002.
The DOT Privacy Risk Management Policy requires all authorized internal sharing of PII be
documented via a Memorandum of Understanding (MOU) or other approved instrument that
articulates the conditions of access and use. The FAA identified multiple instances where
agreement on limited use consistent with applicable SORN or other notice given to individuals
has not be executed. The FAA is recommended to establish a POA&M for control UL-1/Internal
Use for each of the sharing listed in the PTA.
The FAA has asserted that it intends to apply a big-bucket schedule to records maintained in the
system. However, the FAA has not provided support that the schedule was coordinated with the
privacy program to ensure that proposed retention of records protected under the Privacy Act is

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consistent with published notices. Within 30 days of the PTA adjudication a copy of the
schedule submitted to NARA for approval and an accompanying privacy analysis for the Privacy
Act records covered by the proposed schedule should be provided to the DOT CPO . If the
Requested information is not received by that date the DOT CPO may recommend to the SAOP
that the system be removed from operational status until the system has a fully approved privacy
plan. In addition, the DOT CPO may request the Senior Agency Official for Records
Management (SAORM) recall the pending schedule from NARA until agreement on limited
retention is reached. Additionally, the SAS replaces functionality of a previously existing
system ATOS/SAS – it is unclear why the records schedule covering that system has not been
directly applied to this system. The FAA is recommended to establish a POA&M for controls
DM-2/Data Retention and Disposal and SI-12/Information Handling and Retention.
NOTE: In its 2014 Quality Control Review of Controls Over DOT's Protection of Privacy
Information the DOT Inspector General noted that Departmental IT systems need to improve
“ongoing validation of specific privacy related security controls for their systems are in effect,
including those that safeguard confidentiality, provide secure remote access, encryption of back
up media, follow up of unauthorized mobile devices, and proper user account and password
settings in accordance with DOT policy. ” FAA management is strongly encouraged to review
NIST SP 800-122, Guide to Protecting the Confidentiality of Personally Identifiable Information
(PII) and make an active determination regarding the applicability of the specific security
controls identified in section 4.3 of the same.
The FAA was notified in the ATOS/SAS system disposal assessment (SDA) ATOS/SAS and
that the recipient system SAS required a full privacy risk management plan prior to operations.
The FAA granted the system without conducting a preliminary privacy risk assessment in the
form of the privacy threshold analysis (PTA). The FAA is required to establish a POA&M for
controls CA-1/Security Assessment and Authorization Policy and Procedures and AR1(b)/Governance and Privacy Program (Privacy Plan) until all privacy risk management issues
identified in the adjudication statement are mitigated and approved for closure by the DOT CPO.
The adjudicated PTA should be uploaded into CSAM as evidence that the required privacy
analysis for this system has been completed and CSAM entries modified as appropriate to reflect
the disposition.
The PTA should be updated not later than the next authorization for the information collection (if
applicable), new privacy risk is introduced into the system (such as those described in the note,
above), or the PTA expiration (3 years from the date of adjudication), whichever is soonest, and
must be approved by the DOT CPO prior to any new collection or use of the data.

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Appendix A
SAS Standard Reports
SAS reports allow users to generate reports matching selected criteria. The table below provides
a brief description of each standard report. Reports are protected by role-based access. In
addition, the report rolls are maintained in Tableau, not SAS and the Tableau environment is
only visible inside the FAA. Select a hyperlink from the menu to the left for report samples.
Configuration [Module 1]
The Contractor/Maintenance Provider List
report displays the Maintenance Providers
(including Essential Maintenance Providers)
and Training contractors as entered by 14 CFR
Contractor/Maintenance
part 121 and 121/135 certificate holders as part
Provider List
of Configuration Data under the Contractors
tab. The report contains the following PII:
Business Name; Business Address; Region,
FAA Regional Office.

Operating Profile
Report

The Operating Profile report allows users to
view the Operating Profile of a selected
certificate holder or to search on the set of
certificate holders that have the same functions.
The report contains the following PII: Region,
FAA Regional Office; Business Name.

Pre-application Report

This report lists the status of the PASI form and
pre-application information that has been
submitted to FAA (e.g. date submitted,
accepted). The report contains the following
PII: FAA Regional Office; Business Name,
Name.

Planning [Module 2]

CHAT Report

This report displays details of the Certificate
Holder Assessment Tool (CHAT) records. The
report can be used by inspectors to see the list
of CHAT updates and the related Risk
Indicators that have been selected by a Principal
Inspector for a CH or set of CHs. The report
contains the following PII: FAA Regional
Office; Business Name, Principal Investigator’s
comments.

Resource Management [Module 3]

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Geographic Routing
History Report

This report displays the routing history of
Geographic resource requests (GEOs) through
the lifecycle of the GEO request. The report
contains the following PII: FAA Regional
Office; DCT ID; Name.

Geographic Summary
Report

The Geographic Summary report provides the
total counts of Geographic resource requests by
status type. The report contains the following
PII: FAA Regional Office; Business Name.

Resource Shortfall
Report

The Resource Shortfall report displays the
DCTs that have been assigned with “Resource
Not Available” (RNA) status. The report
contains the following PII: FAA Regional
Office; Business Name; Name.

Data Collection [Module 4]

Count of DCTs by
Status Report

This report provides a graphical representation,
in the form of a bar graph, of the total counts of
DCTs by status. It displays the DCT Status on
the horizontal axis and the total counts by
Specialty (AW/OP) on the vertical axis. This
report contains no PII.

DCT Findings Report

The DCT Findings report is organized by DCT
Title and DCT ID to display all the question
responses by response type (e.g., negative,
positive, N/A, and Not Observable - N/O). The
report contains the following PII: FAA
Regional Office; Business Name; Name; DCT
ID; Additional Comments.

DCT Status Report

This report is designed to help an office track
the status of DCTs for a specified quarter. It
assists in tracking DCTs through all the phases
of the SAS lifecycle. The report contains the
following PII: Business Name; Name;; DCT ID.

8430-13 Report

The 8430-13 report provides office managers
using SAS with a list of the 8430-13 numbers
used by resources in their office. An 8430-13 is
a number on a physical paper form that is part
of a booklet. Inspectors fill the forms out when
performing inspections as part of their job
function. The report contains the following PII:
FAA Regional Office; Business Name; Name;
DCT ID.

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Analysis, Assessment and Action (AAA) [Module 5]
Action Item Tracking
Tool (AITT) Report

The Action Item Tracking Tool (AITT) report
provides actions listed by CH/A, Office, and
Source as submitted and updated by users. The
report contains the following PII: Name

Assessment
Determination and
Actions Report

The Assessment Determination and Actions
report lists all of the assessment determinations
and related actions for CH/As based on the
criteria entered by the user. It displays details
about the determination including the
justification text and details about which actions
(if any) were selected. This report contains the
following PII: FAA Regional Office.

Assessment Findings
Report

The Assessment Findings Report provides the
question response data type (e.g., positive,
negative, N/A, and N/O) by DCT within
assessments. The report contains the following
PII: Name.

User Administration

Roster Report

The Roster report provides details on internal
SAS users. The report contains the following
PII: Name; User ID; Email Address; Telephone
Number; Office; Title; Region.

Proxy Report

The Proxy report provides users with a list of
the proxy assignments based on the search
criteria entered. This report is useful to
understand which users are assigned as a proxy
on the behalf of other users. The report is a twopart report. The first set of data, for single SAS
user record, displays the user(s) that are
assigned as a proxy to that user and in what
roles. The second set of data displays the users
and their respective roles that the user is acting
as a proxy for. The report contains the following
PII: Name; Office; Region.

External User Roster
Report

The External User Roster report provides users
with a list of external users This report is useful
for internal SAS users to quickly find the
contact information for an external contact. The
report contains the following PII: Name; Email
Address; Telephone Number; Business Name;
District Office.

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DOT Privacy Program

FAA/SAS
Privacy Threshold Assessment (PTA)

Audit Reports

Login History Report

The Login History report provides the Security
Auditors with the login history for internal and
external users presented based on the search
criteria entered. The report contains the
following PII: Region, Office, Name.

Unsuccessful Login
Attempt Report

The Unsuccessful Login Attempt report
displays the attempted logins by inactive
internal SAS users and external SAS users. The
data displays inactive internal SAS users that
are on the FAA domain that attempt to login,
active external SAS users that attempt to log in
with an incorrect password, and inactive
external SAS users that attempt to log in. The
report displays the following PII: Region,
Office, Name; User ID; IP Address.

User Account Change
Report

The User Account Change report displays
records of internal and external SAS user
accounts have been enabled, disabled, or
modified. The report displays the following PII:
Region, Office, Name.

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