1625-0079 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

Version number: 04-2016
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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:
Form Title:

N/A
N/A

Component:

U.S. Coast Guard (USCG)

Office:

CG-REG

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Standards of Training, Certification and Watchkeeping for Seafarers
(STCW), 1995, 1997 and 2010 Amendments to the International
Convention
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:
Office:
Phone:

1625-0079
Extension

OMB Expiration
Date:
Date of last PTA (if
applicable):

January 31, 2020
N/A

PROJECT OR PROGRAM MANAGER
Mr. David Du Pont
CG-REG
Title:
Reg Dev Mgr
202-372-1497
Email:
David.A.DuPont@uscg.mil
COMPONENT INFORMATION COLLECTION/FORMS CONTACT
Mr. Anthony Smith
CG-612
Title:
PRA Coordinator
202-475-3532
Email:
Anthony.D.Smith@uscg.mil

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

SPECIFIC IC/Forms PTA QUESTIONS
1. Purpose of the Information Collection or Form
The purpose of this information collection is to ensure compliance with the international
requirements of the Standards of Training, Certification and Watchkeeping for Seafarers
(STCW) Convention, and to maintain an acceptable level of quality in activities associated
with training and assessment of merchant mariners.
There is no form associated with this collection. The information collected includes the
mariner’s name, officer/rating endorsement and Merchant Mariner Credential (MMC)
number, and the instructor/designated examiner’s name, job title, officer/rating
endorsement, MMC number and signature.
The authority for this collection is 46 U.S.C. Chapters 71 and 73.
Records are maintained in accordance with NARA’s retention schedule: NC1-26-76-2 Item
# 406.

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.

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

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.).
☒ 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.
Click here to enter text.

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)
Provide link:

e. What information will DHS collect on the form?
The information collected includes the mariner’s name, officer/rating endorsement and
MMC number, and the instructor/designated examiner’s name, job title, officer/rating
endorsement, MMC number and signature.
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone 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
☐ Known Traveler Number
☐ Visa Number
☐ Trusted Traveler Number (Global
☐ Passport Number
Entry, Pre-Check, etc.)
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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

☐ Bank Account, Credit Card, or other
financial account number
☒ Other. Please list: Merchant Mariner
Credential (MMC) number

☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
46 U.S.C. Chapters 71 and 73.
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 MMC number ensures that mariner training and assessment information is properly
linked to his/her Merchant Seamen’s Record.
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.
The information is provided in association with an
“Application for Merchant Mariner Credential”
(form CG-719B). CG-719B has a Privacy Notice
located at the bottom of the form.
☐ 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 CG credentialing specialist enters information
into the Merchant Mariner Licensing and
Documentation System (MMLD) database.
☐ Scanned forms (completed forms are scanned into
an electronic repository).

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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

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

☒ Manually (data elements manually entered). Please
describe.
The CG credentialing specialist enters information
into the MMLD database.
☐ Automatically. Please describe.

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

☒ By a unique identifier.2 Please describe. If
information is retrieved by personal identifier, please
submit a Privacy Act Statement with this PTA.
A CG credentialing specialist would retrieve
information using the mariner name or MMC
number.
☐ By a non-personal identifier. Please describe.

NARA retention schedule number: NC1-26-76-2 Item #
d. What is the records
406.
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
Records are disposed/deleted in accordance with the
that records are
Agency business rules and the retention schedule.
disposed of or deleted
in accordance with
the retention
schedule?
f. Is any of this information shared outside of the original program/office? If yes,
describe where (other offices or DHS components or external entities) and why.
What are the authorities of the receiving party?
☐ Yes, information is shared with other DHS components or offices. Please describe.
Click here to enter text.
☐ Yes, information is shared external to DHS with other federal agencies, state/local
partners, international partners, or non-governmental entities. Please describe.
Click here to enter text.
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

Version number: 04-2016
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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

☒ No. Information on this form is not shared outside of the collecting office.

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:

A.L. Craig

Date submitted to component Privacy
Office:
Date submitted to DHS Privacy Office:

January 16, 2020

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.)

January 23, 2020
☐ 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 this information collection is to ensure compliance with the international
requirements of the Standards of Training, Certification and Watchkeeping for Seafarers
(STCW) Convention, and to maintain an acceptable level of quality in activities associated
with training and assessment of merchant mariners.
There is no form associated with this collection.
The information collected includes the mariner’s name, officer/rating endorsement and
Merchant Mariner Credential (MMC) number, and the instructor/designated examiner’s
name, job title, officer/rating endorsement, MMC number, and signature.
This collection is covered by DHS/USCG/PIA-015, Merchant Mariner Licensing
Documentation System and DHS/USCG-030 Merchant Seaman’s Record and DHS/All-004,
General Information Technology Access Account Record System SORNs

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Version number: 04-2016
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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

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Version number: 04-2016
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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:
Date approved by DHS Privacy Office:
PTA Expiration Date

Click here to enter text.
January 23, 2020
January 23, 2023

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.
☒ Privacy Impact Assessment (PIA) required.
☒ 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 Click here to enter a date.
by PRIV:
IC/Form PCTS Number: Click here to enter text.
Privacy Act
Choose an item.
Statement:
Click here to enter text.
PTA:
Choose an item.
Click here to enter text.
PIA:
System covered by existing PIA
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

If covered by existing PIA, please list: DHS/USCG/PIA-015 Merchant
Mariner Licensing Documentation System
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/USCG-030 Merchant
Seamen's Records, June 25, 2009, 74 FR 30308
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 submitting this PTA to discuss the information collection, which is
associated with OMB Control number 1525-0079. The purpose of this information
collection is to ensure compliance with the international requirements of the
Standards of Training, Certification and Watchkeeping for Seafarers (STCW)
Convention, and to maintain an acceptable level of quality in activities associated
with training and assessment of merchant mariners.
There is no form associated with this collection. The information collected includes
the mariner’s name, officer/rating endorsement and Merchant Mariner Credential
(MMC) number, and the instructor/designated examiner’s name, job title,
officer/rating endorsement, MMC number, and signature. The information provided
is stored in the Merchant Mariner Licensing and Documentation System (MMLD).
The DHS Privacy Office agrees this is a privacy-sensitive information collection,
requiring PIA and SORN coverage.
PKA coverage is provided by DHS/USCG/PIA-015 Merchant Mariner Licensing
Documentation System, which allows for the collection of information to (1) manage
the issuance of credentials to Merchant Mariners and process merchant mariner
applications; (2) produce merchant mariner credentials; (3) track merchant
mariner credentials issued by the Coast Guard; (4) track the status of merchant
mariners with respect to service, training, credentials, and qualifications, related to
the operation of commercial vessels; (5) qualify merchant mariners for benefits and
services administered by other agencies; and (6) perform merchant mariner call-ups
related to national security.
SORN coverage is provided by DHS/USCG-030 Merchant Seaman’s Record, which
allows for the collection of information to administer the Commercial Vessel Safety
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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

Program to determine domestic and international qualifications for the issuance of
licenses, documents, and staff officer certifications. This includes establishing
eligibility of a merchant mariner's document, duplicate documents, or additional
endorsements issued by the Coast Guard and establishing and maintaining
continuous records of the persons documentation transactions.

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