1625-0032 Privacy Threshold Analysis

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

Page 1 of 11

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

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:

CG-949

Form Title:

Permit to Carry Excursion Party

Component:

U.S. Coast Guard (USCG)

Office:

CG-REG

IF COVERED BY THE PAPERWORK REDUCTION ACT:
Collection Title:
Small Passenger Vessels –- Title 46 CFR Subchapters K and T
OMB Control
Number:
Collection status:

Name:
Office:
Phone:

Name:
Office:
Phone:

1625-0057
Extension

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

June 30, 2021
April 10, 2017

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
A.L. Craig
CG-6P
Title:
PRA Coordinator
202-475-3528
Email:
Albert.L.Craig@uscg.mil

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

SPECIFIC IC/Forms PTA QUESTIONS
1. Purpose of the Information Collection or Form
a. Describe the purpose of the information collection or form.
The U.S. Coast Guard (USCG) is renewing the PTA for form CG-949, titled “Permit to Carry
Excursion Party.”
The Coast Guard prescribed regulations for the design, construction, alteration, repair
and operation of small passenger vessels to secure the safety of individuals and property
on board. The regulations are in 46 CFR Subchapters K and T.
The purpose of this collection is to document excursion permit operating conditions.
The Coast Guard issues a permit (i.e., form CG-949) to a vessel owner/operator that
seeks to operate an inspected vessel temporarily beyond the limits of the vessel’s
Certificate of Inspection.
The form contains the signature of the authorized official issuing the form, port of issue
(i.e., where authorized official endorsed the form) and vessel-specific information.
b. List the DHS (or Component) authorities to collect, store, and use this
information.
The authority for this collection is 46 U.S. Code 3305 and 3306.

2. Describe the IC/Form
a. Does this form collect any
Personally Identifiable
Information” (PII1)?

☒ Yes
☐ No

b. From which type(s) of
individuals does this form
collect information?
(Check all that apply.)

☐ Members of the public
☐ U.S. citizens or lawful permanent
residents
☐ Non-U.S. Persons

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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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

☒ DHS Employees/Contractors (list
Components)
☐ 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.).
☐ Business entity.
If a business entity, is the only
information collected business contact
information?
☐ Yes
☐ No
☐ Law enforcement.
☒ DHS employee/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 form contains the signature of the authorized official issuing the form, port of issue
(i.e., where authorized official endorsed the form) and vessel-specific information.
f. Does this form collect Social Security number (SSN) or other element that is
stand-alone Sensitive Personally Identifiable Information (SPII)? No.
☐ 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
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

☐ Passport Number
☐ Bank Account, Credit Card, or other
financial account number
☐ Other. Please list:

☐ Trusted Traveler Number (Global
Entry, Pre-Check, etc.)
☐ Driver’s License Number
☐ Biometrics

g. List the specific authority to collect SSN or these other SPII elements.
N/A
h. Is SSN necessary to carry out the functions of this form and/or fulfill
requirements of the information collection? Note: even if you are properly
authorized to collect SSNs, you are required to use an alternative identifier. If
there are technological, legal, or regulatory limitations to eliminating the SSN,
privacy-enhancing alternatives should be taken, such as truncating the SSN.
N/A
i. How will this information be used? What is the purpose of the collection?
The form is used by the Coast Guard to document the excursion permit operating
conditions. A permit is issued when a vessel owner/operator requests to operate an
inspected vessel temporarily beyond the limits of the vessel’s Certificate of Inspection.
j.

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.
☒ No. Information is not retrieved by personal
identifier.

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.
Click here to enter text.
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

☒ Scanned forms (completed forms are scanned into
an electronic repository). Please describe the
electronic repository.
Forms that the Coast Guard receives are
maintained in Marine Information for Safety and Law
Enforcement (MISLE) database.
b. If electronic, how
does DHS input the
responses into the IT
system?

☒ Manually (data elements manually entered). Please
describe.
A scanned form is uploaded to the vessel-specific
file in MISLE.
☐ Automatically. Please describe.
Click here to enter text.

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.
Click here to enter text.
☒ By a non-personal identifier. Please describe.
A search is conducted using vessel-specific
information.
A record is retained for the life of the vessel; NARA
retention schedule number N1-026-05-015.

d. What is the records
retention
schedule(s)? Include
the records schedule
number.
e. How do you ensure
that records are
disposed of or deleted
in accordance with
the retention
schedule?

As records are maintained in the MISLE database,
disposal/deletion is in accordance with the business
rules for the database.

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

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.
☒ 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.

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

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

A.L. Craig

Date submitted to Component Privacy
Office:
Concurrence from other Components
involved (if applicable):
Date submitted to DHS Privacy Office:

June 10, 2021

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.)

N/A
June 14, 2021
☐ Yes. Please include it with this PTA
submission.
☒ No. Please describe why not.
Information is not retrieved by a personal
identifier.

Component Privacy Office Recommendation:
Please include recommendation below, including what existing privacy compliance
documentation is available or new privacy compliance documentation is needed.
The U.S. Coast Guard (USCG) is renewing the PTA for form CG-949, titled “Permit to Carry
Excursion Party.”
The Coast Guard prescribed regulations for the design, construction, alteration, repair and
operation of small passenger vessels to secure the safety of individuals and property on
board. The regulations are in 46 CFR Subchapters K and T.
The form is used by the Coast Guard to document the excursion permit operating
conditions. A permit is issued when a vessel owner/operator requests to operate an
inspected vessel temporarily beyond the limits of the vessel’s Certificate of Inspection.
The Permit to Carry Excursion Party (CG-949) contains the signature of the authorized
official issuing the form, port of issue (i.e., where authorized official endorsed the form) and
vessel-specific information. The form is maintained in vessel-specific file in the Marine
Information for Safety and Law Enforcement (MISLE) database.
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

The Permit to Carry Excursion Party is privacy sensitive with coverage provided by
DHS/USCG/PIA-008 MISLE. A Privacy Notice will be posted on the 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 ADJUDICATION
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Kattina Do

DHS Privacy Office Approver (if applicable):
PCTS Workflow Number:
Date approved by DHS Privacy Office:
PTA Expiration Date

Max Binstock
0017679
June 17, 2021
June 17, 2024

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.

Privacy Act
Statement:
System PTA:
PIA:

Choose an item.
Click here to enter text.
Choose an item.
Click here to enter text.
Choose an item.
If covered by existing PIA, please list: Click here to enter text.
If a PIA update is required, please list: Click here to enter text.

SORN:
If covered by existing SORN, please list: Click here to enter text.
If a SORN update is required, please list: Click here to enter text.
DHS Privacy Office Comments:
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 describe rationale for privacy compliance determination above.
USCG is submitting this renewal PTA to discuss the Permit to Carry Excursion Party,
Form CG-949. The purpose of this collection is to document excursion permit
operating conditions. The Coast Guard issues a permit (i.e., form CG-949) to a vessel
owner/operator that seeks to operate an inspected vessel temporarily beyond the
limits of the vessel’s Certificate of Inspection.
The form contains the signature of the authorized official issuing the form, port of
issue (i.e., where authorized official endorsed the form) and vessel-specific
information.
The DHS Privacy Office (PRIV) agrees that this form is privacy-sensitive. However, no
PIA coverage is required because the only PII is collected from USCG personnel, and
no SORN coverage is required as the information is retrieved by personal identifier.
Also, no Privacy Act Statement is required.
Generally, this type of information is covered by DHS/USCG/PIA-008 MISLE, which
outlines the risks of capturing information required to support the Coast Guard’s
marine safety, security, environmental protection and law enforcement programs
and DHS/USCG-013, which outlines the Coast Guard’s collection and maintenance of
records related to safety, security and law enforcement performance history of
vessels, facilities, people and organizations engaged in marine transportation,
including enforcement action, that can be used to identify and address safety,
security and environmental risks and to establish vessel eligibility for
documentation as a U.S. flag vessel.

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