Adjudicated Privacy Threshold Assessment

U.S. Department of Transportation

Office of the Chief Information Officer (OCIO)
Privacy Threshold Assessment (PTA)
National Highway Traffic Safety Administration
Office of Behavioral Safety Research
Rearview Video Training for Older Drivers

signed
KARYN Digitally
by KARYN MARIE
MARIE GORMAN
Date: 2023.03.13
GORMAN 16:26:42 -04'00'

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U.S. Department of Transportation

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 Threshold 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 system 1 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

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.
1

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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 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: Rearview Video Training for Older Drivers
Cyber Security Assessment and Management (CSAM) ID: N/A
SYSTEM MANAGER CONTACT Information:
Name: Kathy Sifrit
Email: Kathy.sifrit@dot.gov
Phone Number: 202-366-0868
Is this a NEW system?
☐ Yes (Proceed to Section 1)
☐ No
☒ Renewal
☐ Modification
Is there a PREVIOUSLY ADJUDICTED PTA for this system?
☐ Yes:

Date: < >

☒ No

1 SUMMARY INFORMATION
1.1

System TYPE
☐ Information Technology and/or Information System
Unique Investment Identifier (UII): Click here to enter text.
Cyber Security Assessment and Management (CSAM) ID: Click here to
enter text.

☐ Paper Based: Click here to enter text.
☐ 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: 2127-0731
☒ Control Number Expiration Date: 8/31/2021

1.2

☐ Other: <>
System OVERVIEW:

NHTSA's OBSR proposes to collect information for a new research to determine the
effectiveness of a training video on proper use of a rear vision system (RVS) in
passenger vehicles in improving backing performance. This research effort entails
collecting driving data using an instrumented vehicle on a closed course from 120
participants evenly distributed across two age groups: 60-69 and 70+, and sex, who
reside in the New River Valley and Roanoke Valley Areas of Virginia. Measures of
backing performance and eye glance behaviors of participants who complete the
training video will be compared to that of participants who view a similar-length
traffic safety video unrelated to backing or Rear Video Systems (RVS) use. The
study will also document participants’ opinions about the RVS technology using a
brief post-experimental questionnaire.
TransAnalytics will conduct this study under a Time and Materials task order on an
IDIQ contract (693JJ921D000035/693JJ922F00137N) with NHTSA. NHTSA
contracted with TransAnalytics to conduct the project, and TransAnalytics
subcontracted to Virginia Tech Transportation Institute (VTTI) to provide vehicle
instrumentation, the closed roadway, recruiting, and data collection support.
TransAnalytics will oversee subcontractors’ work, ensure the protection of
participants’ data and privacy of the participants, conduct final analyses, interpret the
findings, and prepare a final report describing the research findings to NHTSA. In
addition to the naturalistic data, there are two (paper) collection instruments that will
be used for the study: a participant screening questionnaire and a consent form.
Eligibility
The eligibility data from the screening questionnaire will be used to identify eligible
participants for this study; results from this questionnaire will not be kept or
analyzed. Participants will be recruited from the New River Valley and Roanoke
Valley areas of Virginia.
Potential participants in the study will apply by responding to a published
advertisement appearing in print media and social media. Other potential participants
will be contacted using VTTI’s proprietary database consisting of previouslyconsented participants.

3

See 44 USC 3501-3521; 5 CFR Part 1320

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VTTI will contact candidate participants by phone, email, or other electronic means.
To qualify for this study, participants must fall into one of two age groups: 1) ages
60-69; and 2) ages 70 and older.
Screening questionnaires will ask about the following to ensure that respondents
meet inclusion criteria:
• Year of birth, age, sex, and race
• COVID-19 vaccination status (if required by VTTI at the moment of the
study)
• Valid Driver license
• Experience with rearview video systems
• Driving habits (e.g. 3 driving trips per week at a minimum)
• Health questions/conditions and medications that would affect their ability to
drive the study vehicle safely.
• Name, address, email, and phone number of those who meet the eligibility
requirements
Individuals who do not meet the eligibility requirements will be excluded because
they may not safely participate in a test-track experiment.
In this study, participants will drive a study-provided vehicle equipped with a
console-mounted RVS display to complete a series of backing tasks. Researchers
will install a data acquisition system (DAS) in the vehicle to collect driving data as
participants complete a series of backing tasks that an earlier study showed were
difficult for older drivers. Participants will also complete a post-experimental
questionnaire about their opinions regarding the technology.
Study
This research effort entails collecting driving data using an instrumented vehicle on a
closed roadway, with 120 participants, evenly distributed by across 2 age groups: 6069 and 70+ and across sex. Eligible participants will go to the study office (on-site at
the closed course) where half (balanced across age and sex) will be assigned to a
training group and the remainder to a control group. Training group members will
view the RVS training video developed in the previous study and control group
members will view an unrelated traffic safety video of the same length as the training
video. Before data collection begins, each participant will be afforded time driving
the test vehicle to become familiar with its handling characteristics and controls; this
will include practice (i.e., not scored) maneuvers using the RVS. Next, an
experimenter riding in the passenger seat, will provide instructions to guide the
participant from task to task during data collection. After completing the driving
tasks, each participant will complete a post experiment questionnaire regarding their
opinions about the technology. At this time, participants will receive incentive
payments and the research team will answer any participant questions. Social
Security Number will be collected only for the purpose of processing the
participant’s payment and will not be included in any part of the study.
Data Collection
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Screening data will be collected via a paper form. The backing data collection
platform will consist of a full-size sedan from VTTI’s instrumented vehicle fleet
with a passenger-side secondary brake that the experimenter can use to stop the
vehicle if necessary to ensure safe vehicle operation. VTTI mounted their data
acquisition system (VTTI DAS) securely and inconspicuously in the test vehicle, and
the VTTI DAS provided the following sources of data: five video camera views that
include the driver’s face, forward roadway, rear roadway/parking space, and the left
and right sides of the vehicle; precise vehicle and target locations using GPS; Multiaxis accelerometers that document hard braking or acceleration; and timing
information.
At the end of the study, NHTSA will receive deidentified and aggregated data, and a
report from the study through a Secure File Transfer Protocol (SFTP) site. Data
consists of vehicle instrumentation data and the data analysis. All data are deidentified with no PII. The data are submitted along with the report so that NHTSA
has the option to process it differently than the contractor, and develop new
graphs/tables to address other questions that arise in the future. Statistical
comparisons will focus on comparing the treatment and control groups in terms of
driver positioning errors, instances of contacting an obstacle or other object, and
proportion of glances toward the RVS, rearview mirrors, and over the shoulder. A
second series of analyses will examine potential differences by age and sex.
Additionally, the data will provide NHTSA a basis from which to help drivers use
this technology safely but does not and is not intended to provide guidance to the
agency.
Video recordings are kept for a pre-determined length of time agreed by VTTI and
Virginia Tech Transportation Institute’s internal Institutional Review Board (IRB).
Any paper copies will be kept in a locked filing cabinet in a locked office. Electronic
copies are stored on limited access, password protected computer system. All video,
hard copies and electronic copies will be destroyed 7 years after completion of the
study.

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
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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?
Screening questionnaires will collect the folling information:
• Citizenship, Age, sex
• COVID-19 vaccination status
• Driver license status, including any license restrictions
• Involvement in motor vehicle crashes, injuries sustained and traffic violations
• Health Issues that would limit their overall ability to drive or affect their
ability to drive the study vehicle safely including use of medications that
cause drowsiness or otherwise impair their ability to drive the study vehicle.
• Vision status
• Social Security Number
• Name, address, email, and phone number

2.3

Does the system RELATE to or provide information about individuals?
☒ Yes: The questionnaire will ask about participants’ knowledge, attitudes,
behavior and driving behaviors while driving a vehicle equipped with RVS
technology.
☐ No

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: Social security number is required for participant compensation
purposes.
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Purpose: Social security number is required for participant compensation
purposes. All participants will receive financial compensation only if they qualify
and actively participate in the study. Social security numbers or VT employee ID
will be collected in a W-9 form for payment purposes only. SSN or any subset
will not be included as study data.

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: << A system without an SSN reduction plan is in violation of the Privacy Act.
Explain why a reduction plan has yet to be completed and provide an anticipated
completion date.>>
2.6

Does the system collect PSEUDO-SSNs?
☐ Yes: << Describe how the pseudo-SSNs are used to accomplish the authorized
purpose and why they are necessary as opposed to lower-risk identifiers.>>

2.7

☒ No: The system does not collect pseudo-SSNs, including truncated SSNs.

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: <>
☒ No:
Explanation: Each individual will be assigned a participant ID for use in all
data collection forms, data analysis, and reporting to track the progress of the
individual’s participation throughout the study. The participant ID will not be
included in the final report to NHTSA. This study is not about the
individuals, but about their ability to use and opinions toward RVS systems.
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
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Exemption Rule: << Provide the full Exemption Rule Name, the Federal
Register SORN citation, and the URL.>>
☐ No

Explanation: << An explanation must be provided for failure to comply with
all of the requirements of the Privacy Act without an Exemption Rule.>>
Expected Publication: << List the expected date of publication for an
Exemption Rule that will bring the system into compliance with the Privacy
Act.>>

2.9

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

Has a PRIVACY IMPACT ASSESSMENT (PIA) been published for this system?
☒ Yes:
Office of Behavioral Safety Research (OBSR) Research Studies - June 10, 2019
https://www.transportation.gov/individuals/privacy/nhtsa-office-behavioral-safetyresearch-obsr-research-studies
☐ No: << If a previous PTA required a PIA as part of adjudication, and a PIA was
not published, provide an explanation. If this is a new system, write “New
System.”>>

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: <>
☒ No
2.11

Does the system have a National Archives and Records Administration
(NARA)-approved RECORDS DISPOSITION schedule for system records?
☐ Yes:
Schedule Identifier: << Identify the relevant NARA schedule, including the
schedule number, title, section, and URL.>>
Schedule Summary: << Provide a synopsis of the relevant portion(s) of the
schedule.>>
☒ In Progress: DAA-0416-2021-0003 Submitted to NARA on 6/8/21
☐ No: Click here to enter text.

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3 SYSTEM LIFECYCLE

3.1

3.2

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

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: <>
☐No
☒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: << Describe any modification that may
introduce new privacy risk, including but not limited to: paper to electronic
conversions, changing anonymous information into information in
identifiable form, significant system management changes (including
application of new technologies), significant system or data merging, use of
new authentication technologies in support of public access, commercial
data sources, new interagency uses, changes in internal flow or data
collection, or alternation of data characterization.>>
☐ Other: << Describe >>
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: <>

3.4

Contractor: << Contractor Name >>

☐ 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
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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:
Confidentiality:
Integrity:
Availability:

☐ Low
☐ Low
☐ Low

☐ Moderate
☐ Moderate
☐ Moderate

☐ High
☐ High
☐ High

☐ Undefined
☐ Undefined
☐ 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
☐ Low
☐ Low

☐ Moderate
☐ Moderate
☐ Moderate

☐ High
☐ High
☐ High

☐ Undefined
☐ Undefined
☐ Undefined

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

Date of Initial Authority to Operate (ATO):
Anticipated Date of Updated ATO: <>
☐ 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: Jose R. Delgado-Forastieri

Email: j.delgado-forastieri@dot.gov

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Phone Number: 202-366-7491
COMPONENT PRIVACY OFFICER Analysis
This collection is to study the participants knowledge, attitudes, behavior and driving
behaviors while driving a vehicle equipped with RVS technology.
Each individual will be assigned a participant ID only to track the progress of the
individual’s participation throughout the study. This ID will not be used in any other way
after the data collection and analysis is concluded and will not be included in the final
deliverable to NHTSA. NHTSA is unable to retrieve PII in the final deliverable by personal
identifier. Therefore, the system is not a a system of records as defined by the Privacy Act.
Individuals consent to participate in the study. While the participants share their SSN for
the purposes of renumeration and limited health information for eligibility purposes, the
privacy risk for this collection is low because the information concerns driving attitudes and
analysis of activities during a closed course simulation. The subcontractor will not share the
PII it collects with NHTSA’s contractor. NHTSA’s contractor will submit deidentified data
to NHTSA and responses will not be associated with individual respondents.
Participants will consent to participate by signing a consent that is consistent with NHTSA’s
Human Subject Testing Order and subject to NCC approval.
OBSR already has a PIA which covers this kind of collection.
A Record Disposition Schedule was submitted to NARA on 6/8/21.

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

Name

Review Date

Business Owner

Kathy Sifrit

1/19/2023

General Counsel

Andrew DiMarsico

3/2/2023

Information System
Security Manager (ISSM)

Nurdan Logan

2/28/2023

Privacy Officer

Jose R. Delgado-Forastieri

3/2/2023

LeErnest Wells

3/2/2023

Records Officer

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

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Control
#
AP-1

Control Name

Authority to Collect

Primary PTA
Question

Satisfied

1.2 - Overview

Other
than
satisfied
X

N/A

Component PO Assessment

A renewal request to OMB is
already in progress.
POA&M
Issue: OMB renewal control
number required. Requirement:
submit PRA package. Timeline:
prior to collection. Note: OMB
authorization required prior to
commencement of study.

DOT CPO Assessment

Concur
POA&M
Issue: OMB renewal control number
required. Requirement: submit PRA
package. Timeline: prior to collection.
Note: OMB authorization required
prior to commencement of study.

AP-2

Purpose Specification

1.2 - Overview

X

Contractor will obtain IRB
approval to collect data.
Purposed defined.

AR-1

Governance and Privacy
Program

Common Control

X

Addressed by DOT CPO.

Concur

AR-2

Privacy Impact and Risk
Assessment

Program
Management

X

Concur

AR-3

Privacy Requirements for
Contractors and Service
Providers
Privacy Monitoring and
Auditing

3.3 - Contractor
System

X

PTA sufficient. OBSR already has
a PIA which covers this kind of
collection. No PIA required.
Standard contract language.

Common Control

X

Addressed by DOT CPO.

Concur

AR-5

Privacy Awareness and
Training

Common Control

X

Addressed by DOT CPO.

Concur

AR-6

Privacy Reporting

Common Control

X

Addressed by DOT CPO.

Concur

AR-4

1

Concur

Concur

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Control
#

Control Name

Primary PTA
Question

Satisfied

X

Other
than
satisfied

N/A

Component PO Assessment

DOT CPO Assessment

Concur

X

SSN is required only for
participant compensation
purposes. SSN will not be
collected for the purpose of the
study. SSN or any subset will
not be included as study data.
Not maintained in SOR.
Data Quality issued addressed in
IRB.

Concur

Activity does not constitute
sharing covered by the CMA.

Concur

AR-7

Privacy-Enhanced System
Design and Development

2.5 - SSN Reduction

AR-8

Accounting of Disclosures

2.7 - SORN

DI-1

Data Quality

1.2 - System
Overview

DI-2

Data Integrity and Data
Integrity Board

3.4 - Security Risk
Categorization

DM-1

Minimization of PII

2.2 – Information
About Individuals

X

Data collection consistent with
purpose.

Concur

DM-2

Data Retention and Disposal

2.11 - Records
Disposition
Schedule

X

Records Schedule was submitted
to NARA and is waiting approval.
Note: records must be treated
as permanent until NARA
approves the new records
schedule.
System not used for testing,
training, research.

Concur

DM-3

X
X

Concur

Note: records must be treated as
permanent until NARA approves the
new records schedule.

2.2 – Information
About Individuals

X

IP-1

Minimization of PII Used in
Testing, Training, and
Research
Consent

2.7 - SORN

X

Not maintained in SOR.

Concur

IP-2

Individual Access

2.8 – Exemption
Rule

X

Not maintained in SOR.

Concur

2

Concur

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Control
#

Control Name

Primary PTA
Question

IP-3

Redress

2.7 - SORN

IP-4

Complaint Management

Common Control

SE-1

Inventory of PII

SE-2

Satisfied

Other
than
satisfied

N/A

X

Component PO Assessment

DOT CPO Assessment

Not maintained in SOR.

Concur

X

Addressed by DOT CPO.

Concur

Common Control

X

Not IT system under FISMA.

Concur

Privacy Incident Response

Common Control

X

Addressed by DOT CPO.

Concur

TR-1

Privacy Notice

2.7 - SORN

X

Not maintained in SOR.

Concur

TR-2

System of Records Notices and
Privacy Act Statements

2.7 - SORN

X

Not maintained in SOR.

Concur

TR-3

Dissemination of Privacy
Program Information

Common Control

X

Addressed by DOT CPO.

Concur

UL-1

Internal Use

2.10 - Internal and
External Use

X

Information not authorized for
disclosure beyond DOT/DOTcontractors.

Concur

UL-2

Information Sharing with Third
Parties

2.10 - Internal and
External Use

X

Information not authorized for
disclosure beyond DOT/DOTcontractors.

Concur

3