Wednesday, October 14, 2009
DHS Privacy Impact Assessments
On Wednesday DHS published a notice in the Federal Register about a number of Privacy Impact Assessments (PIA) that were approved by DHS Privacy Office last spring. Of the twelve PIA listed in the notice two deal with the CFATS system. All of the PIA will be available on the DHS Privacy web site until December 14th. After that they will be available upon request to the privacy office (email@example.com). The two CSAT PIA are currently listed on the DHS Counterterrorism Laws and Regulations web page. There are a number of links on that page and it might be difficult to find the PIA links. The specific links are provided in the brief discussions below. The first of the CSAT PIA was designed to update the CSAT PIA for the addition of the Site Security Plan and the increased number of personnel that were authorized to be Preparers for that document. Additionally, the ‘new’ CSAT Tip Line was included as the Help Desk would be asking for voluntary submission of personal identification information (PII) when people made reports on the Tip Line. This PIA was approved June 5th. The second CSAT PIA was added to reflect the collection of PII from government employees and contractors to authorize their use of the CHEMS system. This is an internal DHS system that extracts facility contact information from CSAT and provides it to authorized government employees and contractors working on chemical facility security issues. CHEMS also allows these people to verify CVI status. This PIA was approved June 11th. Both of these PIA provide detailed information about how a variety of personal information collected by the CFATS program through the CSAT tool is used and protected by DHS. Everyone who has provided personal identification information through CSAT owes it to their own peace of mind to review these documents.