Friday, March 29, 2013

CFATS PSP – Other Information to be Collected

This is part of a continuing series of blog posts about the CFATS Personnel Surety Program that was described in a 60-day information collection request (ICR) notice in Friday’s Federal Register. This post will look at what additional information (in addition to the personally identifiable information (PII) previously discussed) ISCD might require a high-risk chemical facility to submit to DHS under the CFATS PSP. The earlier posts in the series are listed below.

While the bulk of the information collection covered under this ICR will be the PII used to vet personnel against the Terrorist Screening Database (TSDB), there is additional information that ISCD will be collecting in its administration of the PSP at the Department level.

Information about the High-Risk Facility

Since the Department envisions that many high-risk facilities will use third-party organizations to submit the PII required for the PSP on it facility personnel, the PSP tool in the on-line Chemical Security Assessment Tool (CSAT) will require information “ that identifies the high-risk chemical facility, or facilities, at which each affected individual has or is seeking access to restricted areas or critical assets” (78 FR 17686). From that wording it would seem that vendors and contractors supporting multiple high-risk facilities will be required to identify which facilities they routinely support as part of their data submissions in the PSP tool.

Additional information may be collected from the facility about its PSP in support of adjudications under Subchapter C of 6 CFR Part 27; in processing requests for extensions,

High-risk chemical facilities will also be required to provide ISCD with a point of contact for the collection of additional information about the facility, its PSP, and individuals who have had their PII submitted for screening.

Additional PII

The previously identified PII will be routinely collected on any individual based upon which submission option the facility chooses to use in their PSP filings. ISCD realizes that from time to time they will have to request additional information about an individual to better confirm or deny potential matches in the TSDB. ISCD and law enforcement agencies might also be expected to contact the facility for further information about individuals that have been identified as matches against the TSDB. The notice makes the point that a “request for additional information from the Department does not imply, and should not be construed to indicate, that an individual is known or suspected to be associated with terrorism” (78 FR 17686).

Additional information may be collected about individuals in the PSP as part of the adjudications under Subchapter C described above. Additionally redress requests by individuals may require facilities to provide additional information about an individual. Unfortunately, this is the only mention of ‘redress’ for individuals who feel that they are wrongly identified as having terrorist ties. This may be because the Department will not necessarily notify the facility if an individual is identified as having terrorist ties and thus individuals are unlikely to know if they are wrongly identified.

The reference in this ICR to redress does mention (in a footnote) a series of Privacy Act documents that the Department issued in June of 2011 as part of the original ICR submission to OMB that was subsequently withdrawn. Those documents will certainly be revised as this new ICR moves forward.

Odd Information

There is one odd paragraph in this section of the ICR; it deals with the collection of what would generally be described as file numbers. The notice states that there will be ‘blank data fields’ in the PSP tool in CSAT that will allow the facility to enter a designation or number unique to an individual so that a facility may better track the data submission. I can’t see any reason why a facility submitting information on their own employees would really need this, but it would sure come in handy for third-party submitters, vendors and contractors who might need to keep track of what facilities are associated with a particular individual.

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