July 20, 2004
Table of Contents
Overview of Federal Aviation Administration (FAA) privacy management process for SASO
Personally Identifiable Information (PII) and SASO
Why SASO collects information
How SASO uses information
How SASO shares information
How SASO provides notice and consent
How SASO ensures data accuracy
How SASO provides redress
How SASO secures information
System of records
The Federal Aviation Administration (FAA) within the Department of Transportation (DOT) has been given the responsibility of civil aviation safety. FAA is responsible for:
One of the proposed programs that would help FAA fulfill this mission is the System Approach to Safety Oversight (SASO) system... Though still in the early planning stages, SASO would integrate three basic flight standards functions into one system:
The proposed SASO system would use a Web interface for all of the above components, and to support the Paperwork Reduction and E-Government Act priorities, it may include a public Web site for some appropriate activities.
The SASO planning process, now underway, first conducts a re-engineering of the flight standards business processes. Then, once these processes are re-engineered, the SASO planning team will consider the SASO Information Technology requirements.
Some or all components of five major existing systems, plus multiple smaller ones, may form the basis of the new SASO. The major related existing systems are: Air Transportation Oversight system, Operations Specifications Subsystem, Safety Performance Analysis, Integrating Rating Application, and OASIS-PENS.
Privacy management is an integral part of the SASO system. DOT/FAA has retained the services of privacy experts to help assess its privacy management program, utilizing proven technology, sound policies and procedures, and proven methodologies. In addition, the SASO planning team includes participation by FAA’s Privacy Officer. This individual assists the SASO team to consider all the fair information practices and applicable laws when making decisions that may affect privacy.
The privacy management process is built upon a methodology that has been developed and implemented in leading companies around the country and globally. The methodology is designed to help ensure that DOT and FAA will have the information, tools, and technology necessary to manage privacy effectively and employ the highest level of fair information practices while allowing FAA to achieve its mission of protecting and enhancing a most important U.S. transportation system. The methodology is based upon the following:
FAA is responsibility for maintaining flight safety. Therefore, FAA must review and take action on flight safety measures pertaining to airmen and other factors. PII in SASO will assist FAA staff to track certifications, conduct safety investigations and inspections, and understand flight surveillance measures. This PII may be used to evaluate safety, contact participants in the flight safety process, and track activities.
SASO is planned as an internal and external capability to analyze safety data, manage time-intensive processes such as airman certification, and share information with appropriate people and organizations. FAA intends to use PII in SASO only for these primary purposes. In addition, SASO may include a logon function to protect the data. If this is the case, SASO will also hold and use PII for authorized users of the system, such as name and password, in order to manage permissions and access.
Until the SASO planning team completes business process re-engineering, the team is unable to predict how SASO will share information. It is expected that some portions of SASO PII will be shared within and outside the organization. However, the SASO team will ensure that Memorandums of Understanding (MOU) are in place to govern this process, and it will set up review processes to make sure that those MOU requirements are met.
In the case that SASO may include a limited public Web site interface to facilitate some online transactions, the Web site will post an accurate privacy policy that contains all the sections required by the E-Government Act of 2002. In addition, after the planning team reviews the results of the business process re-engineering, the team will work to ensure that adequate and clear notice is provided and that the public has the option to choose whether or not to participate in any optional, secondary uses of personal data.
Under the provisions of the Privacy Act, individuals may request searches of some SASO data to determine if any records have been added that may pertain to them. This is accomplished by sending a written notarized request directly to the responsible SASO staff member(s) that contains name, designee number, and information regarding the request.
As provided for by the Representatives of the Administrator System of Records notice under the Privacy Act, individuals with questions about privacy and SASO may contact FAA directly. If SASO also includes a public Web site section, the posted privacy policy will additionally provide contact information for FAA’s Privacy Officer.
SASO will take appropriate security measures to safeguard PII and other sensitive data. SASO will apply DOT security standards, including but not limited to routine scans and monitoring, back-up activities, and background security checks of FAA employees and contractors.
In addition, access to SASO PII will be limited according to job function. FAA will control access privileges according to the “minimum necessary” rule, with the most sensitive data, such as social security number, accessible only to one or more system administrators as necessary.
The following access safeguards will also be implemented:
FAA will certify and accredit the security of SASO in accordance with DOT standard requirements.