PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
PRIVACY IMPACT ASSESSMENT
Date
June 23, 2006
Prepared for:
U.S. Department of Transportation,
Pipeline and Hazardous Materials Safety Administration (PHMSA),
400 7th Street, SW, Room 7118, Washington, DC 20590
TABLE OF CONTENTS
Overview of the Intermodal Hazardous Material Database (Intermodal HazDB)
Pipeline and Hazardous Materials Safety Administration Privacy Management Process
Personally Identifiable Information (PII) and Intermodal HazDB
Why Intermodal HazDB Collects Information.
How Intermodal HazDB Uses information
How Intermodal HazDB Shares Information
How Intermodal HazDB Provides Notice and Consent
How Intermodal HazDB Ensures Data Accuracy.
How Intermodal HazDB Provides Redress
How Intermodal HazDB Secures Information
How Long Intermodal HazDB Retains Information
System of Records
The U.S. Department of Transportation (DOT), Pipeline and Hazardous Materials Safety Administration (PHMSA) currently administers an Intermodal Hazardous Material Database (HazDB) for sharing information among and within transportation modes.
There are presently four transportation modes, also referred to as Operating Administrations, that either own systems that interface with HazDB, are subscribers to the HazDB web portal, or provide content information into the Intermodal database. HazDB is an authoritative repository of companies (carriers / shippers) transporting hazardous material on ships, air, highways, and railways. When an accident or incident related to hazardous material occurs, it is recorded in the Intermodal database. All special permits, approvals, inspections, and compliance reviews, discrepancies, and warnings for companies transporting hazardous material are entered into the HazDB.
The four Operating Administrations are as follows:
HazDB supports the mission and goals of the Intermodal Hazardous Materials Program Office, including outreach, training, and exploring methods of improving DOT-wide sharing of shipper data to better identify problem shippers, potential trends, and ultimately reduce accidents related to transporting hazardous material. HazDB is an integrated repository of information that
HazDB provides Operational Administrations with quick and broad access to an information repository in support of cross transportation mode, data query, and analysis to support Decision Makers, Data Analysts, Field Inspectors, and Team Leaders about regulated companies.
Privacy management is an integral part of the Intermodal HazDB system. PHMSA has retained the services of privacy experts to help assess its privacy management program, utilizing proven technology, sound policies and procedures, and established methodologies.
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 PHMSA will have the information, tools, and technology necessary to manage privacy effectively and employ the highest level of fair information practices while allowing PHMSA to achieve its mission of protecting and enhancing the U.S. transportation system. The methodology is based upon the following steps:
The Intermodal system does not receive, store, process or transmit Personally Identifiable Information (PII). Systems communicating with HazDB that contain PII and non-personally identifiable information are responsible for establishing security controls preventing the release of PII to the HazDB system.
The Intermodal system conducts random checks of the database on a regular basis searching for PII that was inadvertently received by field agents, inspectors, an individual completing an incident report or company filling-out a registration form. In the event that PII is identified within the Intermodal system, corrective actions will be initiated to secure this information until it is properly analyzed and removed.
The Intermodal system receives information from a variety of sources that include; Field Agents, Inspectors, Operating Administration systems; PHMSA Hazardous Material Information System (HMIS) and the Federal Motor Carrier Safety Administration (FMCSA) MCMIS, shippers / carriers, and subscribers. All information stored in the Intermodal database is used selectively by each subscriber to: (1) Begin an inspection of a registered company, (2) Initiate an “Approval, Penalty, Discrepancy, Special Permit or Warning”, (3) Conduct compliance reviews of hazardous materials and shippers, (4) Generate reports; Compliance, Inspections, Incidents, Trend Analysis, in addition annual reporting for Hazardous Liquid or Carbon Dioxide Systems, and for Hazardous Liquid Pipelines.
The process by which information is exchanged between systems is through extensible markup language (XML) technology. A field agent, inspector or subscriber can enter information through the Intermodal web portal (http://hip.dot.gov ) or by contacting the system administrators.
The Intermodal system is an authoritative repository, containing shipper / carrier registration information, incident reports related to hazardous material, special permits, approvals, penalties and reports. This information is used by Operating Administrations, data analysts and field agents in performing verification and validation of hazardous material through inspections and enforcement efforts. The Intermodal system provides an integrated information source to
All carrier / shipper registration information as well as hazardous material incident reports stored in the Intermodal HazDB is accessible with the following DOT Operating Administrations. These Administrations use this information for coordinating hazardous material inspections, trend analysis, and measuring program effectiveness by conducting queries about companies involved in the transportation of Hazardous Materials:
Pipeline and Hazardous Materials Safety Administration (PHMSA),
Federal Aviation Administration (FAA),
Federal Motor Carrier Safety Administration (FMCSA),
Federal Railroad Administration (FRA),
US DOT Office of Intermodalism
The Intermodal HazDB system provides visible links to a privacy policy describing our privacy practices and information. Carriers and shippers of hazardous material can view this information by visiting the following website: http://phmsa.dot.gov/about/privacy.html.
It is the responsibility of shippers / carriers to provide accurate information during the registration of a hazardous material. An individual reporting a hazardous material incident also has the same responsibility to accurately record the information on the incident reporting form. In both instances, a verification of registration and incident reporting is conducted either during inspection of the hazardous material or through enforcement efforts.
The Intermodal HazDB online system has business rules built into the form that allow for quality checks on required and standardized information. In addition, this system provides some internal field validation functionality, and some fields are required.
A carrier / shipper or an individual reporting a hazardous material incident can contact a PHMSA Intermodal representative to address data inaccuracies. All redress actions will be conducted in accordance with DOT redress policy and procedures.
The Intermodal system is currently operating at DOT Headquarters in Washington, DC. Physical access to the Intermodal HazDB system is limited to appropriate personnel through building key cards and room-access key pads. Personnel with physical access have all undergone and passed DOT background checks.
In addition to physical access, electronic access to the Intermodal database is limited according to job function. PHMSA verifies and authenticates new users before providing Intermodal system access by requiring written or email verification of an official source for each request. PHMSA manages privileges according to the following roles:
The Intermodal system has established appropriate security measures to safeguard the system and system information. Intermodal HazDB applies DOT security standards, including but not limited to routine scans and monitoring, back-up activities, and background security checks of PHMSA employees and contractors.
The following matrix describes the privileges and safeguards around each of these roles as they pertain to non-personally identifiable information:
The Intermodal system retains approvals, incidents, inspections, penalties, discrepancies, warnings, special permits, and registration of shippers / carriers of hazardous material in the database for 20 years. This retention period will have a positive impact on improving accuracy in trend analysis reports, measuring program effectiveness related to special permits, hazardous material incidents, company reviews / inspections, and enforcement of penalties.
The Intermodal HazDB system is not a system of record subject to the Privacy Act. The information in the database is categorized as non-personally identifiable information. The Intermodal system is being certified and accredited in accordance with DOT information technology security standards, the National Institute of Standards Technology (NIST) special publications, and defined management, operational, and technical security requirements.