DEPARTMENT OF TRANSPORTATION
Federal Motor Carrier Safety Administration (FMCSA)
PRIVACY IMPACT ASSESSMENT
ANALYSIS & INFORMATION ONLINE (A&I)
June 15, 2009
TABLE OF CONTENTS
Overview of FMCSA privacy management process for A&I Online
Personally Identifiable Information (PII) and A&I Online
Why A&I Online collects information
How A&I Online uses information
How A&I Online shares information
How A&I Online provides notice and consent
How A&I Online ensures data accuracy
How A&I Online provides redress
How A&I Online secures information
How Long A&I Online Retains Information
System of Records
Overview of FMCSA Privacy Management Process for A&I Online
The Federal Motor Carrier Safety Administration (FMCSA) within the U.S. Department of Transportation (DOT) has been given the mission of reducing crashes, injuries, and fatalities involving large trucks and buses (motor carriers). In carrying out its safety mandate, FMCSA:
- Develops and enforces data-driven regulations that balance motor carrier safety with industry efficiency
- Employs safety information systems to focus on higher risk motor carriers in enforcing safety regulations
- Targets educational messages to motor carriers, commercial drivers, and the public
The A&I Online assists FMCSA in achieving these agency objectives. A&I Online is a web-based system designed to provide the basis of the statistical analysis that is performed, providing safety history and ratings for commercial motor vehicles, commercial drivers, and carrier safety information. The business processes included in realizing FMCSA's mission are the performance of compliance reviews and inspections on motor carrier operations and inspections of commercial motor vehicles, and other data elements which may result in enforcement actions being taken against a motor carrier for failure to adhere to motor carrier laws and regulations. A&I Online contains the data related to these processes and allows all authorized users access to that data in the performance of their duties. Sources of data for FMCSA's A&I Online are other FMCSA applications or systems including:
- Motor Carrier Information System (MCMIS)
- Enforcement Management Information System (EMIS)
The A&I Online system processes and provides safety information that has PII as follows:
- Motor Carrier Safety Status Measurement System (SafeStat): An automated, data driven analysis system designed by FMCSA. This system is accessed by FMCSA employees and contractors and the general public. The SafeStat combines current and historical carrier-based safety performance information to measure the safety fitness of interstate commercial motor carriers and intrastate commercial motor carriers that transport hazardous materials. A&I Online receives a monthly snapshot of data from MCMIS. This information includes Federal and State data on crashes, roadside inspections, on-site compliance review results and enforcement history. The Driver's name, Driver's license number and Date of Birth is included in this snapshot of data. SafeStat enables FMCSA to quantify and monitor the safety status of individual motor carriers on a monthly basis and thereby focus enforcement resources on carriers posing the greatest potential safety risk.
- FMCSA Tools: This module includes information resources available on A&I Online that are only accessible to FMCSA employees and State partners via user id and password authentication. This module has a sub module:
- Driver Information Resource: The Driver Information Resource (DIR) provides a secure web based lookup capability that allows FMCSA and State enforcement personnel to view a driver's crash and inspection history by driver name or commercial driver license number. A driver's crash and/or violation data will be displayed if the driver had an inspection within 3 years or a crash within 5 years. All crash and inspection events that meet these criteria will be displayed along with the motor carrier for whom they were operating. The system also allows FMCSA and State enforcement to search by U.S. DOT number or carrier name to obtain a list of all drivers affiliated with the specified carrier that had an inspection within 3 years or a crash within 5 years. The DIR module receives a monthly snapshot of inspection and crash data from MCMIS. The data includes PII such as Driver name, Driver's License Number, Date of Birth and Age.
Privacy management is an integral part of A&I. DOT/FMCSA has retained the services of privacy experts to assess its Privacy Management Program through the use of proven technologies, sound policies and procedures, and established methodologies.
The U.S. Department of Transportation (DOT) privacy management process is built upon a methodology that enables DOT/FMCSA to have the information, tools, and technology necessary to effectively protect PII while allowing FMCSA to achieve its mission. The methodology includes the following:
- Establishing appropriate authorities, responsibilities, and controls for information management with input from systems architecture, technology, security, legal, and other disciplines
- Identifying, documenting, and addressing privacy risks
- Developing and implementing appropriate policies and procedures and updating them when necessary
- Monitoring compliance with applicable laws, regulations, policies, and procedures
- Providing training to all DOT employees and contractors with access to PII
- Effectively maintaining the privacy protection principles of:
- Openness
- Individual Participation
- Purpose Specification
- Collection Limitation
- Use Limitation
- Data Quality and Integrity
- Security Safeguards
- Accountability and Auditing
Privacy is a significant consideration in the operation of the FMCSA A&I Online.
Personally Identifiable Information (PII) and A&I Online
The A&I Online contains both Personally Identifiable Information and non-personally Identifiable from commercial motor vehicle (CMV) drivers:
- Last, First, and Middle Name
- Social Security Number
- Date of Birth
- Home Address
- Driver License Number
- Home Telephone Number
- Age
- Employment History
Why A&I Online Collects Information
A&I Online collects PII to provide motor carrier safety information including statistical and analytical resources for FMCSA and State enforcement personnel. A&I contains the data for the performance of compliance reviews and inspections on motor carrier operations and inspections of commercials motor vehicles, and other data elements which may results in enforcement actions being taken against a motor carrier for failure to adhere to motor carrier and laws and regulations.
How A&I Online Uses Information
The A&I Online information is used to provide quick and efficient access to descriptive statistics and analyses regarding commercial vehicle, driver, and carrier safety information. It is used by Federal and State and local law enforcement personnel as well as the motor carrier industry, insurance companies, and the general public.
How A&I Online Shares Information
The A&I Online system does not share PII data with any other systems. A&I Online is not the authoritative source for the PII data, PII data is collected from other FMCSA systems for statistical analysis of historical data. It is used by Federal and State enforcement personnel, as well as the motor carrier industry, insurance companies, and the general public.
The following groups have access to A&I:
- CMV Drivers, Motor Carriers, and General Public - Has access to view statistical analysis and generalized reports only. No authentication is required.
- FMCSA and State Enforcement Users - Authorized FMCSA users have full access to all the data to review and monitor the applications. A User ID and password is required to access the system.
- System Administrators and Developers - Federal contractors (System administrators and developers) at the Volpe National Transportation Systems Center (Volpe Center) has full access to the A&I Online to perform their assigned roles and responsibilities (development and maintenance of the system).
How A&I Online Provides Notice and Consent
The A&I Online does not collect PII directly from individuals. The A&I Online only stores PII that has been collected through other FMCSA systems for statistical analysis of historical data. It is not the authoritative source for the PII data. The A&I Online has a link to DOT Privacy Policy that contains all requirements by the E-Government Act of 2002.
How A&I Online Ensures Data Accuracy
A&I ONLINE does not collect PII directly from individuals. MCMIS is the authoritative source for the data in A&I Online. The MCMIS system provides internal data edit checks on all data submitted to MCMIS. FMCSA data entry contractors have a verification process to ensure that accurate information is entered in MCMIS. The Federal and State system where the crash, inspection and compliance review data are entered contains data quality edit checks before the data is submitted to MCMIS.
Individuals who provide PII through mail-in forms to request MCMIS reports provide that PII directly and are responsible for its accuracy. FMCSA staff reviewing and approving submitted forms check for completeness on required fields, and verify requirements when there is a question of whether a requestor has the right to a PII-containing report.
Individuals who must submit PII in order to obtain direct access to MCMIS submit this information directly. These individuals may contact their approving supervisor for any corrections to submitted information.
How A&I Online Provides Redress
MCMIS is the authoritative source for the data in A&I Online. The A&I Online includes links to the DOT Privacy Policy and the DataQs system (https://dataqs.fmcsa.dot.gov/login.asp). The Privacy Policy describes DOT information practices related to the online collection and the use of PII. DataQs is an electronic means for filing concerns about federal and state data released to the public by FMCSA. Individuals can use DataQs to challenge information included in their records. Motor carriers, state agencies, and FMCSA offices can use DataQs to challenge information concerning crashes, inspections, compliance reviews, safety audits, enforcement actions, vehicle registrations, operating authorities, insurance policies, and consumer complaints. After a challenge has been submitted, DataQs automatically forwards the challenge to the appropriate office for resolution and allows the party that submitted the challenge to monitor its status.
DataQs cannot be used to challenge safety ratings or civil actions managed under 49 CFR 385.15 (Administrative Review) or 49 CFR 385.17 (Change to Safety Rating Based upon Corrective Actions). Any challenges to information provided by state agencies must be resolved by the appropriate state agency.
How A&I Online Secures Information
User access controls were developed to ensure that the number of individuals with access to restricted information in A&I Online was kept to a minimum and was restricted to only those with a need to know. This strategy improves data confidentiality and integrity. These access controls were developed in accordance with Federal Information Processing Standards (FIPS) Publication 200, Minimum Security Requirements for Federal Information and Information Systems dated March 2006 and National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53 Rev. 2, Recommended Security Controls for Federal Information Systems dated December 2007. Audit provisions were also included to ensure that A&I Online is used appropriately by authorized users and monitored for unauthorized usage.
The data center in which A&I Online operates is a restricted access facility. Except for a small list of personnel with trusted access privileges, DOT personnel and contractors are required to sign in and sign out, give the purpose and estimated time of their visit, and be escorted by someone with trusted access privileges. A&I Online requires FMCSA and State enforcement personnel to be authenticated with a valid user name and password, except for users of the public web application. The general public access is unrestricted via http://ai.fmcsa.dot.gov.
A certification and accreditation (C&A) is performed every three years to ensure that A&I Online meets FMCSA and federal security requirements. A&I Online also undergoes an additional C&A whenever a major change occurs to the system. A&I Online is assessed in accordance with the Office of Management and Budget (OMB) Circular A-130 Appendix III, Security of Federal Automated Information Resources and the DOT Certification and Accreditation Guidance.
Additional activities are performed more frequently to ensure that A&I Online complies with regulatory requirements. Continuous monitoring activities are also performed annually to provide ongoing oversight of security controls and to detect misuse of information stored in A&I. The FMCSA Continuous Monitoring Program includes the following activities:
- Configuration management and configuration control processes
- Security impact analyses on changes to the information system
- Regular assessments of select security controls in the information system
- Security status reports to appropriate agency officials
How Long A&I Online Retains Information
A&I Online retains and disposes of information in accordance with the approved records retention schedule as required by the National Archives and Records Administration (NARA).
The master files are logged and backed up. The master tape is retained in a secure offsite storage facility and then destroyed in accordance with applicable NARA retention schedule N1-557-05-07 Item #1. The master tape is designated for deletion under this retention schedule when 5 years old, when no longer needed, or when information is superseded or becomes obsolete, whichever is sooner.
System of Records
FMCSA and State enforcement personnel can retrieve reports by Driver's name and Driver's License Number. FMCSA is in the process of preparing a Privacy Act System of Records Notice for A&I Online that will be published in the Federal Register.