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Privacy Impact Assessment Update For The Advance Passenger Information System (Apis) - U.s. Department Of Homeland Security - 2013 Page 5

Privacy Impact Assessment Update

CBP, APIS PIA Update

Page 5

determine appropriate temporary retention periods for DHS datasets on a system-by-system

basis. This Framework includes factors related to the sensitivity of a dataset and operational

considerations. Factors related to the sensitivity of a dataset include: the circumstances of

collection, the amount of U.S. Person information in the dataset, and the sensitivity of the

particular data fields (e.g., sensitive personally identifiable information) that are requested.

Operational factors include: the mission benefits to DHS, the mission benefits to NCTC, and

any limitations for the DHS data steward (e.g., DHS’s own retention period for the dataset).

Using the Data Retention Framework of Factors, DHS and NCTC agreed to a one year

temporary retention period for all APIS information provided to NCTC.

This temporary

retention period matches DHS’s own retention period for APIS information.

The 2013 MOA documents NCTC’s expanded temporary retention period and augments

the privacy protections of the 2011 agreement with NCTC. The MOA augments privacy

protections related to transparency, redress, and oversight. To promote transparency, the MOA

requires DHS and NCTC to develop public PIAs that provide notice regarding the existence and

contents of the MOA and to cooperate to promote transparency through efforts such as joint

presentations to Congress and the DHS Data Privacy and Integrity Advisory Committee. With

respect to redress, the MOA requires NCTC to establish a redress mechanism for individuals

whose PII has been retained as terrorism information. The redress process will direct any request

for correction or redress to DHS for resolution, as appropriate. For any records corrected by

DHS through this process, NCTC will correct those records in its possession when it receives a

notification of the correction from DHS. To increase oversight, DHS and NCTC have refined

the quarterly reporting requirements regarding NCTC’s use and retention of the DHS

information. Additionally, the MOA allows DHS to assign an on-site oversight representative to

NCTC to provide intelligence, data stewardship, privacy, civil rights, and civil liberties oversight

of the handling of DHS information by NCTC.

Privacy Impact Analysis

The System and the Information Collected and Stored within the System

There is no change in the collection of APIS records.

Uses of the System and the Information

There are no changes to the uses of the information.

Privacy Impact Assessment Update For The Advance Passenger Information System (Apis) - U.s. Department Of Homeland Security - 2013 Page 5