DEPARTMENT OF TRANSPORTATION
Office of the Secretary of Transportation (OST)

 PRIVACY IMPACT ASSESSMENT 

 The Case Tracking System (CTS)

November 12, 2008

TABLE OF CONTENTS

Overview of Privacy Management Process
Personally Identifiable Information (PII) & CTS
Why CTS Collects Information
How CTS uses information
How CTS Shares Information
How CTS Provides Notice and Consent
How CTS Ensures Data Accuracy
TSS Provides Redress
How CTS Secures Information
How Long CTS Retains Information
System of Records

Overview of Privacy Management Process

The Case Tracking System (CTS) allows users to track cases assigned to the Office of Hearings, and manage caseloads and casework. Users can assign judges, lawyers, and interns to specific cases and track actions taken on the case. Once a case is finalized and a decision is issued, cases are closed and data is archived for future reference.

Privacy management is an integral part of the Department of Transportation (DOT) CTS. The Office of the Secretary (OST) 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 OST will have the information, tools and technology necessary to manage privacy effectively and employ the highest level of fair information practices while allowing OST to achieve its mission of protecting and enhancing the U.S. transportation system. The methodology is based upon the following steps:

• Establish priority, authority, and responsibility. Appointing a cross-functional privacy management team to ensure input from systems architecture, technology, security, legal, and other disciplines necessary to ensure that an effective privacy management program is developed.
• Assess the current privacy environment. This involves interviews with key individuals involved in the CTS system to ensure that privacy risks are identified, addressed and documented.
• Organize the resources necessary for the project’s goals. Internal OST resources, along with outside experts, are involved in reviewing the technology, data uses, and associated risks. They are also involved in developing the necessary redress systems and training programs.
• Develop the policies, practices, and procedures. The resources identified in the paragraph above work to develop effective policies, practices, and procedures to ensure that fair information practices are complied with. The policies are designed to protect privacy effectively while allowing OST to achieve its mission.
• Implement the policies, practices, and procedures. Once the policies, practices, and procedures are developed, they must be implemented. This involves training all individuals who will have access to and/or process personally identifiable information (PII). It also entails working with vendors to ensure that they maintain the highest standard for privacy while providing services to the OST project.
• Maintain policies, practices, and procedures. Due to changes in technology, personnel and other aspects of any program, effective privacy management requires that technology and information be available to the privacy management team to ensure that privacy policies, practices, and procedures continue to reflect actual practices. Regular monitoring of compliance is required.
• Manage exceptions and/or problems with the policies, practices, and procedures. This step involves the development and implementation of an effective redress and audit system to ensure that any complaints are effectively addressed and corrections made, if necessary.

Personally Identifiable Information (PII) & CTS

CTS allows users to track cases assigned to the Office of Hearings, and manage caseloads and casework. As such, it contains information on individuals that includes names, position, phone numbers, duty titles and addresses.  

The CTS modules will contain and publicly post the following information: CTS does not publicly post any PII information.

Why CTS Collects Information

CTS collects the PII in order to effectively track case assignments.

How CTS uses information

OST personnel enter case assignment information and then manage alterations and subsequent contacts with scheduled personnel.

How CTS Shares Information

In accordance with Sections A4 and A5 of the CTS System Security Plan, CTS is located in DOT’s Common Operating Environment (COE). The system does not share data with other systems.

How CTS Provides Notice and Consent

CTS displays the DOT approved system warning banner to alert users of notice and consent to monitoring prior to login.

How CTS Ensures Data Accuracy

CTS employs the data accuracy checks inherit in MS SQL 2000 database software to ensure data validity and accuracy. The system has been reviewed to ensure, to the greatest extent possible, it is accurate, relevant, timely and complete via security testing and evaluation.

How CTS Provides Redress

Validation checks are built into the application software that both prompt the user that an incorrect entry has been entered and must be corrected, and that a user has successfully input data.

How CTS Secures Information

CTS takes appropriate security measures to safeguard PII and other sensitive data. CTS applies DOT security standards, including but not limited to routine scans and monitoring, back-up activities, and background security checks of OST employees and contractors.

How Long CTS Retains Information

CTS retains PII information for a minimum of one year.

System of Records

CTS contains information that is part of existing System of Records subject to the Privacy Act, because it can be searched by an individual’s name, position, address and phone number. In most instances, DOT/OST 12 applies and the Department of Transportation controls the data and maintains System of Records responsibilities.

OST has certified and accredited the security of CTS in accordance with DOT information technology security standard requirements.