DEPARTMENT OF TRANSPORTATION
Federal Motor Carrier Safety Administration (FMCSA)
PRIVACY IMPACT ASSESSMENT
Computing Technologies, Inc. (CoTs) DOT LAN
June 15, 2009
TABLE OF CONTENTS
Overview of FMCSA privacy management process for COTS DOT LAN
Personally Identifiable Information (PII) and COTS DOT LAN
Why COTS DOT LAN collects information
How COTS DOT LAN uses information
How COTS DOT LAN shares information
How COTS DOT LAN provides notice and consent
How COTS DOT LAN ensures data accuracy
How COTS DOT LAN provides redress
How COTS DOT LAN secures information
How Long CoTs DOT LAN Retains Information
System of Records
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
To meet these goals, FMCSA partners with stakeholders including federal, state, and local enforcement agencies; the motor carrier industry; safety groups; and organized labor on efforts to reduce crashes involving motor carriers. Since the first step towards reducing accidents is to understand them, FMCSA collects and maintains commercial vehicle safety data as well as a national inventory of motor carriers and shippers subject to Federal Motor Carrier Safety Regulations (FMCSR) and Federal Hazardous Materials Regulations (FHMR). The CoTs DOT LAN assists FMCSA in managing this data. CoTs DOT LAN resides at and is maintained by Computing Technologies, Inc. (CoTs), an independent third-party contractor located in Fairfax, Virginia. CoTs DOT LAN is currently in the operations and maintenance phase of the system life cycle.
Information in CoTs DOT LAN is an exact copy of the Motor Carrier Information Management System (MCMIS) database and is refreshed every two weeks with new information from MCMIS. MCMIS information is uploaded onto McQuery, a server that resides on CoTs DOT LAN. MCMIS is a central repository for the efficient sharing of information about CMV drivers and motor carriers and is frequently accessed by Federal, State, foreign and local government agencies. In order to ensure that MCMIS continue to operate efficiently, CoTs DOT LAN is used to reduce the volume of information requests submitted to MCMIS.
Privacy management is an integral part of CoTs DOT LAN. 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 Personally Identifiable Information (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:
- 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 CoTs DOT LAN.
This Privacy Impact Assessment (PIA) was conducted because CoTs DOT LAN receives a snapshot of PII from MCMIS via McQuery, a server that resides on CoTs DOT LAN. The following PII is stored on CoTs DOT LAN:
- Commercial motor vehicle (CMV) driver name
- CMV driver date of birth
- CMV driver license number
- CMV driver social security number or employer identification number (if CMV driver is sole proprietor of motor carrier)
- CMV driver address (if CMV driver is sole proprietor of motor carrier)
- CMV driver phone number (if CMV driver is sole proprietor of motor carrier)
- Requestor or company name (if company is sole proprietorship)
- Requestor or company phone number or email address (if company is sole proprietorship).
CoTs DOT LAN does not collect information directly. It uses a copy of information that has been collected in MCMIS to generate data reports. This ensures that MCMIS operates efficiently by reducing the volume of information requests submitted to MCMIS.
Information in CoTs DOT LAN is used to fulfill data requests within FMCSA in the support of FMCSA operations. Data reports are generated for the following groups when requested:
- FMCSA Freedom of Information Act (FOIA) Office employees
- CoTs employees responsible for the support and maintenance of the CoTs DOT LAN
- Volpe Center contractors responsible for performing tests on MCMIS without causing disruptions to MCMIS operations
These reports may include the names, addresses, or phone numbers of CMV drivers if these drivers are the sole proprietor of a motor carrier. Additionally, FMCSA may use requester PII (names and phone numbers or emails) when responding to data requests if the requestor is an individual or the sole proprietor of a business.
CoTs DOT LAN generates the following data reports that are disclosed to the public:
- Responses to FOIA requests
- Responses to other information requests from the public for a fee
- Data approved for release to the general public (such as press release data)
PII may be included in data reports disclosed to the public if the reports contain the company name, address, or phone number of sole proprietorships. Any other disclosures of PII would be as described in the Prefatory Statement of Routine Uses, etc.
Requests for information stored in CoTs DOT LAN cannot be submitted directly to CoTs DOT LAN. Users are required to download a request form from the MCMIS catalog on the MCMIS website, complete the form manually, and mail the completed form along with a check for payment to the FMCSA Data Dissemination Program in Merrifield, VA. The amount of the check and check number is stored in CoTs DOT LAN. The account information is not stored in CoTs DOT LAN.
MCMIS, which is the source for information stored in CoTs DOT LAN, requires motor carriers to submit a Motor Carrier Identification Report (MCS-150) to obtain a USDOT Number. MCMIS uses internal validation functionality to ensure that all required data fields have been completed on MCS-150. FMCSA data entry contractors have a 3-step verification process to ensure that accurate information is entered in MCMIS. When an application is received, the first individual reviews the application to ensure that all required data elements are present. Another individual verifies that the data is correct. The final individual approves the information before it is entered into MCMIS. The federal and state information systems used to enter crash, inspection, and compliance review data (SAFETYNET, ASPEN, and CAPRI) contain internal validation functionality to ensure the data is complete and correct before it is submitted to MCMIS.
Requestors who provide PII via forms mailed to the FMCSA Data Dissemination Program when requesting data reports from CoTs DOT LAN provide their 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 report containing PII.
CoTs DOT LAN does not directly provide redress. The DataQs system 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. If the information is corrected, the change will be made in MCMIS. CoTs DOT LAN will receive the change through the data refresh.
Only those individuals with direct access to MCMIS (i.e., authorized internal federal and state employees, Volpe contractors, and CoTs employees) must read and agree to a warning message that discusses the penalties of unauthorized access before logging in.
User access controls were developed to ensure that the number of individuals with access to restricted information in CoTs DOT LAN 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. The FMCSA Office of Information Technology has provided guidance to assist CoTs contractors in protecting the confidentiality and integrity of PII associated with CoTs DOT LAN. Audit provisions were also included to ensure that CoTs DOT LAN is used appropriately by authorized users and monitored for unauthorized usage.
CoTs DOT LAN is housed in a building that is leased by CoTs, 3028 Javier Road, Suite 400, Fairfax, Virginia 22031. Most of this building is occupied by CoTs contractors and is not open to the general public. Firewalls and intrusion prevention systems are used to protect CoTs DOT LAN from intrusions and data loss.
Data access is determined by permission levels, and CoTs DOT LAN employs role-based access controls. User accounts are assigned access rights based on the roles and responsibilities of the individual user. Users are required to authenticate with a valid user name and password in order to gain access to CoTs DOT LAN.
A certification and accreditation (C&A) is performed every three years to ensure that CoTs DOT LAN meets FMCSA and federal security requirements. CoTs DOT LAN also undergoes an additional C&A whenever a major change occurs to the system. CoTs DOT LAN 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 CoTs DOT LAN complies with regulatory requirements. CoTs DOT LAN undergoes an annual risk assessment that identifies potential threats and risks associated with the LAN, and all identified risks are documented in a Plan of Action and Milestones (POA&M) for remediation by the system owner. As open risk items are resolved, the FMCSA IT Security Team updates the appropriate security documents with the new information. Continuous monitoring activities are also performed at least annually to provide ongoing oversight of security controls and to detect misuse of information stored in CoTs DOT LAN. The FMCSA Continuous Monitoring Program involves 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 CoTs DOT LAN to determine the extent of potential threats and associated risks throughout its systems development life cycle (SDLC) and security status reports to appropriate agency officials
Operating system and application patches are verified weekly by CoTs contractors and monthly by the FMCSA IT Security Team.
CoTs DOT LAN retains CMV driver PII for two weeks. Requester PII is retained indefinitely. The Volpe Center sends a data refresh to CoTs every two weeks for uploading onto CoTs DOT LAN. FMCSA plans to use this system for 5 years.
Personal identifiers are not used to search for information in CoTs DOT LAN. Therefore, CoTs DOT LAN is not a Privacy Act system and does not require a SORN.