United States Government Accountability Office

GAO Report to the Chairman, Committee on 

Appropriations, House of 

Representatives 

DATA MINING 

Early Attention to 

Privacy in Developing 

a Key DHS Program 

Could Reduce Risks 

February 2007 

 

GAO-07-293 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

February 2007

DATA MINING

Early Attention to Privacy in Developing a 

Highlights of GAO-07-293, a report to the Key DHS Program Could Reduce Risks 

Chairman, Committee on Appropriations, 

House of Representatives

The government’s interest in using 

technology to detect terrorism and 

other threats has led to increased 

use of data mining. A technique for 

extracting useful information from

large volumes of data, data mining 

offers potential benefits but also 

raises privacy concerns when the 

data include personal information. 

GAO was asked to review the 

development by the Department of

Homeland Security (DHS) of a data 

mining tool known as ADVISE 

(Analysis, Dissemination, 

Visualization, Insight, and Semantic

Enhancement). Specifically, GAO

was asked to determine (1) the

tool’s planned capabilities, uses, 

and associated benefits and 

(2) whether potential privacy 

issues could arise from using it to

process personal information and

how DHS has addressed any such

issues. GAO reviewed program 

documentation and discussed these 

issues with DHS officials. 

What GAO Recommends

To ensure that privacy protections

are in place, GAO is recommending

that the Secretary of Homeland

Security immediately conduct a 

privacy impact assessment of the 

ADVISE tool and implement 

privacy controls, as needed, to

mitigate any identified risks. 

DHS generally agreed with the 

content of this report and 

described actions initiated to 

address GAO’s recommendations. 

ADVISE is a data mining tool under development intended to help DHS 

analyze large amounts of information. It is designed to allow an analyst to 

search for patterns in data—such as relationships among people, 

organizations, and events—and to produce visual representations of these 

patterns, referred to as semantic graphs (see fig.). None of the three planned 

DHS implementations of ADVISE that GAO reviewed are fully operational.

(GAO did not review uses of the tool by the DHS Office of Intelligence and 

Analysis.) The intended benefit of the ADVISE tool is to help detect 

threatening activities by facilitating the analysis of large amounts of data. 

DHS is currently in the process of testing the tool’s effectiveness.

Use of the ADVISE tool raises a number of privacy concerns. DHS has added 

security controls to the tool; however, it has not assessed privacy risks.

Privacy risks that could apply to ADVISE include the potential for erroneous 

association of individuals with crime or terrorism and the misidentification 

of individuals with similar names. A privacy impact assessment would 

identify specific privacy risks and help officials determine what controls are 

needed to mitigate those risks. ADVISE has not undergone such an 

assessment because DHS officials believe it is not needed given that the tool 

itself does not contain personal data. However, the tool’s intended uses 

include applications involving personal data, and the E-Government Act and 

related guidance emphasize the need to assess privacy risks early in systems 

development. Further, if an assessment were conducted and privacy risks 

identified, a number of controls could be built into the tool to mitigate those 

risks. For example, controls could be implemented to ensure that personal 

information is used only for a specified purpose or compatible purposes, and 

they could provide the capability to distinguish among individuals that have 

similar names to address the risk of misidentification. Because privacy has 

not been assessed and mitigating controls have not been implemented, DHS 

faces the risk that ADVISE-based system implementations containing 

personal information may require costly and potentially duplicative 

retrofitting at a later date to add the needed controls. 

Generic Semantic Graph 

www.gao.gov/cgi-bin/getrpt?GAO-07-293.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Linda Koontz at

(202) 512-6240 or koontzl@gao.gov. 
Contents 

Letter 1

Results in Brief 2

Background 4

ADVISE Is Intended to Help Identify Patterns of Interest to 

Homeland Security Analysts 13 

DHS Has Not Yet Addressed Key Privacy Risks Associated with 

Expected Uses of the ADVISE Tool 18 

Conclusions 23

Recommendations for Executive Action 23 

Agency Comments and Our Evaluation 24 

Appendix I Objectives, Scope, and Methodology 26 

Appendix II Comments from the Department of Homeland 

Security 27 

Appendix III GAO Contact and Staff Acknowledgments 30 

Table 

Table 1: Fair Information Practices 12 

Figures 

Figure 1: An Overview of the Data Mining Process 5 

Figure 2: Major Elements and Functions of ADVISE 14 

Figure 3: Typical Semantic Graph 16 

Page i GAO-07-293 Data Mining
Abbreviations 

ADVISE Analysis, Dissemination, Visualization, Insight, and 

 Semantic Enhancement 

DHS Department of Homeland Security 

ICAHST Interagency Center for Applied Homeland Security 

 Technology 

OECD Organization for Economic Cooperation and 

 Development 

OMB Office of Management and Budget 

PIA privacy impact assessment 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page ii GAO-07-293 Data Mining
United States Government Accountability Office

Washington, DC 20548 

 

February 28, 2007 

The Honorable David R. Obey 

Chairman, Committee on Appropriations 

House of Representatives 

Dear Mr. Chairman: 

Since the terrorist attacks of September 11, 2001, there has been an 

increasing focus on the need to prevent and detect terrorist threats 

through technological means. Data mining—a technique for extracting 

useful information from large volumes of data—is one type of analysis that 

has been used increasingly by the government to help detect terrorist 

threats. While data mining offers a number of promising benefits, its use 

also raises privacy concerns when the data include personal information.1

Federal agency use of personal information is governed primarily by the 

Privacy Act of 1974 and the E-Government Act of 2002, which prescribe 

specific activities that agencies must perform to protect privacy, such as 

(1) ensuring that personal information is used only for a specified purpose, 

or related purposes, and that it is accurate for those purposes and 

(2) conducting assessments of privacy risks associated with information 

technology used to process personal information, known as privacy 

impact assessments.2

 Agencies that wish to reap the potential benefits of 

data mining are faced with the challenge of implementing adequate 

privacy controls for the systems that they use to perform these analyses.

You asked us to review the Department of Homeland Security’s (DHS) 

development of an analytical tool known as Analysis, Dissemination, 

Visualization, Insight, and Semantic Enhancement (ADVISE). Specifically, 

we agreed with your staff that our objectives were to determine (1) the 

planned capabilities, uses, and associated benefits of the ADVISE tool and 

(2) whether potential privacy issues could arise from using ADVISE to 

 1

For purposes of this report, the term personal information encompasses all information 

associated with an individual, including both identifying and nonidentifying information. 

Personally identifying information, which can be used to locate or identify an individual,

includes things such as names, aliases, and agency-assigned case numbers. 

2

A privacy impact assessment is an analysis of how personal information is collected, 

stored, shared, and managed in a federal system to ensure that privacy requirements are

addressed. 

Page 1 GAO-07-293 Data Mining
process personal information and how DHS has addressed any such 

issues. Our review did not include intelligence applications, such as uses 

of the tool by the DHS Office of Intelligence and Analysis. 

To address our first objective, we identified and analyzed the ADVISE 

tool’s planned capabilities, uses, and associated benefits. We reviewed 

program documentation, including annual program execution plans, and 

interviewed agency officials responsible for managing and implementing 

the program. We also interviewed officials at DHS components that have 

begun to implement the tool3

 in order to identify their current or planned 

uses, the progress of their implementation, and the benefits they hope to

gain. 

To address our second objective, we searched for potential privacy 

concerns by reviewing relevant reports, including prior GAO reports and 

the DHS Privacy Office 2006 report on data mining.4

 We identified and 

analyzed actions to comply with the Privacy Act of 1974 and the 

E-Government Act of 2002. We also interviewed technical experts within 

the DHS Science and Technology Directorate and personnel responsible 

for implementing ADVISE at DHS components to assess privacy controls 

included in the ADVISE tool, as well as the quality assurance processes for 

data analyzed using ADVISE. We performed our work from June 2006 to 

December 2006 in the Washington, D.C., metropolitan area and Laurel, 

Maryland. Our work was performed in accordance with generally accepted 

government auditing standards. Our objectives, scope, and methodology 

are discussed in more detail in appendix I. 

ADVISE is a data mining tool under development that is intended to 

facilitate the analysis of large amounts of data. It is designed to

accommodate both structured data (such as information in a database) 

and unstructured data (such as e-mail texts, reports, and news articles) 

and to allow an analyst to search for patterns in data, including

relationships among entities (such as people, organizations, and events), 

Results in Brief 

 3

These DHS components include Immigration and Customs Enforcement and other

components. We also interviewed officials from the Interagency Center of Applied 

Homeland Security Technology, who are responsible for testing the tool’s capabilities. 

ADVISE is also being used by the Office of Intelligence and Analysis. We did not review 

that application. 

4

DHS, Data Mining Report: DHS Privacy Office Response to House Report 108-774 (July

6, 2006). 

Page 2 GAO-07-293 Data Mining
and to produce visual representations of these patterns, referred to as 

semantic graphs. Although none are fully operational, DHS’s planned uses 

of this tool include implementations at four departmental components 

(including Immigration and Customs Enforcement and other

components).5

 DHS is also considering further deployments of ADVISE. 

The intended benefit of the ADVISE tool is to help detect activities that 

threaten the United States by facilitating the analysis of large amounts of 

data that otherwise would be very difficult to review. DHS is currently in 

the process of testing the tool’s effectiveness. 

Use of the ADVISE tool raises a number of privacy concerns. DHS has 

added security controls to the ADVISE tool, including access restrictions, 

authentication procedures, and security auditing capability. However, it 

has not assessed privacy risks. Privacy risks that could apply to ADVISE 

include the potential for erroneous association of individuals with crime 

or terrorism, the misidentification of individuals with similar names, and 

the use of data that were collected for other purposes. A privacy impact 

assessment would determine the specific privacy risks associated with 

ADVISE and help officials determine what controls are needed to mitigate

those risks. Although DHS officials are considering conducting a modified 

version of such an assessment, the ADVISE tool has not yet been assessed 

because department officials believe it is not needed given that the 

ADVISE tool itself does not contain personal data. However, the tool’s 

intended uses include applications involving personal information, and the 

E-Government Act, as well as related Office of Management and Budget 

and DHS guidance, emphasize the need to assess privacy risks early in 

systems development. Further, if a privacy impact assessment were 

conducted now and privacy risks identified, a number of controls exist 

that could be built into the tool to mitigate those risks. For example, 

controls could be implemented to ensure that personal information is used 

only for a specified purpose or compatible purposes, or they could provide 

the capability to distinguish among individuals that have similar names (a 

process known as disambiguation) to address the risk of misidentification. 

Because privacy risks such as these have not been assessed and decisions 

about mitigating controls have not been made, DHS faces the likelihood 

that ADVISE-based system implementations containing personal 

information may require costly and potentially duplicative retrofitting at a

later date to add the needed privacy controls. 

 5

ADVISE is also being used by the Office of Intelligence and Analysis. We did not review 

that application. 

Page 3 GAO-07-293 Data Mining
To ensure that privacy protections are in place before DHS proceeds with 

implementations of systems based on ADVISE, we are recommending that

the Secretary of Homeland Security immediately conduct a privacy impact

assessment of the ADVISE tool to identify privacy risks and implement 

privacy controls to mitigate those risks. 

We obtained oral and written comments on a draft of this report from 

DHS. In its comments DHS generally agreed with the content of this report 

and described actions initiated to address our recommendations. 

As defined in a report that we issued in May 2004,

6

 data mining is the 

application of database technology and techniques—such as statistical 

analysis and modeling—to uncover hidden patterns and subtle 

relationships in data and to infer rules that allow for the prediction of 

future results. This definition is based on the most commonly used terms 

found in a survey of the technical literature. 

Background 

Data mining has been used successfully for a number of years in the 

private and public sectors in a broad range of applications. In the private

sector, these applications include customer relationship management, 

market research, retail and supply chain analysis, medical analysis and 

diagnostics, financial analysis, and fraud detection. In the government, 

data mining has been used to detect financial fraud and abuse. For 

example, we used data mining to identify fraud and abuse in expedited 

assistance and other disbursements to Hurricane Katrina victims.7

Although the characteristics of data mining efforts can vary greatly, data

mining generally incorporates three processes: data input, data analysis, 

and results output. In data input, data are collected in a central data 

“warehouse,” validated, and formatted for use in data mining. In the data 

analysis phase, data are typically queried to find records that match topics

of interest. The two most common types of queries are pattern-based 

queries and subject-based queries: 

 6

GAO, Data Mining: Federal Efforts Cover a Wide Range of Uses, GAO-04-548 

(Washington, D.C.: May 4, 2004). 

7

GAO, Expedited Assistance for Victims of Hurricane Katrina and Rita: FEMA’s Control

Weaknesses Exposed the Government to Significant Fraud and Abuse, GAO-06-403T 

(Washington, D.C.: Feb. 13, 2006). 

Page 4 GAO-07-293 Data Mining
• Pattern-based queries search for data elements that match or depart from 

a predetermined pattern (e.g., unusual claim patterns in an insurance 

program). 

• Subject-based queries search for any available information on a 

predetermined subject using a specific identifier. This could be personal 

information such as an individual identifier (e.g., an individual’s name or 

Social Security number) or an identifier for a specific object or location. 

For example, the Navy uses subject-based data mining to identify trends in 

the failure rate of parts used in its ships. 

The data analysis phase can be iterative, with the results of one query

being used to refine criteria for a subsequent query. The output phase can 

produce results in printed or electronic format. These reports can be 

accessed by agency personnel and can also be shared with personnel from 

other agencies. Figure 1 depicts a generic data mining process. 

Figure 1: An Overview of the Data Mining Process 

Sources: GAO, adapted from Vipin Kumar and Mohammed J. Zaki.

Data

warehouse

Data from the 

private sector

Data from 

public sources

Other federal 

data

Agency data

Input Analysis Output

Collected, linked, 

validated, and 

formatted

Results can be in 

printed or electronic 

format

Pattern-based query Results

Subject-based query

Iterative query

Analysis can be iterative with the 

results of one query being used to 

refine criteria for a subsequent query 

Results

Results

Iterative query Results

In recent years, data mining has emerged as a prevalent government 

mechanism for processing and analyzing large amounts of data. In our May 

2004 report, we noted that 52 agencies were using or were planning to use 

Page 5 GAO-07-293 Data Mining
data mining in 199 cases, of which 68 were planned, and 131 were 

operational. Additionally, following the terrorist attacks of September 11, 

2001, data mining has been used increasingly as a tool to help detect 

terrorist threats through the collection and analysis of public and private 

sector data. This may include tracking terrorist activities, including money 

transfers and communications, and tracking terrorists themselves through 

travel and immigration records. According to an August 2006 DHS Office 

of Inspector General survey of departmental data mining initiatives,8

 DHS 

is using or developing 12 data mining programs, 9 of which are fully 

operational and 3 of which are still under development. 

One such effort is the ADVISE technology program. Managed by the DHS 

Science and Technology Directorate,9

 the ADVISE program is primarily 

responsible for (1) continuing to develop the ADVISE data mining tool and 

(2) promoting and supporting its implementation throughout DHS. 

According to program officials, it has spent approximately $40 million to 

develop the tool since 2003. 

To promote the possible implementation of the tool within DHS 

component organizations, program officials have made demonstrations 

(using unclassified data) to interested officials, highlighting the tool’s 

planned capabilities and expected benefits. Program officials have 

established working relationships with component organizations that are 

considering adopting the tool, including detailing them staff (typically

contractor-provided) to assist in the setup and customization of their 

ADVISE implementation and providing training for the analysts who are to 

use it. 

Program officials project that implementation of the tool at a component 

organization should generally consist of six main phases and take 

approximately 12 to 18 months to complete. The six phases are as follows: 

• preparing infrastructure and installing hardware and software; 

• modeling information sources and loading data; 

 8

DHS Office of Inspector General, Survey of DHS Data Mining Activities (August 2006).

9

The mission of the Science and Technology Directorate is to act as the primary research 

and development arm of DHS, providing federal, state, and local officials with the

technology and capabilities to protect the United States homeland. 

Page 6 GAO-07-293 Data Mining
• verifying and validating that loaded data are accurate and accessible; 

• training and familiarizing analysts and assisting in the development of 

initial research activities using visualization tools; 

• supporting analysts in identifying the best ways to use ADVISE for their 

problems, obtaining data, and developing ideas for further improvements; 

and 

• turning over deployment to the component organizations to maintain the 

system and its associated data feeds.

The program has also provided initial funding for the setup, customization, 

and pilot testing of implementations within components, under the 

assumption that when an implementation achieves operational status, the

respective component will take over operations and maintenance costs. 

Program officials estimate that the tool’s operations and maintenance 

costs will be approximately $100,000 per year, per analyst. The program 

has also offered additional support to components implementing the tool,

such as helping them develop privacy compliance documentation. 

According to DHS officials, the program has spent $12.15 million of its $40 

million in support of several pilot projects and test implementations 

throughout the department. 

Currently, the department’s Interagency Center for Applied Homeland 

Security Technologies (ICAHST) group within the Science and Technology 

Directorate is testing the tool’s effectiveness, adequacy, and costeffectiveness as a data mining technology. ICAHST has completed 

preliminary testing of basic functionality and is currently in the process of

testing the system’s effectiveness, using mock data to test how well 

ADVISE identifies specified patterns of interest. 

The impact of computer systems on the ability of organizations to protect 

personal information was recognized as early as 1973, when a federal 

advisory committee on automated personal data systems observed that 

“The computer enables organizations to enlarge their data processing 

capacity substantially, while greatly facilitating access to recorded data, 

both within organizations and across boundaries that separate them.” In 

addition, the committee concluded that “The net effect of computerization 

Privacy Concerns Have 

Been Raised Regarding 

Data Mining 

Page 7 GAO-07-293 Data Mining
is that it is becoming much easier for record-keeping systems to affect 

people than for people to affect record-keeping systems.” 10

In May 2004, we reported that mining government and private databases 

containing personal information creates a range of privacy concerns.11

Through data mining, agencies can quickly and efficiently obtain 

information on individuals or groups by searching large databases 

containing personal information aggregated from public and private 

records. Information can be developed about a specific individual or a 

group of individuals whose behavior or characteristics fit a specific 

pattern. The ease with which organizations can use automated systems to 

gather and analyze large amounts of previously isolated information raises 

concerns about the impact on personal privacy. 

Further, we reported in August 200512 that although agencies responsible 

for certain data mining efforts took many of the key steps required by 

federal law and executive branch guidance for the protection of personal 

information, none followed all key procedures. Specifically, while three of 

the four agencies we reviewed had prepared privacy impact assessments 

(PIA)—assessments of privacy risks associated with information 

technology used to process personal information—for their data mining 

systems, none of them had completed a PIA that adequately addressed all 

applicable statutory requirements. We recommended that four agencies 

complete or revise PIAs for their systems to fully comply with applicable 

guidance. As of December 2006, three of the four agencies reported that 

they had taken action to complete or revise their PIAs. 

Federal law includes a number of separate statutes that provide privacy 

protections for information used for specific purposes or maintained by 

specific types of entities. The major requirements for the protection of 

personal privacy by federal agencies come from two laws, the Privacy Act

of 1974 and the privacy provisions of the E-Government Act of 2002. The 

Federal Laws and 

Guidance Define Steps to 

Protect Privacy of 

Personal Information 

 10U.S. Department of Health, Education, and Welfare, Records, Computers and the Rights 

of Citizens: Report of the Secretary’s Advisory Committee on Automated Personal Data

Systems (Washington, D.C.: July 1973). 

11GAO-04-548. 

12GAO, Data Mining: Agencies Have Taken Key Steps to Protect Privacy in Selected

Efforts, but Significant Compliance Issues Remain, GAO-05-866 (Washington, D.C.: Aug.

15, 2005). 

Page 8 GAO-07-293 Data Mining
Office of Management and Budget (OMB) is tasked with providing 

guidance to agencies on how to implement the provisions of both laws and 

has done so, beginning with guidance on the Privacy Act, issued in 1975. 

The Privacy Act places limitations on agencies’ collection, disclosure, and 

use of personal information maintained in systems of records. The act

describes a “record” as any item, collection, or grouping of information 

about an individual that is maintained by an agency and contains his or her 

name or another personal identifier. It also defines “system of records” as 

a group of records under the control of any agency from which 

information is retrieved by the name of the individual or by an individual

identifier. The Privacy Act requires that when agencies establish or make 

changes to a system of records, they must notify the public through a 

“system of records notice”: that is, a notice in the Federal Register

identifying, among other things, the type of data collected, the types of 

individuals about whom information is collected, the intended “routine” 

uses of data, and procedures that individuals can use to review and correct 

personal information.13 In addition, the act requires agencies to publish in 

the Federal Register notice of any new or intended use of the information 

in the system, and provide an opportunity for interested persons to submit 

written data, views, or arguments to the agency. 

Several provisions of the act require agencies to define and limit 

themselves to specific predefined purposes. For example, the act requires 

that to the greatest extent practicable, personal information should be 

collected directly from the subject individual when it may affect an 

individual’s rights or benefits under a federal program. The act also 

requires that an agency inform individuals whom it asks to supply 

information of (1) the authority for soliciting the information and whether 

disclosure of such information is mandatory or voluntary; (2) the principal 

purposes for which the information is intended to be used; (3) the routine 

uses that may be made of the information; and (4) the effects on the 

individual, if any, of not providing the information. In addition, the act 

requires that each agency that maintains a system of records store only 

such information about an individual as is relevant and necessary to 

accomplish a purpose of the agency.

 13Under the Privacy Act of 1974, the term “routine use” means (with respect to the

disclosure of a record) the use of such a record for a purpose that is compatible with the

purpose for which it was collected. 5 U.S.C. § 552a(a)(7). 

Page 9 GAO-07-293 Data Mining
Agencies are allowed to claim exemptions from some of the provisions of 

the Privacy Act if the records are used for certain purposes. For example, 

records compiled for criminal law enforcement purposes can be exempt 

from a number of provisions, including (1) the requirement to notify 

individuals of the purposes and uses of the information at the time of 

collection and (2) the requirement to ensure the accuracy, relevance, 

timeliness, and completeness of records. In general, the exemptions for 

law enforcement purposes are intended to prevent the disclosure of 

information collected as part of an ongoing investigation that could impair 

the investigation or allow those under investigation to change their 

behavior or take other actions to escape prosecution. 

The E-Government Act of 2002 strives to enhance protection for personal 

information in government information systems or information collections 

by requiring that agencies conduct PIAs. As described earlier, a PIA is an 

analysis of how personal information is collected, stored, shared, and 

managed in a federal system. More specifically, according to OMB 

guidance,

14 a PIA is an analysis of how 

...information is handled: (i) to ensure handling conforms to applicable legal, regulatory,

and policy requirements regarding privacy; (ii) to determine the risks and effects of 

collecting, maintaining, and disseminating information in identifiable form in an electronic 

information system; and (iii) to examine and evaluate protections and alternative processes 

for handling information to mitigate potential privacy risks. 

Agencies must conduct PIAs before (1) developing or procuring 

information technology that collects, maintains, or disseminates 

information that is in a personally identifiable form or (2) initiating any 

new data collections involving personal information that will be collected, 

maintained, or disseminated using information technology if the same 

questions are asked of 10 or more people. OMB guidance also requires 

agencies to conduct PIAs in two specific types of situations: (1) when, as a 

result of the adoption or alteration of business processes, government 

databases holding information in personally identifiable form are merged, 

centralized, matched with other databases, or otherwise significantly 

manipulated and (2) when agencies work together on shared functions 

 14OMB, Guidance for Implementing the Privacy Provisions of the E-Government Act of 

2002, Memorandum M-03-22 (Washington, D.C.: Sept. 26, 2003). 

Page 10 GAO-07-293 Data Mining
involving significant new uses or exchanges of information in personally 

identifiable form.15

DHS has also developed its own guidance16 requiring PIAs to be performed 

when one of its offices is developing or procuring any new technologies or

systems, including classified systems, that handle or collect personally 

identifiable information. It also requires that PIAs be performed before 

pilot tests are begun for these systems or when significant modifications 

are made to them. Furthermore, DHS has prescribed detailed requirements 

for PIAs. For example, PIAs must describe all uses of the information, and 

whether the system analyzes data in order to identify previously unknown 

patterns or areas of note or concern.

The Privacy Act of 1974 is largely based on a set of internationally 

recognized principles for protecting the privacy and security of personal 

information known as the Fair Information Practices. A U.S. government 

advisory committee first proposed the practices in 1973 to address what it 

termed a poor level of protection afforded to privacy under contemporary 

law.17 The Organization for Economic Cooperation and Development 

(OECD)18 developed a revised version of the Fair Information Practices in 

1980 that has, with some variation, formed the basis of privacy laws and 

related policies in many countries, including the United States, Germany, 

Fair Information Practices 

 15A PIA may not be required for all systems. For example, no assessment is required when

the information collected relates to internal government operations, when the information 

has been previously assessed under an evaluation similar to a PIA, or when privacy issues

are unchanged. 

16DHS Privacy Office, PIA Official Guidance (March 2006). 

17U.S. Department of Health, Education, and Welfare, Records, Computers and the Rights 

of Citizens: Report of the Secretary’s Advisory Committee on Automated Personal Data

Systems (Washington, D.C.: July 1973). 

18OECD, Guidelines on the Protection of Privacy and Transborder Flow of Personal Data

(Sept. 23, 1980). The OECD plays a prominent role in fostering good governance in the 

public service and in corporate activity among its 30 member countries. It produces

internationally agreed-upon instruments, decisions, and recommendations to promote rules

in areas where multilateral agreement is necessary for individual countries to make

progress in the global economy. 

Page 11 GAO-07-293 Data Mining
Sweden, Australia, New Zealand, and the European Union.19 The eight 

principles of the OECD Fair Information Practices are shown in table 1.

Table 1: Fair Information Practices

Principle Description

Collection limitation The collection of personal information should be limited, should 

be obtained by lawful and fair means, and, where appropriate, 

with the knowledge or consent of the individual. 

Data quality Personal information should be relevant to the purpose for 

which it is collected, and should be accurate, complete, and 

current as needed for that purpose. 

Purpose specification The purposes for the collection of personal information should 

be disclosed before collection and upon any change to that 

purpose, and its use should be limited to those purposes and 

compatible purposes. 

Use limitation Personal information should not be disclosed or otherwise used 

for other than a specified purpose without consent of the 

individual or legal authority. 

Security safeguards Personal information should be protected with reasonable 

security safeguards against risks such as loss or unauthorized 

access, destruction, use, modification, or disclosure. 

Openness The public should be informed about privacy policies and 

practices, and individuals should have ready means of learning 

about the use of personal information. 

Individual participation Individuals should have the following rights: to know about the 

collection of personal information, to access that information, to 

request correction, and to challenge the denial of those rights. 

Accountability Individuals controlling the collection or use of personal 

information should be accountable for taking steps to ensure 

the implementation of these principles. 

Source: OECD. 

The Fair Information Practices are not precise legal requirements. Rather,

they provide a framework of principles for balancing the need for privacy

with other public policy interests, such as national security, law 

enforcement, and administrative efficiency. Ways to strike that balance 

vary among countries and according to the type of information under 

consideration. 

 19European Union Data Protection Directive (“Directive 95/46/EC of the European 

Parliament and of the Council of 24 October 1995 on the Protection of Individuals with 

Regard to the Processing of Personal Data and the Free Movement of Such Data”) (1995). 

Page 12 GAO-07-293 Data Mining
ADVISE is a data mining tool under development that is intended to 

facilitate the analysis of large amounts of data. It is designed to

accommodate both structured data (such as information in a database) 

and unstructured data (such as e-mail texts, reports, and news articles) 

and to allow an analyst to search for patterns in data, including

relationships among entities (such as people, organizations, and events) 

and to produce visual representations of these patterns, referred to as 

semantic graphs. Although none are fully operational, DHS’s planned uses 

of this tool include implementations at several departmental components, 

including Immigration and Customs Enforcement and other components. 

DHS is also considering further deployments of ADVISE. The intended

benefit of the ADVISE tool is to help detect activities that threaten the 

United States by facilitating the analysis of large amounts of data that 

otherwise would be prohibitively difficult to review. DHS is currently in 

the process of testing the tool’s effectiveness. 

ADVISE provides several capabilities that help to find and track 

relationships in data. These include graphically displaying the results of 

searches and providing automated alerts when predefined patterns of 

interest emerge in the data. The tool consists of three main elements—the 

Information Layer, Knowledge Layer, and Application Layer (depicted in

fig. 2). 

ADVISE Is Intended 

to Help Identify 

Patterns of Interest to 

Homeland Security 

Analysts 

The ADVISE Tool Provides 

Analytical Capabilities 

Intended to Identify 

Patterns of Interest to DHS 

Analysts 

Page 13 GAO-07-293 Data Mining
Figure 2: Major Elements and Functions of ADVISE 

Source: DHS.

Application Layer

Knowledge Layer

Information Layer

Analysis and visualization

Analysis component Consolidated data

Semantic 

graph

Structured 

information

Unstructured 

information

Knowledge Layer interface 

Information Layer interface 

Automated 

alert

At the Information Layer, disparate data are brought into the tool from 

various sources. These data sources can be both structured (such as 

computerized databases and watch lists) and unstructured (such as news 

feeds and text reports). For structured data, ADVISE contains software 

applications that load the data into the Information Layer and format it to 

conform to a specific predefined data structure, known as an ontology. 

Generally speaking, ontologies define entities (such as a person or place),

attributes (such as name and address), and the relationships among them. 

Information Layer 

For unstructured data, ADVISE includes several tools that extract 

information about entities and attributes. As with structured data, the 

output of these analyses is formatted and structured according to an 

ontology. Tagging information as specific entities and attributes is more 

difficult with unstructured data, and ADVISE includes tools that allow 

analysts to manually identify entities, attributes, and relationships among 

them. According to DHS officials, research is continuing on developing

Page 14 GAO-07-293 Data Mining
efficient and effective mechanisms for inputting different forms of 

unstructured data. 

ADVISE can also include information about the data—known as 

“metadata”—such as the time period to which the data pertain and 

whether the data refer to a U.S. person. ADVISE metadata also include 

confidence attributes, ranging from 1 to –1, which represent subjective 

assessments of the accuracy of the data. Each data source has a 

predefined confidence attribute. Analysts can change the confidence 

attribute of specific data, but changes to confidence levels are tracked and 

linked to the analysts making the changes. 

At the Knowledge Layer, facts and relationships from the Information 

Layer are consolidated into a large-scale semantic graph and various 

subgraphs. Semantic graphing is a data modeling technique that uses a 

combination of “nodes,” representing specific entities, and connecting 

lines, representing the relationships among them. Because they are wellsuited to representing data relationships and linkages, semantic graphs 

have emerged as a key technology for consolidating and organizing 

disparate data. Figure 3 represents the format that a typical semantic 

graph could take. The Knowledge Layer contains the semantic graph of all 

facts reported through the Information Layer interface and organized 

according to the ontology. 

Knowledge Layer 

Page 15 GAO-07-293 Data Mining
Figure 3: Typical Semantic Graph 

Source: GAO. 

Person of 

interest

Phone 

records

Financial 

transactions

No-fly lists

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30jeoedg094jape0re

095hg5eaeep49we0

49jitgap493304poa

wpollajoeire09gjfkdu

i04930jeoedg094jap

e0re095hg5eaeep4

9we049jitgap49330

4poawpollajoeire09g

jfkdui04930jeoedg0

94jape0re095hg5ea

eep49we049jitgap4

93304poawpollajoeir

e09gjfkdui04930jeo

edg094jape0re095h

g5eaeep49we049jit

gap493304poawpoll

ajoeire09gjfkdui049

30jeoedg094jape0re

095hg5eaeep49we0

49jitgap493304poa

4poaw polla joeire

Listed

Listed

Talked to

Talked to

Talked to

Talked to

Member of

Activities funded

Funded

Traveled to

Tra

Traveled to

veled to

Current events

Related to

Spending

Spending

Acquainted with

Organization 

affiliation

Person of 

interest

Countries

visited

Geopolitical events Banking 

activity

Airline manifests

Person of 

interest

Person of 

interest

Person of 

interest

Person of 

interest

Watch lists

The Knowledge Layer also includes the capability to provide automatic 

alerts to analysts when patterns of interest (or partial patterns) are 

matched by new incoming information. 

At the Application Layer, analysts are able to interact with the data that 

reside in the Knowledge Layer. The Application Layer contains tools that 

allow analysts to perform both pattern-based and subject-based queries 

and to search for data that match a specific pattern, as well as data that 

are connected with a specific entity. For example, analysts could search 

for all of the individuals who have traveled to a certain destination within 

a given period of time, or they could search for all information connected

with a particular person, place, or organization. The resulting output of 

these searches is then graphically displayed via semantic graphs. 

Application Layer 

ADVISE’s Application Layer also provides several other capabilities that

allow for the further examination and adjustment of its output. An analyst 

Page 16 GAO-07-293 Data Mining
can pinpoint nodes on a semantic graph to view and examine additional 

information related to them, including the source from which the 

information and relationships are derived, the data source’s confidence 

level, and whether the data pertain to U.S. persons. 

The ADVISE Application Layer also provides analysts the ability to 

monitor patterns of interest in the data. Science and Technology 

Directorate staff work with component staff to define patterns of interest 

and build an inventory of automated searches. These patterns are 

continuously being monitored in the data, and an alert is provided 

whenever there is a match. For example, an analyst could define a pattern 

of interest as “all individuals traveling from the United States to the Middle 

East in the next 6 months” and have the ADVISE tool provide an alert 

whenever this pattern emerges in the data. 

ADVISE Is Expected to 

Benefit DHS by Helping to 

Detect Potentially 

Threatening Activities 

The current planned uses of the ADVISE tool include implementations at 

several DHS components that are planning to use it in a variety of 

homeland security applications to further their respective organizational 

missions. Currently none of these implementations is fully operational or 

widely accessible to DHS analysts. Rather, they are all still in various 

phases of systems development. These applications are expected to use 

the tool primarily to help analysts detect threats to the United States, such

as identifying activities and/or individuals that could be associated with 

terrorism. 

The intended benefit of the ADVISE tool is to consolidate large amounts of 

structured and unstructured data and permit their analysis and 

visualization. The tool could thus assist analysts to identify and monitor 

patterns of interest that could be further investigated and might otherwise 

have been missed. 

None of the DHS components have fully implemented the tool in 

operational systems and, as discussed earlier, testing of the tool is still 

under way. Until such testing is complete and component implementations 

are fully operational, the intended benefit remains largely potential. 

Page 17 GAO-07-293 Data Mining
Use of the ADVISE tool raises a number of privacy concerns. DHS has 

added security controls to the ADVISE tool, including access restrictions, 

authentication procedures, and security auditing capability. However, it 

has not assessed privacy risks. Privacy risks that could apply to ADVISE 

include the potential for erroneous association of individuals with crime 

or terrorism through data that are not accurate for that purpose, the 

misidentification of individuals with similar names, and the use of data 

that were collected for other purposes. A PIA would determine the privacy 

risks associated with ADVISE and help officials determine what specific 

controls are needed to mitigate those risks. Although department officials 

believe a PIA is not needed given that the ADVISE tool itself does not 

contain personal data, the E-Government Act of 2002 and related federal 

guidance require the completion of PIAs from the early stages of 

development. Further, if a PIA were conducted and privacy risks 

identified, a number of controls exist that could be built into the tool to 

mitigate those risks. For example, controls could be implemented to 

ensure that personal information is used only for a specified purpose or 

compatible purposes, or they could provide the capability to distinguish 

among individuals that have similar names (a process known as 

disambiguation) to address the risk of misidentification. Because privacy 

risks such as these have not been assessed and decisions about mitigating

controls have not been made, DHS faces the likelihood that system 

implementations based on the tool may require costly and potentially 

duplicative retrofitting at a later date to add the needed controls. 

Like other data mining applications, the use of the ADVISE tool in 

conjunction with personal information raises concerns about a number of 

privacy risks that could potentially have an adverse impact on individuals. 

As the DHS Privacy Office’s July 2006 report on data mining activities 

notes, “privacy and civil liberties issues potentially arise in every phase of

the data mining process.” 20

DHS Has Not Yet 

Addressed Key 

Privacy Risks 

Associated with 

Expected Uses of the 

ADVISE Tool 

Potential Privacy Concerns 

Arise with the Use of the 

ADVISE Tool to Process 

Personal Information 

Potential privacy risks can be categorized in relation to the Fair 

Information Practices, which, as discussed earlier, form the basis for 

privacy laws such as the Privacy Act. For example, the potential for 

personal information to be improperly accessed or disclosed relates to the 

security safeguards principle, which states that personal information 

 20DHS, Data Mining Report: DHS Privacy Office Response to House Report 108-774 (July

6, 2006), p. 12. 

Page 18 GAO-07-293 Data Mining
should be protected against risks such as loss or unauthorized access, 

destruction, use, modification, or disclosure. Further, the potential for 

individuals to be misidentified or erroneously associated with

inappropriate activities is inconsistent with the data quality principle that 

personal data should be accurate, complete, and current, as needed for a 

given purpose. Similarly, the risk that information could be used beyond 

the scope originally specified is based on the purpose specification and 

use limitation principles, which state that, among other things, personal 

information should only be collected and used for a specific purpose and 

that such use should be limited to the specified purpose and compatible 

purposes. 

Like other data mining applications, the ADVISE tool could misidentify or 

erroneously associate an individual with undesirable activity such as 

fraud, crime, or terrorism—a result known as a false positive. False 

positives may be the result of poor data quality, or they could result from 

the inability of the system to distinguish among individuals with similar 

names. Data quality, the principle that data should be accurate, current, 

and complete as needed for a given purpose, could be particularly difficult

to ensure with regard to ADVISE because the tool brings together 

multiple, disparate data sources, some of which may be more accurate for 

the analytical purpose at hand than others. If data being analyzed by the

tool were never intended for such a purpose or are not accurate for that 

purpose, then conclusions drawn from such an analysis would also be 

erroneous. 

Another privacy risk is the potential for use of the tool to extend beyond 

the scope of what it was originally designed to address, a phenomenon 

commonly referred to as function or mission “creep.” Because it can

facilitate a broad range of potential queries and analyses and aggregate 

large quantities of previously isolated pieces of information, ADVISE could 

produce aggregated, organized information that organizations could be 

tempted to use for purposes beyond that which was originally specified 

when the information was collected. The risks associated with mission 

creep are relevant to the purpose specification and use limitation

principles. 

DHS Has Implemented 

Security Controls but Has 

Not Yet Assessed Privacy 

Risks 

To address security, DHS has included several types of controls in 

ADVISE. These include authentication procedures, access controls, and 

security auditing capability. For example, an analyst must provide a valid

user name and password in order to gain access to the tool. Further, upon 

gaining access, only users with appropriate security clearances may view 

Page 19 GAO-07-293 Data Mining
sensitive data sets. Each service requested by a user—such as issuing a 

query or retrieving a document—is checked against the user’s credentials

and access authorization before it is provided. In addition, these user 

requests and the tool’s responses to them are all recorded in an audit log. 

While inclusion of controls such as these is a key step in guarding against 

unauthorized access, use, disclosure, or modification, such controls alone 

do not address the full range of potential privacy risks. The need to 

evaluate such risks early in the development of information technology is 

consistently reflected in both law (the E-Government Act of 2002) and 

related federal guidance. The E-Government Act requires that a PIA be 

performed before an agency develops or procures information technology 

that collects, maintains, or disseminates information in a personally 

identifiable form. Further, both OMB and DHS PIA guidance emphasize 

the need to assess privacy risks from the early stages of development.21

However, although DHS officials are considering performing a PIA, no PIA 

or other privacy risk assessment has yet been conducted. The DHS Privacy

Office22 instructed the Science and Technology Directorate that a PIA was 

not required because the tool alone did not contain personal data.23

According to the Privacy Office rationale, only specific system

implementations based on ADVISE that contained personal data would 

likely require PIAs, and only at the time they first began to use such data. 

However, guidance on conducting PIAs makes it clear that they should be 

 21DHS PIA guidance states that “[t]he purpose of a PIA is to demonstrate that system 

owners and developers have consciously incorporated privacy protections throughout the

entire life cycle of a system. This involves making certain that privacy protections are built

into the system from the start, not after the fact when they can be far more costly or could

affect the viability of the project.” In addition, OMB guidance states that “[a]gencies should

commence a PIA when they begin to develop a new or significantly modified IT system.” 

22The DHS Privacy Office was created in response to the Homeland Security Act of 2002,

Pub. L. No. 107-296, § 222, 116 Stat. 2155 (Nov. 25, 2002). The Privacy Officer is responsible 

for, among other things, “assuring that the use of technologies sustain[s], and do[es] not 

erode privacy protections relating to the use, collection, and disclosure of personal 

information.” 

23It is important to note the distinction between the PIA requirement, based on the EGovernment Act, and the requirements of the Privacy Act. Because the ADVISE tool itself 

does not contain any data, it is not considered a system of records for purposes of the

Privacy Act and thus is not subject to the requirements of that law. As ADVISE 

implementations move from development to operations, they may lead to the creation or 

modification of systems of records, which would require the development of appropriate 

privacy notices to be published in the Federal Register and other actions to protect 

privacy. 

Page 20 GAO-07-293 Data Mining
performed at the early stages of development. OMB’s PIA guidance 

requires PIAs at the IT development stage, stating that they “should 

address the impact the system will have on an individual’s privacy, 

specifically identifying and evaluating potential threats relating to 

elements identified [such as the nature, source, and intended uses of the 

information] to the extent these elements are known at the initial stages of

development.” Regarding ADVISE, the tool’s intended uses include 

applications containing personal information. Thus the requirement to 

conduct a PIA from the early stages of development applies. 

As of November 2006, the ADVISE program office and DHS Privacy Office 

were in discussions regarding the possibility of conducting a privacy 

assessment similar to a PIA but modified to address the development of a

technological tool. No final decision has yet been made on whether or how 

to proceed with a PIA. However, until such an assessment is performed, 

DHS cannot be assured that privacy risks have been identified or will be 

mitigated for system implementations based on the tool. 

Privacy Protection 

Controls to Mitigate 

Identified Risks Exist and 

Could Be Built into 

ADVISE 

A variety of privacy controls can be built into data mining software 

applications, including the ADVISE tool, to help mitigate risks identified in

PIAs and protect the privacy of individuals whose information may be 

processed. DHS has recognized the importance of implementing such 

privacy protections when data mining applications are being developed. 

Specifically, in its July 2006 report, the DHS Privacy Office recommended 

instituting controls for data mining activities that go beyond conducting 

PIAs and implementing standard security controls. Such measures could 

be applied to the development of the ADVISE tool.24 Among other things, 

the DHS Privacy Office recommended that DHS components use data 

mining tools principally as investigative tools and not as a means of 

making automated decisions regarding individuals.25 The report also 

emphasizes that data mining should produce accurate results and 

recommends that DHS adopt data quality standards for data used in data 

mining. Further, the report recommends that data mining projects give 

 24The Privacy Office’s report states that ADVISE is a “technology” and not a data mining 

program. Accordingly, the report’s recommendations ostensibly would not apply to

ADVISE. However, the report acknowledges that uses of ADVISE may constitute data 

mining, in which case the recommendations would apply. 

25ADVISE does not provide an automated means for making decisions about individuals. 

Rather, it is an analysis tool to aid analysts in identifying relationships and patterns of

interest. 

Page 21 GAO-07-293 Data Mining
explicit consideration to using anonymized data when personally 

identifiable information is involved. Although some of the report’s 

recommendations may apply only to operational data mining activities, 

many reflect system functionalities that can be addressed during 

technology development. 

Based on privacy risks identified in a PIA, controls exist that could be 

implemented in ADVISE to mitigate those risks. For example, controls 

could be implemented to enforce use limitations associated with the 

purpose specified when the data were originally collected. Specifically, 

software controls could be implemented that require an analyst to specify

an allowable purpose and check that purpose against the specified 

purposes of the databases being accessed. 

Regarding data quality risks, the ADVISE tool currently does not have the

capability to distinguish among individuals with similar identifying 

information, nor does it have a mechanism to assess the accuracy of the

relationships it uncovers. To address the risk of misidentification, 

software could be added to the tool to distinguish among individuals that

have similar names, a process known as disambiguation. Disambiguation

tools have been developed for other applications. Additionally, although 

the ADVISE tool includes a feature that allows analysts to designate 

confidence levels for individual pieces of data, no mechanism has been 

developed to assess the confidence of relationships identified by the tool. 

While software specifically to determine data quality would be difficult to 

develop, other controls exist that could be readily used as part of a 

strategy for mitigating this risk. For example, anonymization could be used

to minimize the exposure of personal data, and operational procedures 

could be developed to restrict the use of analytical results containing 

personal information that could have data quality concerns. To implement 

anonymization, the tool would need the software capability to handle 

anonymized data or have a built-in data anonymizer. DHS currently does 

not have plans to build anonymization into the ADVISE tool.26

Until a PIA that identifies the privacy risks of ADVISE is conducted and

privacy controls to mitigate those risks are implemented, DHS faces the

 26In addition, a feature was to be implemented in January 2007 that would enforce an

internal DHS rule regarding how long information about U.S. persons can be maintained in

intelligence data bases. However, because this control is designed to respond only to the

DHS rule—and not to identified privacy risks—it leaves potential concerns unaddressed 

about how personal information is used when it is maintained and processed by ADVISE. 

Page 22 GAO-07-293 Data Mining
risk that privacy concerns will arise during implementation of systems 

based on ADVISE that may be more difficult to address at that stage and 

possibly require costly retrofitting. 

The ADVISE tool is intended to provide the capability to ingest large 

amounts of data from multiple sources and to display relationships that 

can be discerned within the data. Although the ADVISE tool has not yet 

been fully implemented and its effectiveness is still being evaluated, the 

chief intended benefit is to help detect activities threatening to the United

States by facilitating the analysis of large amounts of data. 

The ADVISE tool incorporates security controls intended to protect the 

information it processes from unauthorized access. However, because 

ADVISE is intended to be used in ways that are likely to involve personal 

data, a range of potential privacy risks could be involved in its operational 

use. Thus, it is important that those risks be assessed—through a PIA—so 

that additional controls can be established to mitigate them. However, 

DHS has not yet conducted a PIA, despite the fact that the E-Government 

Act and related OMB and DHS guidance emphasize the need to assess 

privacy risks early in systems development. Although DHS officials stated

that they believe a PIA is not required because the tool alone does not 

contain personal data, they also told us they are considering conducting a 

modified PIA for the tool. Until a PIA is conducted, little assurance exists 

that privacy risks have been rigorously considered and mitigating controls 

established. If controls are not addressed now, they may be more difficult 

and costly to retrofit at a later stage.

To ensure that privacy protections are in place before DHS proceeds with 

implementations of systems based on ADVISE, we recommend that the 

Secretary of Homeland Security take the following two actions: 

Conclusions 

Recommendations for 

Executive Action 

• immediately conduct a privacy impact assessment of the ADVISE tool to 

identify privacy risks, such as those described in this report, and 

• implement privacy controls to mitigate potential privacy risks identified in

the PIA. 

Page 23 GAO-07-293 Data Mining
We received oral and written comments on a draft of this report from the 

DHS Departmental GAO/Office of Inspector General Liaison Office. 

(Written comments are reproduced in appendix II.) DHS officials generally 

agreed with the content of this report and described actions initiated to 

address our recommendations. DHS also provided technical comments, 

which have been incorporated in the final report as appropriate. 

In its comments DHS emphasized the fact that the ADVISE tool itself does 

not contain personal data and that each deployment of the tool will be 

reviewed through the department’s privacy compliance process, including, 

as applicable, development of a PIA and a system of records notice. DHS

further stated that it is currently developing a “Privacy Technology 

Implementation Guide” to be used to conduct a PIA for ADVISE. Although 

we have not reviewed the guide, it appears to be a positive step toward 

developing a PIA process to address technology tools such as ADVISE. 

It is not clear from the department’s response whether the privacy 

controls identified based on applying the Privacy Technology 

Implementation Guide to ADVISE are to be incorporated into the tool 

itself. We believe that any controls identified by a PIA to mitigate privacy 

risks should be implemented, to the extent possible, in the tool itself. 

Specific development efforts that use the tool will then have these 

integrated controls readily available, thus reducing the potential for added 

costs and technical risks. The department also requested that we change

the wording of our recommendation; however, we have retained the 

wording in our draft report because it clearly emphasizes the need to 

incorporate privacy controls into the ADVISE tool itself. 

As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the Secretary 

of Homeland Security and other interested congressional committees. 

Copies will be made available to others on request. In addition, this report 

will be available at no charge on our Web site at www.gao.gov. 

Agency Comments 

and Our Evaluation 

Page 24 GAO-07-293 Data Mining
If you have any questions concerning this report, please call me at 

(202) 512-6240 or send e-mail to koontzl@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this report. Key contributors to this report are listed in 

appendix III. 

Sincerely yours, 

Linda D. Koontz 

Director, Information Management Issues 

Page 25 GAO-07-293 Data Mining
Appendix I: Objectives, Scope, and Appendix I: Objectives, Scope, and Methodology 

Methodology 

Our objectives were to determine the following: 

• the planned capabilities, uses, and associated benefits of the Analysis 

Dissemination, Visualization, Insight, and Semantic Enhancement 

(ADVISE) tool and 

• whether potential privacy issues could arise from using the ADVISE tool to 

process personal information and how the Department of Homeland 

Security (DHS) has addressed any such issues. 

To address our first objective, we identified and analyzed the tool’s 

capabilities, planned uses, and associated benefits. We reviewed program 

documentation, including annual program execution plans, and 

interviewed agency officials responsible for managing and implementing 

the program, including officials from the DHS Science and Technology 

Directorate and the Lawrence Livermore and Pacific Northwest National 

Laboratories. We also viewed a demonstration of the tool’s semantic 

graphing capability. In addition, we interviewed officials at DHS 

components to identify their current or planned uses of ADVISE, the 

progress of their implementations, and the benefits they hope to gain from 

using the tool. These components included Immigrations and Customs 

Enforcement and other components. We also interviewed officials from 

the Interagency Center of Applied Homeland Security Technology 

(ICAHST), who are responsible for conducting testing of the tool’s 

capabilities. We also visited ICAHST at the John Hopkins Applied Physics 

Laboratory in Laurel, Maryland, to view a demonstration of its testing 

activities. We did not conduct work or review implementations of ADVISE

at the DHS Office of Intelligence and Analysis. 

To address our second objective, we identified potential privacy concerns 

that could arise from using the ADVISE tool by reviewing relevant reports, 

including prior GAO reports and the DHS Privacy Office 2006 report on 

data mining. We identified and analyzed DHS actions to comply with the 

Privacy Act of 1974 and the E-Government Act of 2002. We interviewed 

technical experts within the DHS Science and Technology Directorate and 

personnel responsible for implementing ADVISE at DHS components to 

assess privacy controls included in the ADVISE tool. We also interviewed 

officials from the DHS Privacy Office. We performed our work from June 

2006 to December 2006 in the Washington, D.C., metropolitan area. Our 

work was performed in accordance with generally accepted government 

auditing standards. 

Page 26 GAO-07-293 Data Mining
Appendix II: Comments from the Department Appendix II: Comments from the Department of Homeland Security

of Homeland Security 

Page 27 GAO-07-293 Data Mining
Appendix II: Comments from the Department 

of Homeland Security

Page 28 GAO-07-293 Data Mining
Appendix II: Comments from the Department 

of Homeland Security

Page 29 GAO-07-293 Data Mining
Appendix III: GAO

A

 Contact and Staff 

cknowledgments 

Page 30 GAO-07-293

Appendix III: GAO Contact and Staff 

Acknowledgments 

Linda D. Koontz, (202) 512-6240 or koontzl@gao.gov 

In addition to the individual named above, John de Ferrari, Assistant 

Director; Idris Adjerid; Nabajyoti Barkakati; Barbara Collier; David 

Plocher; and Jamie Pressman made key contributions to this report. 

Data Mining

GAO Contact 

Staff 

Acknowledgments 

(310765) 
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