PIA ‐ Airmen/Aircraft Registry Modernization System

DEPARTMENT OF TRANSPORTATION

Federal Aviation Administration

Privacy Impact Assessment

Airmen/Aircraft Registry Modernization System (RMS)

August 12, 2004

Table of Contents

Overview of Federal Aviation Administration (FAA) privacy management process for RMS

Personally Identifiable Information (PII) and RMS

Why RMS Collects Information

How RMS uses information

How RMS shares information

How RMS provides notice and consent

How RMS ensures data accuracy

How RMS provides redress

How RMS secures information

System of records

Overview of Federal Aviation Administration (FAA) Privacy Management

Process for RMS

The Federal Aviation Administration (FAA) within the Department of Transportation (DOT) has

been given the responsibility for civil aviation safety. FAA is responsible for:

Regulating civil aviation to promote safety;

Encouraging and developing civil aeronautics, including new aviation technology;

Developing and operating a system of air traffic control and navigation for both civil and

military aircraft;

Researching and developing the National Airspace System and civil aeronautics;

Developing and carrying out programs to control aircraft noise and other environmental

effects of civil aviation; and

Regulating U.S. commercial space transportation

One of the systems that helps FAA fulfill this mission is the Airmen/Aircraft Registry

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Modernization System (RMS). This system allows FAA to maintain airmen and aircraft records,

including but not limited to:

Airmen:

You can find RMS' system of records notices, DOT/FAA 847 and DOT/FAA 801,Records

documenting the certificate type, class, rating(s) and limitation(s) issued to an airman.

Aircraft:

To whom the aircraft is registered

Aircraft ownership

Legal instruments pertinent to aircraft

Though RMS has been in existence for some time, recent improvements have moved some

functionality to the Web, supporting Section 208 of the E­Government Act of 2002 goals.

Privacy management is an integral part of the RMS system. DOT/FAA has retained the services

of privacy experts to help assess its privacy management program, utilizing proven technology,

sound policies and procedures, and proven 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 FAA will have the information, tools, and technology

necessary to manage privacy effectively and employ the highest level of fair information

practices while allowing FAA to achieve its mission of protecting and enhancing a most important

U.S. transportation system. The methodology is based upon the following:

Establish priority, authority, and responsibility. Appointing a cross­functional 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 RMS system to ensure that privacy risks are identified and documented.

Organize the resources necessary for the project's goals. Internal DOT/FAA 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 an effective policy or policies, practices, and procedures to ensure

that fair information practices are complied with. The policies are designed to protect

privacy effectively while allowing DOT/FAA 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 FAA 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) and RMS

To handle airmen certifications and aircraft registrations, FAA requires PII about airmen and

aircraft owners/registrants. With this in mind, RMS may include or collect the following data on

airmen and/or aircraft owners and registrants, either for authentication or certification

requirements: Name, Date of birth (airmen only), Social security number (airmen only),

Driver's license number, passport number, or government ID number, Physical Description

(height, weight, hair and eye color, sex, and citizenship), Address (airmen only), Medical

records (airmen only), Certificate number (airmen only) In the past, RMS used an airman's

social security number as the certificate number. FAA is now changing that practice, developing

unique certificate numbers not affiliated with social security number. During this change, airmen

can request, online or offline, that his or her social security number not appear as a certificate

number. For an individual's PII to be included in RMS, that individual must be associated with

an airmen or aircraft certificate or application.

Why RMS Collects Information

FAA is responsible for granting airmen certification and aircraft registration and managing the

processes, both of which require PII. FAA uses the PII in RMS to grant, track, and monitor

airmen and aircraft certificates. In addition, FAA may use PII in RMS to contact individuals for

more pertinent information, handle applicable requests, and aggregate data for trend analyses.

In addition, RMS supports restricted access functionality to all parts of the system. Therefore,

RMS contains usernames and passwords for FAA employees and associates that data with

individuals accessing RMS. Members of the public can also perform some functions online

pertaining to their airmen account. Therefore, RMS also contains email addresses and passwords

for public Website users with approved access.

How RMS Uses Information

RMS is primarily planned as an internal tool to manage and store records, analyze safety data

and manage time­intensive processes such as examination activities. FAA intends to use PII in

RMS only for these primary purposes. FAA will use this PII in the same privacy­sensitive manner

it does now.

How RMS Shares Information

In some cases, FAA may need to share some information in RMS with other departments of the

FAA, or perhaps other government agencies, such as law enforcement. Routine sharing of this

nature is provided for and monitored through Memorandums of Understanding that define

protocols, recipients, security, authorized uses, and other protections. FAA shares RMS data in

accordance with the Privacy Act of 1974 and as required by law.
How RMS Provides Notice and Consent

For an individual's PII to be in RMS, he or she must have either applied for or have an airmen

certification, or have been associated with an aircraft registration.

Notice is provided through the applicable Privacy Act System of Records notices, DOT/FAA 847 ­

Aviation Records on Individuals, and DOT/FAA 801 ­ Aircraft Registration System. In addition, as

RMS includes a limited public Website interface to facilitate some online transactions, the

Website posts an accurate privacy policy that contains all the protections and advisories

required by the E­Government Act.

FAA employees and contractors with approved access to RMS may provide PII associated with

their login and password to the system. In these cases, FAA staff members must read a notice

and disclosure statement before logging in that describes obligations and privacy protections.

How RMS Ensures Data Accuracy

RMS receives most PII either directly through forms submitted by the individual in question, or

through additional contact or interaction with the individual. The length of time a record remains

on the RMS system is governed by federal guidelines, and information on the retention policy is

provided in Privacy Act System of Records notices DOT/FAA 847 and DOT/FAA 801. RMS does

provide some online functionality that allows an individual to request changes to some of his or

her information, such as address, and to request that his or her social security number not be

used as the certificate number.

Under the provisions of the Privacy Act, individuals may request searches of some RMS data to

determine if any records have been added that may pertain to them. This is accomplished by

sending a written request directly to the program office that contains name, authentication

information, and information regarding the request. FAA does not allow public access to the

information stored in the RMS.

How RMS Provides Redress

As provided for by the Privacy Act System of Records notices DOT/FAA 801 and DOT/FAA 847,

individuals with questions about privacy and RMS may contact FAA directly. The posted privacy

policy on the RMS public Website will additionally provide contact information for FAA's Privacy

Officer.

How RMS Secures Information

RMS takes appropriate security measures to safeguard PII and other sensitive data. RMS applies

DOT security standards, including but not limited to, routine scans and monitoring, back­up

activities, and background security checks of FAA employees and contractors.

In addition, FAA access to RMS PII is limited according to job function. There is a formal

approval process that must occur, in which one or managers approve an individual's RMS

access, before that access is granted. FAA controls access privileges according to the minimum
necessary rule.

The following access safeguards are also be implemented:

Passwords expire after a set period.

Accounts are locked after a set period of inactivity.

Minimum length of passwords is eight characters.

Passwords must be a combination of letters, numbers, and special characters.

Accounts are locked after a set number of incorrect attempts.

System of Records

RMS contains information that is part of two existing systems of records subject to the Privacy

Act, because it is searched by an individual's name and unique identifiers. You can find RMS'

system of records notices, DOT/FAA 847 and DOT/FAA 801, by going to:

http://cio.ost.dot.gov/policy/records.html.

FAA is in the process of certifying and accrediting the security of RMS in accordance with DOT

standard information technology requirements.

Updated: Thursday, March 19, 2015

Contact Us

Claire Barrett

Chief Privacy Officer

1200 New Jersey Ave, SE

Washington, DC 20590

United States

privacy@dot.gov

Business Hours:

8:30am­5:00pm ET, M­F

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