Comments on CAPPS II Airline Profiling System due to TSA Today
After the first round of mostly negative comments that were received by the Transportation Security Administration (TSA) earlier this year, the agency has issued a new Federal Register notice describing a somewhat revised system. Unfortunately, the new proposal is just as bad, and in some cases, worse than the first proposed system.
Under the new proposed rules, the Computer Assisted Passenger Prescreening System II (CAPPS II) will be used not only to try to identity possible terrorists, but it will be used to identify those "where there is an indication of a serious violation of criminal law". In other words, CAPPS II has just been expanded to become a general tool of law enforcement – before it has even been proven to find terrorists!
The revised proposal narrows the list of agencies and outside groups who can have access to your personal data, but distribution of personal data is still quite broad.
We now know that CAPPS II will require airlines to collect full name, address, and phone number from you when you make an airline reservation. That information will be "matched" against demographic information held on you by data aggregators (ChoicePoint, Axciom, etc.) to verify your identity. Other data will be used to determine if you are a risk. There is very little recourse if you feel you’ve been incorrectly flagged as a risk, and there is great evidence that if a mistake has been made, no one will want to take responsibility. For a preview of what's likely to happen, see the JetBlue scandal that is currently unfolding.
Please make your views known – send in comments to the TSA and tell them you want the CAPPS II program permanently halted.
Your comments matter. CAPPS II was scheduled to go into effect in February, but the large outcry against it forced the TSA to postpone implementation and to speak with privacy groups. Additionally, the overwhelming public outcry against TIA (the Total Information Awareness program) led the Senate to defund the project for the time being. So please, send in your comments!
We've provided two a sample letters that you can use as starting points for your
comments -- or if you prefer, use one or the other verbatim (and don't forget to sign it).
The first sample letter briefly covers many different areas of concern about the proposal. The second sample letter uses the recent JetBlue events to illustrate several specific problems with the CAPPS II proposal.
(The letters are also available in Microsoft Word (first letter, second letter)
and text (first letter, second letter) formats.)
To submit comments by mail
You must
identify the docket number DHS/TSA-2003-1 at the beginning of your
comments, and you should submit two copies of your comments. Please address your comments to
Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
To submit comments by e-mail
You may
submit comments via e-mail at privacy@dhs.gov. Please reference
the docket number DHS/TSA-2003-1 in the subject line of the e-mail.
Tips for Writing Good Comments
- Remember to keep your comments brief and to the point.
- If you have examples of how you've been impacted by inaccurate data (denied a mortgage or credit card, been an identity theft victim, etc.) include that in your comments. Keep it brief.
- State what you want TSA to do -- withdraw the proposal, allow more time for public comment, etc.
- Don't forget to allow enough time for your comments to arrive by Sept. 30. If you are sending them by mail, remember that delivery is slow in Washington D.C.; consider using Express Mail or FedEx.
- Consider sending a copy of your comments to your legislators as well, to let them know that this is an issue you care about.
Last updated September 30, 2003
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