Massive surveillance system proposed by US Department of Transportation

Comments due to DOT by February 23

An innocuous looking notice in the January 15th issue of the Federal Register informs the public that the Department of Transportation (DOT) intends to establish a system of record under the Privacy Act of 1974.

SUMMARY: DOT proposes to add a system of records to the list of DOT Privacy Act Systems of Records that are exempt from one or more provisions of the Privacy Act. Public comment is invited.

The full text of the proposal is also available at http://cryptome.org/tsa011503.htm.

What does this mean? The DOT is asking for approval for a system that would allow files with extensive information to be kept for every airline passenger. The proposal asks for approval to store essentially any information in the system, using such open-ended terms as “Passenger Name Records (PNRs) and associated data; financial and transactional data; public source information; proprietary data; and information from law enforcement and intelligence sources.” You would not be able to view information gathered about you, nor would you be allowed to amend or correct incorrect information.

Although the stated purpose is to improve aviation security, the "Routine Uses" of the information are much broader. Unfortunately, the "safeguards" provided for the data are extremely weak; the huge number of people who will have access to such a vast amount of personal information will inevitably lead to massive privacy violations and identity theft.

It seems likely that this system will be one of the key databases used in the Computer Assisted Passenger Prescreening System II (CAPPS II), a subject we’ve discussed frequently here at PrivacyActivism (see link for more information). We are concerned that this public notice essentially conceals the truth about the system in order to evade the public debate that is currently taking place regarding secret data surveillance systems.

Your comments matter. Several years ago, the FDIC’s “Know your customer” proposal was withdrawn after receiving overwhelmingly negative comments -- over 200,000 comments were received with less than a dozen in support of the proposal. The overwhelming public outcry against TIA (the Total Information Awareness program) has led the Senate to defund the project for the time being. Please, send in your comments!

We've provided a sample letter that you can use as a starting point for your comments -- or if you prefer, use it verbatim.

HTML: http://www.privacyactivism.org/docs/assrcomm.htm

Microsoft Word: http://www.privacyactivism.org/docs/assrcomm.doc

Text: http://www.privacyactivism.org/docs/assrcomm.txt

Update on Feb. 20: Electronic submissions will be accepted!

• The Docket ID is OST-1996-1437
• The Document Title is Privacy Act of 1974; Implementation
• Be sure to click the appropriate choice for Submission method: Enter a Comment if you want to type directly into the form, Attach a file if you are going to attaching a file
• Leave the other fields in the Document Information section as is.
• Fill out the Submitter Information.
• When finished with the first page, click continue to continue to second page.
• After typing your comments or providing the filename, press submit

Documentary Services Division
Attention: Docket Section, Room PL-101
Docket No. OST-1996-1437
Department of Transportation, SVC-124
Washington, DC 20590

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 DOT 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 Monday. 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.

More information is available at <http://www.privacyactivism.org/Item/69>.

Last updated February 23, 2003