1 Page 1 of 10 Before the PRIVACY OFFICE DEPARTMENT OF HOMELAND SECURITY Washington, DC Privacy Act of 1974, System of Records Notice (SORN, DHS/CBP 006, Automated Targeting System (ATS DHS COMMENTS OF THE IDENTITY PROJECT (IDP AND JOHN GILMORE (IDP A project of the First Amendment Project 1736 Franklin St., 9th Floor Oakland, CA submits these comments in response to the Privacy Act of 1974, System of Records Notice (SORN for records system DHS/CBP 006, the Automated Targeting System (ATS, published at 71 Federal Register (November 2, 2006, docket number DHS The stated purpose of the system of records is expressly forbidden by the Department of Homeland Security Appropriations Act, 2007, Title V, Sec The SORN would impermissibly include records describing how individuals exercise rights of assembly and other rights guaranteed by the First Amendment, is factually inaccurate, omits many of the categories of individuals about whom information would be (and perhaps already is being collected and fails to give the required notice to data subjects, and would constitute a criminal violation of the Privacy Act by the responsible agency officers or employees.
2 Page 2 of 10 respectfully requests that the proposed system of records not be created or, if it has been created already, that the data contained in it and in all backups and copies be destroyed. I. ABOUT THE IDENTITY PROJECT (IDP,, provides advice, assistance, publicity, and legal defense to those who find their rights infringed, or their legitimate activities curtailed, by demands for identification, and builds public awareness about the effects of ID requirements on fundamental rights. IDP is a program of the First Amendment Project, a nonprofit organization providing legal and educational resources dedicated to protecting and promoting First Amendment rights. II. THE STATED PURPOSE OF THE AUTOMATED TARGETING SYSTEM (ATS SYSTEM OF RECORDS IS EXPRESSLY FORBIDDEN BY CONGRESS. The Department of Homeland Security Appropriations Act, 2007, P.L (H.R. 5441, provides in Title V, Sec. 514 (e, a copy of which is attached as an appendix to these comments, None of the funds provided in this or previous appropriations Acts may be utilized to develop or test algorithms assigning risk to passengers whose names are not on Government watch lists. Previous DHS appropriations acts have similar provisions. This SORN violates that prohibition. While Sec. 514(a prohibits the deployment or implementation, on other than a test basis, of the Secure Flight program or any other follow on or successor passenger prescreening program until all of the conditions contained in paragraphs (1 through (10 of section 522(a of Public Law (118 Stat have been successfully met, which they to date have not, Sec. 514(e unequivocally and without limitation to the Secure Flight program prohibits the development or testing of algorithms assigning risk to passengers whose names are not on Government watch lists. The prohibition is placed upon the Department of Homeland Security and not limited to domestic passenger data. In fact, because Sec. 514(e stands separate from 514(a, prohibits testing where 514(a does not, and makes no mention of Secure Flight, 514(e is much broader in scope than 514(a. The proposed ATS system of records would violate this prohibition. According to the SORN, the ATS builds a risk assessment for... travelers based on criteria and rules developed by CBP [DHS Bureau of customs and Border Protection]. ATS maintains the resulting assessment... This assessment
3 Page 3 of 10 and related rules history associated with developing a risk assessment for an individual are maintained for up to forty years to support ongoing targeting requirements. 71 Federal Register There is no indication in the SORN that these records or risk assessments are limited to individuals whose names appear on Government watch lists. Even if one were to argue that Sec. 514(e does not apply to ATS, or that ATS is not within the meaning of any other follow on or successor passenger prescreening program as defined in Sec. 514(a, the algorithms assigning risk to passengers in the Secure Flight program are arguably the same as those contemplated by this SORN. By cloaking this prohibited action in a border issue, and by not even publicly recognizing the manifest operational overlap here, the Department of Homeland Security directly and openly contravenes Congress clear intent. Further, in the routine uses section of the SORN, sub-section N, DHS is specifically describing what Sec. 514(e prohibits. Since the function of this records system is expressly forbidden by Congress, the SORN should be immediately and expressly withdrawn, and any records or data already collected or being maintained pursuant to it, or for this forbidden purpose, along with any copies or backups, should be immediately destroyed. III. THE DATA COLLECTED IMPERMISSIBLY INCLUDES THAT OF DOMESTIC TRAVEL. PNR's for international flights can, and often do, contain data about domestic travel within the USA. According to the SORN, the ATS may include the entire PNR, including All travel itinerary for specific PNR. A PNR can contain data on any number of sequential flights, including connecting flights as well as flights separated by surface ( ARNK segments. This could include multiple domestic flights prior or subsequent to the international leg in the same PNR, including flights that do not connect from or to international flights and neither originate nor terminate at international gateways. In addition, information in PNR's for purely domestic journeys within the USA could be included in Split/Divided PNR information in ATS records, if the person(s making such a domestic journey was originally included in the same PNR as, and was then split or divided into a separate (cross-referenced PNR from, someone whose journey included an international leg.
4 Page 4 of 10 The Government's collection of domestic PNR information, as envisioned by the long shelved Secure Flight program, is clearly impermissible (see again Sec. 514(a. Because the collection of international PNR information would be inextricably intertwined with the domestic PNR information, the collection of either is impermissible. IV. THE ATS SYSTEM WOULD INCLUDE RECORDS DESCRIBING HOW INDIVIDUALS EXERCISE RIGHTS OF ASSEMBLY AND OTHER RIGHTS GUARANTEED BY THE FIRST AMENDMENT, WITHOUT STATUTORY AUTHORIZATION. The Privacy Act of 1974, 5 U.S.C. 552a(e(7, provides that: Each agency that maintains a system of records shall -... maintain no record describing how any individual exercises rights guaranteed by the First Amendment unless expressly authorized by statute or by the individual about whom the record is maintained or unless pertinent to and within the scope of an authorized law enforcement activity. As we have explained in comments filed with this Department in other rulemaking proceedings, travel necessarily incorporates the act of assembly, a right specifically protected by the First Amendment. See "Passenger Manifests for Commercial Aircraft Arriving in and Departing From the United States; Passenger and Crew Manifests for Commercial Vessels Departing From the United States", Comments of the Identity Project, et al., before the Bureau of Customs and Border Protection, Department of Homeland Security, docket USCBP (October 12, 2006, available at <http://hasbrouck.org/idp/idp-apis-comments.pdf>. Travel records such as Passenger Name Records (PNR s thus are, directly and by definition, records of our acts of assembly. PNR s describe how any individual exercises rights guaranteed by the First Amendment in numerous ways. One PNR can contain reservations for an entire group of people traveling and assembling together. Multiple PNR s for people traveling and assembling together can be cross-referenced to indicate their association, even when they are traveling from different places. PNR s for travel by members of organizations frequently identify their organizational affiliations through discount eligibility codes, particularly through unique meeting codes (included in ticketing information and other PNR data categories that identify a specific assembly. PNR s record with whom we assemble, when and for how long we assemble, where and from where we assemble, and how (by exactly what means of transport we assemble, among other details of our acts of assembly.
5 Page 5 of 10 None of the exceptions to the Privacy Act s prohibition on keeping of records about the exercise of rights protected by the First Amendment applies in this case. First, any claimed statutory authorization for the maintenance of such a system of records is, at most, implied, not express. No statute mandates the collection or retention by the DHS of PNR data. In fact, as detailed earlier in these comments, the claimed purpose of the ATS system is expressly forbidden by the most recent Department of Homeland Security Appropriations Act, as well as by multiple similar prior acts. Second, the maintenance of these records could hardly be considered authorized by the individuals about whom the records are maintained. The DHS has provided no mechanism to obtain consent, or to permit individuals to opt out or prevent the inclusion of records about them in the system. On the contrary, the DHS has proposed to exempt this system of records from even the limited requirements of the Privacy Act for accuracy, relevance, access, and so forth. Third, the system expressly includes all travelers (and, although it fails to give them notice, many other categories of individuals, without any limitation to those who are the target of any law enforcement activity. To invoke the law enforcement exemption to the protections of the Privacy Act, there must exist some degree of individualized suspicion. A blanket requests for all records of a particular type is not permissible. Therefore, DHS is generally, and specifically regarding the collection of data concerning how individuals exercise First Amendment rights, violating the Privacy Act if their stated exemption to its protections here is law enforcement. Accordingly, the inclusion in the ATS system of PNR's data or any other data concerning how individuals exercise rights of assembly or other rights protected by the First Amendment is forbidden by the Privacy Act. Any such data that has been collected, and any copies or backups, should be destroyed. The system of records should be modified to exclude such data, and a new SORN should be published. V. THE SYSTEM OF RECORDS NOTICE IS FACTUALLY INACCURATE. According to the SORN, the Automated Targeting System... was previously covered by the Treasury Enforcement Communications System System of Records Notice.... This system of records notice does not identify or create any new collection of information. This claim is false.
6 Page 6 of 10 The most recent SORN for the Treasury Enforcement Communications System (TECS was published at 66 Federal Register at (October 18, There is no mention in that SORN for the TECS system of any use of this data to generate risk assessments or for targetting, as disclosed for the first time in this SORN for the ATS records system. In addition, the SORN for the TECS system describes the categories of records in the system as: Every possible type of information from a variety of Federal, state and local sources. This reference to Federal, state, and local sources clearly implies Federal, state, and local government sources. There is no mention in the SORN for TECS of data from non-governmental, commercial sources such as the airline reservation systems that are the source of Passenger Name Records (PNR s, whose inclusion in these records is disclosed for the first time in the SORN for the ATS records system. The false and misleading claim in the SORN for the ATS system that it does not identify or create any new collection of information appears designed to cover up the apparent fact that the previous SORN for the TECS system was deficient, and that the ongoing collection of categories of data such as commercial data, and uses of that data such as for creation of risk assessments and targeting, not disclosed in that SORN, have been in violation of the Privacy Act. VI. THE ATS SORN FAILS TO GIVE THE NOTICE REQUIRED. 5 U.S.C. 552a(e(4(B, the Privacy Act of 1974, requires that the SORN include the categories of individuals on whom records are maintained in the system. But the SORN for the ATS system of records omits large categories of individuals about whom the ATS system, as described in that SORN, would contain personally identifiable information. The SORN discloses that the ATS system of records will cover A. Persons seeking to enter or exit the United States;... and D. Persons who serve as operators, crew, or passengers on any vessel, vehicle, aircraft, or train who enters or exits the United States. But the SORN also discloses that the ATS will include airline Passenger Name Records (PNR s. PNR s contain personally identifiable information on numerous other categories of individuals, not mentioned in the SORN or given the required notice that they are included in the ATS system. Among those additional categories of individuals not mentioned in the SORN, about whom PNR s and thus the ATS system would contain information, are the following:
7 Page 7 of 10 A. Travel arrangers, personal assistants and administrative staff, travel managers, group coordinators, event organizers, and family members and friends assisting with travel arrangements, as identified by the received from field in the PNR (acknowledged in the SORN as one of the PNR data categories included in the ATS system that records the person who requested the creation of the reservation or the most recent change to it. B. People who pay for tickets for others, or who hold joint credit or debit cards with people who purchase travel for themselves or others whether or not they travel themselves as identified from the form of payment fields in ticketing records in PNR s (again, a category of PNR data acknowledged in the SORN as included in the ATS system. C. Friends, family members, hosts, housemates, domestic partners, and business associates of travellers, as identified from the "local contact" and "document delivery" information in PNR's (which may include phone numbers, descriptions of the relationship of the contact to the traveller, and in some cases addresses. D. Travel industry personnel, including travel agents and airline reservation, check-in, and ticketing staff, as identified by the unique agent sine or log-in ID in the PNR and by the city or pseudo-city (airline office or travel agency branch or location and the LNIATA or set address of the terminal or data connection on which the entry was made (the CRS or airline hosting system counterpart of an Internet IP address. E. Clients, customers, and employers of travellers, even if they aren t travelling, as identified by billing and accounting codes for travel by others undertaken on their behalf or at their expense. Corporate travel agencies routinely include codes in PNR s to indicate to the traveller (or the traveller s employer to which department, project, or client the cost of the trip is to be billed. In the case of a law firm, these entries routinely identify the specific client, case, or matter on whose behalf or at whose expense the travel was undertaken. Thus clients of law firms, consultants, financial advisors, and other professionals are routinely the subject of data in PNR s, and thus could be the subject of data (including legally privileged data in the proposed system.
8 Page 8 of 10 In order to avoid a violation of the Privacy Act, or terminate the ongoing violation if the ATS system of records containing PNR s has already been created, a revised SORN should be published as soon as possible to give these categories of individuals the notice to which they are entitled. VII. MAINTENANCE OF THE ATS SYSTEM OF RECORDS WOULD CONSTITUTE A CRIMINAL VIOLATION OF THE PRIVACY ACT ON THE PART OF THE RESPONSIBLE AGENCY OFFICERS OR EMPLOYEES. The Privacy Act of 1974, 5 U.S.C. 552a(I(2, provides that: Any officer or employee of an agency who willfully maintains a system of records without meeting the notice requirements of subsection (e(4 of this section shall be guilty of a misdemeanor. As discussed immediately above, the SORN for the ATS system does not meet the notice requirements of 5 U.S.C. 552a(e(4 with respect to the categories of individuals on whom records are to be maintained in the system. As a result, willful maintenance of the ATS system containing data from PNR s concerning any categories of individuals other than individuals actually travelling, would be a criminal violation of the Privacy Act of 1974, 5 U.S.C. 552a(I(2, on the part of each officer or employee of any agency willfully participating in such maintenance. VIII. CONCLUSION AND RECOMMENDATIONS The stated purpose of the system of records, the assignment of risk scores to all international air travellers to and from the USA, is expressly forbidden by the Department of Homeland Security Appropriations Act, The proposed system of records would impermissibly include records describing how individuals exercise rights of assembly and other rights guaranteed by the First Amendment, without express statutory authorization. The SORN is materially inaccurate, omits many of the categories of individuals about whom information would be (and perhaps already is being collected and fails to give the notice to data subjects required by the Privacy Act, and maintenance of the proposed system of records would constitute a criminal violation of the Privacy Act on the part of the responsible agency officers or employees. respectfully requests that the proposed system of records not be created and, if it has been created already, that the data contained in it and in all backups and copies be destroyed.
9 Page 9 of 10 Respectfully submitted, (IDP A project of the First Amendment Project 1736 Franklin St., 9th Floor Oakland, CA /s/ Edward Hasbrouck, Consultant to IDP on travel-related issues James P. Harrison Staff Attorney, First Amendment Project Director, IDP John Gilmore Post Office Box San Francisco, CA 94117
10 Page 10 of 10 APPENDIX Department of Homeland Security Appropriations Act, 2007, P.L (H.R TITLE V: GENERAL PROVISIONS SEC (a None of the funds provided by this or previous appropriations Acts may be obligated for deployment or implementation, on other than a test basis, of the Secure Flight program or any other follow on or successor passenger prescreening program, until the Secretary of Homeland Security certifies, and the Government Accountability Office reports, to the Committees on Appropriations of the Senate and the House of Representatives, that all ten of the conditions contained in paragraphs (1 through (10 of section 522(a of Public Law (118 Stat have been successfully met. (b The report required by subsection (a shall be submitted within 90 days after the Secretary provides the requisite certification, and periodically thereafter, if necessary, until the Government Accountability Office confirms that all ten conditions have been successfully met. (c Within 90 days of enactment of this Act, the Secretary shall submit to the Committees on Appropriations of the Senate and the House of Representatives a detailed plan that describes: (1 the dates for achieving key milestones, including the date or time frames that the Secretary will certify the program under subsection (a; and (2 the methodology to be followed to support the Secretary s certification, as required under subsection (a. (d During the testing phase permitted by subsection (a, no information gathered from passengers, foreign or domestic air carriers, or reservation systems may be used to screen aviation passengers, or delay or deny boarding to such passengers, except in instances where passenger names are matched to a Government watch list. (e None of the funds provided in this or previous appropriations Acts may be utilized to develop or test algorithms assigning risk to passengers whose names are not on Government watch lists. (f None of the funds provided in this or previous appropriations Acts may be utilized for data or a database that is obtained from or remains under the control of a non-federal entity: Provided, That this restriction shall not apply to Passenger Name Record data obtained from air carriers.
This document is scheduled to be published in the Federal Register on 07/14/2016 and available online at http://federalregister.gov/a/2016-16598, and on FDsys.gov 9110-04 DEPARTMENT OF HOMELAND SECURITY
This document is scheduled to be published in the Federal Register on 02/11/2016 and available online at http://federalregister.gov/a/2016-02788, and on FDsys.gov Billing Code: 5001-06 DEPARTMENT OF DEFENSE
Frequently Asked Questions Regarding Customs and Border Protection Receipt of Passenger Name Records Related to Flights between the European Union and the United States United States law requires airlines
Section by Section DEPARTMENT OF HOMELAND SECURITY CYBERSECURITY AUTHORITY AND INFORMATION SHARING Sec. 1. Department of Homeland Security Cybersecurity Authority Section 1(a) amends Title II of the Homeland
BILLING CODE: 4410-10 DEPARTMENT OF HOMELAND SECURITY Office of the Secretary DHS-2008-0052 Privacy Act of 1974; Department of Homeland Security, U.S. Customs and Border Protection Electronic System for
UNDERTAKINGS OF THE DEPARTMENT OF HOMELAND SECURITY BUREAU OF CUSTOMS AND BORDER PROTECTION (CBP) In support of the plan of the European Commission (Commission) to exercise the powers conferred on it by
Legislative Language SECTION 1. DEPARTMENT OF HOMELAND SECURITY CYBERSECURITY AUTHORITY. Title II of the Homeland Security Act of 2002 (6 U.S.C. 121 et seq.) is amended (a) in section 201(c) by striking
for the Crew Member Self Defense Training (CMSDT) Program February 6, 2008 Contact Point Michael Rigney Federal Air Marshal Service Flight Programs Division Michael.Rigney@dhs.gov Reviewing Officials Peter
AUDIT REPORT OF THE PRIVACY COMMISSIONER OF CANADA Passenger Protect Program Transport Canada Section 37 of the Privacy Act 2009 AUDIT OF PASSENGER PROTECT PROGRAM, TRANSPORT CANADA The audit work reported
TH CONGRESS ST SESSION S. ll To codify mechanisms for enabling cybersecurity threat indicator sharing between private and government entities, as well as among private entities, to better protect information
Securities Whistleblower Incentives and Protection 15 USC 78u-6 (As added by P.L. 111-203.) 15 USC 78u-6 78u-6. Securities whistleblower incentives and protection (a) Definitions. In this section the following
(4910-62-P) DEPARTMENT OF TRANSPORTATION Office of the Secretary Docket No. DOT-OST-2015-0235 Privacy Act of 1974; Department of Transportation, Federal Aviation Administration, DOT/FAA-801; Aircraft Registration
PBGC-19: Office of General Counsel Case Management System Excerpted from Federal Register: Sept. 9, 2014 (Volume 79, Number 174) General Routine Uses System Name: Office of General Counsel Case Management
H.R.1268 Emergency Supplemental Appropriations Act for Defense, the Global War on Terror, and Tsunami Relief, 2005 (Enrolled as Agreed to or Passed by Both House and Senate) TITLE II--IMPROVED SECURITY
Chapter 21 Credit Services Organizations Act 13-21-1 Short title. This chapter is known as the "Credit Services Organizations Act." Enacted by Chapter 29, 1985 General Session 13-21-2 Definitions -- Exemptions.
YOUR DUTIES UNDER THE FAIR CREDIT REPORTING ACT The Staff of the Consumer Financial Protection Bureau (CFPB) has prepared the following required notices in compliance with the Fair Credit Reporting Act
ATTORNEY GENERAL OF THE STATE OF NEW YORK INTERNET BUREAU In the Matter of Assurance No. 15-185 Investigation by ERIC T. SCHNEIDERMAN, Attorney General of the State of New York, of Uber Technologies, Inc.,
Setting the Record Straight: U.S. Department of Homeland Security Policies on Protecting Privacy Lauren Saadat and Shannon Ballard 1 As published in the November 2007 issue of Data Protection Law & Policy
This document is scheduled to be published in the Federal Register on 01/27/2016 and available online at http://federalregister.gov/a/2016-01517, and on FDsys.gov Billing Code: 5001-06 DEPARTMENT OF DEFENSE
Privacy Impact Assessment Of the Office of Inspector General Information Technology Infrastructure Systems Program or application name: Office of Inspector General Information Technology Infrastructure
SECURITIES AND EXCHANGE COMMISSION 17 CFR PART 239 [RELEASE NO. 33-8871; FILE NO. S7-30-07] RIN 3235-AK02 REVISIONS TO FORM S-11 TO PERMIT HISTORICAL INCORPORATION BY REFERENCE AGENCY: Securities and Exchange
BEST CASE BANKRUPTCY NOTICE TO END USER Best Case, LLC, recognizes that it may benefit end users of its Best Case Bankruptcy software to have immediate access to a credit reporting agency. To that end,
Senate Bill No. 38 Committee on Transportation and Homeland Security CHAPTER... AN ACT relating to criminal records; creating the Records and Technology Division of the Department of Public Safety; enumerating
ADVISOR/LENDER APPLICANT ASSISTANCE AGREEMENT This ADVISOR/LENDER APPLICANT ASSISTANCE AGREEMENT (the Agreement ) is made this day of, 200_ by and between Oaktree Funding Corporation, a California Corporation
for the Enterprise Services Management System April 28, 2016 Contact Point Marshall Nolan Border Enforcement and Management Systems Division Office of Information Technology U.S. Customs & Border Protection
All users of consumer reports must comply with all applicable regulations. Information about applicable regulations currently in effect can be found at the Consumer Financial Protection Bureau s website,
This document is scheduled to be published in the Federal Register on 02/11/2016 and available online at http://federalregister.gov/a/2016-02770, and on FDsys.gov Billing Code: 5001-06 DEPARTMENT OF DEFENSE
The High-Performance Computing Act of 1991 (Public Law 102-194) as amended by the Next Generation Internet Research Act of 1998 (P.L. 105-305) and the America COMPETES Act of 2007 (P.L 110-69) An Act To
This document has been compiled by the California Association of Collectors for informational purposes and placing the Rosenthal Act in a centralized location for the use of CAC members. The information
Overview of the Impact of the Privacy Reforms on Credit Reporting June 2012 Andrew Galvin, Partner 1 OVERVIEW 1.1 Credit Reporting Reform - Background When initially passed, the Privacy Act 1988 essentially
Province of Alberta PUBLIC SECTOR PENSION PLANS ACT Revised Statutes of Alberta 2000 Chapter P-41 Current as of September 1, 2014 Office Consolidation Published by Alberta Queen s Printer Alberta Queen
VOLUNTEER & EMPLOYEE CRIMINAL HISTORY SERVICE (VECHS) USER AGREEMENT FOR CRIMINAL HISTORY RECORD INFORMATION 1. Purpose This Agreement, entered into by the Hawaii Criminal Justice Data Center (hereinafter
DEPARTMENT OF HEALTH AND HUMAN SERVICES Control of Communicable Diseases Q Rule Comments; RIN 0920-AA03 Notice of Proposed Rulemaking COMMENTS OF THE ELECTRONIC PRIVACY INFORMATION CENTER By notice published
Department of Defense DIRECTIVE NUMBER 5400.11 October 29, 2014 DCMO SUBJECT: DoD Privacy Program References: See Enclosure 1 1. PURPOSE. This directive: a. Reissues DoD Directive (DoDD) 5400.11 (Reference
NAFSA: Association of International Educators 1307 New York Avenue NW Eighth Floor Washington, DC 20005-4701 Telephone: 1.202.737.3699 Fax: 1.202.737.3657 E-mail: email@example.com http://www.nafsa.org President
This document is scheduled to be published in the Federal Register on 08/07/2015 and available online at http://federalregister.gov/a/2015-19466, and on FDsys.gov DEPARTMENT OF HOMELAND SECURITY U.S. Customs
United States Trustee Program Privacy Impact Assessment for the Credit Counseling/Debtor Education System (CC/DE System) Issued by: Larry Wahlquist, Privacy Point of Contact Reviewed by: Approved by: Vance
This document is scheduled to be published in the Federal Register on 09/22/2016 and available online at https://federalregister.gov/d/2016-22807, and on FDsys.gov Billing Code: 5001-06 DEPARTMENT OF DEFENSE
Information for Management of a Service Organization Copyright 2015 American Institute of Certified Public Accountants, Inc. New York, NY 10036-8775 All rights reserved. For information about the procedure
INTERIOR FRANCHISE FUND PERMANENT AUTHORITY TO OPERATE The authority of the Secretary of the Interior to perform centralized administrative services (including interagency acquisitions), and the establishment
Terms and Conditions IMPORTANT LEGAL NOTICE Introduction This legal notice applies to the entire contents of this booking engine. Please take some time to read these Terms and Conditions of Use ( Terms
H. R. 4173 466 activities and evaluates the effectiveness of the Ombudsman during the preceding year. The Investor Advocate shall include the reports required under this section in the reports required
Exemption No. 11022 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 20591 In the matter of the petition of PURDUE UNIVERSITY S DEPARTMENT OF AVIATION
This document is scheduled to be published in the Federal Register on 10/27/2015 and available online at http://federalregister.gov/a/2015-27229, and on FDsys.gov Billing Code: 5001-06 DEPARTMENT OF DEFENSE
UNDERTAKINGS OF THE UNITED STATES BUREAU OF CUSTOMS AND BORDER PROTECTION AND THE UNITED STATES TRANSPORTATION SECURITY ADMINISTRATION In support of the plan of the European Commission (EC) to exercise
TRACERS INFORMATION SPECIALISTS, INC. Subscriber Certification of Use for FCRA-REGULATED PRODUCTS Compliance Exhibit C 1. Reseller has access to consumer reports from one or more consumer credit reporting
118 STAT. 2809 Public Law 108 447 108th Congress An Act Making appropriations for foreign operations, export financing, and related programs for the fiscal year ending September 30, 2005, and for other
SENATE, No. STATE OF NEW JERSEY th LEGISLATURE INTRODUCED JUNE, 00 Sponsored by: Senator JEFF VAN DREW District (Cape May, Atlantic and Cumberland) SYNOPSIS "New Jersey Fair Debt Collection Practices Act."
EXECUTIVE OFFICE OF THE PRESIDENT OFFICE OF MANAGEMENT AND BUDGET WASHINGTON, D.C. 20503 THE DIRECTOR M-05-24 August 5, 2005 MEMORANDUM FOR THE HEADS OF ALL DEPARTMENTS AND AGENCIES FROM: SUBJECT: Joshua
CHAPTER 172 AN ACT concerning consumer credit reports and supplementing Title 56 of the Revised Statutes. BE IT ENACTED by the Senate and General Assembly of the State of New Jersey: C.56:11-28 Short title.
This document is scheduled to be published in the Federal Register on 10/31/2014 and available online at http://federalregister.gov/a/2014-25905, and on FDsys.gov 9110-04 DEPARTMENT OF HOMELAND SECURITY
October 10, 2012 PRESIDENTIAL POLICY DIRECTIVE/PPD-19 SUBJECT: Protecting Whistleblowers with Access to Classified Information This Presidential Policy Directive ensures that employees (1) serving in the
CLIENT MEMORANDUM From: West Corporation Re: New Federal Communication Commission Rule for Autodialed and Prerecorded Message Telemarketing Calls and Abandoned Call Provisions Date: February 17, 2012 Federal
U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Public Aircraft Operations Date: 2/12/14 Initiated by: AFS-800 AC No: 00-1.1A Change: 1. PURPOSE. This advisory
September 18, 1998 No. 8261 This opinion is issued in response to questions from Jan Curry, Manager of the Driver and Motor Vehicle Services Branch of the Oregon Department of Transportation (ODOT), about
July 2016 1101 CONNECTICUT AVENUE NW, SUITE 1100 WASHINGTON, DC 20036-4303 202.785.0453 FAX. 202.785.1487 WWW.NASFAA.ORG Financial Aid Data Sharing I. Introduction Financial aid professionals collect and
1 SB243 2 165240-3 3 By Senator Orr 4 RFD: Finance and Taxation General Fund 5 First Read: 17-MAR-15 Page 0 1 SB243 2 3 4 ENROLLED, An Act, 5 To amend Section 40-2A-10 Code of Alabama, 1975; to 6 remove
HireRight, Inc. will be verifying the information you provided to Dignity Health, during the pre-employment process and researching background information at our request. Our objective is to complete this
1 of 12 One Hundred Second Congress of the United States of America AT THE FIRST SESSION Begun and held at the City of Washington on Thursday, the third day of January, one thousand nine hundred and ninety-one
DAVIDL. LAKEY,M.D COMMISSIONER TEXAS DEPARTMENT OF STATE HEALTH SERVICES RECEIVED JUN 04 20@8 OPINION COMMITTEE June 2,2008 1100 W. 49' Street. Austin, Texas 78756 1-888-963-7111. htto:llwww.dshs.state.h.us
Business Associate Agreement This Agreement is entered into as of ("Effective Date"), between ( Covered Entity ), and ( Business Associate ). RECITALS WHEREAS, Business Associate provides services on behalf
New Hampshire Statutes Title 31 Trade and Commerce Chapter 359-B Consumer Credit Reporting 359-B:22 Definitions. In this subdivision: I. "Identity theft" means the unauthorized taking or use of an individual's
MEMORANDUM OF UNDERSTANDING BETWEEN THE UNITED STATES FEDERAL TRADE COMMISSION AND THE INFORMATION COMMISSIONER S OFFICE OF THE UNITED KINGDOM ON MUTUAL ASSISTANCE IN THE ENFORCEMENT OF LAWS PROTECTING
Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Westfax, Inc. Petition for Consideration and Clarification Rules and Regulations Implementing the Telephone Consumer
SUMMARY OF THE FAIR CREDIT REPORTING ACT The Fair Credit Reporting Act (FCRA) covers the use of many types of consumer information maintained by consumer reporting agencies. Consumer reports are defined
for the (CWS System) DHS/TSA/PIA-036 January 13, 2012 Contact Point Carolyn Y. Dorgham Program Manager, National Explosives Detection Canine Team Program Carolyn.Dorgham@dhs.gov Reviewing Official Mary
PROPOSED CHANGES TO THE OECD MODEL TAX CONVENTION DEALING WITH THE OPERATION OF SHIPS AND AIRCRAFT IN INTERNATIONAL TRAFFIC Public discussion draft 15 November 2013 15 January 2014 15 November 2013 PROPOSED
STATEMENT OF PROTOCOL BETWEEN THE PUBLIC COMPANY ACCOUNTING OVERSIGHT BOARD OF THE UNITED STATES AND THE DUBAI FINANCIAL SERVICES AUTHORITY The Public Company Accounting Oversight Board ("PCAOB") in the
OFFICE OF CHIEF COUNSEL DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 March 1, 2000 Number: 200113029 Release Date: 3/30/2001 CC:PA:DPL:Br1 GL-803646-00 UILC: 6103.00-00 INTERNAL
1 L.R.O. 2001 Electronic Transactions CAP. 308B CHAPTER 308B ELECTRONIC TRANSACTIONS ARRANGEMENT OF SECTIONS SECTION PART I Preliminary 1. Short title. 2. Interpretation. 3. Non-application of Parts II
GAO United States Government Accountability Office Report to Congressional Committees February 2005 AVIATION SECURITY Measures for Testing the Impact of Using Commercial Data for the Secure Flight Program
Foreign Corrupt Practices Act Amendments 1 Appendix E SEC. 5001. SHORT TITLE. This part may be cited as the Foreign Corrupt Practices Act Amendments of 1988. SEC. 5002. PENALTIES FOR VIOLATIONS OF ACCOUNTING
AGREEMENT AEP Energy Services, Inc. ( AEPES ), an Ohio corporation and a wholly owned subsidiary of American Electric Power Company, Inc. ( AEP ), a New York corporation, by its undersigned officer, pursuant
UNITED STATES OF AMERICA BEFORE THE FEDERAL TRADE COMMISSION 132 3088 COMMISSIONERS: Edith Ramirez, Chairwoman Julie Brill Maureen K. Ohlhausen Joshua D. Wright Terrell McSweeny In the Matter of PaymentsMD,
Title 45: Public Welfare PART 160 GENERAL ADMINISTRATIVE REQUIREMENTS 160.103 Definition Business associate: (1) Except as provided in paragraph (4) of this definition, business associate means a person
MEMORANDUM OF UNDERSTANDING BETWEEN THE UNITED STATES FEDERAL TRADE COMMISSION AND THE OFFICE OF THE DATA PROTECTION COMMISSIONER OF IRELAND ON MUTUAL ASSISTANCE IN THE ENFORCEMENT OF LAWS PROTECTING PERSONAL
CHAPTER 267 AN ACT concerning third party administrators of health benefits plans and third party billing services and supplementing Title 17B of the New Jersey Statutes. BE IT ENACTED by the Senate and
Information for Management of a Service Organization Copyright 2011 American Institute of Certified Public Accountants, Inc. New York, NY 10036-8775 All rights reserved. For information about the procedure
THE FAIR CREDIT REPORTING ACT As a public service, the staff of the Federal Trade Commission (FTC) has prepared the following complete text of the Fair Credit Reporting Act (FCRA), 15 U.S.C. 1681 et seq.
Credit Repair Organizations Act Title IV of the Consumer Credit Protection Act (Public Law 90-321, 82 Stat. 164) is amended to read as follows: TITLE IV--CREDIT REPAIR ORGANIZATIONS'' Sec. 401. Short title.
Your consent to our cookies if you continue to use this website.