PTA - Occupant Seating and Anthropometry

U.S. Department of Transportation

Office of the Chief Information Officer (OCIO)
Privacy Threshold Assessment (PTA)
National Highway Traffic Safety Administration
Office of Vehicle Safety Research (OVSR)
Occupant Anthropometry and Seating

ABRAHAM
MICAH
EVANS SR

1

Digitally signed by
ABRAHAM MICAH
EVANS SR
Date: 2024.10.01
15:19:48 -04'00'

U.S. Department of Transportation

Privacy Threshold Assessment (PTA)
The Privacy Threshold Assessment (PTA) is an analytical tool used to determine the scope
of privacy risk management activities that must be executed to ensure that the
Department’s initiatives do not create undue privacy risks for individuals.
The Privacy Threshold Assessment (PTA) is a privacy risk management tool used by
the Department of Transportation (DOT) Chief Privacy Officer (CPO). The PTA
determines whether a Department system 1 creates privacy risk for individuals that
must be further analyzed, documented, or mitigated, and determines the need for
additional privacy compliance documentation. Additional documentation can include
Privacy Impact Assessments (PIAs), System of Records notices (SORNs), and Privacy
Act Exemption Rules (Exemption Rules).

The majority of the Department’s privacy risk emanates from its direct collection, use,
storage, and sharing of Personally Identifiable Information (PII), 2 and the IT systems
used to support those processes. However, privacy risk can also be created in the
Department’s use of paper records or other technologies. The Department may also
create privacy risk for individuals through its rulemakings and information collection
requirements that require other entities to collect, use, store or share PII, or deploy
technologies that create privacy risk for members of the public.

To ensure that the Department appropriately identifies those activities that may create
privacy risk, a PTA is required for all IT systems, technologies, proposed rulemakings,
and information collections at the Department. Additionally, the PTA is used to alert
other information management stakeholders of potential risks, including information
security, records management and information collection management programs. It is
also used by the Department’s Chief Information Officer (CIO) and Associate CIO for IT
Policy and Governance (Associate CIO) to support efforts to ensure compliance with
other information asset requirements including, but not limited to, the Federal Records
Act (FRA), the Paperwork Reduction Act (PRA), the Federal Information Security
Management Act (FISMA), the Federal Information Technology Acquisition Reform Act
(FITARA) and applicable Office of Management and Budget (OMB) guidance.
Each Component establishes and follows its own processes for developing, reviewing,
and verifying the PTA prior to its submission to the DOT CPO. At a minimum the PTA
must be reviewed by the Component business owner, information system security

For the purposes of the PTA the term “system” is used throughout document but is not limited to traditional
IT systems. It can and does refer to business activity and processes, IT systems, information collection, a
project, program and/or technology, and proposed rulemaking as appropriate for the context of the assessment.
2
The term “personally identifiable information” refers to information which can be used to distinguish or trace
an individual's identity, such as their name, social security number, biometric records, etc. alone, or when
combined with other personal or identifying information which is linked or linkable to a specific individual,
such as date and place of birth, mother’s maiden name, etc.
1

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manager, general counsel, records officers, and privacy officer. After the Component
review is completed, the Component Privacy Office will forward the PTA to the DOT
Privacy Office for final adjudication. Only PTAs watermarked “adjudicated” and
electronically signed by the DOT CPO are considered final. Do NOT send the PTA
directly to the DOT PO; PTAs received by the DOT CPO directly from program/business
owners will not be reviewed.
If you have questions or require assistance to complete the PTA please contact your
Component Privacy Officer or the DOT Privacy Office at privacy@dot.gov. Explanatory
guidance for completing the PTA can be found in the PTA Development Guide found on
the DOT Privacy Program website, www.dot.gov/privacy.

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U.S. Department of Transportation

PROGRAM MANAGEMENT
SYSTEM name: Occupant Anthropometry and Seating
Cyber Security Assessment and Management (CSAM) ID: N/A
SYSTEM MANAGER CONTACT Information:
Name: Elizabeth Lafferty
Email: Elizabeth.lafferty@dot.gov
Phone Number: 202-336-6222
Is this a NEW system?
☒ Yes (Proceed to Section 1)
☐ No
☐ Renewal
☐ Modification
Is there a PREVIOUSLY ADJUDICTED PTA for this system?
☐ Yes:

Date:

☐ No

1 SUMMARY INFORMATION
1.1

System TYPE
☐ Information Technology and/or Information System
Unique Investment Identifier (UII): Click here to enter text.
Cyber Security Assessment and Management (CSAM) ID: Click here to
enter text.

☐ Paper Based: Click here to enter text.
☐ Rulemaking
Rulemaking Identification Number (RIN): <>
Rulemaking Stage:
☐ Notice of Proposed Rulemaking (NPRM)
☐ Supplemental NPRM (SNPRM):
☐ Final Rule:
Federal Register (FR) Notice: Click here to enter text.

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☒ Information Collection Request (ICR)3
☒ New Collection

☐ Approved Collection or Collection Renewal

☐ OMB Control Number: Click here to enter text.

☐ Control Number Expiration Date: Click here to enter text.

☐ Other: Click here to enter text.
1.2

System OVERVIEW:
The National Highway Traffic Safety Administration (NHTSA) was established to
reduce deaths, injuries, and economic losses resulting from motor vehicle crashes on
the Nation’s highways. As part of this statutory mandate, NHTSA is authorized to
conduct research and collect data related to new and emerging technologies that
impact or may impact motor vehicle safety. See 49 U.S.C. § 30182.
NHTSA has a long history and objective to develop anthropomorphic test devices
(ATDs), e.g., test dummies, to help understand and measure the human body’s
movement during a crash, and see how it fares with various vehicle safety features.
ATD development has evolved through original dummy development, 3D modeling,
and the current THOR dummies through extensive research. Additional development
has led to parametric human body modeling, in which human body models (HBMs)
are morphed to represent people with widely varying size and shape.
Concurrent with the development of parametric HBMs, crash injury data analyses
have highlighted the potential benefits of these new tools. In particular, the field data
indicate that female occupants experience higher risks of some injuries in certain
types of crashes. Crash injury data also show that individuals with high body mass
are at higher risks of some injuries, possibly due to differences in the interaction with
the restraint systems.
NHTSA will collect information from licensed drivers to determine:
1. their eligibility to participate in a data collection of occupant anthropometry,
seating, and in-vehicle foot placement, and
2. their anthropometric measurements, seated anthropometric measurements,
seatbelt fit, and in-vehicle foot placement.
The objective of this study is to gather a new database of information on adult body
size, shape, posture, and motion to support advancement in safety applications. This
study will add to the body of the knowledge on motor vehicle anthropometry, will
support crash safety, and equitable occupant protection through the development of
HBMs and anthropomorphic test devices (ATDs). Findings from the data collection
effort will be compiled in a deidentified final report as well as incorporated into a
realistic human body shape modeler based on real deidentified measurement data.

3

See 44 USC 3501-3521; 5 CFR Part 1320

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U.S. Department of Transportation

NHTSA has contracted with the UMTRI; contract # 693JJ923F000284 to conduct
the experimental data collection of in-lab and in-vehicle occupant anthropometry.
Eligibility of candidates
Candidates will be male and female licensed drivers, ages 18+, in the Ann Arbor, MI
region and willing to travel to the UMTRI. Efforts will be made to enroll male and
female participants across a range of ages, stature by sex, and body mass index
(BMI). An age between 30 and 60 years will be targeted for roughly 70% of the total
participants. Their participation will be voluntary.
Candidates are recruited using University of Michigan’s Health Research portal,
https://umhealthresearch.org/. Prospective candidates will respond to the U-M Health
Research posting by completing a screening questionnaire on a Google Form.
Candidates who screen eligible will be contacted by phone to confirm the survey
responses and, if eligible, to schedule an appointment. Eligible candidates are those
whose answers to the Google Form questions are consistent with the inclusion and
exclusion criteria.
Eligibility requirements include the ability to read and speak English, ability to drive
for two hours continuously, hold a current and unrestricted U.S. driver’s license,
have been a licensed driver for at least one year, drive a car daily for an average of at
least 15 minutes, and comfortable driving on the highway and local roads. Exclusion
criteria include individuals with musculoskeletal ailments impeding the ability to
walk or sit comfortably or musculoskeletal deformities such as scoliosis or
amputations.
The study will ask the candidates:
1. First and Last name
2. Emails
3. Phone Number
4. Valid driver license
5. Sex
6. Race and ethnic background
7. English speaking
8. Age, height, and weight
9. Driving habits
10. Health questions (musculoskeletal ailments and deformities)
This research will be conducted over two studies and involves five information
collection components, including a screening questionnaire, an eligibility phone call,
an informed consent for in-lab data collection, a pre-drive in-vehicle questionnaire,
and an informed consent for the in-vehicle data collection. We estimate that 2000
screening questionnaires will be filled out to obtain the needed number of eligible
candidates. We estimate that up to 600 individuals that completed the screening
questionnaires will need to be contacted to obtain the needed number of 300 subjects
for the lab study. 100 individuals from the in-lab study will be invited to participate
in the in-vehicle study.
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U.S. Department of Transportation

Study
Individuals who have expressed interest in study participation through the University
of Michigan’s Health Research portal and meet the eligibility criteria based on their
Google Form will be contacted by phone. The investigators identify individuals who
may be eligible based on their responses on the screening questionnaire, confirm
eligibility and continued interest, and set up a time for in-lab consent and data
collection. No new information is obtained during this call. At the study visit, the
participants will be escorted to a private room upon arrival at UMTRI for the consent
process. Each version of the consent is set up electronically. Participants will
undergo the consent process with a member of the research team using a desktop
computer or tablet. After electronically signing the consent document, the participant
will be able to download or be emailed a copy of the signed form. After consent,
participants will undergo a series of anthropometric measurements to include: (1)
standard manual anthropometric measurements; (2) seated measurements in a hard
seat with a portable coordinate measuring machine (FARO Arm); (3) additional
landmark measurements in seating mockups using the FARO Arm; (4) a 3D surface
scan in the seating mockup using a 3D scanner; and (5) whole body scanning in the
VITUS XXL whole body laser scanner.
A subset of the in-lab respondents will be selected for the in-vehicle study. These
100 participants will be asked to complete an electronic questionnaire to capture
additional information about footwear. Upon arrival for the in-vehicle study,
participants will undergo the consent process with a member of the research team.
After consent, participants will be trained on the vehicle-specific safety and Advance
Driver-Assistance System (ADAS) features (we plan to select vehicles with adaptive
cruise control; other ADAS systems may also be present). Posture, belt fit, and
position of selected vehicle components will be recorded using a FARO Arm
coordinate measurement system and the vehicle Driver-Assistance System.
Naturalistic driving data collection will occur during the driving session.
NHTSA plans to provide monetary compensation for both in-lab and in-vehicle
study participation through UMTRI. SSN will not be collected.
Data will be stored on password protected UMTRI servers accessible only to the
study team. The identifiable data that will be retained at UMTRI beyond the end of
the study will consist of photos and videos of the participants’ faces during driving.
Retention of these data is needed to facilitate future analyses.
All results in the report will be presented to NHTSA in an aggregated, deidentified
form, and no personal identifiable information will be shared in the report. NHTSA
will receive a report deliverable describing the methods and results of the study from
the contractor, which will then be published in the National Transportation Library.
Data from study will be shared publicly in a manner that does not include any
personal identifiable information. Statistical blurring methods will be used to
scramble facial features of 3D scans. All deidentified data may be shared, including
questionnaire responses, body dimensions, three-dimensional body models, and other
data, but no personal identifying information, including identifiable face images, will
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be shared outside of the study team. Data may be shared via a UMTRI website or by
other means.

2 INFORMATION MANGEMENT
2.1

SUBJECTS of Collection
Identify the subject population(s) for whom the system collects, maintains, or
disseminates PII. (Check all that apply)
☒ Members of the public:

☒ Citizens or Legal Permanent Residents (LPR)
☐ Visitors
☐ Members of the DOT Federal workforce

☐ Members of the DOT Contract workforce

2.2

☐ System Does Not Collect PII. If the system does not collect PII, proceed
directly to question 2.3.

What INFORMATION ABOUT INDIVIDUALS will be collected, used, retained,
or generated?
Screening questionnaires will ask about the following to ensure that respondents
meet inclusion criteria:
1 Name
2 Age, height, & weight
3 Cell phone
4 Email
5 Sex
6 Race and ethnic background
7 Musculoskeletal ailments and deformities
In-lab and in-vehicle data collections will also include:
1 Standard manual anthropometric measurements
2 Seated anthropometric measurements with a portable coordinate measuring
machine
3 Additional anthropometric landmark measurements in seating mockups
4 Photos and videos of the participants’ faces during driving
5 3D surface scan in the seating mockup using a 3D scanner
6 Whole body scanning in a whole-body laser scanner
7 Video data to study occupant driving posture

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2.3

Does the system RELATE to or provide information about individuals?
☒ Yes: The information collection will gather information on adult’s body size,
shape, posture, and motion to support advancement in safety applications to support
crash safety and equitable occupant protection.
☐ No

If the answer to 2.1 is “System Does Not Collect PII” and the answer to 2.3 is “No”,
you may proceed to question 2.10.
If the system collects PII or relate to individual in any way, proceed to question 2.4.

2.4

Does the system use or collect SOCIAL SECURITY NUMBERS (SSNs)? (This
includes truncated SSNs)
☐ Yes:
Authority:
Purpose: Click here to enter text.

2.5

☒ No: The system does not use or collect SSNs, including truncated SSNs.
Proceed to 2.6.

Has an SSN REDUCTION plan been established for the system?
☐ Yes:

☐ No: Click here to enter text.
2.6

Does the system collect PSEUDO-SSNs?
☐ Yes:

☒ No: The system does not collect pseudo-SSNs, including truncated SSNs.

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U.S. Department of Transportation

2.7

Will information about individuals be retrieved or accessed by a UNIQUE
IDENTIFIER associated with or assigned to an individual?
☐ Yes
Is there an existing Privacy Act System of Records notice (SORN) for the
records retrieved or accessed by a unique identifier?
☐ Yes:
SORN:
☐ No:
Explanation:
Expected Publication:

2.8

☒ Not Applicable: Proceed to question 2.9

Has a Privacy Act EXEMPTION RULE been published in support of any
Exemptions claimed in the SORN?
☐ Yes

Exemption Rule:

☐ No

Explanation:
Expected Publication:

2.9

☒ Not Applicable: SORN does not claim Privacy Act exemptions.

Has a PRIVACY IMPACT ASSESSMENT (PIA) been published for this system?
☐ Yes:

PIA Name:
Publication date:
URL:

☒ No: New System

2.10

☐ Not Applicable: The most recently adjudicated PTA indicated no PIA was
required for this system.
Does the system EXCHANGE (receive and/or send) DATA from another
INTERNAL (DOT) or EXTERNAL (non-DOT) system or business activity?
☐ Yes: Click here to enter text.
☒ No

2.11

Does the system have a National Archives and Records Administration
(NARA)-approved RECORDS DISPOSITION schedule for system records?
☐ Yes:
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Schedule Identifier:
NARA schedule:
Schedule Number, Title and section:
URL:
Schedule Summary:
☐ In Progress:

☒ No: Records Officer (RO) has determined that a records schedule is needed. The
RO is currently working the program office to complete the draft.

3 SYSTEM LIFECYCLE

3.1

3.2

The systems development life cycle (SDLC) is a process for planning, creating,
testing, and deploying an information system. Privacy risk can change
depending on where a system is in its lifecycle.
Was this system IN PLACE in an ELECTRONIC FORMAT prior to 2002?

The E-Government Act of 2002 (EGov) establishes criteria for the types of
systems that require additional privacy considerations. It applies to systems
established in 2002 or later, or existing systems that were modified after 2002.
☐ Yes: <>
☐ No
☒ Not Applicable: System is not currently an electronic system. Proceed to
Section 4.
Has the system been MODIFIED in any way since 2002?
☐ Yes: The system has been modified since 2002.
☐ Maintenance.
☐ Security.

☐ Changes Creating Privacy Risk: Click here to enter text.
☐ Other: Click here to enter text.
3.3

☐ No: The system has not been modified in any way since 2002.
Is the system a CONTRACTOR-owned or -managed system?
☐ Yes: The system is owned or managed under contract.
Contract Number:

Contractor: Click here to enter text.

☐ No: The system is owned and managed by Federal employees.
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U.S. Department of Transportation

3.4

Has a system Security Risk CATEGORIZATION been completed?
The DOT Privacy Risk Management policy requires that all PII be protected
using controls consistent with Federal Information Processing Standard
Publication 199 (FIPS 199) moderate confidentiality standards. The OA Privacy
Officer should be engaged in the risk determination process and take data types
into account.
☐ Yes: A risk categorization has been completed.

Based on the risk level definitions and classifications provided above,
indicate the information categorization determinations for each of the
following:
Confidentiality:
Integrity:
Availability:

☐ Low
☐ Low
☐ Low

☐ Moderate
☐ Moderate
☐ Moderate

☐ High
☐ High
☐ High

☐ Undefined
☐ Undefined
☐ Undefined

Based on the risk level definitions and classifications provided above,
indicate the information system categorization determinations for each of
the following:
Confidentiality:
Integrity:
Availability:

3.5

☐ Low
☐ Low
☐ Low

☐ Moderate
☐ Moderate
☐ Moderate

☐ High
☐ High
☐ High

☐ Undefined
☐ Undefined
☐ Undefined

☐ No: A risk categorization has not been completed. Provide date of
anticipated completion. Click here to enter text.
Has the system been issued an AUTHORITY TO OPERATE?
☐ Yes:

Date of Initial Authority to Operate (ATO):
Anticipated Date of Updated ATO:
☐ No:

☐ Not Applicable: System is not covered by the Federal Information Security
Act (FISMA).

4 COMPONENT PRIVACY OFFICER ANALYSIS

The Component Privacy Officer (PO) is responsible for ensuring that the PTA is as
complete and accurate as possible before submitting to the DOT Privacy Office for
review and adjudication.
COMPONENT PRIVACY OFFICER CONTACT Information
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U.S. Department of Transportation

Name: Jose R. Delgado-Forastieri
Email: j.delgadoforastieri@dot.gov
Phone Number: 202-366-7491

COMPONENT PRIVACY OFFICER Analysis
The objective of this study is to gather information on adult’s body size, shape, posture, and
motion to support advancement in safety applications to support crash safety and equitable
occupant protection.
Participants will be recruited through a UMTRI owned list of individuals and potential
participants from the public based on a pre-screening questionnaire to determine their
eligibility to participate in the study. Participants will be asked to sign the consent forms
approved by an Independent Review Board (IRB) and by NHTSA’s Counsel’s Office.
The SSN from participants is not collected.
The OVSR already has a published PIA but it has to be updated for this kind of study.
Each participant will be assigned a test ID for use in all data collection forms, data analysis,
and reporting to track the progress of the individual’s participation throughout the study.
After the study is concluded UMTRI will send NHTSA a copy of the deidentified
aggregated report. The participant ID will not be included in the final report to NHTSA; and
the records cannot be retrieved by a unique identifier; therefore, this collection does not
meet the requirements of a systems of records.
Deidentified data may be shared, including questionnaire responses, body dimensions, threedimensional body models, and other data, but no personal identifying information, including
identifiable face images.
The privacy risk is high, because name, contact information, body size and facial video will
be collected.

5 COMPONENT REVIEW
Prior to submitting the PTA for adjudication, it is critical that the oversight offices
within the Component have reviewed the PTA for completeness, comprehension and
accuracy.
Component Reviewer

Name

Review Date

Business Owner

Elizabeth Lafferty

8/8/2024

General Counsel

Andrew DiMarsico

9/12/2024

Information System
Security Manager (ISSM)

Hadiyah Adams

8/22/2024

Privacy Officer

Jose R. Delgado-Forastieri

9/13/2024

LeErnest Wells

8/23/2024

Records Officer

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U.S. Department of Transportation
Table 1 - Individuals who have reviewed the PTA and attest to its completeness, comprehension and accuracy.

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U.S. Department of Transportation

Control
#
AP-1

Control Name
Authority to Collect

Primary PTA
Question

Satisfied

1.2 - Overview

Other
than
Satisfied
X

N/A

Component PO Assessment
Title 49 USC 30182
POAM: PRA Package must be
approved before collection.

DOT CPO
Assessment
Create AP-1
POA&M: PRA
Package must be
approved before
collection.

AP-2

Purpose Specification

1.2 - Overview

X

Purpose defined.

Substantive
records are not
retrieved by an
identifier linked to
and individual and
the records are not
about individuals
and are therefore,
not subject to the
Privacy Act.
Concur

AR-1

Governance and Privacy
Program
Privacy Impact and Risk
Assessment

Common
Control
Program
Management

X

Addressed by DOT CPO.

Concur

POAM: The Appendix B of
existing PIA must be updated to
include this study.
Time: 180 days

Create AR-2
POA&M

AR-2

X

1

Issue: PIA
required.
Requirement:
Update OSVR
PIA with adding

U.S. Department of Transportation

Control
#

Control Name

Primary PTA
Question

Satisfied

Other
than
Satisfied

N/A

Component PO Assessment

DOT CPO
Assessment
Occupant
Anthropometry
and Seating
Timeline: 90
days.
Concur

AR-3

Privacy Requirements for
Contractors and Service
Providers

3.3 - Contractor
System

X

AR-4

Privacy Monitoring and
Auditing
Privacy Awareness and
Training
Privacy Reporting

Common
Control
Common
Control
Common
Control

X

Not IT system under FISMA.
UMTRI manages this system,
and also ensure to review the
contract clauses for accuracy.
Addressed by DOT CPO.

X

Addressed by DOT CPO.

Concur

X

Addressed by DOT CPO.

Concur

AR-7

Privacy-Enhanced System
Design and Development

2.5 - SSN
Reduction

X

Concur

AR-8

Accounting of Disclosures

2.7 - SORN

X

DI-1

Data Quality

1.2 - System
Overview

X

All participants will receive
financial compensation only if
they qualify and actively
participate in the study. SSN will
not be collected.
Control is N/A to the primary
purposes and records of the
system. Substantive records in
the system do not include records
protected by the Privacy Act.
Control is N/A to the primary
purposes and records of the

AR-5
AR-6

2

Concur

Concur

Concur

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Control
#

Control Name

DI-2

Data Integrity and Data
Integrity Board

DM-1

Minimization of PII

DM-2

Data Retention and
Disposal

Primary PTA
Question

3.4 - Security
Risk
Categorization
2.2 –
Information
About
Individuals
2.11 - Records
Disposition
Schedule

Satisfied

Other
than
Satisfied

N/A

X
X

3

Component PO Assessment
system. Substantive records in
the system do not include records
protected by the Privacy Act.
Activity does not constitute
sharing covered by the CMA.

DOT CPO
Assessment

Concur

Data collection consistent with
purpose.

Concur

POAM: OVSR will work with
the Records Officer to establish
and submit to NARA a Retention
Schedule for these records.
Timeline: 180 days

Create DM-2
POA&M
Issue: Records are
stored on NHTSA
share drive.
Requirement:
OVSR will work
with the Records
Officer to
establish and
submit to NARA a
Retention
Schedule for these
records.
Timeline: 180
days

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Control
#

Control Name

DM-3

Minimization of PII Used
in Testing, Training, and
Research

IP-1

Consent

IP-2

Primary PTA
Question

Satisfied

Other
than
Satisfied

N/A

Component PO Assessment

DOT CPO
Assessment

2.2 –
Information
About
Individuals
2.7 - SORN

X

System not used for testing,
training, research.

Concur

X

Control is N/A to the primary
purposes and records of the
system. Substantive records in
the system do not include records
protected by the Privacy Act.

Individual Access

2.8 – Exemption
Rule

X

IP-3

Redress

2.7 - SORN

X

IP-4

Complaint Management

SE-1

Inventory of PII

SE-2

Privacy Incident Response

Common
Control
Common
Control
Common
Control

Control is N/A to the primary
purposes and records of the
system. Substantive records in
the system do not include records
protected by the Privacy Act.
Control is N/A to the primary
purposes and records of the
system. Substantive records in
the system do not include records
protected by the Privacy Act.
Addressed by DOT CPO.

Satisfied - Consent
mechanism
established with
IRB; information
is collected
directly from
individuals.
Concur

X
X
X

4

Concur

Concur

Not IT system under FISMA.

Concur

Addressed by DOT CPO.

Concur

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Control
#

Control Name

Primary PTA
Question

Satisfied

Other
than
Satisfied

N/A

Component PO Assessment

DOT CPO
Assessment
Concur

TR-1

Privacy Notice

2.7 - SORN

X

TR-2

System of Records Notices
and Privacy Act Statements

2.7 - SORN

X

TR-3

Dissemination of Privacy
Program Information
Internal Use

Common
Control
2.10 - Internal
and External
Use
2.10 - Internal
and External
Use

X

Control is N/A to the primary
purposes and records of the
system. Substantive records in
the system do not include records
protected by the Privacy Act.
Control is N/A to the primary
purposes and records of the
system. Substantive records in
the system do not include records
protected by the Privacy Act.
Addressed by DOT CPO.

X

No internal sharing.

Concur

X

Deidentified data may be shared,
including questionnaire
responses, body dimensions,
three-dimensional body models,
and other data, but no PII
including identifiable face
images will be shared

Concur

UL-1
UL-2

Information Sharing with
Third Parties

5

Concur

Concur

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