DHS published this Privacy Impact Assessment (PIA) to explain its plan to expedite DHS’s ability to meet a critical mission need through the use of an interim manual data transfer process. Specifically, DHS has a critical mission need to perform classified queries on its unclassified data in order to identify individuals supporting the terrorist activities of: (1) the Islamic State of Iraq and the Levant (ISIL), (2) al-Qa’ida in the Arabian Peninsula (AQAP), (3) al-Nusrah Front, (4) affiliated offshoots of these groups, or (5) individuals seeking to join the Syria-Iraq conflict. (These individuals are often referred to as “foreign fighters” by the media and in public discourse.) The ability to perform classified searches of unclassified data for this uniquely time sensitive purpose will allow DHS to better identify and track foreign fighters who may seek to travel from, to, or through the United States. This type of comparison is a long-standing mission need; however, the specific threat has shortened the timeframe in which DHS must meet the need.
To meet this critical mission need, DHS will adopt an interim process that foregoes many of the automated protections of the DHS Data Framework, such as the tagging of necessary data sets in the unclassified data lake. By foregoing these automated protections, DHS will be able to expedite transfers of information from the Electronic System for Travel Authorization (ESTA), the Advance Passenger Information System (APIS), Form I-94 records, and Passenger Name Records (PNR) directly from the unclassified DHS domain to the classified DHS domain through a manual process.
Although the interim process deviates from the standard model of the Data Framework, DHS is pursuing this process under the auspices of the Data Framework in order to utilize aspects of the Framework’s policies, governance, and transparency. Moreover, the interim solution will only continue until the standard model is capable of meeting the mission need. DHS remains committed to the standard model of the Data Framework for meeting DHS’s mission needs in the long-term, and the Department will revert to the standard model once the technical capabilities are available. Consequently, regular development on the Framework will continue and will not be affected by the use of the interim process.