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Tsa Reply to Homeland Security Re X-ray Privacy 2010

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FEB 2 4 2010

u.s. Department of Homeland SeaJrlty
601 South 12th Street
Arlington, VA 20598

The Honorable Bennie G. Thompson
Chairman
Committee on Homeland Security
U.S. House of Representatives
.Washington, DC 20515-0004

Transportation
Security

Administration

Dear Chairman Thompson:
Thank you for your letter of January 21, 2010, regarding the privacy concerns that the
Committee on Homeland Security has raised about the capability of Advanced Imaging
Technology (AIT) to store, print, record, and export images.
The Transportation Security Administration (TSA) is committed to providing world class
security while preserving privacy in our security programs. The AIT program meets this
commitment through TSA's screening protocol that ensures complete anonymity for passengers
undergoing AIT scans. TSA has not deviated from these operational protocols, which were first
published in a Privacy Impact Assessment (PIA) in January 2008 before any devices in the AIT
pilot went' into operation. That PIA, and every PIA update since, states, "[w]hile the equipment
has the capability of collecting and storing an image, the image storage functions will be disabled
by the manufacturer before the devices are placed in an airport and will not have the capability to
be activated by operators."
The procurement specifications mentioned in your letter support TSA's statements on AlT.
The specifications state:
•

The "systems will prohibit the storage and exporting of passenger images during normal
screening operations" (para. 3.1.1.1.2); and

•

"During the screening mode, the WBI [whole body imager] shall be prohibited from
exporting passenger image data, including via the Security Technology Integrated
Program (STIP) which is networking of technology. During the test mode, the WBI shall
not be capable of conducting passenger screening. The WBI shall prohibit local storage
of image data in all modes." (para. 3.1.1.1.2).

Below please find TSA's responses to your specific questions:

1.

Why does the procurement require the capability to store, print, record, and export
images?
TSA requires AIT machines to have the capability to retain and export imagines only for
testing, training, and evaluation purposes. Testing was done at the TSA Systems
Integration Facility (TSIF) and the Transportation Security Laboratory (TSL). Images
used for operator training were also recorded and used at the Threat Mitigation
Laboratory (TML), the facility where Transportation Security Officer (TSO) training is
developed. All AIT machines are delivered to airports without the capability to store,
print, or transmit images, and cannot be modified by the operators. TSOs operating in the
airport environment have neither the technical capability nor the authority to change the
AIT into test mode.

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2.

What is the extent of the ability AIT to store and transmit data?
AIT has the ability to store' and transmit data; however, the only locations where the
functionalities of storage and data transmission are enabled are at the testing and
development sites: TSIF, TSL, and TML.

3.

Provide the titles of the employees who have the authority to place the machines in
test mode and the number of employees that fall into this category.
Test Engineers at TSL - 8
Test Engineers at TSIF - 3
Training Development Contractors at TML - 4

4.

Under what circumstances, if any, can AIT machines be entered into test mode in
the airport settings?
There are no circumstances when the system would be entered into the test mode in an
airport environment.

5.

Who at TSA is authorized as a Level "Z" user? Please provide the titles of these
employees and state if any government contractors or any other non-TSA officials
are Level "Z" users. Also, provide the number of employees and or contractors that
have this designation.
Test Engineers at TSL - 8
Test Engineers at TSIF - 3
Training Development Contractors at TML - 4
Contracting Officer Technical Representative - I
Vendor Technicians - 26
Headquarters Deployment Team - 3
The above include both Federal employees and government contractors.

6.

What are the details of the privacy filters built into the AIT?
When the machines are delivered to an airport for screening operations, the privacy filters
are already in place. The level of filtering is described in the PIA. The image filter
setting is approved by TSA, it is configured into the imaging machine at the factory and
cannot be changed by the operator of the machine in the airport environment.
Each vendor's approved image filter is recorded in the published PIA. Any changes to
these filters will be published in an updated PIA and widely communicated to the
traveling public.
Any changes to privacy settings on individual machines can only be made by the "z"
users. The only people with "z,. user access for use in the lab setting are select personnel
in TSA's Office of Security Technology and technicians from the manufacturer.

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7.

Has TSA asked the Chief Privacy Officer to amend or update the current Privacy
Impact Assessment to reDect the storage capability of AIT and identify the
individuals who have this authority?
No. The PIA accurately states the operational storage capability of the AIT in the airport
environment. Storage capability for AIT in the TSL and TSIF is not discussed because
the flying public is not screened in those locations.

8.

What protections does the AIT have that will prevent people outside of TSA from
obtaining image data through the device's USB and }~themet capabilities?
The machine cannot transmit or store the image onto the USB device. AITs used for
screening operations at airports are not able to store, export, print, or transmit images.
All images are deleted from the system after they are reviewed by the remotely-located
operator. The image storage functions are disabled by the manufacturer before the
devices are placed in an airport and do not have the capability to be activated by the
operators. The screening statistical data that may be saved or transferred include an
officer's user identification as well as log in and log out times.
The machines are not networked. The current specification does not have a STIP
requirement and the referenced specification is out of da~e; therefore, they cannot be
hacked. In addition, all produced images transmitted from the machine to the remote
viewing room are encrypted.
Also, there are strict procedures applicable to AIT operation. No cameras, cellular
telephones, or other devices capable of capturing an image are permitted in the image
viewing room. Any official or employee who fails to follow these strict procedures is
subject to serious discipline up to and including removal.

I appreciate that you took the time to share the Committee's privacy concerns about AIT and
hope this information is helpful. If! may be offurther assistance, please contact LaVita LeGrys,
Assistant Administrator for the Office Legislative Affairs, at (571) 227-2717.
Sincerely yours,
.....

Gale D. Rossides
Acting Administrator