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Privacy Impact Assessment
Information Collected and Purpose
Formulas Online is a web-based application that supports the online submission of applications, along with the routing and processing of submissions and sample analysis requests for beverage and nonbeverage alcohol product formula. The intent of this application is to streamline the management process for the three regulatory functions vital to the mission of TTB. The regulatory functions consist of the following compliance approval processes: (i) beverage alcohol formula process and approval, (ii) certificate of label issuance approval (COLA); and (iii) nonbeverage product information processes for tax and regulatory compliance. All submissions and sample analysis requests are provided with secure cross-organizational access.
Information Use and Sharing
Formulas Online stores names, mailing addresses, phone numbers, and e-mail addresses for those individuals who have provided the aforementioned information on the application. Formulas Online provides applicants with a publicly facing website enabling them to view the information in the application and to check the status of the application while it is awaiting approval. Each application is specifically linked to the individual who submits it and only designated and approved TTB officials have direct access to personally identifiable information (PII) stored within Formulas Online. With regard to the roles assigned within the application, all individuals receive access rights based on their status.
For an individual's PII to be stored in Formulas Online, the individual must have willingly and intentionally filled out and submitted an application. The application is subject to the Privacy Act and a Privacy Act SORN that addresses all required categories of information has been published in the Federal Register.
The Alcohol and Tobacco Tax and Trade Bureau (TTB) will take appropriate security measures to safeguard PII and other sensitive data stored on Formulas Online. TTB will apply Department of the Treasury security standards, including but not limited to, routine scans and monitoring, back-up activities, and background security checks for all TTB employees and contractors. Accordingly, access to Formulas Online PII will be limited to specific job function and access will be controlled based on least privilege.
The following access safeguards will also be implemented:
- Passwords expire after a set period;
- Accounts are locked after a set period of inactivity;
- Minimum length of passwords is eight characters;
- Passwords are combination of letters, numbers, and symbols; and
- Accounts are locked after a set number of incorrect attempts.