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Fish tickets are reported by processors, but some are "white van fleet".
Data sensitivity and security
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Information collected pursuant to requirements of the MSA, including permit application information, is protected by its confidentiality provisions at § 402 and under its implementing regulations at 50 CFR Part 600 Subpart E, including NOAA Administrative Order (NAO) 216-100. Additional protections of the Privacy Act and FOIA apply to such data as well as those collected under the Halibut Act.
Mitigating controls
Registration will be open to new permit applicants, existing permit holders, and agents of both. From the system perspective, there is little difference between permit holders and agents of permit holders. (Agents should file a notarized letter of authorization from each permit owner that the agent represents. The permit owner is responsible for transactions pertaining to their permit, and if they have delegated to an agent without submitting the authorization letter, that doesn't absolve them of any responsibility.) New permit applicants will not be identifiable with the same level of assurance as existing permit holders, but, as the permit application is processed, the confidence in the permit holder's identity will grow. And as a new permit applicant starts out with no value in the system, there is little at risk for these participants whose identity is less certain.
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