As stated in the NMFS Procedural Directive 32-110-01 "Use and Implementation of Electronic Signatures" policy directive, a risk assessment needs to be made to determine the risks most likely to occur due to the replacement of the current process with an electronic one and the mitigation techniques used by the system. Since NPS is a system that will be used to collect, process, and store permit related data, the greatest risks involved with implementing and switching over to NPS are:
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NMFS program officials must perform a qualitative risk assessment consistent with the analytic framework called out in OMB M-01-04, "E-authentication Guidance for Federal Agencies." The OMB policy, and in turn, the NMFS Procedural Directive identify seven potential categories of impact from using e-signatures that include:
- 1) Inconvenience, distress, or damage to standing or reputation to any party
- 2. Financial loss to any party
- 3. Agency liability
- 4. Harm to agency programs or public interests
- 5. Unauthorized release of sensitive information
- 6. Personal safety
- 7. Civil or criminal violations
Based on the risk assessment conducted by the FIS e-signature task force, the analysis focused on the following potential impacts listed below.