Commentary

4 October 2006

Greeley Koch October 2006 Commentary on the TSA Guidelines For Registered Traveler SE/SP

-- I am writing on behalf of the 2,500 members in 49 countries of the Association of Corporate Travel Executives (ACTE). Fifty-three percent of these members are major U.S.- based corporations that generate hundreds of thousands of business trips annually. With an estimated 50,000 travelers in the air on any given week, our membership constitutes a major user segment of the proposed Registered Traveler Program.

ACTE has been providing the Transportation Security Administration (TSA) with business travel industry data for the past four years -- including a traveler survey that polled more than 1,000 individuals regarding their expectations of a Registered Traveler (RT) program. As the association’s president, I welcome this opportunity to comment on the recent guidelines for Sponsoring Entities and Service Providers, with regarding key provisions that do not appear in the document and which hold special significance for business travelers.

The comprehensive guidelines specifically details the role of the Sponsoring Entity (which may be an airport authority or an airline) and the Service Provider (a vendor approved to collect and verify traveler identity). The Service Provider is commissioned to notify the Registered Traveler applicant of acceptance in the program. It is the responsibility of the TSA to notify the applicant of a risk assessment if “Not Approved.”

While this absolves the Service Provider or the Sponsoring Entity of any further obligation to those who receive a “Not Approved” designation, it does not minimize the impact this result may have on the corporate (e.g. employment) standing of the applicant. In an ACTE poll taken earlier this year, sixteen percent of the respondent companies claimed rejected applications would raise questions about that particular employee. Seven percent of the respondent companies further indicated a traveler's decision not to apply for participation in the program could also impact that employee's corporate/employment standing.

Despite claims that the notification process is confidential and voluntary, corporate buy-in to the program (volume purchasing of RT participation through a local service provider) could negate that level of privacy. This pressure changes the nature of a “voluntary” RT program.

ACTE continues to call for a detailed and speedy resolution process to be included in any Registered Traveler program proposal to minimize the potential corporate impact of being declined by the program -- and to correct any inaccurate information that turns up in a traveler's vetting.

Two other issues not spelled out in the guidelines regard (i) the process that ensues when an applicant is given a “Not Approved” designation; and (ii) the disposition of information collected on individuals who may choose to withdraw from the program at some later date.
• Are applicants who earn a “Not Approved” advanced to a “No Fly “ list or simply subject to a more rigorous secondary inspection?
• Applicants agree to be vetted by the TSA when applying for participation in the Registered Traveler Program. It is understood that the vetting will become an ongoing process. Does the vetting process end if an individual withdraws from the program, and if so, what happens to the stored information. (This is important as the onus for storing the data rests with the Service Provider.)

The guidelines also include a provision for “excess information.” The term “excess information” refers to data requested by the Service Provider but not required (nor possible) to submit to the TSA. The nature of this “excess information” and its proposed use by Service Providers is not explained in the guidelines, nor has it been presented in previous versions of the Registered Traveler Program. The subject of “excess information” needs to be fully defined before it is made an option to the Service Provider.

While the guidelines for the SE/SP may not necessarily include the answers to these questions (as they may exist outside the realm of SE/SP responsibility), the success of the Registered Traveler program rests heavily on corporate acceptance. The best means of securing that acceptance would be to make addressing these concerns a program priority.

The Association of Corporate Travel Executives has been a supporter of the Registered Traveler concept since 2002. ACTE welcomes the opportunity to bring industry insight to future government planning. Our resources are at your disposal.

Thank you.