Amtrak has released a third batch of records (1st interim response, 2nd interim response) in response to our Freedom of Information Act (FOIA) request for information about Amtrak’s collection and “sharing” with the US and Canadian governments of information about Amtrak travelers on international routes between the US and Canada:

1. Amtrak-FOIA-29OCT2014-signed.pdf (note that this file is actually in .doc format, and is not a copy of our request, as the filename might imply, but a collection of responsive records)
2. date of birthAM.doc
3. Function summary.doc
4. IDPFOIARequest.pdf (another collection of responsive records, beginning with a list of all of Amtrak’s cross-border routes including both trains and Amtrak feeder buses)
5. Regression User testing 9222305 (4).doc
6. TheIdentityProject_InterimResponse3.pdf (cover letter from Amtrak’s FOIA office accompanying the interim response)
7. wspBORDER.doc

The files with “.doc” filenames all appear to be from Amtrak’s IT department, and relate to the implementation by Amtrak of requirements for inclusion of passenger ID data desired by the US government in each Amtrak reservation for travel across the US-Canada border. As we have noted previously, this “requirement” was imposed internally and “voluntarily” by Amtrak, and was not a requirement of any law, regulation, or order from any other US or Canadian government agency.  It remains unclear from the records released to date whether anyone in Amtrak’s IT department was aware that this was solely an Amtrak requirement and not an externally imposed obligation.

According to these records, Amtrak began requiring a date of birth in the reservation, before a ticket could be issued, for each passenger on any international route, including infant passengers, beginning in November or December of 2000. (There are some inconsistencies in the dates in different records.)  Beginning in July or August 2005, Amtrak began also requiring a nationality and passport or other ID number in each such reservation, as part of Amtrak’s “voluntary” participation in the DHS “Advanced Passenger Information System” (APIS) also used by airlines.

These records include the formats used by Amtrak sales agents working directly in Amtrak’s own “ARROW” reservation system, as well as the formats used by travel agents making Amtrak reservations through each of the four major CRSs/GDSs: Amadeus, Galileo, Sabre, and Worldspan.  Amtrak’s software testing staff noted the complexity of these formats (which is indicative of how burdensome they are for the travel agents who have to learn and use them) and the likelihood of errors by travel agents. The Amtrak records include information provided to travel agents and travelers, describing these “requirements” but giving no clue that these requirements were voluntarily self-imposed by Amtrak itself.

The files linked above are posted here exactly as we received them by email from Amtrak’s FOIA office. The filenames are not indicative of the actual file contents, and some of the filename extensions don’t correspond to the file formats. One of the “.pdf” files, for example, is actually in MS-Word “.doc” format (also readable in Libre Office among other programs) rather than in PDF format.

We requested that all records found in digital form be released as bitwise copies of the files as found in Amtrak’s filesystems, but some of the files we received appear to be derivative, modified versions of copies of the original files, in some cases in completely different formats.

Most of the the records responsive to our request that we believe are likely to exist have not yet been released. Amtrak is continuing to process our request, and we expect further responses.