Privacy Threshold Analysis (PTA) for TSP

T he Privacy Office

U.S. Department of Homeland Security

Washington, DC 20528

703-235-0780, [email protected]

www.dhs.gov/privacy

Privacy Threshold Analysis

Version date: June 10^th, 2009

Page 7 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)

This form is used to determine whether
a Privacy Impact Assessment is required.

Please use the attached form to determine whether a Privacy Impact Assessment (PIA) is required under the E-Government Act of 2002 and the Homeland Security Act of 2002. 

Please complete this form and send it to your component Privacy Office. If you do not have a component Privacy Office, please send the PTA to the DHS Privacy Office:

Rebecca J. Richards

Director of Privacy Compliance

The Privacy Office

U.S. Department of Homeland Security

Washington, DC 20528

Tel: 703-235-0780

[email protected]

Upon receipt, the DHS Privacy Office will review this form. If a PIA is required, the DHS Privacy Office will send you a copy of the Official Privacy Impact Assessment Guide and accompanying Template to complete and return.

A copy of the Guide and Template is available on the DHS Privacy Office website, www.dhs.gov/privacy, on DHSOnline and directly from the DHS Privacy Office via email: [email protected], phone: 703-235-0780.

PRIVACY THRESHOLD ANALYSIS (PTA)

Please complete this form and send it to the DHS Privacy Office.
Upon receipt, the DHS Privacy Office will review this form
and may request additional information.

Summary Information

Date submitted for review: August 1, 2009

Name of Project: FEMA FY 2009 Trucking Security Program (TSP)

Name of Component:

Name of Project Manager: Paul Belkin

Email for Project Manager: [email protected]

Phone number for Project Manager: 202-786-9771

Type of Project:

Information Technology and/or System^

A Notice of Proposed Rule Making or a Final Rule.

Other: Seeking OMB clearance for TSP

Specific Questions

1. Describe the project and its purpose:

 In partnership with the Transportation Security Administration (TSA), FEMA has the lead for designing and operating the administrative mechanisms for the FY 2009 Trucking Security Program (TSP). The purpose of the TSP is primarily focused on the purchase and installation or enhancement of equipment and systems related to tractor and trailer tracking systems. TSP will provide funding to develop a system for DHS to monitor, collect, and analyze tracking information; and develop plans to improve the effectiveness of transportation and distribution of supplies and commodities during catastrophic events. It is targeted for Tier I (11 or more tractors) and Tier II (10 or less tractors) trucking companies.

Applicants that have complied with all administrative grant requirements will have their proposals evaluated by a national review panel of subject matter experts from federal agencies. Applications will be evaluated based on feasibility, timelines, and sustainability. FEMA is responsible for notifying the State Administrative Agencies (SAAs) of trucking projects funded under this grant program.

2. Status of Project:

This is a new development effort.

This is an existing project.

Date first developed: 2005

Date last updated: August 1, 2009

FEMA is seeking OMB clearance for the TSP.

3. Could the project relate in any way to an individual?¹

No. Please skip ahead to the next question.

Yes. Please provide a general description, below.

The type of information that may be collected and/or retained are the names of organizational Point(s) of Contact, organizational address, organizational email addresses, and additional contact information.

4. Do you collect, process, or retain information on: (Please check all that apply)

DHS Employees

Contractors working on behalf of DHS

The Public

The System does not contain any such information.

5. Do you use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs)

No.

Yes. Why does the program collect SSNs? Provide the function of the SSN and the

legal authority to do so:

<Please provide the function of the SSN and the legal authority to do so.>

6. What information about individuals could be collected, generated or retained?

TSP awards are made by organization, not by individual. The only eligible applicants for TSP funds are those who have a current security plan subject to Title 49 CFR 172.800 Transport Tier I Commodities as defined by TSA and consist of 11 or more tractors (Tier I) or consist of 10 or less tractors (Tier II). Consequently, the type of applicant information that may be collected and/or retained includes:

• names of organizational Point(s) of Contact;

• organizational address;

• organizational email addresses;

• organizational fax number;

• organizational Investment Justification;

• EIN and DUNS numbers; and

• Other data as required for completion of standard federal grant application forms.

7. If this project is a technology/system, does it relate solely to infrastructure? [For example, is the system a Local Area Network (LAN) or Wide Area Network (WAN)]?

No. Please continue to the next question.

Yes. Is there a log kept of communication traffic?

No. Please continue to the next question.

Yes. What type of data is recorded in the log? (Please choose all that apply.)

Header

Payload Please describe the data that is logged.

<Please list the data elements in the log.>

8. Can the system be accessed remotely?

No.

Yes. When remote access is allowed, is the access accomplished by a virtual private network (VPN)?

No. Applicants provide application data upon submitting their proposals to FEMA via grants.gov, which is accessible via Internet.    

Yes.

9. Is Personally Identifiable Information² physically transported outside of the LAN? (This can include mobile devices, flash drives, laptops, etc.)

No.

Yes. PII, as it relates to an individual's employment by an eligible grant entity, is transported outside the LAN (via Internet) and transmitted to grants.gov. FEMA accesses grants.gov to download application data, which includes PII, such as an organization's Point of Contact (POC) name, organizational POC's email address, and organizational POC's telephone number .    

10. Does the system connect, receive, or share Personally Identifiable Information with any other DHS systems³?

No

Yes. Please list:

     

11. Are there regular (ie. periodic, recurring, etc.) data extractions from the system?

No.

Yes. Are these extractions included as part of the Certification and Accreditation⁴?

Yes.

No.      

12. Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?

Unknown.

No.

Yes. Please indicate the determinations for each of the following:

Confidentiality: Low Moderate High Undefined

Integrity: Low Moderate High Undefined

Availability: Low Moderate High Undefined

PRIVACY THRESHOLD REVIEW

(To be Completed by the DHS Privacy Office)

Date reviewed by the DHS Privacy Office:      

Name of the DHS Privacy Office Reviewer: <Please enter name of reviwer.>

DESIGNATION

This is NOT a Privacy Sensitive System – the system contains no Personally Identifiable Information.

This IS a Privacy Sensitive System

Category of System

IT System

National Security System

Legacy System

HR System

Rule

Other:      

Determination

PTA sufficient at this time

Privacy compliance documentation determination in progress

PIA is not required at this time

A PIA is required

System covered by existing PIA:      

A new PIA is required.

A PIA Update is required.

A SORN is required

System covered by existing SORN:      

A new SORN is required.

DHS PRIVACY OFFICE COMMENTS

     

 The E-Government Act of 2002 defines these terms by reference to the definition sections of Titles 40 and 44 of the United States Code. The following is a summary of those definitions:

•“Information Technology” means any equipment or interconnected system or subsystem of equipment, used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. See 40 U.S.C. § 11101(6).

•“Information System” means a discrete set of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information. See: 44. U.S.C. § 3502(8).

Note, for purposes of this form, there is no distinction made between national security systems or technologies/systems managed by contractors. All technologies/systems should be initially reviewed for potential privacy impact.

1 Projects can relate to individuals in a number of ways. For example, a project may include a camera for the purpose of watching a physical location. Individuals may walk past the camera and images of those individuals may be recorded. Projects could also relate to individuals in more subtle ways. For example, a project that is focused on detecting radioactivity levels may be sensitive enough to detect whether an individual received chemotherapy.

2 Personally Identifiable Information is information that can identify a person. This includes; name, address, phone number, social security number, as well as health information or a physical description.

3 PII may be shared, received, or connected to other DHS systems directly, automatically, or by manual processes. Often, these systems are listed as “interconnected systems” in TAFISMA.

4 This could include the Standard Operation Procedures (SOP) or a Memorandum of Understanding (MOU)