Privacy Threshold Analysis (PTA)

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 9 of 9

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: Intercity Bus Security Grant Program (IBSGP)

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: FEMA is seeking OMB clearance for FEMA's Intercity Bus Security Grant Program (IBSGP).

Specific Questions

1. Describe the project and its purpose:

In partnership with DHS Transportation Security Administration (TSA), FEMA has the lead for designing and operating the administrative mechanisms for the Intercity Bus Security Grant Program (IBSGP). The purpose of the IBSGP is to provide grant funding to eligible private operators providing transportation by an over-the-road bus for security improvements.

A Federal interagency working group, including representatives from TSA, the Federal Motor Carrier Safety Administration (FMCSA), and FEMA will evaluate proposals of those applicants that have complied with all administrative and programmatic grant requirements, as determined by FEMA and TSA. TSA and FEMA will review the interagency recommendations and make funding recommendations to the Secretary. Additional details on the IBSGP can be found at http://www.fema.gov/pdf/government/grant/ibsgp/fy09_ibsgp_guidance.pdf.

2. Status of Project:

This is a new development effort.

This is an existing project.

Date first developed: October 1, 2005

Date last updated: August 1, 2009

FEMA is seeking OMB clearance for the Intercity Bus Security Grant Program (IBSGP).

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?

IBSGP awards are made by organization, not individuals. Only private operators providing fixed-route or charter transportation by an over-the-road bus servicing an Urban Area Security Initiative (UASI) jurisdiction are eligible for the IBSGP. Charter companies must make a minimum of 50 trips annually to one or more UASI jurisdictions. Companies with 250 or more over-the-road buses in operation and providing the highest volume of services to high-risk urban areas are considered Tier I. All other applicants that meet the minimum eligibility requirements will be placed in Tier II. IBSGP has six standard federal grant forms: Application for Federal Assistance SF-424, Disclosure of Lobbying Activities SF-LLL, Budget Information SF-424A, Assurances SF-424B, Budget Information-Construction Form SF-424C, and Assurances-Construction Programs SF-424D. Consequently, IBSGP collects/retains applicant information, including:

• Names of organizational Point(s) of Contact;

• Organizational address;

• Organizational email addresses;

• Organizational telephone and fax number;

• Organizational Investment Justification;

• Employer Identification Number (EIN) and (Dun & Bradstreet) DUNS numbers; and

•  FORMTEXT Type of Submission;

• Type of Application;

• Date Received;

• Applicant Identifier;

• Federal Entity Identifier;

• Federal Award Identifier;

• Date Received by State;

• State Application Identifier;

• Department Name;

• Division Name;

• Name of Federal Agency;

• Catalog of Federal Domestic Assistance (CFDA) Number;

• CFDA Title and;

• Funding Opportunity Number;

• Competition Identification Number; and Areas Affected by Project

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. Personally Identifiable Information (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 (i.e. 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)