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pdfThe 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 10th, 2009
Page 1 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.
The 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 10th, 2009
Page 2 of 9
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's Operation Stonegarden (OPSG) Grant Program
Name of Component: Federal Emergency Managment Agency
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 Operation Stonegarden (OPSG)
Grant Program.
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.
The 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 10th, 2009
Page 3 of 9
SPECIFIC QUESTIONS
1.
Describe the project and its purpose:
In partnership with DHS' Customs and Border Patrol (CBP/BP), FEMA has the lead for
designing and operating the administrative mechanisms for the Operation Stonegarden
(OPSG) Grant Program. The purpose of OPSG is to provide funding to designated localities
to enhance cooperation and coordination between Federal, State, local, and tribal law
enforcement agencies in a joint mission to secure the U.S. borders along routes of ingress
from International borders to include travel corridors in States bordering Mexico and
Canada, as well as States and territories with International water borders. OPSG funds must
be used to increase operational capabilities of Federal, State, local and tribal law enforcement,
promoting a layered, coordinated approach to law enforcement within U.S. Border States and
territories.
Applicants that have complied with all administrative and programmatic grant
requirements, as determined by State and CBP/BP Sector Headquarters representatives, will
have their proposals evaluated and prioritized (based on need and impact) by the
aforementioned parties. After this level of review, a federal review process is conducted by a
panel of evaluators from components within FEMA and CBP/BP.
2.
Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: October 2005
Date last updated: October 2009
The program priorities and pool of eligible applicants, among other items such as
allowable costs or cost share requirements, can differ by grant year.
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.
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.
The 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 10th, 2009
Page 4 of 9
The type of information that may be collected and/or retained are the names of
organizational/grantee
Point(s)
of
Contact,
organizational/grantee
address,
organizational/grantee 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.
The 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 10th, 2009
Page 5 of 9
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:
6.
What information about individuals could be collected, generated or retained?
OPSG awards are made by organization, not by an individual. The only eligible applicants
for OPSG funds are a select number of Governor-designated State Administrative Agencies
(SAAs). OPSG has four standard federal grant forms: Application for Federal Assistance SF424; Disclosure of Lobbying Activities; Budget Information - Non-Construction Programs SF424A; and Assurances - Non-Construction Programs SF-424B. However, each preparedness
grant program varies and has a different set of requirements. Consequently, OPSG collects
and/or retains the type of applicant information that may be collected and/or retained
including:
o
Type of Submission;
o
Type of Application;
o
Date Received;
o
Applicant Identifier;
o
Federal Entity Identifier;
o
Federal Award Identifier;
o
Date Received by State;
o
State Application Number;
o
Names of Organizational Point(s) of Contact;
o
Organizational Address;
o
Organizational Email Addresses;
o
Organizational Telephone and Fax Number;
o
Organizational Investment Justification;
o
Department Name;
o
Division Name;
o
Name of Federal Agency;
The 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 10th, 2009
Page 6 of 9
7.
o
Catalog of Federal Domestic Assistance Numbers (CFDA);
o
CFDA Title;
o
Funding Opportunity Number;
o
Competition Identification Number;
o
Areas Affected by Project; and
o
Employer Identification Number (EIN) and Dun & Bradstreet (DUNS) numbers.
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.
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.
The 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 10th, 2009
Page 7 of 9
9.
Is Personally Identifiable Information 2 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:
2
Low
Moderate
High
Undefined
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)
The 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 10th, 2009
Page 8 of 9
Integrity:
Low
Moderate
High
Undefined
Availability:
Low
Moderate
High
Undefined
The 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 10th, 2009
Page 9 of 9
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)
DATE reviewed by the DHS Privacy Office: March 23, 2010
NAME of the DHS Privacy Office Reviewer: Rebecca J. Richards
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: Grant Management Programs
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/FEMA-004
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS
| File Type | application/pdf |
| File Title | DHS PRIVACY OFFICE |
| Author | pia |
| File Modified | 2010-03-23 |
| File Created | 2010-03-23 |