Draft PTA to DHS Office of Privacy
Draft PTA to DHS.doc
Petition for U Nonimmigrant Status
Draft PTA to DHS Office of Privacy
OMB: 1615-0104
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 10th, 2009
Page
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
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: March 31, 2010
Name of Project: Form I-918
Name of Component:
Name of Project Manager: Essie Bell
Email for Project Manager: [email protected]
Phone number for Project Manager: 202-272-8035
Type of Project:
Information Technology and/or System
A Notice of Proposed Rule Making or a Final Rule.
Other: Extension of Form I-918 under the Paperwork Reduction Act
Specific Questions
Describe the project and its purpose:
This form is used by victims of certain qualifying criminal activity to obtain temporary immigration benefits.
Status of Project:
This is a new development effort.
This is an existing project.
Date first developed:
Date last updated: August 31, 2009
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.
Yes this form is used by individuals who are victims of a qualifying crime and who want to apply for immigration benefits.
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.
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.>
What information about individuals could be collected, generated or retained?
Name, Address, Date of birth, A-Number
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.>
Can the system be accessed remotely?
No.
Yes. When remote access is allowed, is the access accomplished by a virtual private network (VPN)?
No.
Yes.
Is Personally Identifiable Information2 physically transported outside of the LAN? (This can include mobile devices, flash drives, laptops, etc.)
No.
Yes.
Does the system connect, receive, or share Personally Identifiable Information with any other DHS systems3?
No
Yes. Please list:
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.
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)
| File Type | application/msword |
| File Title | DHS PRIVACY OFFICE |
| Author | pia |
| Last Modified By | Stephen Tarragon |
| File Modified | 2010-04-26 |
| File Created | 2010-04-26 |
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