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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: April 13, 2009
Page 1 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 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,
and fax: 703‐235‐0442.
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: April 13, 2009
Page 2 of 7
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: January 30, 2009
NAME of Project: Citizen Corps Affiliate Programs and Organizations Application
Name of Component: Federal Emergency Managment Agency
Name of Project Manager: Penny Burke
Email for Project Manager: [email protected]
Phone number for Project Manger: 202‐786‐9610
TYPE of Project:
Information Technology and/or System ∗
A Notice of Proposed Rule Making or a Final Rule.
Other:
∗
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: April 13, 2009
Page 3 of 7
SPECIFIC QUESTIONS
1.
Describe the project and its purpose:
Citizen Corps Affiliate Programs and Organizations offer communities resources for public
education, outreach, and training; represent volunteers interested in helping to make their
community safer; or offer volunteer service opportunities to support first responders, disaster
relief activities, and community safety efforts. Providing formal recognition to these
programs and similar organizations by affiliating them with Citizen Corps assists the
program reach its goal of having every American participate in making their communities
and families safer. In order to ensure that interested parties appropriately further the Citizen
Corps mission, Citizen Corps requests supporting information from those programs and
organizations seeking to become affiliates. Currently, there are 27 Citizen Corps Affiliates
and we would like to extend our Citizen Corps Affiliate Programs and Organizations
Application (1660‐0097) Office of Management and Budget (OMB) Paper Work Reduction
Act Clearance for 3 years.
2.
Status of Project:
This is a new development effort.
This an existing project.
Date first developed: July 12, 2006
Date last updated: July 12, 2006
There are no content changes to the Citizen Corps Affiliate Programs and
Organizations Application 1660‐0097. This request is to extend our application
clearance.
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 individual information collected is personnel contacts of the Citizen Corps Affiliate
Applicant used for communication between FEMA and said applicant. The individual
contact information includes:
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: April 13, 2009
Page 4 of 7
•
name,
•
phone number,
•
email address,
•
And business physical address.
No personal non‐professional information is required.
4.
Do you collect, process, or retain information on: (Please check all that apply)
DHS Employees
Contractors working on behalf of DHS
The Public
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?
In order to ensure that Citizen Corps affiliates only with those programs and
organizations that are capable of supporting its mission, Citizen Corps will request
the following information from not‐for‐profit and governmental organizations that
would like to become affiliates:
•
A written request for membership and a statement of intent to meet Citizen
Corpsʹ conditions for membership;
•
A copy of the organizationʹs Constitution or charter, and bylaws, with
evidence therein of their commitment to non‐discrimination in hiring and in the
provision of services;
•
A brief history of the organization, including its mission statement,
membership, and examples of past practices;
•
A copy of the Internal Revenue Serviceʹs certification of the organizationʹs
501(c)(3) status or a state certification, if the organization is not‐for‐profit entity;
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: April 13, 2009
Page 5 of 7
•
A statement as to how the organization plans to further the Citizen Corps
mission;
•
A statement as to how the organization will work with Citizen Corps
Councils at the national, state, tribal, or local levels;
•
Names and titles of administrative personnel or points of contact; and
Address and telecommunications information, including e‐mail and web site
addresses.
This information can be submitted in letter format and is be reviewed by DHS/FEMA
personnel who are working with the Citizen Corps program.
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.
8.
Can the system be accessed remotely?
No.
Yes.
9.
When remote access is allowed, is the access accomplished by a virtual private network
(VPN)?
Yes
No
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: April 13, 2009
Page 6 of 7
10.
Is Personally Identifiable Information 2 physically transported outside of the LAN? (This can
include mobile devices, flash drives, laptops, etc.)
No.
Yes.
11.
Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems?
No
Yes. Please list:
12.
Are there regular data extractions from the system?
No.
Yes. Are these extractions included as part of the Certification and Accreditation 3 ?
Yes.
No.
13.
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:
Integrity:
Availability:
2
Low
Moderate
High
Undefined
Low
Moderate
High
Undefined
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
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: April 13, 2009
Page 7 of 7
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)
DATE reviewed by the DHS Privacy Office: April 22, 2009
NAME of the DHS Privacy Office Reviewer: Nathan Coleman, Acting Director Privacy
Compliance
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: DHS/FEMA‐006
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS
| File Type | application/pdf |
| File Title | DHS PRIVACY OFFICE |
| Author | pia |
| File Modified | 2009-04-22 |
| File Created | 2009-04-22 |