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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 8
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 8
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: Interoperable Emergency Communications Grant Program (IECGP)
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 FEMAʹs Interoperable Emergency
Communications Grant Program (IECGP).
∗
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 8
SPECIFIC QUESTIONS
1.
Describe the project and its purpose:
In partnership with the Department of Homeland Security (DHS) Office of Emergency
Communications (OEC), the Interoperable Emergency Communications Grant Program
(IECGP) is mandated by Section 1809 of the Homeland Security Act of 2002 (6 U.S.C. §579), as
amended by Section 301(a), Title III of the Implementing Recommendations of the 9/11
Commission Act of 2007 (P.L. 110‐053), which states the Secretary shall establish the IECGP
to make grants to States to carry out initiatives to improve local, tribal, statewide, regional,
national and, where appropriate, international interoperable emergency communications,
including communications in collective response to natural disasters, acts of terrorism, and
other man‐made disasters.
FEMA and OEC officials with subject matter expertise will evaluate and select applications
for those applicants that have complied with all administrative and programmatic grant
requirements, as determined by FEMA.
2.
Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: 2008
Date last updated: August 1, 2009
FEMA is seeking Office of Management & Budget (OMB) clearance for the IECGP.
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.
1
Do you collect, process, or retain information on: (Please check all that apply)
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 8
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:
6.
What information about individuals could be collected, generated or retained?
IECGP awards are made by organization, not by an individual. The only eligible
applicants for IECGP funds are Governor‐designated State Administrative Agencies
(SAAs). IECGP has six standard federal grant forms: Application for Federal
Assistance SF‐424, Disclosure of Lobbying Activities SF‐LLL, Budget Information ‐
Non‐Construction Programs SF‐424A, Assurances ‐ Non‐Construction Programs SF‐
424B, Budget Information ‐ Construction Form SF‐424C, and Assurances ‐
Construction Programs SF‐424D. Each preparedness grant program varies and has a
different set of requirements. Consequently, FEMA collects and/or retains the type of
applicant information that may be collected and/or retained including:
•
Type of Submission;
•
Type of Application;
•
Date Received;
•
Applicant Identifier;
•
Federal Entity Identifier;
•
Federal Award Identifier;
•
Date Received by State;
•
State Application Number;
•
Names of Organizational Point(s) of Contact;
•
Organizational Address;
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 8
7.
•
Organizational Email Addresses;
•
Organizational Telephone and Fax Number;
•
Organizational Investment Justification;
•
Department Name;
•
Division Name;
•
Name of Federal Agency;
•
Catalog of Federal Domestic Assistance Numbers (CFDA);
•
CFDA Title;
•
Funding Opportunity Number;
•
Competition Identification Number;
•
Areas Affected by Project; and
•
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)?
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 8
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 individualʹs 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 organizationʹs Point of Contact (POC)
name, organizational POCʹs email address, and organizational POCʹs 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.
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)
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 8
No.
Yes. Please indicate the determinations for each of the following:
Confidentiality:
Integrity:
Availability:
Low
Moderate
High
Undefined
Low
Moderate
High
Undefined
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 8 of 8
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)
DATE reviewed by the DHS Privacy Office: November 5, 2009
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: FEMA 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 | 2009-11-12 |
| File Created | 2009-11-12 |