Privacy Threshold Analysis (PTA)

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 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: November 2009
NAME of Project: FEMA's Urban Areas Security Initiative (UASI) Nonprofit Security Grant
Program (NSGP)
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 Office of Management & Budget (OMB) clearance for the Urban
Areas Security Initiative (UASI) Nonprofit Security 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:
FEMA’s Urban Areas Security Initiative (UASI) Nonprofit Security Grant Program (NSGP)
provides funding support for target hardening activities to nonprofit organizations that are at
high risk of a terrorist attack. The design of this program is to promote coordination and
collaboration in emergency preparedness activities among public and private community
representatives, State and local government agencies (i.e., state departments of homeland
security, state departments of emergency management), and Citizen Corps Councils.
State and local representatives with subject matter expertise will evaluate and prioritize
applications (based on need and impact) for those applicants that have complied with all
administrative and programmatic grant requirements, as determined by FEMA and
developed from stakeholder input. Lastly, a panel of evaluators from components within
FEMA conducts a federal review process.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: October 2005
Date last updated: August 1, 2009
FEMA is seeking OMB clearance for the NSGP.

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 types 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 9
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?
NSGP awards by organization, not by an individual. The only eligible applicants for NPSG
funds are Governor-designated State Administrative Agencies (SAAs). NSGP has four
standard federal grant forms: Application for Federal Assistance SF-424; Disclosure of
Lobbying Activities; Budget Information - Non-Construction Programs SF-424A; and
Assurances - Non-Construction Programs SF-424B. Each preparedness grant program varies
and has a different set of requirements. Consequently, NSGP 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;



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);

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


CFDA Title;



Funding Opportunity Number;



Competition Identification Number;



Areas Affected by Project; and



Employer Identification Number (EIN), and Dun & Bradstreet (DUNS) numbers.

NSGP does not collect the name of the contact at commercial housing entities because it
doesn't award directly to them. NSGP only awards to the SAAs who then make subawards
with the money.
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. 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. NSGP is a grant program, as such,
GD&A uses existing systems to collect data for use by the grant programs. 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:

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 8 of 9
Confidentiality:

Low

Moderate

High

Undefined

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: December 2, 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