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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 14, 2009
NAME of Project: Environmental‐Historic Preservation Management Information System
(EMIS)
Name of Component: Federal Emergency Managment Agency
Name of Project Manager: Angela Gladwell; Laura Shick
Email for Project Manager: [email protected]; [email protected]
Phone number for Project Manager: A. Gladwell: 202‐646‐3193; L. Shick: 202‐646‐2685
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: June 10th, 2009
Page 3 of 8
SPECIFIC QUESTIONS
1.
Describe the project and its purpose:
EMIS is a stand‐alone web‐based system created to standardize FEMAʹs environmental
planning and historic preservation (EHP) compliance review process through consistency in
data collection, storage, and decision‐making. Numerous Federal EHP laws and Executive
Orders apply to Federal agencies and Federally‐funded actions, including FEMAʹs grant‐
funded projects related to disaster response, recovery, mitigation, and emergency
preparedness. Examples of EHP laws and Executive Orders include the following: National
Environmental Policy Act, National Historic Preservation Act, Endangered Species Act,
Executive Order 19988 ‐ Floodplain Management, Executive Order 11990 ‐ Protection of
Wetlands, and Executive Order 12898 ‐Federal Actions to Address Environmental Justice in
Minority Populations and Low‐Income Populations. EMIS is used to document the agencyʹs
compliance with these EHP requirements.
With EMIS, all EHP reviews are conducted and all EHP‐related documentation is stored in a
standard manner in a single system. The use of EMIS ensures that the EHP compliance
review is performed consistently and in a standard manner for all FEMA‐funded projects
across all disaster and non‐disaster programs. The automation of the EHP review and
compliance determination process is more efficient than conducting paper‐based project
reviews, thereby allowing faster approval and funding of projects.
2.
Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: September 21, 2006
Date last updated: May 27, 2009
Database code change (no application/java changes) so that EMIS is able to process Public
Assistance Grant Program projects submitted by the Emergency Management Mission
Integrated Environment (EMMIE) that were initially not queued to EMIS for EHP review.
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
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.
EMIS does not collect information from applicants for FEMA grant assistance, instead that
information is collected by the FEMA grant program itself (e.g. Public Assistance Grant
Program). However, EMIS stores copies of correspondence (letters, emails, faxes, and
transcripts of telephone conversations) with resource agencies (e.g. US Fish and Wildlife
Service, State Historic Preservation Offices), which may include names of staff at those
agencies and their business contact information. The names and business contact
information of these individuals consulted can be typed and stored in the various comment
fields of EMIS. The sole purpose of collecting and storing this information is to document
compliance with EHP requirements.
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.
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:
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 5 of 8
6.
What information about individuals could be collected, generated or retained?
Under the various EHP laws, (examples of which are located in section 1), FEMA is legally
required to consult with other Federal, state and local agencies and offices responsible for the
protection and management of environmental resources and historic properties.
EMIS may store information on staff, consultants, and contractors who prepare EHP
documents, conduct EHP analyses, and perform the EHP project review. Information that
may be stored in EMIS includes:
7.
Names (first, last, middle)
Business mailing addresses
Business email addresses
Business telephone numbers (desk, cell, blackberry)
Business fax 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.
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 6 of 8
9.
Is Personally Identifiable Information2 physically transported outside of the LAN? (This can
include mobile devices, flash drives, laptops, etc.)
No.
Yes.
10.
Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems3?
No
Yes. Please list:
EMIS has a link to view subgrant applications that are generated in the Mitigation Directorateʹs
eGrants system (MTeGrants) and in EMMIE. MTeGrants is currently the grants management
system for the non‐disaster Hazard Mitigation Assistance Grant Program (Pre‐Disaster
Mitigation Grant Program, Flood Mitigation Assistance Grant Program, Severe Repetitive Loss
Grant Program, Repetitive Flood Claims Grant Program), and EMMIE is currently the grants
management system for the Public Assitance Grant Program.
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?
EMIS data is extracted, transformed, and loaded (ETL) electronically via Oracle’s materialized
views every night into FEMA’s Enterprise Data Warehouse. The Data Warehouse is a web‐based
analytical database used to perform ad‐hoc reporting, evaluate trends, and decide where best to
assign resources to accomplish FEMAʹs mission. Both EMIS and Data Warehouse are only
available to users with a FEMA domain account (i.e. agency staff and contractors).
Yes.
No.
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
12.
Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown.
No.
Office of Environmental Planning & Historic Preservation (OEHP) is currently working with the
Mitigation Directorate’s Enterprise Architecture team to complete the C&A, and has budgeted to
complete the initial phase in FY10.
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: September 16, 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 Grants
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 | 2009-09-17 |
File Created | 2009-09-16 |