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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 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: August 1, 2009
NAME of Project: Freight Rail Security Grant Program (FRSGP)
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:
6.
What information about individuals could be collected, generated or retained?
FRSGP awards are made by organization, not by an individual. The only eligible
applicants are Class I, II, and III freight railroad carriers that transport SSM and
owners of railroad cars that transport TIH materials. FRSGP has four standard
federal grant forms: Application for Federal Assistance SF‐424, Disclosure of
Lobbying Activities SF‐LLL, Budget Information SF‐424A, and Assurances SF‐424B.
Consequently, each preparedness grant program varies and has a different set of
requirements. FRSGP collects and/or retains applicant information including:
•
Type of Submission;
•
Type of Application;
•
Date Received;
•
Applicant Identifier;
•
Federal Entity Identifier;
•
Federal Award Identifier;
•
State Application Identifier;
•
Names of organizational Point(s) of Contact;
•
Employer Identification Number (EIN) and Dun & Bradstreet (DUNS)
numbers;
•
Organizational address;
•
Organizational email addresses;
•
Department Name;
•
Division Name;
•
Organizational telephone and fax number;
•
Organizational Investment Justification;
•
Name of Federal Agency;
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
•
Catalog of Federal Domestic Assistance (CFDA) Number;
•
CFDA Title and;
•
Funding Opportunity Number;
•
Competition Identification Number; and
•
Areas Affected by Project
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 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 systems 3 ?
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 Accreditation 4 ?
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:
Confidentiality:
2
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
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
Integrity:
Availability:
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 9 of 9
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)
DATE reviewed by the DHS Privacy Office: October 30, 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: Grant Management Programs
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/FEMA‐2006‐002
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS
File Type | application/pdf |
File Title | DHS PRIVACY OFFICE |
Author | pia |
File Modified | 2009-10-30 |
File Created | 2009-10-30 |