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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: Intercity Bus Security Grant Program (IBSGP)
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 Intercity Bus Security Grant
Program (IBSGP).
∗
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:
In partnership with DHS Transportation Security Administration (TSA), FEMA has the lead
for designing and operating the administrative mechanisms for the Intercity Bus Security
Grant Program (IBSGP). The purpose of the IBSGP is to provide grant funding to eligible
private operators providing transportation by an over‐the‐road bus for security
improvements.
A Federal interagency working group, including representatives from TSA, the Federal
Motor Carrier Safety Administration (FMCSA), and FEMA will evaluate proposals of those
applicants that have complied with all administrative and programmatic grant requirements,
as determined by FEMA and TSA. TSA and FEMA will review the interagency
recommendations and make funding recommendations to the Secretary. Additional details
on
the
IBSGP
can
be
found
at
http://www.fema.gov/pdf/government/grant/ibsgp/fy09_ibsgp_guidance.pdf.
2.
Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: October 1, 2005
Date last updated: August 1, 2009
FEMA is seeking OMB clearance for the Intercity Bus Security Grant Program
(IBSGP).
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.
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 4 of 9
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.
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?
IBSGP awards are made by organization, not individuals. Only private operators
providing fixed‐route or charter transportation by an over‐the‐road bus servicing an
Urban Area Security Initiative (UASI) jurisdiction are eligible for the IBSGP. Charter
companies must make a minimum of 50 trips annually to one or more UASI
jurisdictions. Companies with 250 or more over‐the‐road buses in operation and
providing the highest volume of services to high‐risk urban areas are considered Tier
I. All other applicants that meet the minimum eligibility requirements will be placed
in Tier II. IBSGP has six standard federal grant forms: Application for Federal
Assistance SF‐424, Disclosure of Lobbying Activities SF‐LLL, Budget Information SF‐
424A, Assurances SF‐424B, Budget Information‐Construction Form SF‐424C, and
Assurances‐Construction Programs SF‐424D. Consequently, IBSGP collects/retains
applicant information, including:
• Names of organizational Point(s) of Contact;
• Organizational address;
• Organizational email addresses;
• Organizational telephone and fax number;
• Organizational Investment Justification;
• Employer Identification Number (EIN) and (Dun & Bradstreet) DUNS
numbers; and
•
Type of Submission;
•
Type of Application;
•
Date Received;
•
Applicant Identifier;
•
Federal Entity Identifier;
•
Federal Award Identifier;
•
Date Received by State;
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
7.
•
State Application Identifier;
•
Department Name;
•
Division Name;
•
Name of Federal Agency;
•
Catalog of Federal Domestic Assistance (CFDA) Number;
•
CFDA Title and;
•
Funding Opportunity Number;
•
Competition Identification Number; and Areas Affected by Project
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. Personally Identifiable Information (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 (i.e. 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: Program
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 Management Program
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/FEMA‐2006‐0002
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS
| File Type | application/pdf |
| File Title | DHS PRIVACY OFFICE |
| Author | pia |
| File Modified | 2010-10-12 |
| File Created | 2009-10-30 |