Privacy Threshold Analyst

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: July 29, 2010
NAME of Project: America's Literacy Directory
Name of Component: US Citizenship and Immigration Services
Name of Project Manager: Rachael M. Shaw
Email for Project Manager: [email protected]
Phone number for Project Manager: 202-272-1361
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 9
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
Project Description on America's Literacy Directory: U.S Citizenship and Immigration
Services Office of Citizenship (OoC) entered into an inter-agency agreement with the
National Institute for Literacy (NIFL) to expand America's Literacy Directory,
www.literacydirectory.org, with information on organziations that offer citizenship
preparation services. To accomplish this task, the OoC would like to use the email addresses
obtained from Citizenship Toolkit recipients and Civics and Citizenship Training Workshop
registrants to encourage individuals to add their program's and/or organization's information
on the America's Literacy Directory. NIFL and its contractor, L-3 Communications, maintain
the information contained within America's Literacy Directory.
Information on OoC's Citizenship Toolkit: For the Civics and Citizenship Toolkit, recipients
must visit www.citizenshiptoolkit.gov and register to receive a copy of the Toolkit. The
Government Printing Office (GPO) hosts the Toolkit website and receives the initial
registrations. On a weekly basis, GPO provides that list to the OoC. The OoC gives it an
initial look and then shares it with Karyn Dubie in the Eastern Forms Center. Karyn's team
scrubs the list for any duplicates (programs can only receive one free copy of the Toolkit) and
then distributes the Toolkits. Currently, the Eastern Forms Center has collected, in an Excel
spreadhseet, over 10,000 toolkit recipients' information (to include email addresses).
Information on OoC's Civics and Citizenship Training Workshops: The OoC provides
national in-person trainings to volunteers and adult educators on naturalization test
preparation to help them better serve their immigrant adult learners. Participants must
register for these trainings at http://www.uscis.gov/teachertraining. The OoC collects
registration information (to include participant's email addresses) and inputs the information
into an Excel spreadsheet. To date, around 3500 people have registered for a Civics and
Citizenship Training workshop.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed:
Date last updated:

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
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 Office of Citizenship would be contacting individuals (who registered for a Toolkit or
who registered for a Training Workshop) via email to inform them about inputting their
program's information on the America's Literacy Directory.

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.

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 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?
The Office of Citizenship collects names, email addresses, occupations, and physical
addresses to ship the Civics and Citizenship Toolkit and to register participants for
the Civics and Citizenship Training Workshops. Although the Office of Citizenship
had prior approval to collect this information, the Office of Citizenship would like to
contact the Toolkit recipients and Training Workshop registrants via email to
promote the America's Literacy Directory.

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.

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
Yes.

9.

Is Personally Identifiable Information 2 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:

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:
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 7 of 9
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 8 of 9
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: August 10, 2010
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: Stakeholder Engagement Initiative:
Customer Relationship Management
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/ALL-002
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS

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