Privacy Threshold Analysis (PTA)

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 1 of 7

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:
Senior Director, Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-343-1717
[email protected]

Upon receipt from your component Privacy Office, 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 DHSConnect and directly from the DHS Privacy Office via email:
[email protected], phone: 202-343-1717.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 2 of 7

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Project or
Program Name:

Intergovernmental Affairs (IGA) Stakeholder Customer Satisfaction Survey
(1660-0130)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Office of External Affairs
(OEA)

Xacta FISMA
Name (if
applicable):

Click here to enter text.

Xacta FISMA
Number (if
applicable):

Click here to enter text.

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Development

Date first
developed:
Date of last PTA
update

Upon OMB and PRA
approval

Pilot launch
date:

N/A

N/A

Pilot end date:

N/A

ATO Status (if
applicable)

Choose an item.

ATO
expiration date
(if applicable):

Click here to enter a date.

PROJECT OR PROGRAM MANAGER
Name:

Robert Nadeau

Office:

OEA, Intergovernmental
Affairs Division

Title:

Acting Director

Phone:

202-212-5193

Email:

[email protected]

INFORMATION SYSTEM SECURITY OFFICER (ISSO) (IF APPLICABLE)
Name:

Click here to enter text.

Phone:

Click here to enter text.

Email:

Click here to enter text.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 3 of 7

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: New PTA
Within FEMA's Office of External Affairs, the Intergovernmental Affairs Division will be fielding a
customer satisfaction survey to collect feedback from state, local, tribal, territorial, and other stakeholders.
The survey will be conducted through online software (Survey Monkey). FEMA will push-out the survey
via email to the members of the OEA Intergovernmental Affairs Division listserv. This survey will allow
the Intergovernmental Affairs Division to revise the services, resources, and initiatives available for
Intergovernmental Affairs Stakeholders.

2. Does this system employ any of the
following technologies:
If you are using any of these technologies and
want coverage under the respective PIA for that
technology please stop here and contact the DHS
Privacy Office for further guidance.

Closed Circuit Television (CCTV)
Social Media
Web portal1 (e.g., SharePoint)
Contact Lists
None of these

3. From whom does the Project or
Program collect, maintain, use, or
disseminate information?
Please check all that apply.

This program does not collect any personally
identifiable information2
Members of the public
DHS employees/contractors (list components):
Contractors working on behalf of DHS
Employees of other federal agencies

4. What specific information about individuals is collected, generated or retained?

1

Informational and collaboration-based portals in operation at DHS and its components that collect, use, maintain, and share
limited personally identifiable information (PII) about individuals who are “members” of the portal or “potential members” who
seek to gain access to the portal.
2
DHS defines personal information as “Personally Identifiable Information” or PII, which is any information that permits the
identity of an individual to be directly or indirectly inferred, including any information that is linked or linkable to that individual,
regardless of whether the individual is a U.S. citizen, lawful permanent resident, visitor to the U.S., or employee or contractor to
the Department. “Sensitive PII” is PII, which if lost, compromised, or disclosed without authorization, could result in substantial
harm, embarrassment, inconvenience, or unfairness to an individual. For the purposes of this PTA, SPII and PII are treated the
same.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 4 of 7

No information about individuals is collected, generated or retained. Survey Monkey will be customized
so as not to save IP addresses.
No. Please continue to next question.
4(a) Does the project, program, or system
Yes. If yes, please list all personal identifiers
retrieve information by personal identifier?
used:
4(b) Does the project, program, or system
No.
use Social Security Numbers (SSN)?
Yes.
4(c) If yes, please provide the specific legal
Click here to enter text.
basis and purpose for the collection of
SSNs:
4(d) If yes, please describe the uses of the
Click here to enter text.
SSNs within the project, program, or
system:
4(e) If this project, program, or system is
No. Please continue to next question.
an information technology/system, does it
relate solely to infrastructure?
Yes. If a log kept of communication traffic,
please answer the following question.
For example, is the system a Local Area Network
(LAN) or Wide Area Network (WAN)?
4(f) If header or payload data3 is stored in the communication traffic log, please detail the data
elements stored.
Click here to enter text.

5. Does this project, program, or system
connect, receive, or share PII with any
other DHS programs or systems4?

No.
Yes. If yes, please list:
Click here to enter text.

6. Does this project, program, or system
connect, receive, or share PII with any
external (non-DHS) partners or
systems?

3

No.
Yes. If yes, please list:
Click here to enter text.

When data is sent over the Internet, each unit transmitted includes both header information and the actual data being sent. The
header identifies the source and destination of the packet, while the actual data is referred to as the payload. Because header
information, or overhead data, is only used in the transmission process, it is stripped from the packet when it reaches its
destination. Therefore, the payload is the only data received by the destination system.
4
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 Xacta.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 5 of 7

6(a) Is this external sharing pursuant to
new or existing information sharing
access agreement (MOU, MOA, LOI,
etc.)?
7. Does the project, program, or system
provide role-based training for
personnel who have access in addition
to annual privacy training required of
all DHS personnel?
8. Per NIST SP 800-53 Rev. 4, Appendix
J, does the project, program, or system
maintain an accounting of disclosures
of PII to individuals who have
requested access to their PII?
9. Is there a FIPS 199 determination?4

Choose an item.
Please describe applicable information sharing
governance in place: N/A
No.
Yes. If yes, please list:

No. What steps will be taken to develop and
maintain the accounting: IP addresses will not be
saved by Survey Monkey.
Yes. In what format is the accounting
maintained:
Unknown.
No.
Yes. Please indicate the determinations for each
of the following:
Confidentiality:
Low
Moderate

High

Undefined

Integrity:
Low

Moderate

High

Undefined

Availability:
Low
Moderate

High

Undefined

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)

4

FIPS 199 is the Federal Information Processing Standard Publication 199, Standards for Security Categorization of Federal
Information and Information Systems and is used to establish security categories of information systems.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 6 of 7

Component Privacy Office Reviewer:

Lane Raffray

Date submitted to Component Privacy
Office:

March 26, 2014

Date submitted to DHS Privacy Office:

March 31, 2014

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
FEMA recommends that the collection is not privacy sensitive and that the PTA is sufficient at this time.

(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Jameson Morgan

PCTS Workflow Number:

1014334

Date approved by DHS Privacy Office:

April 2, 2014

PTA Expiration Date

April 2, 2017
DESIGNATION
No

Privacy Sensitive System:

Choose an item.

Category of System:
Determination:

If “no” PTA adjudication is complete.

If “other” is selected, please describe: Click here to enter text.
PTA sufficient at this time.
Privacy compliance documentation determination in progress.
New information sharing arrangement is required.
DHS Policy for Computer-Readable Extracts Containing Sensitive PII
applies.
Privacy Act Statement required.
Privacy Impact Assessment (PIA) required.
System of Records Notice (SORN) required.
Paperwork Reduction Act (PRA) Clearance may be required. Contact
your component PRA Officer.
A Records Schedule may be required. Contact your component Records
Officer.

PIA:

Choose an item.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 7 of 7

SORN:

If covered by existing PIA, please list: Click here to enter text.
Choose an item.

If covered by existing SORN, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
The DHS Privacy Office agrees with the FEMA Privacy Office’s recommendation that 1660-0130 is a
non-privacy sensitive system. No PIA or SORN coverage is required at this time because no PII is
collected, stored, maintained, or shared by this survey.
FEMA has sent a copy of the survey to the DHS Privacy Office. The survey contains no PII and does not
pose any privacy risks. A new PTA is required if this survey changes or starts to collect PII.