Privacy Threshold Analysis (PTA)

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 6
PRIVACY THRESHOLD ANALYSIS (PTA)

CONTACT LISTS
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 6
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: 01/23/2012
NAME of Project: FEMA Form 516-0-1 Federal Hotel and Motel Fire Safety Declaration Form
Name of Component: Federal Emergency Managment Agency
Name of Project Manager: Bruce Hensler
Email for Project Manager: [email protected]
Phone number for Project Manger: 301-447-1263
TYPE of Project:
Information Technology and/or System ∗
A Notice of Proposed Rule Making or a Final Rule.
Other: Information Collection

∗

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 6
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
The Federal Emergency Management Agency (FEMA) United States
Fire
Administration (USFA) uses FEMA Form 516-0-1, The Federal Hotel and Motel Fire
Safety Declaration Form, to collect basic information on life-safety systems related
directly to fire-safety in hotels, motels, and similar places of accommodation
applying for inclusion on the National Master List (NML). Public Law 101-391
requires FEMA to establish and maintain a list of hotels, motels, and similar places of
public accommodation meeting minimum requirements for protection of life from
fire; the list is known as the National Master List (NML) . The referenced law
resulted from a series of deadly fires in hotels and motels, occurring in the 1970's and
1980's, with high loss of life. Property owners, lodging general managers, or their
designee/delegate (“applicants”), complete the form (FEMA Form 516-0-1 (Paper and
Electronic)) providing basic information including identification of the owner(s) of
the property, the business's EIN (Employer Identification Number), and provisions
for life-safety from fire. The form requests specific responses from applicants as to
the installation of smoke detectors in all guestrooms of properties submitted for
listing on the NML. In addition, applicants must indicate if the lodging establishment
has an automatic fire sprinkler system where the building is four stories or higher.
The information is collected and distributed through an on-line, electronic database
accessed through the USFA website. Information submitted voluntarily by lodging
establishments is reviewed and if the criteria meet the Hotel and Motel Fire Safety
Act requirements they are given a FEMA ID number and listed in the NML database.
Federal travelers and the public seeking public accommodation with provisions for
life-safety from fire access the NML through the online database
(http://www.usfa.fema.gov/applications/hotel) and identified lodging establishments
in the area to which they are traveling . For statutory reference see Title 15 U.S.C. §§
2224-26. Paper copies are stored in secured file cabinets and electronic forms are
maintained in the FEMA USFA Web Farm This collection of information and form
are part of OMB No. 1660-0068.

2.

Status of Project:
This is a new development effort.
This an existing project.
Date first developed: 1990
Date last updated: 2009

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 6
FEMA Records Management requires the reassessment and re-calculation of
burden hours to complete the form to ensure compliance with the
Paperwork Reduction Act, as amended .
3.

Is the information collected directly from the individuals seeking information from the
Department or working collaboratively with the Department on various projects?
Yes.
No. Please describe the information source and collection method.

4.

Does the individual have the option to decline submitting the information collected?
Yes.
No.

5.

Is the information collected limited to non-sensitive personally identifiable information? An
example of sensitive personally identifiable information is the social security number or date of
birth.
Yes.
No.

6.

What information about individuals could be collected, generated or retained?
Business Point of Contact information includes the Property Owner, General
Manager or their designee/delegate’s: Name; Title, Name of Organization/Business;
Property/Mailing Address; Business Email Address; Business Phone Number;
Business Fax Number; and may include signature.

7.

Is the contact information only being used for the purpose for which it originally was
collected, i.e., to contact individuals?
Yes.
No.

8.

With whom could the information be shared?
Only Organization name and contact phone numbers are shared with the public.

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 6
9.

Are program or project user access controls in place governing who may view or access the
contact information?
Yes.
No.

10.

Has an Authority to Operate from the Chief Information Security Officer been granted to the
program or project that the document or database which stores the contact information?
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

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 6
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: January 24, 2012
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: Contact Lists PIA
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS Correspondence and Mailing
List SORN
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS