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 10, 2010
Page 1 of 6
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 from the 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: 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 10, 2010
Page 2 of 6
PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Date Submitted for Review: December 9, 2011
Name of Project: Assistance to Firefighter Grants Program
System Name in TAFISMA: AFG-Assisted Firefighters Grant
Name of Component: Federal Emergency Managment Agency
Name of Project Manager: Catherine Patterson
Email for Project Manager: [email protected]
Phone Number for Project Manager: 202.786.9796
Type of Project:
Information Technology and/or System. ∗
A Notice of Proposed Rule Making or a Final Rule.
Form or other Information Collection.
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 10, 2010
Page 3 of 6
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
The Assistance to Firefighters Grant Program project is a competitive grant opportunity that
is administered by the Assistance to Firefighters Program Office. The grant application
package is included in the Office of Management and Budget Information Collection Request
1660-0054. The purpose of the application is to assess the needs of each individual applicant
compared to the other applicants interested in the opportunity. The authority for Assistance
to Firefighters Grant Program (AFG) is derived from the Federal Fire Protection and Control
Act of 1974 (15 U.S.C. §§ 2229 et seq.), as amended. This submission is necessary in order for
DHS to effectively implement a competitive grant program and meet the fiscal deadlines. The
data generated through the grant application process is stored and maintained in the AFGAssisted Firefighter Grant IT system, which was de-coupled from the National Emergency
Management Information System (NEMIS). This system does not relate to any other grant
application system such as Non
‐Disaster (ND) Grants. Applicants are state, county, and
municipal organizations/entities in charge of administering fire fighting duties.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: March 02, 2002
Date last updated: July 15, 2011
Application undergoes minor edits/adjustments each year. For example, in 2010, we
asked each applicant the following questions: Are all of your active firefighters
trained to NFPA 1001 or equivalent? If not, will you be asking for training funds for
this purpose with this application or will you obtain the appropriated training
through other resources? In 2010, these questions will be changed to: What percent of
your active firefighters are trained to the level of Firefighter II? If you answered less
than 100% to either question above, are you requesting training funds to bring 100%
of your firefighters into compliance with NFPA 1001, Firefighter I and NFPA 1001,
Firefighter II?

3.

From whom do you collect, process, or retain information on: (Please check all that apply)
DHS Employees.
Contractors working on behalf of DHS.
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 10, 2010
Page 4 of 6
The System does not contain any such information.
4.

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:

5.

What information about individuals could be collected, generated or retained?
The only information collected and retained is the name, title, phone numbers, and email
address for the applying organizations Points of Contact (POC).

6.

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.

7.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems 1?
No.
Yes.

1

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.

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 10, 2010
Page 5 of 6
Please list:
8.

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:

Low

Moderate

High

Undefined

Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
Date reviewed by the DHS Privacy Office: December 9, 2011
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: Grant Program
Determination
PTA sufficient at this time.

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 10, 2010
Page 6 of 6
Privacy compliance documentation determination in progress.
PIA is not required at this time.
PIA is required.
System covered by existing PIA: Grants Management Programs PIA
New PIA is required.
PIA update is required.
SORN not required at this time.
SORN is required.
System covered by existing SORN: DHS/FEMA 004 Grant Management
Information Files
New SORN is required.
DHS PRIVACY OFFICE COMMENTS: THIS PTA WAS COMPLETED AS PART OF THE LEGACY
NEMIS PROJECT. THE PTA DOCUMENTS BOTH THE IT SYSTEM THAT WAS DE-COUPLED
FROM NEMIS (AFG-ASSISTED FIREFIGHTER GRANT), AS WELL AS THE AFG PROGRAM AND
ITS ASSOCIATED INFORMATION COLLECTION REQUEST (1660-0054), WHICH IS WHY THE ‘IT
SYSTEM AND ‘OTHER’ DESIGNATIONS ARE BOTH CHECKED ABOVE.