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 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 DHS Connect 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: July 2, 2012
Name of Project: Crisis Counseling Assistance and Training Program – Immediate and
Regular Services Program
System Name in TAFISMA: Not Applicable
Name of Component: Federal Emergency Management Agency
Name of Project Manager: Tanya Stevenson
Email for Project Manager: [email protected]
Phone Number for Project Manager: 202-212-5719
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 Crisis Counseling Assistance and Training Program (CCP) consist of two grant
programs entitled the Immediate Services Program (ISP) and Regular Services Program
(RSP). The CCP provides supplemental funding to States, U.S. Territories, and Federally
Recognized Tribes after a Presidential disaster declaration. The ISP program is available for
a limited period of time not to exceed 60 days from the date of declaration, unless an RSP
application for longer-term funding is submitted. In that case, immediate services funding
may be continued until the RSP application has been approved or disapproved. The RSP
provides funding for up to nine months from the date awarded. The information submitted in
the application is provided on specific disasters for the consideration of funding to States,
U.S. Territories, and federally recognized Tribes, to provide services for community
outreach, consultation and public education, group and individual crisis counseling, referral
and resource linkage and coping techniques.
2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed:
Date last updated: 03/07/2010
To add the Regular Services Application (RSP) to an existing collection in use under
OMB #1660-0085.

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 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

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
legal authority to do so:
5.

What information about individuals could be collected, generated or retained?
The Point of Contact for the State Mental Health Authority provides: name, title, agency,
agency address, work email address, work phone number, and signature on the RSP
application.
The Governor’s Authorized Representative provides: name, title, agency, agency address,
work email, work phone number, and signature.
The following information may also be collected for a “Preparer”, “Point of Contact,”
“Alternate point of contact,” “Crisis Counseling Assistance and Training Program (CCP)
Provider Contact/Manager,” or ”Consultant:”
name, agency/organization,
agency/organization address, phone number, and email address.
The following personally identifiable information may be collected from a “Service
Provider:” email and director’s name.
“Trainers” may provide: name and agency/organization affiliation.

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.

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
Yes.
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: July 13, 2012
Name of the DHS Privacy Office Reviewer: Dayo Simms
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: Information Collection Form
Determination

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
PTA sufficient at this time.
Privacy compliance documentation determination in progress.
PIA is not required at this time.
PIA is required.
System covered by existing PIA:
DHS/FEMA/PIA-013-Grant Management Programs, July 14, 2009
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, August 7, 2009
New SORN is required.
DHS PRIVACY OFFICE COMMENTS:
The Crisis Counseling Assistance and Training Program- Immediate and Regular Services Program is
covered under an existing PIA DHS/FEMA/PIA-013-Grant Management Programs and SORN
DHS/FEMA 004 Grant Management Information Files. The update to add a form which captures
contact information for the Regular Services Program is also covered under the aforementioned
privacy documents. The PTA is sufficient for this update. All of the data elements involved in this
collection comply with the existing PTA and SORN.