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pdfThe 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: December , 2008
Page 1 of 8
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: December , 2008
Page 2 of 8
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: April 30, 2009
NAME of Project: Integrated Hiring Operations and Personnel (IHOP) Program
Name of Component: Transportation Security Administration
Name of Project Manager: Mohammed A. Taher
Email for Project Manager: [email protected]
Phone number for Project Manger: 571‐227‐1141
TYPE of Project:
Information Technology and/or System ∗
A Notice of Proposed Rule Making or a Final Rule.
Other: Provides a full range of human capital services, seamlessly, in an end‐to‐end
process supporting the entire life cycle of the TSA employee.
∗
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: December , 2008
Page 3 of 8
SPECIFIC QUESTIONS
1.
Describe the project and its purpose:
The HRAccess Program is a replacement for Human Resource Services which is currently
furnished by three contractors ‐ Accenture, CPS, and AVUE. The contact will provide most
of the Human Resource processing for TSA. Lockheed Martin will perform a wide range of
Human Resource Services which include Recruitment and Hiring, Personnel, Payroll
Processing, Workforce Planning, Postion Management/Classification, Help Desk, Program
Management, Project Management, Contractor Financial/Contract Management, Systems
Integration, and Transition Services.
2.
Status of Project:
This is a new development effort.
This an existing project.
Date first developed: July 14, 2008
Date last updated:
Update of PTA in latest DHS format.
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 System will provide the majority of Human Resource Services for employees of the
Transportation Security Administration. As such it requires the collection, storage, and
dissemination of a wide range of information about individuals. This information is required
to meet the Human Resource needs of the agency.
4.
Do you collect, process, or retain information on: (Please check all that apply)
DHS Employees
Contractors working on behalf of DHS
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: December , 2008
Page 4 of 8
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: December , 2008
Page 5 of 8
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:
The system collects social security numbers because they are needed to keep records
accurate. Other people may have the same name and birth date. Public Law 104‐134 (April
26, 1996) asks Federal agencies to use this number to help identify individuals in agency
records. Without the social security number the application may be deemed incomplete.
6.
What information about individuals could be collected, generated or retained?
a. Personally Identifiable Information (PII) including name, social security number,
bank account number, and residence address.
b. The full range of applicant and employee related data such as employee status,
qualifications, benefits, and education.
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.
9.
When remote access is allowed, is the access accomplished by a virtual private network
(VPN)?
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: December , 2008
Page 6 of 8
Yes
No
10.
Is Personally Identifiable Information 2 physically transported outside of the LAN? (This can
include mobile devices, flash drives, laptops, etc.)
No.
Yes.
11.
Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems?
No
Yes. Please list:
12.
Are there regular data extractions from the system?
No.
Yes. Are these extractions included as part of the Certification and Accreditation 3 ?
Yes.
No.
13.
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
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: December , 2008
Page 7 of 8
Integrity:
Availability:
Low
Moderate
High
Undefined
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: December , 2008
Page 8 of 8
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)
DATE reviewed by the DHS Privacy Office: May 5, 2009
NAME of the DHS Privacy Office Reviewer: Nathan Coleman
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: HRAccess is currently in draft
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/TSA‐022
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS
File Type | application/pdf |
File Title | DHS PRIVACY OFFICE |
Author | pia |
File Modified | 2009-05-05 |
File Created | 2009-05-05 |