Privacy Threshold Anaysis (PTA)

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

Privacy Threshold Analysis
Version date: November 6, 2012
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:
Rebecca J. Richards
Senior Director of 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.

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

Privacy Threshold Analysis
Version date: November 6, 2012
Page 2 of 7

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

Post Hurricane Sandy Survivor Research (1660-NW80)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

PNP/Individual and
Community Preparedness
Division

TAFISMA Name:

Click here to enter text.

TAFISMA
Number:

Click here to enter text.

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Development

PROJECT OR PROGRAM MANAGER
Name:

Chad Stover

Office:

Individuals and Community
Preparedness Division

Title:

Individual and Community
Preparedness Division
Program Specialist

Phone:

202-786-9860

Email:

[email protected]

INFORMATION SYSTEM SECURITY OFFICER (ISSO)
Name:
Phone:

Email:

ROUTING INFORMATION
Date submitted to Component Privacy Office:

March 25, 2013

Date submitted to DHS Privacy Office:

May 7, 2013

Date approved by DHS Privacy Office:

May 17, 2013

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

Privacy Threshold Analysis
Version date: November 6, 2012
Page 3 of 7

SPECIFIC PTA QUESTIONS
1. Please describe the purpose of the project or program:
Please provide a general description of the project and its purpose in a way a non-technical person could
understand.
The FEMA Office of Protection and National Preparedness (PNP), Individual and Community
Preparedness Division (ICPD), has contracted with the Gallup to conduct research through a telephone
survey and a series of moderated focus groups regarding the experiences of Hurricane Sandy disaster
survivors. The research will evaluate the effectiveness of preparedness behaviors. This research supports
the mission of ICPD, to help achieve greater community awareness, preparedness, and resiliency
nationwide.
Gallup will conduct the research using its own data. Gallup will select a random sample of individuals
who live in zip codes affected by Hurricane Sandy who have previously agreed to allow Gallup to contact
them. The survey participants are not necessarily FEMA individual assistance applicants. The survey
participants are not necessarily FEMA individual assistance applicants. Gallup will use its own telephone
numbers, age, and race data to stratify the survey sample. If a survivor agrees to participate in a focus
group and chooses to provide contact information, Gallup may collect an email address and possibly a
new phone number from a survivor to coordinate their participation in the group, and once the focus
group has ended, this information will be deleted. The focus groups will be audio recorded for
transcription purposes and will not be video recorded.
Neither FEMA nor Gallup will incorporate the email addresses or phone numbers into its files. In
addition, FEMA will not collect, maintain, or store any of the results from the surveys or focus groups.
FEMA receives an aggregate report from its contractor (Gallup).

2. Project or Program status
January 10, 2013
Date first developed:
February 5, 2013
Date last updated:

Choose an item.
Pilot launch date:
Pilot end date:

August 1, 2013
April 30, 2014

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

1

Contractors working on behalf of DHS
Members of the public
This program does not collect any personally
identifiable information 1

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

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

Privacy Threshold Analysis
Version date: November 6, 2012
Page 4 of 7

4. What specific information about individuals could be collected, generated or retained?
Please provide a specific description of information that might be collected, generated or retained such
as names, addresses, emails, etc.
Telephone number and email address. FEMA does not store or retain this information. The information is
voluntarily provided by participants of the focus groups. It is only used by Gallup to facilitate focus group
participation. It is then deleted.

Does the Project or Program use Social
Security Numbers (SSNs)?
If yes, please provide the legal authority for
the collection of SSNs:
If yes, please describe the uses of the SSNs
within the Project or Program:

5. Does this system employ any of the
following technologies:

No
NA
NA

Closed Circuit Television (CCTV)
Sharepoint-as-a-Service

If project or program utilizes any of these
technologies, please contact Component Privacy
Officer for specialized PTA.

Social Media
Mobile Application (or GPS)
Web portal 2
None of the above

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 next question.
Yes. If a log kept of communication traffic,
please answer the following question.

harm, embarrassment, inconvenience, or unfairness to an individual. For the purposes of this PTA, SPII and PII are treated the
same.
2

Informational and collaboration-based portals in operation at DHS and its components which collect, use,
maintain, and share limited personally identifiable information (PII) about individuals who are “members” of the
portal or who seek to gain access to the portal “potential members.”

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

Privacy Threshold Analysis
Version date: November 6, 2012
Page 5 of 7

If header or payload data 3 is stored in the communication traffic log, please detail the data
elements stored.
Click here to enter text.

6. Does this project or program connect,
receive, or share PII with any other
DHS programs or systems 4?

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

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

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

Is this external sharing pursuant to new
or existing information sharing access
agreement (MOU, MOA, LOI, etc.)?

Choose an item.
NA
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 TAFISMA.
3

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

Privacy Threshold Analysis
Version date: November 6, 2012
Page 6 of 7

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Lane Raffray

Date submitted to DHS Privacy Office:

Click here to enter a date.

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
FEMA recommends that the PTA is sufficient at this time. The two data elements that Gallup could
possibly collect on behalf of FEMA (phone number and email) are not incorporated into FEMA or
contractor files and are not linked or linkable to any other data about the individual.

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

Dayo Simms

Date approved by DHS Privacy Office:

May 17, 2013

PCTS Workflow Number:

980727
DESIGNATION
No

Privacy Sensitive System:

Other

Category of System:
Determination:

If “no” PTA adjudication is complete.

If “other” is selected, please describe: Survey
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.

PIA:
SORN:

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

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

Privacy Threshold Analysis
Version date: November 6, 2012
Page 7 of 7

If covered by existing SORN, please list: Click here to enter text.
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
PRIV agrees that FEMA’s Post Hurricane Sandy Survivor Research project is not privacy sensitive
because FEMA does not collect or maintain PII about individuals during this process. Instead, Gallup’s
use of its own files to contact members of the public and generate non privacy sensitive aggregate data for
FEMA does not require a PIA. This survey also does not require a SORN because FEMA does not store
or maintain PII about an individual that is uniquely retrievable.