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: July 7, 2012
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
Senior 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 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: 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: July 7, 2012
Page 2 of 6

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

Public Benefit Conveyance

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

SSFMD

TAFISMA Name:

n/a

TAFISMA
Number:

n/a

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Operational

PROJECT OR PROGRAM MANAGER
Name:

Adrian Austin

Office:

Real Property

Title:

Building Management
Specialist

Phone:

202-212-2099

Email:

[email protected]

INFORMATION SYSTEM SECURITY OFFICER (ISSO)
Name:

n/a

Phone:

n/a

Email:

ROUTING INFORMATION
Date submitted to Component Privacy Office:

February 6, 2013

Date submitted to DHS Privacy Office:

May 31, 2013

Date approved by DHS Privacy Office:

June 17, 2013

n/a

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: July 7, 2012
Page 3 of 6

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.
FEMA Form 119-0-1 is used to collect information from members of the public to process applications
for Public Benefit Conveyance (PBC) and Base Realignment and Closure (BRAC) programs whereby
state, local, or tribal governments may acquire Federal surplus property for emergency management
purposes at no cost. This activity is authorized by 40 U.S.C. §§ 541 and 553, and 41 C.F.R. parts 10275.750 through 102-75.815.

2. Project or Program status
August 1, 2010
Date first developed:
August 1, 2010
Date last updated:

Existing
Pilot launch date:
Pilot end date:

Click here to enter a date.
Click here to enter a date.

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

Contractors working on behalf of DHS
X Members of the public
This program does not collect any personally
identifiable information1

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.
 Applicant’s name;

1



Job title;



Address;



Email address; and



Phone number.

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

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: July 7, 2012
Page 4 of 6

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
n/a
n/a

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 portal2
X 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)?

X No. Please continue to next question.
Yes. If a log kept of communication traffic,
please answer the following question.

If header or payload data3 is stored in the communication traffic log, please detail the data
elements stored.
n/a

6. Does this project or program connect,
receive, or share PII with any other
DHS programs or systems4?

X No.

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.”
3

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.

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: July 7, 2012
Page 5 of 6

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?

X 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.)?

Please describe applicable information sharing
governance in place.
n/a

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

LaKia Samuel

Date submitted to DHS Privacy Office:

May 31, 2013

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
Not a privacy sensitive collection. Recommend previous adjudication of no PIA or SORN coverage
needed. FEMA only tracks the type of inventory given out, and does not collect any PII from the public.

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

Dayo Simms

Date approved by DHS Privacy Office:

June 13, 2013

PCTS Workflow Number:

982893
DESIGNATION

Privacy Sensitive System:

Yes

Category of System:

Other

4

If “no” PTA adjudication is complete.

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: July 7, 2012
Page 6 of 6

If “other” is selected, please describe: Form/ Information
Collection
Determination:

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.

System covered by existing PIA
PIA:

If covered by existing PIA, please list: DHS/ALL/PIA-006 Department of Homeland
Security General Contact Lists
System covered by existing SORN

SORN:

If covered by existing SORN, please list: DHS/ALL-002 - Department of Homeland
Security (DHS) Mailing and Other Lists System November 25, 2008, 73 FR 71659

DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
PRIV disagrees with the FEMA Privacy recommendation that the PBC collection is not privacy sensitive.
This collection of PII from members of the public requires a PIA and SORN. PRIV will adjudicate this
PTA under the Contacts List PIA and Mailing List SORN. However, this may be more appropriately
covered in the Grants Management Programs PIA and SORN or another PIA and SORN, more closely
linked to the program. PRIV requests that FEMA evaluate the PBC and determine whether there is an
Existing PIA or SORN that would provide more specific coverage for this program.