Privacy Threshold Analysis (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:

Urban Area Security Initiative (UASI) Non Profit Security Grant Program
(NSGP)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Protection and National
Preparedness (PNP)

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:

Operational

PROJECT OR PROGRAM MANAGER
Name:

Angel McLaurine-Qualls

Office:

Grant Programs Directorate
(GPD)

Title:

Program Specialist

Phone:

202-279-0596

Email:

[email protected]

INFORMATION SYSTEM SECURITY OFFICER (ISSO)
Name:

Click here to enter text.

Phone:

Click here to enter text.

Email:

ROUTING INFORMATION
Date submitted to Component Privacy Office:

April 24, 2013

Date submitted to DHS Privacy Office:

August 2, 2013

Date approved by DHS Privacy Office:

August 13, 2013

Click here to enter text.

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 Grant Programs Directorate (GPD) manages the Urban Areas Security Initiative (UASI) Non Profit
Security Grant Program (NSGP). The UASI NSGP provides funding support for target hardening and
other physical security enhancements and activities to nonprofit organizations that are at high risk of
terrorist attack and located within one of the specific UASI-eligible Urban Areas. While this funding is
provided specifically to high-risk nonprofit organizations under The Consolidated Appropriations Act,
2012, Division D (Pub. L. No. 112-74), the program seeks to integrate nonprofit preparedness activities
with broader State and local preparedness efforts. It is also designed to promote coordination and
collaboration in emergency preparedness activities among public and private community representatives,
as well as State and local government agencies, and Citizen Corps Councils. Information related to the
UASI NSGP is collected pursuant to Section 2003 of the Homeland Security Act of 2002, 6 U.S.C. § 604,
as amended by Section 101, Title I of the Implementing Recommendations of the 9/11 Commission Act
of 2007 (Pub. L. No. 110-053) and is part of OMB ICR No. 1660-0110. Information related to the UASI
NSGP is collected from the members of the public, specifically, nonprofit organizations requesting
federal funds and State agencies supporting the applicant’s request. All applicants must submit their
application to each State within which any part of the high-risk urban area is located for review before
submission to FEMA.
During the application process, grant applicant’s and state points-of-contact (POC) and or representatives
provide their name, title, address, phone number(s), email address, and signatures. States submit UASI
NSGP grant information on behalf of the nonprofit applicant using the Department of Health and Human
Services (HHS) Grants.gov. Information is then transferred into the FEMA Non-Disaster (ND) Grants
Management System which consolidates the entire non-disaster grants management lifecycle into a single
system. The FEMA ND Grants system is currently adjudicated by DHS under the FEMA Grant
Management Programs PIA and the related DHS/FEMA – 004 Grant Management Information Files
SORN, 74 FR 39,705 (Aug. 7, 2009).

2. Project or Program status
September 29, 2010
Date first developed:
September 29, 2010
Date last updated:
3. From whom does the Project or
Program collect, maintain, use or
disseminate information?
Please check all that apply.

Existing
Pilot launch date:
Pilot end date:

Click here to enter a date.
October 31, 2013

DHS Employees
Contractors working on behalf of DHS
Members of the public

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

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.
The UASI NSGP collects the following information about grant applicant’s and state POC or
representative:
Name;
Title/Position;
Mailing address(es);
Email address(es); and
Phone number(s).

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

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
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
202-343-1717, [email protected]
www.dhs.gov/privacy

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

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.

If header or payload data3 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 systems4?

No.
Yes. If yes, please list:
FEMA ND Grants

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:
HHS Grants.gov

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

Choose an item.
Please describe applicable information sharing
governance in place.
N/A

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.
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.

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:

LeVar J. Sykes

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 privacy compliance coverage by the FEMA Grant Management Programs PIA and
the related DHS/FEMA – 004 Grant Management Information Files SORN.

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

Jameson Morgan

Date approved by DHS Privacy Office:

August 13, 2013

PCTS Workflow Number:

986425
DESIGNATION

Privacy Sensitive System:
Category of System:
Determination:

Yes

If “no” PTA adjudication is complete.

IT System
If “other” is selected, please describe: Click here to enter text.
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:
SORN:

If covered by existing PIA, please list: DHS/FEMA/PIA – 013 Grant Management
Programs
System covered by existing SORN

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: DHS/FEMA-004 Grant Management Information
Files
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.

The DHS Privacy Office concurs with the FEMA Privacy Office’s assessment. This system will
receive coverage under the DHS/FEMA/PIA – 013 Grant Management Programs PIA and the
DHS/FEMA – 004 Grant Management Information Files SORN.
This program helps provide funding support for target hardening and other physical security
enhancements and activities to nonprofit organizations that are at high risk of terrorist attack.
The system also integrates nonprofit preparedness activities with broader State and local
preparedness efforts. In order to fulfill this mission, the system must collect a minor amount of
PII from grant applicants and state points-of-contact (POC) and or representatives such as: name,
address, phone number(s), and email address.
The DHS/FEMA/PIA – 013 Grant Management Programs PIA provides sufficient coverage for
the information collection described in this PTA as the purpose of the PIA is to allow for
information to be collected in order to determine awards for disaster and non-disaster grants, and
for the issuance of awarded funds.
The DHS/FEMA – 004 Grant Management Information Files SORN provides coverage to
systems of records related to determining awards for disaster and non-disaster grants, and for the
issuance of awarded funds. The collection of information in this system is consistent with the
purpose, categories of records, and categories of individuals, and routine uses of this SORN.