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:

FEMA Transit Security Grant Program (TSGP)

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:

Steven P. Billings

Office:

GPD/PGD/TISB

Title:

Investigative Analyst

Phone:

202-786-9516

Email:

[email protected]

INFORMATION SYSTEM SECURITY OFFICER (ISSO)
Name:

Click here to enter text.

Phone:

Click here to enter text.

Email:

Click here to enter text.

ROUTING INFORMATION
Date submitted to Component Privacy Office:

August 23, 2013

Date submitted to DHS Privacy Office:

August 23, 2013

Date approved by DHS Privacy Office:

September 11, 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 Federal Emergency Management Agency (FEMA) Grant Programs Directorate (GPD) manages the
Transit Security Grant Program (TSGP). The TSGP is a FEMA grant program that focuses on
transportation infrastructure protection activities. The collection of information for TSGP is mandated by
Section 1406, Title XIV of the Implementing Recommendations of the 9/11 Commission Act of 2007, 6
U.S.C. §1135, which directs the Secretary to establish a program for making grants to eligible public
transportation agencies for security improvements. Additionally, the above authorities ,authorizes the
Secretary to determine the requirements for grant recipients, including application requirements.
TSGP provides funding directly to public transportation (which include intra-city bus, commuter bus, and
all forms of passenger rail) entities to facilitate training, infrastructure hardening, exercises, public
awareness and operational packages to protect critical surface transportation infrastructure and the
traveling public from acts of terrorism, major disasters, and other emergencies
Information related to the TSGP is collected as part of OMB ICR No. 1660-0112 from the general public,
specifically, State, local, and private organizations requesting federal funds. During the application
process, grant applicant’s points-of-contact (POC) and or representatives provide their name, title,
address, phone number(s), email address, and signatures. Grant applicants enter TSGP grant information,
including the above PII of POCs and representatives into the U.S. Health and Human Services (HHS)
Grants.gov system. Additional information supporting the grant application is uploaded and entered 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.

2. Project or Program status
FY 2005
Date first developed:
October 31, 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.
Click here to enter a date.

DHS Employees
Contractors working on behalf of DHS

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

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.
The TSGP collects the following information about grant applicant’s POC and or representative:
Name;
Title;
Mailing address(es);
Email address(es);
Phone number(s); and
Signatures.

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 System

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 System

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.
Recommend 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:

September 11, 2013

PCTS Workflow Number:

992625
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 agrees with FEMA Privacy Office’s assessment that the Transit Security Grant
Program (TSGP) requires coverage under the DHS/FEMA/PIA – 013 Grant Management Program PIA
and the DHS/FEMA – 004 Grant Management Information Files SORN.
This program collects general PII related to funding public transportation entities to facilitate training,
infrastructure hardening, exercises, public awareness and operational packages to protect critical surface
transportation infrastructure and the traveling public from acts of terrorism, major disasters, and other
emergencies. In order to provide these grants, TGSP must receive general information from members of
the public requesting such grants. The DHS/FEMA/PIA – 013 Grant Management Programs PIA
provides coverage to TSGP because it allows information to be collected in order to determine awards for
both disaster and non-disaster grants and for the issuance of awarded funds. The DHS/FEMA – 004
SORN provides coverage for records collected by TSGP in order to assist in determining awards for both
disaster and non-disaster grants, for the issuance of awarded funds, and to allow DHS to contact
individuals to ensure completeness and accuracy of grants and applications.