Privacy Threshold Analysis

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: July 24, 2012
Page 1 of 9

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: July 24, 2012
Page 2 of 9

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

Public Assistance (PA) Program (1660-0017)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

ORR-Recovery-PA

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:

Cliff Brown

Office:

ORR-Recovery-PA

Title:

Program Specialist

Phone:

202.646.4136

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:

February 14, 2013

Date submitted to DHS Privacy Office:

February 28, 2013

Date approved by DHS Privacy Office:

February 28, 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: July 24, 2012
Page 3 of 9

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 mission of the Federal Emergency Management Agency's (FEMA) Public Assistance (PA) Grant
Program is to provide assistance to State, Tribal and local governments, and certain types of Private NonProfit (PNP) organizations so that communities can quickly respond to and recover from major disasters
or emergencies declared by the President. Specifically, the program provides assistance for debris
removal, emergency protective measures, and the repair, replacement, or restoration of disaster-damaged,
publicly owned facilities and the facilities of certain PNP organizations. The PA Program also
encourages protection of these damaged facilities from future events by providing assistance for hazard
mitigation measures during the recovery process.
The program uses standard forms for PA collections as a well as narratives that do not use forms
including: appeals; requests and recommendations for arbitrations; State Administrative Plans and
amendments; requests for time extensions; and requests for additional funding.

2. Project or Program status
December 17, 2008
Date first developed:
7/1/09
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.

1

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

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: July 24, 2012
Page 4 of 9

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.
Certain Privacy Act forms require names, work address, work and cell phone and email address. The
forms include:
• FF 90‐49 Request for Public Assistance – The Request asks for general information from
the State (Grantee) that identifies the applicant and starts the grant process.
Name, title, business phone, fax number, home phone, cell phone, and email address
• FF 90‐91 Project Worksheet (PW) – FEMA or the applicant (sub‐grantee), assisted by the
State as appropriate will prepare a PW for each project. Federal funds are obligated to
the State based on the approved PW. The State will then approve sub grants based on
the PWs approved for each applicant.
Name, title, and signature
• FF 90‐91A Damage Description and Scope of Work Continuation Sheet (PW) – FEMA
or the applicant (sub‐grantee) assisted by the State as appropriate will prepare a PW for
each project. The scope of work is developed on the PW describing in detail the work
necessary to return the facility to its pre‐disaster design. The optional PW ‐ Damage
Description and Scope of Work Continuation Sheet provides additional space for this
purpose.
Name, title, and signature
FF 90‐91B Cost Estimate Continuation Sheet (PW) FEMA or the applicant (sub‐grantee)
assisted by the State as appropriate will prepare a PW for each project. The Project Cost
is developed on the PW estimating the cost for repair of the damages described in the
Project Description of the PW. The optional PW‐ Cost Estimate Continuation Sheet
provides additional space to estimate the cost to restore the facility to its pre‐disaster
condition.
Name, title, and signature
• FF 90‐91C Maps and Sketches Sheet (PW) ‐ FEMA or the applicant (sub grantee) assisted
by the State as appropriate will prepare a PW for each project. The optional PW – Maps
and Sketches Sheet provides field personnel with specific information that enables the
facility to be easily located should a site visit be necessary and damages to be described
in terms of the function of the facility and its features, or items requiring repair, before
work is accomplished because it can affect eligibility determinations.
N/A
• FF 90‐91D Photo Sheet (PW)‐ FEMA or the applicant (sub grantee) assisted by the State
as appropriate will prepare a PW for each project. The optional PW – Photo Sheet
provides field personnel with specific information that enables facility damages to be
documented before work is accomplished because it can affect eligibility determinations.
N/A

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: July 24, 2012
Page 5 of 9

FF 90-111 Grantee Quarterly Progress Report – Grantee and sub-grantee assisted by FEMA as
appropriate – This quarterly progress report is used to monitor performance and financial status of
grantees.
• FF 90‐120 Special Considerations Questions ‐ FEMA or the applicant (sub grantee)
assisted by the State as appropriate will prepare a PW for each project. The Special
Considerations Questions may be used to record factors that could affect compliance
with environmental resources, disaster assistance, and historic preservation legislation
and Executive Orders on floodplain, wetlands, and environmental justice.
N/A
• FF 121 PNP Facility Questionnaire – The optional PNP Facility Questionnaire, is used by FEMA and
State personnel to help determine the eligibility of specific facilities to be approved as a PNP
organization.
Name of Contact Person
•FF 90‐123 Force Account Labor Summary Record – FEMA or the applicant (sub grantee) assisted by
the State as appropriate, will prepare a PW for each project. The optional Force Account Labor Summary
Record may be used to record applicant personnel costs.
Name and title
• FF 90‐124 Materials Summary Record – FEMA or the applicant (sub grantee) assisted by the State as
appropriate, will prepare a PW for each project. The optional Materials Summary Record may be used to
record the supplies and materials an applicant may take out of stock or purchase.
Name and title
• FF 90‐125 Rented Equipment Summary Record ‐ FEMA or the applicant (sub grantee) assisted by
the State as appropriate will prepare a PW for each project. The optional Rented Equipment Summary
Record may be used to record the costs of rented or leased equipment.
Name and title
FF 90‐126 Contract Work Summary Record – FEMA or the applicant (sub grantee) assisted by the
State as appropriate, will prepare a PW for each project. The optional Contract Work Summary Record
may be used to record the costs or work that an applicant has done by contract.
Name and title
• FF 90‐127 Force Account Equipment Summary Record – FEMA or the applicant (subgrantee)
assisted by the State as appropriate, will prepare a PW for each project. The optional Force Account
Equipment Summary Record may be used to record applicant equipment costs.
Name and title
• FF 90‐128 Applicant’s Benefits Calculation Worksheet ‐ FEMA or the applicant (subgrantee)
assisted by the State as appropriate will prepare a PW for each project. The optional Applicant’s Benefits
Calculation Worksheet may be used to record the costs fringe benefits for force account labor.
Name and title

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: July 24, 2012
Page 6 of 9

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
Click here to enter text.
Click here to enter text.

Closed Circuit Television (CCTV)
SharePoint-as-a-Service (SPaaS)
Customer Relationship Management-as-aService (CRMaaS)
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.

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

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.”
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.

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: July 24, 2012
Page 7 of 9

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.
Please describe applicable information sharing
governance in place.
Click here to enter text.

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.
4

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: July 24, 2012
Page 8 of 9

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

Lane Raffray

Date submitted to DHS Privacy Office:

February 26, 2013

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
Recommend the following coverage:
For the PA Program:
PIA: DHS/FEMA/PIA-013 - Grant Management Programs (which covers EMMIE).
SORN: DHS/FEMA-004 - Grant Management Information Files System of Records, 74 FR 39705
(August 7, 2009).
For forms also used for HMGP:
PIA: DHS/FEMA/PIA-025 – Hazard Mitigation Grant Program (HMGP) System.
SORN: DHS/FEMA-009 - Hazard Mitigation Assistance Grant Programs System of Records, 77 FR
17783 (July 23, 2012).
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Debra Danisek

Date approved by DHS Privacy Office:

February 28, 2013

PCTS Workflow Number:

Click here to enter text.
DESIGNATION

Privacy Sensitive System:

Yes

If “no” PTA adjudication is complete.

Other
Category of System:

Determination:

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

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: July 24, 2012
Page 9 of 9

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/FEMA/PIA-013 Grant Management Programs
and DHS/FEMA/PIA-025 - The Hazard Mitigation Grant Program (HMGP) System
System covered by existing SORN

If covered by existing SORN, please list: DHS/FEMA-004 Grant Management
Information Files August 7, 2009 74 FR 39705 and DHS/FEMA-009- Hazard Mitigation
Assistance Grant Programs System of Records July 23, 2012, 77 FR, 17783
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
FEMA submits this PTA and accompanying e(3) statement for review. The e(3) statement is to be used
on all forms mentioned above that collect PII. PII collected only pertains to contact information for State,
local, and tribal partners seeking grant funding. FEMA grant programs are directed at a broad spectrum
of state and local emergency responders, including firefighters, emergency medical services, emergency
management agencies, law enforcement, and public officials. Due to the coverage by two different PIAs
and SORNs, the e(3) statement has been written to include both SORNs. It may be used for all forms
included as part of this PTA.
SORN:

All of the above forms, with the exception of FEMA Form 90-111, are used for the Public Assistance
Grant Program. DHS Privacy Office approves these forms as privacy-sensitive, with coverage under the
existing DHS/FEMA/PIA-013 - Grant Management Programs and DHS/FEMA-004 Grant Management
Information Files SORN.
FEMA Form 90-111 is used for both the Public Assistance Grant Program and the Hazard Mitigation
Grant Program. Therefore, DHS Privacy Office approves FF 90-111 with coverage under both the
existing DHS/FEMA/PIA-013 - Grant Management Programs and DHS/FEMA-004 Grant Management
Information Files SORN and the existing DHS/FEMA/PIA-025 – The Hazard Mitigation Grant Program
(HMGP) System and corresponding DHS/FEMA-009 - Hazard Mitigation Assistance Grant Programs
System of Records.