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: June 10, 2010
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
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 the 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: June 10, 2010
Page 2 of 6
PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Date Submitted for Review: February 14, 2012
Name of Project: Hazard Mitigation Grant Program (HMGP)
System Name in TAFISMA: Hazard Mitigation Grant Program (HMGP)
Name of Component: Federal Emergency Management Agency
Name of Project Manager: Shabbar Saifee
Email for Project Manager: [email protected]
Phone Number for Project Manager: 202-646-3142
Type of Project:
Information Technology and/or System. ∗
A Notice of Proposed Rule Making or a Final Rule.
Form or other Information Collection.
Other:

∗

The E-Government Act of 2002 defines these terms by reference to the definition sections of Titles 40 and
44 of the United States Code. The following is a summary of those definitions:
•“Information Technology” means any equipment or interconnected system or subsystem of
equipment, used in the automatic acquisition, storage, manipulation, management, movement,
control, display, switching, interchange, transmission, or reception of data or information. See 40
U.S.C. § 11101(6).
•“Information System” means a discrete set of information resources organized for the collection,
processing, maintenance, use, sharing, dissemination, or disposition of information. See: 44. U.S.C. §
3502(8).
Note: for purposes of this form, there is no distinction made between national security systems or
technologies/systems managed by contractors. All technologies/systems should be initially reviewed for
potential privacy impact.

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: June 10, 2010
Page 3 of 6
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
Authorized by Section 404 of the Robert T. Stafford Disaster Relief and Emergency Assistance
Act, as amended (the Stafford Act), the Federal Emergency Management Agency’s (FEMA)
Federal Insurance and Mitigation Administration (FIMA) administers grant programs for states
and localities that seek to implement activities and projects in order to reduce or eliminate risk of
future damage to life or property. The Hazard Mitigation Grant Program (HMGP) is one such
program. The key purpose of HMGP is to ensure that the opportunity to take critical mitigation
measures to reduce the risk of loss of life and property from future disasters is not lost during the
reconstruction process following a disaster. HMGP may fund mitigation activities for properties
that are not insured by the National Flood Insurance Program (NFIP).
HMGP information is collected and maintained in the Hazard Mitigation Grants Program IT
system. The IT system collects and stores grant applications for applicants and sub-applicants
associated with a Presidential major disaster declaration. The application information includes
notations and reports of decisions from insurance, disaster, or similar financial aid and/or income
from other Federal and State agencies, insurance companies, employer, bank, financial or credit
data service, and public or private entities as they relate to payments and/or financial assistance
received by individual property owner for property included in the grant application.
Applicants are the states involved in the disaster and sub-applicants can include state agencies,
Indian Tribal governments, local governments or communities, and private non-profit
organizations.
Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: August 30, 1998
Date last updated: August 15, 2011
Description: General system enhancements and bug fixes to internal and external
functional areas of the HMGP system.

2.

From whom do you collect, process, or retain information on: (Please check all that apply)
DHS Employees.
Contractors working on behalf of DHS.

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: June 10, 2010
Page 4 of 6
The Public.
The System does not contain any such information.
3.

Do you use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs)
No.
Yes. Why does the program collect SSNs? Provide the function of the SSN and the
legal authority to do so:

4.

What information about individuals could be collected, generated or retained?
The personally identifiable information that may be collected or retained includes:
Applicant/co-applicant (public): the individual property owners' names, co-owner, title
holder, individual owner's damaged property address, individual property owner's home
phone number, individual property owner's office phone number, individual property
owner's cell phone number, individual property owner's mailing address, individual
property owner's status regarding flood insurance, individual property owner's National
Flood Insurance Program (NFIP) policy number, individual property owner's insurance
policy provider for the property proposed to be mitigated with FEMA funds, individual
property owner's signature, Governor's authorized representative name, Governor's
authorized representative signature, grant applicant organization point of contact (POC)
name, grant applicant POC organization, grant application POC office phone number, grant
applicant POC office mailing address, and grant applicant POC email address.
FEMA employees or contractors: name and title.

5.

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 the next question.
Yes. Is there a log kept of communication traffic?
No. Please continue to the next question.
Yes. What type of data is recorded in the log? (Please choose all that apply.)
Header.
Payload Please describe the data that is logged.

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: June 10, 2010
Page 5 of 6
6.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems 1?
No.
Yes.
Please list: FEMA's Enterprise Data Warehouse (EDW)

7.

Is there a Certification & Accreditation record within OCIO’s FISMA tracking system?
Unknown
No.
Yes. Please indicate the determinations for each of the following:
Confidentiality:

Low

Moderate

High

Undefined

Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
Date reviewed by the DHS Privacy Office: February 15, 2012
Name of the DHS Privacy Office Reviewer: Brian E. Anderson
DESIGNATION
This is NOT a Privacy Sensitive System – the system contains no Personally Identifiable
Information.
This IS a Privacy Sensitive System
Category of System
IT System.
National Security System.
1

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: June 10, 2010
Page 6 of 6
Legacy System.
HR System.
Rule.
Other:
Determination
PTA sufficient at this time.
Privacy compliance documentation determination in progress.
PIA is not required at this time.
PIA is required.
System covered by existing PIA:
New PIA is required.
PIA update is required.
SORN not required at this time.
SORN is required.
System covered by existing SORN: DHS/FEMA 009 Hazard Mitigation
Assistance Grant Programs
New SORN is required.
DHS PRIVACY OFFICE COMMENTS: THE HMGP IT SYSTEM HAS BEEN RECENTLY
DECOUPLED FROM NEMIS. NEMIS HMGP REQUIRES A NEW PIA. ALL OTHER HAZARD
MITIGATION ASSISTANCE GRANT PROGRAMS ARE MAINTAINED WITHIN THE
MITIGATION E-GRANTS IT SYSTEM.
THE DHS/FEMA 009 SORN IS BEING UPDATED.