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 8

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 8

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

FEMA Homeland Security Grant Program (HSGP) and Operation
Stonegarden (OPSG) Grant Program

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:

Julie Vernetti

Office:

GPD

Title:

Program Analyst

Phone:

202-786-9857

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:

July 15, 2013

Date submitted to DHS Privacy Office:

August 23, 2013

Date approved by DHS Privacy Office:

September 23, 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 8

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 FEMA Grants Program Directorate (GPD) manages FEMA’s Homeland Security Grant Program
(HSGP). The HSGP is an important part of the Administration’s larger, coordinated effort— known as
the Federal Investment Strategy— to strengthen homeland security preparedness. The HSGP implements
objectives addressed in a series of post-9/11 laws, strategy documents, plans, and Homeland Security
Presidential Directives (HSPDs). FEMA manages the HSGP pursuant to section 603 of the Homeland
Security Act of 2002 as amended (HSA), 6 U.S.C. § 101 et seq.), and from the Implementing
Recommendations of the 9/11 Commission Act of 2007, Pub. L. No. 110-053.
Additionally, the GPD manages the FEMA Operation Stonegarden (OPSG) Grant Program. The OPSG
Grant Program provides funding to designated localities to enhance cooperation and coordination between
Federal, State, local, and tribal law enforcement agencies in a joint mission to secure the U.S. borders
along routes of ingress from International borders to include travel corridors in States bordering Mexico
and Canada, as well as States and territories with International water borders. Funding is used to increase
operational capabilities of Federal, State, local and tribal law enforcement, promoting a layered,
coordinated approach to law enforcement within U.S. Border States and territories.
The OPSG Grant Program is a component of the FEMA HSGP, and is managed in accordance with
Section 2004(a) of the HSA , as amended by Section 101, Title I of the Implementing Recommendations
of the 9/11 Commission Act of 2007, Pub. L. No. 110-053.
Information related to the OPSG Grant Program is currently collected as part of OMB ICR No. 16600119, however, OPSG Grant Program is being reviewed to be consolidated under the HSGP which is
covered by the OMB ICR No. 1660-0125. Information for both grant programs are collected from the
general public, specifically, State, local, and tribal governments 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 HSGP and OPSG grant information into the U.S. Health and Human Services
(HHS) Grants.gov system. Grants.gov then transfers information into the FEMA Non-Disaster (ND)
Grants Management System which consolidates the entire non-disaster grants management lifecycle into
a single system. Grant specific supporting documents and information is uploaded and entered into the
FEMA ND Grants system by the grant applicant. 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
October 31, 2010
Date first developed:
October 31, 2010
Date last updated:

Existing
Pilot launch date:
Pilot end date:

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

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 8

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
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 HSGP and OPSG Grant Program collects the following information about grant applicant’s POC or
representative:
Name;
Title;
Mailing address(es);
Email address(es);
Phone number(s); and
Signature.

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:
If project or program utilizes any of these
1

No
Click here to enter text.
Click here to enter text.

Closed Circuit Television (CCTV)
Sharepoint-as-a-Service

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 8

technologies, please contact Component Privacy
Officer for specialized PTA.

Social Media
Mobile Application (or GPS)
Web portal2
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.
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.”
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 8

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 8

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 23, 2013

PCTS Workflow Number:

992624
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 8 of 8

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 Homeland Security
Grant Program (HSGP) and Operation Stonegarden (OPSG) Grant Program requires coverage under the
DHS/FEMA/PIA – 013 Grant Management Program PIA and the DHS/FEMA – 004 Grant Management
Information Files SORN. The Appendix to the Grant Management Program PIA will be updated to reflect
coverage of HSGP and OPSG.
This program collects general PII in order to provide funding via grants to designated localities to
enhance cooperation and coordination between Federal, State, local, and tribal law enforcement agencies.
In order to provide grants through both systems (HSGP and OPSG), FEMA must receive general
information from members of the public requesting such grants. The DHS/FEMA/PIA – 013 Grant
Management Programs PIA provides coverage to HSGP and OPSG 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 HSGP and
OPSG 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. The DHS/FEMA/PIA – 013 Grant Management Programs PIA Appendix will be
updated to reflect coverage of HSPG and OPSG.