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:
LeVar J. Sykes
Senior Privacy Analyst
The Privacy Office
Federal Emergency Management Agency
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 202-212-2201

[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: 202-212-2201.

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: May 17, 2012
Name of Project: Grant Reporting Tool
System Name in TAFISMA: Grants Reporting Tool (GRT)
Name of Component: Federal Emergency Managment Agency
Name of Project Manager: Kathy Fletcher
Email for Project Manager: [email protected]
Phone Number for Project Manager: 202.786.9628
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:
The Grants Reporting Tool (GRT) improves the accuracy and efficiency of Homeland Security’s
annual award and biannual grant reporting by providing a user‐friendly web‐based reporting
system. It is designed to help State Administrative Agencies (SAAs) meet all grant-related
reporting requirements identified in the Homeland Security Grant Program (HSGP), Urban Areas
Security Initiative (UASI), and the Transit Security Grant Program (TSGP) grant application kits.
The GRT will be used to capture all grant data (i.e. HSGP, UASI, TSGP, Buffer Zone Protection
Program (BZPP), Intercity Passenger Rail Security Grant Program (IPRSGP)) from planned
obligations in the Initial Strategy Implementation Plan (ISIP) process, twice yearly expenditure
updates through the Biannual Strategy Implementation Report (BSIR) process, and final funding
in the close‐out reporting period.

2.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: November 18, 2004
Date last updated: March 15, 2012
This release is to address 6 Change Requests and 5 Defect Requests for GRT.

3.

From whom do you collect, process, or retain information on: (Please check all that apply)
DHS Employees.
Contractors working on behalf of DHS.
The Public.
The System does not contain any such information.

4.

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:

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
5.

What information about individuals could be collected, generated or retained?
Users are required to provide personal information to receive access to the system. GRT
collects:
• Name Prefix
• First name
• Last Name
• Street Address
• City
• State
• Zip Code
• Office Phone number
• Fax number
• Email address
• Organizational Affiliation
• Urban Area Affiliation (if applicable)
• Security Question which is one of the following:
1. What is your first pet’s name?
2. What is your father’s middle name?
3. What is your high school mascot?
4. Who is your childhood best friend?
• Unique username
• Password
• Role Assignment and User Permissions

6.

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.

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
Yes. What type of data is recorded in the log? (Please choose all that apply.)
Header.
Payload Please describe the data that is logged.

7.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems 1?
No.
Yes.
Please list:

8.

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: May 18, 2012
Name of the DHS Privacy Office Reviewer: Brian E. Anderson
DESIGNATION
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
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.
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
Management Programs

by

existing

PIA:

DHS/FEMA/PIA-013

Grant

New PIA is required.
PIA update is required.
SORN not required at this time.
SORN is required.
System covered by existing SORN: DHS/FEMA-004 Grant Management
Information Files
New SORN is required.
DHS PRIVACY OFFICE COMMENTS