FRCoP Privacy Threshold Analysis - 2010

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: May 4, 2010
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
Director of Privacy Compliance
The Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
Tel: 703-235-0780

[email protected]

Upon receipt, 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 DHSOnline 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: May 4, 2010
Page 2 of 8

PRIVACY THRESHOLD ANALYSIS (PTA)
Please complete this form and send it to the DHS Privacy Office.
Upon receipt, the DHS Privacy Office will review this form
and may request additional information.
SUMMARY INFORMATION
DATE submitted for review: May 4, 2010
NAME of Project: First Responder Communities of Practice (FR CoP)
Name of Component: Science and Technology
Name of Project Manager: King Waters
Email for Project Manager: [email protected]
Phone number for Project Manager: 202.254.6766
TYPE of Project:
Information Technology and/or System 
A Notice of Proposed Rule Making or a Final Rule.
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: May 4, 2010
Page 3 of 8
SPECIFIC QUESTIONS
1.

Describe the project and its purpose:
DHS S&T Directorate‘s First Responder Technologies (R-Tech) program is developing a
secure web application to provide the nation’s First Responders with a platform they can use
to collaborate on important issues that affect the safety and security of the nation. The First
Responders Community of Practice (FR CoP) application will serve federal, state, local and
tribal First Responders in fostering information sharing, communication, collaboration and
innovation. The system will be owned by DHS S&T and hosted at a DHS data center. The
system will be operated by S&T and S&T contractors, who will have access to system user
registration data.

Status of Project:
This is a new development effort.
This is an existing project.
Date first developed: 12/11/2009
Date last updated:
December 2009: system initial ATO.
2.

Could the project relate in any way to an individual? 1
No. Please skip ahead to the next question.
Yes. Please provide a general description, below.
FR CoP is a social networking and collaboration site specifically designed to connect First
Responders with one another. Users will be identified by their "real" name and not an
alias/username within the system (joe.smith for example). Additionally, users will provide
their first and last name, their First Responder discipline (Firefighter, Police, EMT, etc.), First
Responder Organization (employer name), First Responder Retirement status, job title,
professional (job location) city, state, zip, and email address when they register. Lastly, users
will have the optional ability to associate an image/photo with their profile.

3.
1

Do you collect, process, or retain information on: (Please check all that apply)

Projects can relate to individuals in a number of ways. For example, a project may include a camera for
the purpose of watching a physical location. Individuals may walk past the camera and images of those
individuals may be recorded. Projects could also relate to individuals in more subtle ways. For example, a
project that is focused on detecting radioactivity levels may be sensitive enough to detect whether an
individual received chemotherapy.

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: May 4, 2010
Page 4 of 8
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:

5.

What information about individuals could be collected, generated or retained?
First name, last name, First Responder discipline (e.g. Firefighter, Police Officer,
EMT), First Responder Retirement status, First Responder Organization (employer
name, e.g. NYPD, Mayberry Fire & Rescue), job location/professional city, state, zip
code, phone number, and email address. This information will be retained in the FR
CoP database for six years or until no longer necessary for all users that submit a
registration form, regardless of whether or not the submitting individual is
ultimately approved for an FR CoP user account. The purpose of this is to assist
vettors in determining if a new registration is being submitted by a prospective user
that has previously been rejected. Users will also be asked to choose a number of
"security questions" and provide the answers to the system. The questions will be
used in the event the user needs to reset their password. Lastly, users will have the
optional ability to associate an image/photo with their profile.

Aside from these obvious data points, the system, by nature, will facilitate "open"
collaboration and information sharing and therefore any individual user may
potentially provide additional information about themselves, their professional
experience, work location/experience, etc. (though what exactly can/should be
provided is covered in the system's Rules of Behavior which will be read and
acknlowdged before any user account is granted). Any additional information (to
include profile photo, phone, bio, associations, certifications and interests) a user
would voluntarily provide to the system will be disclosed only to other FR CoP users
of their choosing through connection requests (initiated by the user themselves or
another user). Each user can approve or deny connection requests to control who

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: May 4, 2010
Page 5 of 8
can view their voluntary information. Once connected with another system user, the
individuals Connected Profile (which consists of full name, email, first responder
retirement status, organization, title, city, State, discipline, and any other volunteered
information) will be disclosed to the allowed user (adding to the list of any existing
user to which they are connected).
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.
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.

Can the system be accessed remotely?
No.
Yes. When remote access is allowed, is the access accomplished by a virtual private network
(VPN)?
No. The FR CoP information system is available on the Internet to the general public
(pending identification and authentication for priveledged areas).
Yes.

8.

Is Personally Identifiable Information 2 physically transported outside of the LAN? (This can
include mobile devices, flash drives, laptops, etc.)
No.

2

Personally Identifiable Information is information that can identify a person. This includes; name, address, phone
number, social security number, as well as health information or a physical description.

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: May 4, 2010
Page 6 of 8
Yes.
9.

Does the system connect, receive, or share Personally Identifiable Information with any other
DHS systems3?
No
Yes. Please list:

10.

Are there regular (ie. periodic, recurring, etc.) data extractions from the system?
No.
Yes. Are these extractions included as part of the Certification and Accreditation4?
Yes.
No.

11.

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

3

Confidentiality:

Low

Moderate

High

Undefined

Integrity:

Low

Moderate

High

Undefined

Availability:

Low

Moderate

High

Undefined

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
This could include the Standard Operation Procedures (SOP) or a Memorandum of Understanding (MOU)

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: May 4, 2010
Page 7 of 8
PRIVACY THRESHOLD REVIEW
(To be Completed by the DHS Privacy Office)

DATE reviewed by the DHS Privacy Office: June 23, 2010
NAME of the DHS Privacy Office Reviewer: Rebecca Richards
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
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
A PIA is required
System covered by existing PIA: DHS‐Wide Portals PIA
A new PIA is required.
A PIA Update is required.
A SORN is required
System covered by existing SORN: DHS/ALL‐004; DHS/ALL‐002
A new SORN is required.
DHS PRIVACY OFFICE COMMENTS

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: May 4, 2010
Page 8 of 8
For more information on the vetting process see earlier PTA – July 20, 2009