Privacy Threshold Analysis (PTA)

T he 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: July 7, 2012

Page 5 of 5

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: 703-235-0780

[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: 703-235-0780.

PRIVACY THRESHOLD ANALYSIS (PTA)

Summary Information

Project or Program Name:	OMB PRA Extension for 1660-0023 Effectiveness of a Community’s Implementation of the NFIP Community Assistance Program CAC and CAV Reports
Component:		Office or Program:	Federal Insurance and Mitigation Administration (FIMA)
TAFISMA Name:	Click here to enter text.	TAFISMA Number:	Click here to enter text.
Type of Project or Program:		Project or program status:

PROJECT OR PROGRAM MANAGER

Name:	Bret Gates
Office:	IM-DM-RR-FM	Title:	Senior Program Specialist
Phone:	202.646.4133	Email:	[email protected]

INFORMATION SYSTEM SECURITY OFFICER (ISSO)

Name:
Phone:		Email:	Click here to enter text.

ROUTING INFORMATION

Date submitted to Component Privacy Office:	June 21, 2013
Date submitted to DHS Privacy Office:	Click here to enter a date.
Date approved by DHS Privacy Office:	Click here to enter a date.

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 FIMA uses FEMA Form (FF) 086-0-28, Community Assistance Contact (CAC) and FF 086-0-29, Community Assistance Visit (CAV) in determining community assistance needs. These information collection tools provide a systematic means of monitoring community NFIP compliance. Through the CAC and CAV process and the associated FEMA forms to collect the data, FEMA can also determine to what extent communities are achieving the flood loss reduction objectives of the NFIP. By providing assistance to communities, the CAC and CAV process also serve to enhance FEMA’s goals of reducing future flood losses, thereby achieving the cost-containment objective of the NFIP. This information is part of OMB ICR 1660-0023.

Project or Program status
Date first developed:	1985	Pilot launch date:	Click here to enter a date.
Date last updated:	2010	Pilot end date:	Click here to enter a date.

From whom does the Project or Program collect, maintain, use or disseminate information? Please check all that apply.

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

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 following information about FEMA employees, local government, and community points of contacts include: Name (both full and initials), Telephone number, Address, Name of Community, Community ID Number, and Agency.
Does the Project or Program use Social Security Numbers (SSNs)?
If yes, please provide the legal authority for the collection of SSNs:	Click here to enter text.
If yes, please describe the uses of the SSNs within the Project or Program:	Click here to enter text.

Does this system employ any of the following technologies: If project or program utilizes any of these technologies, please contact Component Privacy Officer for specialized PTA.	Closed Circuit Television (CCTV) Sharepoint-as-a-Service 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.

Does this project or program connect, receive, or share PII with any other DHS programs or systems4?	No. Yes. If yes, please list: Click here to enter text.
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.)?	Please describe applicable information sharing governance in place. N/A

PRIVACY THRESHOLD REVIEW

(To be Completed by COMPONENT PRIVACY OFFICE)

Component Privacy Office Reviewer:	Click here to enter text.
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.
Click here to enter text.

(To be Completed by the DHS Privacy Office)

DHS Privacy Office Reviewer:	Click here to enter text.
Date approved by DHS Privacy Office:	Click here to enter a date.
PCTS Workflow Number:	Click here to enter text.

DESIGNATION

Privacy Sensitive System:		If “no” PTA adjudication is complete.
Category of System:		If “other” is selected, please describe: Click here to enter text.
Determination: 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.
PIA:	If covered by existing PIA, please list: Click here to enter text.
SORN:	If covered by existing SORN, please list: Click here to enter text.
DHS Privacy Office Comments: Please describe rationale for privacy compliance determination above.
Click here to enter text.

1 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.

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.