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 7

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 7

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

Request for Site Inspection/Landowners Authorization/Ingress/Egress
Agreement (1660-0030)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Individual Assistance
Division

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:

Update

PROJECT OR PROGRAM MANAGER
Name:

Johnathan Torres

Office:

Individual Assistance

Title:

Sr. Program Specialist

Phone:

202-212-1079

Email:

[email protected].
gov

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 16, 2013

Date submitted to DHS Privacy Office:

October 25, 2013

Date approved by DHS Privacy Office:

November 6, 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 7

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 Landowner’s Authorization Ingress-Egress Agreement, FEMA FORM 010-0-10, authorizes the
Federal government to place a manufactured (or similar) housing unit on the landowner’s property in
response to applicant’s eligibility at the federally declared disaster where direct housing is authorized.
This agreement is necessary before any direct housing assistance can be physically assessed and placed at
the landowner’s property. It only occurs when the disaster applicant (typically the landowner) applies and
is eligible for direct housing assistance (manufactured/factory built housing).
This form collects personally identifiable information from the disaster survivor as part of this
information collection.

2. Project or Program status
November 1, 2010
Date first developed:
November 1, 2010
Date last updated:

Choose an item.
Pilot launch date:
Pilot end date:

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

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.
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.

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 7

Applicant name, Applicant address, applicant phone number, applicant FEMA registration number, site
information (if different from the applicant address), Witness signature, applicant signature, site
owner/agent signature.
From DHS employees/contractors: name 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:

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

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

If project or program utilizes any of these
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.

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.

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 7

6. Does this project or program connect,
receive, or share PII with any other
DHS programs or systems4?

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:
Individual Assistance (formerly NEMIS-IA)
HOMES module
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.)?

Choose an item.
Please describe applicable information sharing
governance in place.
Click here to enter text.

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 7

PRIVACY THRESHOLD REVIEW
(TO BE COMPLETED BY COMPONENT PRIVACY OFFICE)
Component Privacy Office Reviewer:

Lane Raffray

Date submitted to DHS Privacy Office:

October 25, 2013

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
PIA: Individual Assistance (Formerly NEMIS-IA)
SORN: DHS/FEMA 008 Disaster Recovery Assistance Files
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Jameson Morgan

Date approved by DHS Privacy Office:

November 6, 2013

PCTS Workflow Number:

998389
DESIGNATION

Privacy Sensitive System:

Yes

If “no” PTA adjudication is complete.

Other
Category of System:

Determination:

If “other” is selected, please describe: Form or other Information
Collection
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 update is required. The DHS/FEMA/PIA – 027 PIA is currently being updated.
PIA:

If covered by existing PIA, please list: DHS/FEMA/PIA – 027 National Emergency
Management Information System-Individual Assistance (NEMIS-IA) Web-based and
Client-based Modules,

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 7

System covered by existing SORN
SORN:

If covered by existing SORN, please list: DHS/FEMA-008 - Disaster Recovery Assistance
Files
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
The DHS Privacy Office agrees with the FEMA Privacy Office’s recommendation that the Request for
Site Inspection/Landowners Authorization/Ingress/Egress Agreement form is a privacy sensitive system
with coverage required under the DHS/FEMA/PIA – 027 NEMIS-IA PIA and the DHS/FEMA – 008
Disaster Recovery Assistance Files SORN. A Privacy Act Statement is also required for this system.
This form collects PII from members of the public seeking direct housing assistance from FEMA.
Members of the public must provide this information in order to apply for and obtain this assistance
before the site can be physically assessed and before housing can be placed at the landowner’s property.
The DHS/FEMA/PIA – 027 NEMIS-IA PIA is currently being updated to support a number of DHS
systems and process. However, the purpose of the PIA is to allow FEMA to collect and process
information obtained from disaster recovery assistance applications via the Disaster Assistance
Improvement Program (DAIP)/Disaster Assistance Call Center (DAC) system. This form will be covered
under the newest version of the NEMIS-IA PIA when it is published.
The DHS/FEMA – 008 Disaster Recovery Assistance Files SORN provides coverage to information
collected by this form in order to register applicants seeking disaster assistance from FEMA, determine
eligibility of the applicants, and to inspect damaged property. The information collection by this form is
consistent with the purpose, categories of records, categories of individuals, and the routine uses within
this SORN.
Per the Privacy Act of 1974, a Privacy Act Statement is also required to be provided to individuals who
fill out this form since they are members of the public who will have information stored in a DHS system
of records. A new PTA is required to be submitted on November 7th, 2014 to reflect coverage under the
updated NEMIS-IA PIA.