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:	Post Hurricane Sandy Survivor Research
Component:	FEMA	Office or Program:	Individual and Community Preparedness Division
TAFISMA Name:	Click here to enter text.	TAFISMA Number:	Click here to enter text.
Type of Project or Program:	Survey/Focus Group	Project or program status:	This is a new development effort.

PROJECT OR PROGRAM MANAGER

Name:	Chad Stover
Office:	Individuals and Community Preparedness Division	Title:	Individual and Community Preparedness Division Program Specialist
Phone:	202-786-9860	Email:	[email protected]

INFORMATION SYSTEM SECURITY OFFICER (ISSO)

Name:	Daniel Lau-Lopez
Phone:	240-205-1728	Email:	[email protected]

ROUTING INFORMATION

Date submitted to Component Privacy Office:	Click here to enter a date.
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 Office of Protection and National Preparedness (PNP), Individual and Community Preparedness Division (ICPD), has contracted with the Gallup to conduct research a series of moderated focus groups with members of the general public regarding the most effective means for presenting disaster preparedness messages. This research supports the mission of ICPD, to help achieve greater community resiliency nationwide.

Participants are selected for the focus group by Gallup, using its own, existing data from a previously identified list of individuals who have agreed to allow Gallup to contact them. Gallup will use its own telephone numbers, age, and race data to stratify the survey sample. If a resident agrees to participate in a focus group, Gallup may collect an email address and possibly a new phone number to coordinate their participation in the group. Once the focus group has ended, this information will be removed from the system. The focus groups will feature audio recording for transcription purposes; no video will be taken of the groups or their participants.

Neither FEMA nor Gallup will incorporate the email addresses or phone numbers into its files. In addition, FEMA will not collect, maintain, or store any of the results from the focus groups. FEMA receives an aggregate report from its contractor (Gallup).

Project or Program status		This is a new development effort.
Date first developed:	01/01/13	Pilot launch date:	08/01/2013
Date last updated:	04/18/13	Pilot end date:	04/30/2014

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.
Telephone number, email addresses
Does the Project or Program use Social Security Numbers (SSNs)?	No
If yes, please provide the legal authority for the collection of SSNs:	N/A
If yes, please describe the uses of the SSNs within the Project or Program:	N/A

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.
The communication log will store the record that a session had occurred, but the log will not contain any PII that was identified during that session.

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. If yes, please list:
Is this external sharing pursuant to new or existing information sharing access agreement (MOU, MOA, LOI, etc.)?	No Please describe applicable information sharing governance in place.

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:		Choose an item. If “no” PTA adjudication is complete.
Category of System:		Choose an item. 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:	Choose an item. If covered by existing PIA, please list: Click here to enter text.
SORN:	Choose an item. 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.