Privacy Threshold Analysis (PTA)

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
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:
Senior Director, 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.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 2 of 7

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

Exemption of State-Owned Properties Under Self-Insurance (1660-0013)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Federal Insurance and
Mitigation Administration
(FIMA)

Xacta FISMA
Name (if
applicable):

Click here to enter text.

Xacta FISMA
Number (if
applicable):

Click here to enter text.

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Existing

Date first
developed:
Date of last PTA
update

October 1, 1973

Pilot launch
date:

Click here to enter a date.

Click here to enter a date.

Pilot end date:

Click here to enter a date.

ATO Status (if
applicable)

Choose an item.

ATO
expiration date
(if applicable):

Click here to enter a date.

PROJECT OR PROGRAM MANAGER
Name:

Mary Chang

Office:

Risk Insurance Division

Title:

Insurance Examiner

Phone:

202-212-4712

Email:

[email protected]

INFORMATION SYSTEM SECURITY OFFICER (ISSO) (IF APPLICABLE)
Name:

Click here to enter text.

Phone:

Click here to enter text.

Email:

Click here to enter text.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 3 of 7

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: Renewal PTA
FEMA’s Federal Insurance and Mitigation Administration (FIMA) manages the “Exemption of StateOwned Properties Under Self-Insurance” process. Under section 102 of the Flood Disaster Protection Act
(FDPA) of 1973, Pub. L. No. 113-100 (codified at 42 U.S.C. § 4012(c)(1)) ,FEMA/FIMA can exempt a
State from purchasing flood insurance for its properties located in a Special Flood Hazard Area (SFHA) if
it implements an adequate self-insurance plan. FIMA regulations at 44 C.F.R. § 760.4 establish when
FEMA/FIMA can accept a State’s self-insurance plan for its State owned properties in SFHAs, thus
exempting it from purchasing flood insurance. The State’s Governor or other duly authorized official
sends a letter (no official form or format) with documentation to FEMA/FIMA seeking exemption and
explaining and certifying that their self-insurance plan meets FIMA regulations. The information
collected is part of OMB ICR No. 1660-0013.

2. Does this system employ any of the
following technologies:
If you are using any of these technologies and
want coverage under the respective PIA for that
technology please stop here and contact the DHS
Privacy Office for further guidance.

Closed Circuit Television (CCTV)
Social Media
Web portal1 (e.g., SharePoint)
Contact Lists
None of these

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

This program does not collect any personally
identifiable information2
Members of the public
DHS employees/contractors (list components):
Contractors working on behalf of DHS
Employees of other federal agencies

1

Informational and collaboration-based portals in operation at DHS and its components that collect, use, maintain, and share
limited personally identifiable information (PII) about individuals who are “members” of the portal or “potential members” who
seek to gain access to the portal.
2
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.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 4 of 7

4. What specific information about individuals is collected, generated or retained?
A State Governor or other duly authorized official of the State seeking a flood insurance exemption for
State properties may provide to FEMA their following contact information: name, address, email
address, and phone number(s).

4(a) Does the project, program, or system
retrieve information by personal identifier?
4(b) Does the project, program, or system
use Social Security Numbers (SSN)?
4(c) If yes, please provide the specific legal
basis and purpose for the collection of
SSNs:
4(d) If yes, please describe the uses of the
SSNs within the project, program, or
system:
4(e) If this project, program, or system is
an information technology/system, does it
relate solely to infrastructure?

No. Please continue to next question.
Yes. If yes, please list all personal identifiers
used:
No.
Yes.
Click here to enter text.

Click here to enter text.

No. Please continue to next question.
Yes. If a log kept of communication traffic,
please answer the following question.

For example, is the system a Local Area Network
(LAN) or Wide Area Network (WAN)?
4(f) If header or payload data3 is stored in the communication traffic log, please detail the data
elements stored.
Click here to enter text.

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

3

No.
Yes. If yes, please list:

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 Xacta.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 5 of 7

Click here to enter text.
6. Does this project, program, or system
connect, receive, or share PII with any
external (non-DHS) partners or
systems?
6(a) Is this external sharing pursuant to
new or existing information sharing
access agreement (MOU, MOA, LOI,
etc.)?
7. Does the project, program, or system
provide role-based training for
personnel who have access in addition
to annual privacy training required of
all DHS personnel?
8. Per NIST SP 800-53 Rev. 4, Appendix
J, does the project, program, or system
maintain an accounting of disclosures
of PII to individuals who have
requested access to their PII?
9. Is there a FIPS 199 determination?4

No.
Yes. If yes, please list:
Click here to enter text.
Choose an item.
Please describe applicable information sharing
governance in place:

No.
Yes. If yes, please list:

No. What steps will be taken to develop and
maintain the accounting:
Yes. In what format is the accounting
maintained: Use of FOIAExpress.
Unknown.
No.
Yes. Please indicate the determinations for each
of the following:

4

Confidentiality:
Low
Moderate

High

Undefined

Integrity:
Low

Moderate

High

Undefined

Availability:
Low
Moderate

High

Undefined

FIPS 199 is the Federal Information Processing Standard Publication 199, Standards for Security Categorization of Federal
Information and Information Systems and is used to establish security categories of information systems.

Privacy Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 6 of 7

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

LeVar J. Sykes

Date submitted to Component Privacy
Office:

Click here to enter a date.

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.
FEMA recommends the following coverage:
PIA: National Flood Insurance Program (NFIP) Information Technology Systems (ITS)
SORN: DHS/FEMA-003 National Flood Insurance Program Files System of Records

(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Jameson A. Morgan

PCTS Workflow Number:

1020824

Date approved by DHS Privacy Office:

May 29, 2014

PTA Expiration Date

May 29, 2017
DESIGNATION

Privacy Sensitive System:
Category of System:
Determination:

Yes

If “no” PTA adjudication is complete.

IT System
If “other” is selected, please describe: Click here to enter text.
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 Office
U.S. Department of Homeland Security
Washington, DC 20528
202-343-1717, [email protected]
www.dhs.gov/privacy

Privacy Threshold Analysis
Version number: 01-2014
Page 7 of 7

Privacy Act Statement required.
Privacy Impact Assessment (PIA) required.
System of Records Notice (SORN) required.
Paperwork Reduction Act (PRA) Clearance may be required. Contact
your component PRA Officer.
A Records Schedule may be required. Contact your component Records
Officer.
System covered by existing PIA
PIA:

If covered by existing PIA, please list: DHS/FEMA – 011 National Flood Insurance
Program (NFIP) Information Technology Systems (ITS)
System covered by existing SORN

SORN:

If covered by existing SORN, please list: DHS/FEMA-003 National Flood Insurance
Program Files System of Records
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 this is a privacy
sensitive system with coverage required under the DHS/FEMA – 011 NFIP ITS PIA and the DHS/FEMA
NFIP SORN.
This PTA was submitted as a 3-year renewal PTA. There have been no changes since the last PTA was
adjudicated on 04/01/2011. This system will continue to be covered under the DHS/FEMA/PIA – 011
NFIP ITS PIA and the DHS/FEMA – 003 NFIP SORN. No further actions are needed at this time.