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 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:
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 8

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

Property Acquisition and Relocation for Open Space (OMB Control No. 16600103)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Federal Insurance and
Mitigation Administration
(FIMA)

Xacta FISMA
Name (if
applicable):

N/A

Xacta FISMA
Number (if
applicable):

N/A

Type of Project or
Program:

Form or other Information
Collection

Project or
program
status:

Update

Date first
developed:
Date of last PTA
update

February 7, 2008

Pilot launch
date:

Click here to enter a date.

July 5, 2011

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:

Cecelia Rosenberg

Office:

Risk Reduction/Grants Policy

Title:

Grants Policy Supervisor

Phone:

202-646-3321

Email:

[email protected]
v

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 8

SPECIFIC PTA QUESTIONS
1. Reason for submitting the PTA: Renewal PTA
The FEMA Federal Insurance and Mitigation Administration (FIMA) administers the Property
Acquisition and Relocation for Open Space program. Pursuant to Robert T. Stafford Disaster Relief and
Emergency Assistance Act, 42 U.S.C. §§ 5121 through 5207; and the National Flood Insurance Act of
1968, as amended, 42 U.S.C. § 4001 FIMA uses FEMA Form (FF) 086-0-31 Statement of Voluntary
Participation for Acquisition of Property for Purpose of Open Space as an agreement for the acquisition
and use of property by a Sub-grantee of a FEMA Hazard Mitigation Assistance (HMA) Grant Program.
FIMA completed this Privacy Threshold Analysis (PTA) as part of the OMB ICR No. 1660-0103 review
and renewal process. There have been no changes to the program since the last PTA was approved on
July 5, 2011.
HMA Grant Program’s sub-grantees are local government agencies that participate in hazard mitigation
with their State government agency. HMA Grant Program’s Grantees are State government agencies.
Property owners can voluntarily sell their property to a sub-grantee, who in turn can request HMG Grant
Program for funding for the property. FEMA HMA Grant Programs require all properties acquired with
FEMA funds to be deed restricted and maintained as open space in perpetuity. This ensures that no future
risks from hazards occur to life or structures on that property, and no future disaster assistance or
insurance payments are made as a result of damages to that property. FIMA provides model language for
the deed restriction and uses FF 81-112 to document this transaction. FIMA collects name, property
address, and signature from property owners and name, title, and signature from a sub-grantee POC to
verify voluntary homeowner participation for a specific property. This information is not part of an IT
system. It is filed in paper form with the State and FEMA project files.

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

1

This program does not collect any personally
identifiable information2

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.

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 8

disseminate information?
Please check all that apply.

Members of the public
DHS employees/contractors (list components):
Contractors working on behalf of DHS
Employees of other federal agencies

4. What specific information about individuals is collected, generated or retained?
FEMA collects some or all of the following information from HMA Grant Program Subgrantee’s POC or
Property Owners:
Name,
title,
property address, or
signature.

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?
For example, is the system a Local Area Network
(LAN) or Wide Area Network (WAN)?

2

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.

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 5 of 8

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?

No.
Yes. If yes, please list:
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

3

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: On an excel spreadsheet.
Unknown.

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.
4
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 8

No.
Yes. Please indicate the determinations for each
of the following:
Confidentiality:
Low
Moderate

High

Undefined

Integrity:
Low

Moderate

High

Undefined

Availability:
Low
Moderate

High

Undefined

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

LeVar Sykes

Date submitted to Component Privacy
Office:

Click here to enter a date.

Date submitted to DHS Privacy Office:

August 20, 2014

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
PIA: N/A (Records are not maintained is a IT System)
SORN: DHS/FEMA-009 - Hazard Mitigation Disaster Public Assistance and Disaster Loan Programs
(March 24, 2014 79 FR 16015)

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 8

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

Jameson A. Morgan

PCTS Workflow Number:

1037495

Date approved by DHS Privacy Office:

August 22, 2014

PTA Expiration Date

August 22, 2017
DESIGNATION
Yes

Privacy Sensitive System:

Form/Information Collection

Category of System:
Determination:

If “no” PTA adjudication is complete.

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 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.

PIA:

Choose an item.
If covered by existing PIA, please list: Click here to enter text.
System covered by existing SORN

SORN:

If covered by existing SORN, please list: DHS/FEMA-009 - Hazard Mitigation Disaster
Public Assistance and Disaster Loan Programs
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
The DHS Privacy Office agrees with the FEMA Privacy Office that Property Acquisition and Relocation
of Open Space is a privacy sensitive system with coverage required under the DHS/FEMA – 009 Hazard
Mitigation Disaster Public Assistance and Disaster Loan Programs SORN.
This PTA was submitted as a renewal PTA. There haven’t been any changes since the last PTA was

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 8 of 8

approved in 2011. This program collects a minimal amount contact PII to facilitate an agreement for the
acquisition and use of property by a Sub-grantee of a FEMA Hazard Mitigation Assistance (HMA) Grant
Program.
The DHS/ALL – 009 SORN allows FEMA to administer the PA grants program, HMA grants programs,
and other disaster grants and disaster loan programs to mitigate and recover from emergencies and
disasters and to assess the customer satisfaction of FEMA public assistance applicants while allowing
FEMA to prevent the duplication of benefits and recoup improper payment.
A PIA is not required at this time per the E-Government Act of 2002 or DHS policies and guidance.