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:

Ready PSA Campaign Creative Testing Research (1660-NW88)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Office of External Affairs

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:

Development

Date first
developed:
Date of last PTA
update

January 9, 2015

Pilot launch
date:

Click here to enter a date.

N/A

Pilot end date:

N/A

ATO Status (if
applicable)

Choose an item.

ATO
expiration date
(if applicable):

N/A

PROJECT OR PROGRAM MANAGER
Name:

Aretha Carter

Office:

External Affairs/Ready

Title:

Ready Campaign Manager

Phone:

202-646-2643

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: New PTA
FEMA’s Office of External Affairs is proposing to conduct focus groups on behalf of the Ready
Communications campaign. These focus groups will test various creative communication concepts to see
which ones resonate with consumers and are most effective.
FEMA will work with its contractor The Advertising Council to implement the research with a third party
research vendor. FEMA’s contractor (The Ad Council) will hire a professional focus group facility to
recruit and manage the actual focus groups. The professional focus groups facility will use its own
existing database of potential participants to complete the focus groups. The Ad Council will provide its
chosen facilitator with a set of FEMA-approved directions for screening possible participants. The focus
group facility maintains all respondent identifying information. Only the first name of each focus group
respondent along with their demographic information collected in the provided recruitment screener will
be shared with The Advertising Council and FEMA. No other personally identifiable information will be
shared.

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 portal 1 (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 information 2
Members of the public
DHS employees/contractors (list components):
Contractors working on behalf of DHS

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

Employees of other federal agencies

4. What specific information about individuals is collected, generated or retained?
From the focus group participants, FEMA’s third-party contractor will share with FEMA the following
demographic data: age, gender, number of children, household composition and marital status. Without
any further information, this information is not linked or linkable by FEMA to any specific individual.
The third-party contractor will also share with FEMA the first name of the participants in the groups.
Only the first name will be shared with FEMA, and as such this information is not PII, as first names are
not uniquely linkable back to the individual participants.
No. Please continue to next question.
4(a) Does the project, program, or system
Yes. If yes, please list all personal identifiers
retrieve information by personal identifier?
used:
4(b) Does the project, program, or system
No.
use Social Security Numbers (SSN)?
Yes.
4(c) If yes, please provide the specific legal
N/A
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?

N/A
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 data 3 is stored in the communication traffic log, please detail the data
elements stored.
Click here to enter text.
N/A

5. Does this project, program, or system
connect, receive, or share PII with any
3

No.

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.

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

other DHS programs or systems 4?

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/agencies 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.
N/A
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:
Unknown.
No.
Yes. Please indicate the determinations for each
of the following:
Confidentiality:
Low
Moderate

High

Undefined

Integrity:
Low

High

Undefined

Moderate

Availability:

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 7

Low

Moderate

High

Undefined

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

Lane Raffray

Date submitted to Component Privacy
Office:

January 13, 2015

Date submitted to DHS Privacy Office:

January 22, 2015

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
This ICR is similar to others that FEMA has conducted, wherein a 3rd party uses its own existing
resources to facilitate a survey/focus group on behalf of FEMA, or in this case, a FEMA contractor.
Neither FEMA nor its contractor incorporates any of the PII used to facilitate this focus group into agency
files and the information is not linked or linkable to agency information about those individuals.
As such, FEMA recommends that this PTA be sufficient at this time.
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Eric M. Leckey

PCTS Workflow Number:

1061962

Date approved by DHS Privacy Office:

January 22, 2015

PTA Expiration Date

January 22, 2018
DESIGNATION

Privacy Sensitive System:
Category of System:
Determination:

No

If “no” PTA adjudication is complete.

Form/Information Collection
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.
PIA:
SORN:

Choose an item.
If covered by existing PIA, please list: Click here to enter text.
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.
This ICR is similar to others that FEMA has conducted, wherein a 3rd party uses its own existing
resources to facilitate a survey/focus group on behalf of FEMA, or in this case, a FEMA contractor.
Neither FEMA nor its contractor incorporates any of the PII used to facilitate this focus group into agency
files and the information is not linked or linkable to agency information about those individuals. The 3rd
party group facilitator does share with FEMA demographic information and the first names of group
participants, however, this information is not linked or linkable to the individual participants, and
therefore, is not PII.
As such, the PTA is sufficient at this time. This adjudication is consistent with that of FEMA’s similar
ICRs.