Privacy Threshold Analysis (PTA)

PTA, FEMA - Community Disaster Loan Program (1660-0083), 20141209, PRIV Final.pdf

Application for Community Disaster Loan (CDL) Program

Privacy Threshold Analysis (PTA)

OMB: 1660-0083

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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:

Community Disaster Loan (1660-0083)

Component:

Federal Emergency
Management Agency (FEMA)

Office or
Program:

Office of Response and
Recovery (ORR)- Public
Assistance (PA) Division

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:

Existing

Date first
developed:
Date of last PTA
update

January 1, 1974

Pilot launch
date:

N/A

May 9, 2012

Pilot end date:

N/A

ATO Status (if
applicable)

Choose an item.

ATO
expiration date
(if applicable):

N/A

PROJECT OR PROGRAM MANAGER
Name:

Martha Polanco

Office:

Public Assistance Division

Title:

Assistant Program Manager

Phone:

202.701.4023

Email:

[email protected].
gov

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

N/A

Phone:

N/A

Email:

N/A

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
The Office of Response and Recovery, Public Assistance Division’s Community Disaster Loan (CDL)
Program provides operational funding (for a period up to 5 years) to help local governments that have
incurred a significant loss in revenue, due to a major disaster, that has or will adversely affect their ability
to provide essential municipal services.
The ICR collects contact information for a POC associated with the ICR, as well as information related to
disaster-related losses for which the loan is requested and the information FEMA requires in order to
route funds to the affected locality as part of the loan program. This PTA will extend the use of the Loan
Package utilized to implement the Community Disaster Loan Program (1660-0083).

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
Employees of other federal agencies

4. What specific information about individuals is collected, generated or retained?

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

The following information is collected on local government’s primary and alternate contacts:
•

The individuals’ name, title, signature, local government mailing address, email address, telephone
numbers and fax numbers.
Financial information to include:
• The local community’s name, address, telephone number, the Financial Institution’s name, address,
telephone number, Direct Deposit Account Number, Bank Routing Number, Claim or Payroll ID
Number;

•

The name and telephone number of the Financial Institution’s Certifying Representative.

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.
N/A

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.
N/A

5. Does this project, program, or system
connect, receive, or share PII with any
other DHS programs or systems 4?

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

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:
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:

Lane Raffray

Date submitted to Component Privacy
Office:

December 4, 2014

Date submitted to DHS Privacy Office:

December 8, 2014

Component Privacy Office Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
PIA: DHS/FEMA 013 – Grant Management Programs
SORN: DHS/FEMA-009 - Hazard Mitigation Disaster Public Assistance and Disaster Loan Programs
March 24, 2014 79 FR 16015
(TO BE COMPLETED BY THE DHS PRIVACY OFFICE)
DHS Privacy Office Reviewer:

Eric M. Leckey

PCTS Workflow Number:

1056653

Date approved by DHS Privacy Office:

December 9, 2014

PTA Expiration Date

December 9, 2017
DESIGNATION

Privacy Sensitive System:

Yes

Category of System:

Form/Information Collection

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.
Paperwork Reduction Act (PRA) Clearance may be required. Contact
your component PRA Officer.

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

A Records Schedule may be required. Contact your component Records
Officer.
PIA:

System covered by existing PIA
DHS/FEMA 013 – Grant Management Programs
System covered by existing SORN

SORN:

DHS/FEMA-009 - Hazard Mitigation Disaster Public Assistance and Disaster Loan
Programs March 24, 2014 79 FR 16015
DHS Privacy Office Comments:
Please describe rationale for privacy compliance determination above.
This ICR, OMB 1660-0083, is a privacy sensitive collection. PII is collected and retained in the
associated forms. The forms in this collection include administrative and financial information from local
governments. The information, submitted by loan applicants enables FEMA to evaluate applications and
make award decisions, monitor ongoing performance and manage the flow of federal funds, and to
appropriately grant closure to the loan. Without this collection, FEMA will be unable to implement its
Community Disaster Loan programs. OMB 1660-0083 is covered by the DHS/FEMA/PIA-013 - Grant
Management Programs PIA and DHS/FEMA-009 Hazard Mitigation Disaster Public Assistance and
Disaster Loan Programs March 24, 2014 79 FR 16015. As such, the forms associated with this ICR
require e3 Privacy Act Statements to provide notice to the public that this information is part of a
DHS/FEMA system of records. FEMA has already completed the e3 Statement for this ICR.


File Typeapplication/pdf
File TitleDHS PRIVACY OFFICE
Authormarilyn.powell
File Modified2014-12-12
File Created2014-12-12

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